From declaration to proof.
InPost and Siemens Energy become the first companies to hold the CSCE sanctions compliance certificate
News
InPost and Siemens Energy are the first companies to receive the CSCE (Certified Sanctions Compliance Entity) certificate – the first independent certificate confirming that a company meets EU sanctions requirements. The certificates were presented on 13 October 2026 at the conference introducing the new standard.
Until recently, sanctions were largely the domain of lawyers and compliance departments. Today the subject is reaching the boardroom. EU Directive 2024/1226 requires Member States to treat the violation of sanctions as a criminal offence. As such, liability extends not only to companies, but also personally – to their managers. Maximum penalties for companies may not be set below 5% of their total worldwide turnover.
“The criminalisation of sanctions violations has moved this subject from the compliance department to the boardroom. Today no one asks whether a company has a sanctions policy. The question is: can it prove that the policy works in practice before a prosecutor, a bank, or a counterparty does?”
« CSCE presents boards, banks, and business partners with a shared, independent point of reference. In place of yet another questionnaire and yet another declaration, we now have a verified audit result produced in accordance with a single, transparent methodology. It is proof, not a declaration, » says Dr Anna Partyka-Opiela, partner in charge of the Compliance, Forensic, and ESG practices at Rymarz Zdort Maruta and CSCE co-author.
Banks, counterparties, and regulators are asking about sanctions compliance ever more often, and a company’s own assurance is no longer sufficient. CSCE is designed specifically to mitigate this. The certificate is awarded following an audit conducted according to a uniform methodology covering seven risk areas. The project’s tagline, « Proof. Not opinion.« , captures its essence: verifiable proof in place of mere declarations.
« In practice, companies rarely have problems with the sanctions lists themselves, but rather with their accompanying issues – the ownership structure of counterparties and their links to sanctioned entities, the circumvention of sanctions through third parties, dual-use goods and others subject to import and export bans, and gaps in documenting decisions. That is why the CSCE methodology covers seven risk areas, not the screening process alone. The certificate is meant to show that the compliance system is complete and coherent, » emphasises Dr Marcin Łukowski of ET CAETERA, an international sanctions expert and co-author of CSCE.
The first certified companies represent sectors where sanctions screening is part of day-to-day operations. For InPost, this is driven by the scale of its logistics operations.
« We operate in several countries and handle millions of parcels every day, so sanctions screening is a matter of operational security for us, not just a formality. We chose independent verification because we believe that responsible businesses should go beyond mere declarations and be able to demonstrate their compliance. For our partners and customers, the CSCE certificate is a clear signal of trust, » says Arleta Adamus, legal counsel, Vice-President of the Management Board of the InPost Foundation, and member of the Board of Directors of the InPost group.
Siemens Energy approached certification from a different angle. For this company, sanctions risk relates to technology and components first and foremost.
« In the energy sector, sanctions screening does not end with checking the counterparty. It covers the entire supply chain, components that may be dual-use, and the end-location and the end-customer ultimately receiving the technology. We have an extensive global compliance programme that also covers export control and sanctions. For us, the CSCE certificate means independent confirmation of the effectiveness and efficiency of the system we have implemented to protect against sanctions risk, » says Marcin Szczepański, Regional Compliance Officer at Siemens Energy.
At the conference, experts and representatives of business, public administration, and non-governmental organisations discussed where companies most often go wrong and how to demonstrate due diligence to regulators and financial institutions. The debate was moderated by Marcin Piasecki, managing editor of the daily Rzeczpospolita, with the following participants:
– Dr Anna Partyka-Opiela, Rymarz Zdort Maruta
– Dr Marcin Łukowski, ET CAETERA
– Marcin Szczepański, Regional Compliance Officer, Siemens Energy
– Kamil Wyszkowski, Executive Director, UN Global Compact Network Poland
– Arleta Adamus, General Counsel, Group Compliance Officer, InPost
Find more about the event here
Learn more about CSCE at https://sanctionscertificate.eu
