POLAND Trends and Developments Contributed by: Jaroslaw Kruk, Joanna Bogdanska and Urszula Brzozowska, KW Kruk and Partners Law Firm
KW Kruk and Partners Law Firm 14 bl. Ladyslawa z Gielniowa Street 02-066 Warsaw Poland
Tel: +48 222 464 600 Fax: +48 222 464 699 Email: office@legalkw.pl Web: www.legalkw.pl
Intermediaries play a large role in fraud disputes The role of intermediaries is becoming increasingly important in the Polish fraud market. Not every case will lead to a claim against a bank, payment provider, technology provider or other service intermediary. Even so, these bodies are often central to tracing, information gathering, mitigation and leverage. This reflects the modern structure of fraud. A payment may pass through several entities before reaching its destination. A scam may rely on messaging infrastruc - ture, spoofed identifiers, hosted websites or account onboarding processes operated by different service providers. The fraudster may be difficult to identify directly, but the surrounding transaction chain often reveals institutions that handled key parts of the event. For that reason, clients are increasingly advised to examine not only the conduct of the primary wrong - doer, but also the ecosystem through which the fraud was executed. Sometimes this analysis supports direct claims, and sometimes it strengthens the fac - tual basis for regulatory engagement or disclosure efforts; in other cases, it simply improves tracing and positions the client better for settlement or enforce - ment. This trend also cuts the other way. Businesses them - selves are under greater scrutiny when they become victims of fraud. Opponents, insurers and other stake - holders are more likely to ask whether the company had adequate controls, whether approval processes were properly followed and whether obvious warn - ing signs were missed. In practice, recovery disputes
Poland – Fraud, Asset Recovery and Business Risk in 2026 Fraud disputes in Poland are becoming more com - plex, more international and more technology-driven. The market is no longer dominated by traditional diversion-of-funds cases alone: clients are increasing - ly facing phishing, fake investment schemes, business email compromise, payment fraud, misuse of corpo - rate structures and crypto-related asset dissipation. That is the reason why fraud and asset recovery work in Poland has become much more immediate and much more operational than it used to be. The legal framework remains important, but the cases that tend to go well are usually the ones where the client reacts quickly, secures the facts early and understands that civil, criminal and regulatory steps often need to be considered together rather than one after another. For clients doing business in Poland, that shift is important because it changes what legal advisers are expected to do. In many cases, the issue is not simply whether there is a claim. The real question is whether anything crucial can still be done before the funds dis - appear, before evidence is lost and before the matter becomes more expensive and harder to control. The Polish legal framework offers a number of effective remedies, but the commercial environment in which those remedies are used has changed significantly. As a result, the market trend in 2026 is clear, because successful fraud work in Poland is increasingly based on co-ordinated response rather than single-track liti - gation.
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