Poland's parliament votes for pre-judicial crypto freeze

On Friday, Poland's lower chamber approved a bill 240-202 that permits the interior minister to freeze cryptocurrencies, bank accounts, and other assets belonging to individuals on a national sanctions list, prior to any judicial review.

The Sejm, Poland's lower house, approved the Act on Restrictive Measures during its 68th session; one lawmaker abstained and 17 were absent. The bill was sent to the Senate on Monday, which under Article 121 of the Constitution has 30 days to approve, modify, or reject it before it moves to President Karol Nawrocki.

This government-proposed legislation, which also enforces EU sanctions regulations, classifies crypto assets as financial instruments that can be frozen, adopting the definition from the EU's Markets in Crypto-Assets (MiCA) framework. The bill defines a freeze as preventing any transfer, movement, use, or alteration that would allow the asset owner to derive benefit.

Only individuals and entities placed on a public national list by the interior minister are subject to the freeze. The minister can act on his own or upon request from agencies such as the financial watchdog, central bank, financial intelligence unit, or internal security service. Grounds for listing include backing a country under EU sanctions, committing severe human rights violations, or launching or funding information manipulation that seriously threatens Poland's security.

To be listed under the information manipulation ground, there must be evidence of a genuine and grave threat to Poland's interests, borders, security, or electoral processes. The legislation exempts standard journalism, political discourse, and publishing, unless such activity constitutes an intentional campaign as defined by the law.

A freeze that starts before a judge weighs in

The minister's ruling becomes effective one day after publication in the ministry's Public Information Bulletin and is enforceable straight away. No appeal can be submitted to the minister for reconsideration. A person on the list can lodge a complaint with an administrative court, but the decision stays in effect until a final judgment is issued, suspending the normal provision that allows a court to halt a contested order.

Additionally, the rules prohibit providing funds or property to listed individuals and can disqualify them from public tenders. In certain circumstances, the economy minister can assign a temporary administrator to liquidate frozen assets or, via a separate directive, transfer ownership to the State Treasury.

What the freeze would mean for bitcoin

The Polish bill does not affect regular bitcoin users in the country. It applies to crypto assets owned, possessed, or controlled by individuals and companies on the sanctions list. Banks, trading platforms, and other entities risk administrative penalties if they do not freeze such assets or allow access to them. Oversight of compliance falls to the financial intelligence unit and the Polish Financial Supervision Authority for firms under their jurisdiction.

The legislation does not outline how authorities could access private keys for self-custodied coins. In practice, enforcement in Poland relies on exchanges, custodians, and other obligated entities that can effectively block a transaction.

What comes next for the bill

The legislation must still pass the Senate and gain President Nawrocki's approval. Nawrocki declined to sign a distinct crypto-assets market bill that the Sejm approved on May 15; in September, legislators attempted to override that veto but fell short with a 241-198 vote. He had also vetoed earlier iterations of that market bill, claiming the regulations were excessive.

The earlier dispute centered on licensing and oversight under the EU's crypto-assets framework, not on sanctions-related freezes. The key questions now are whether the Senate will modify the pre-court freeze provision and whether President Nawrocki will approve a sanctions law that covers bitcoin.