International Fraud and Asset Tracing 2026

POLAND Law and Practice Contributed by: Jaroslaw Kruk, Joanna Bogdanska and Urszula Brzozowska, KW Kruk and Partners Law Firm

for a crime or fiscal offence, or in connection with the execution of a request for legal assistance. 7.3 Crypto-Assets Fraud involving crypto-assets has become increas - ingly relevant in Poland. While crypto-assets are not legal tender, the regulatory environment is no longer as undeveloped as it once was, with the EU MiCA framework now applying across the Union. At the same time, the Polish domestic supervisory frame - work remains in a transitional phase. In February 2026, the Polish Financial Supervision Authority indi - cated that, during the transitional period under MiCA, certain entities may continue to operate under previ - ously applicable national rules until 1 July 2026 or until they obtain or are refused authorisation, whichever occurs first.

From an asset recovery perspective, cases involving crypto-assets remain factually and evidentially diffi - cult, especially where assets have been transferred across multiple wallets, platforms or jurisdictions. The main challenge is therefore the practical difficulty of tracing, identifying and securing the relevant assets and counterparties in time.

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