Polish Sejm Votes to Let Minister Freeze Crypto Without Court Order

Poland's interior minister would gain the power to freeze crypto holdings, bank balances and other property through administrative decisions, with no prior court order, under a bill the Sejm approved on Nov. 6 by 240 votes to 202, with one abstention.

The measure, the Act on Restrictive Measures (originally numbered 3003), still needs Senate consideration and the signature of President Karol Nawrocki. The Senate can propose amendments, in which case the bill returns to the Sejm. Most provisions would take effect 30 days after official publication.

How the freeze mechanism works

The interior minister would maintain a public list of designated people and entities and specify which restrictions apply to each. Financial assets explicitly include crypto assets, defined as in the EU's MiCA regulation. A designation becomes enforceable the day after it is published in the ministry's public information bulletin.

Affected parties can appeal to an administrative court, but an appeal does not automatically suspend the restrictions. The decision keeps force until the judgment is final. Exchanges and custodians would have to block access to listed customers' assets before any judicial review. A freeze does not transfer ownership to the state.

Individual listings carry no automatic expiry. Listed parties can request removal, and exemptions could allow access to frozen resources for basic needs, legal fees and certain other expenses. The bill's 24-month limit applies to restrictions on economic cooperation with a country, not to individual freezes.

Wider grounds than the 2022 framework

Administrative freezes already exist in Poland's 2022 sanctions legislation, which tied the minister's immediately enforceable listing powers to Russian aggression against Ukraine and repression in Russia and Belarus. The new bill extends the grounds to certain foreign-backed information operations that threaten national security. The text requires a demonstrated risk of a real and serious threat and excludes ordinary expression and journalism unless they constitute the specified deliberate activity.

Lawmakers approved amendments on Nov. 6 clarifying how crypto assets, financial instruments and other property are treated. The bill is not a general freeze on crypto holdings; it applies only to designated parties. It relates to implementing EU Directive 2024/1226, though the national list is a separate domestic mechanism.

Objections and practical limits

Opposition lawmakers and legal groups have raised concerns about property rights and free expression. Ordo Iuris, a legal institute, argued in an October analysis that the listing grounds and delayed judicial relief threaten property rights and freedom of expression, and that the list goes beyond what EU law requires. Those are the institute's legal objections, not a court ruling. Poland's National Broadcasting Council warned in September that unclear definitions in the information manipulation provisions could affect media organizations.

Some reaction was sharper. Roman Fritz wrote, in a post circulated by Slavic Networks:

"SHAME IN THE SEJM! THEY PASSED THE TOTALITARIAN LAW! COMMUNISM IS BACK IN FULL!"

Roman Fritz

Enforcement has limits. Norton Rose Fulbright notes that exchanges can only stop assets leaving accounts they control, and restrictions on service providers do not prevent peer-to-peer transfers on public decentralized networks. For self-custodied wallets, enforcement would depend on authorities identifying the assets, and a government order would not by itself hand officials control of private keys.

What it means for the market

For Polish exchanges and custodians, the practical change is a compliance duty that bites before a judge weighs in. The vote follows a separate setback for domestic crypto policy: in September the Sejm failed to override Nawrocki's third veto of the domestic MiCA implementation bill, with 241 to 198 in favor, short of the required three-fifths majority, as we reported in our coverage of that failed override. The Senate takes up the restrictive-measures bill next, and Nawrocki's signature remains the final step.