The Admissibility of Illegally Obtained Evidence
I. Introduction
Consider the following scenario: an entrepreneur suspects that his business partner is embezzling funds from their jointly held company. He engages a private investigator who, without authorization, gains access to the partner’s electronic mail account and discovers incriminating correspondence. The question that inevitably arises is whether such evidence may be admitted in judicial proceedings. The answer, as is often the case in matters of procedural law, depends upon a constellation of factors: the nature of the proceedings, the applicable jurisdiction, and the character of the illegality attending the acquisition of the evidence.
The admissibility of evidence obtained in violation of law constitutes one of the most contentious domains of procedural jurisprudence. While substantive law has undergone gradual harmonization through international treaties and conventions, the procedural rules governing evidentiary exclusion remain profoundly heterogeneous, reflecting divergent constitutional traditions, legal cultures, and criminal policy priorities across different jurisdictions.
II. Fundamental Terminological Distinctions
Before undertaking a systematic analysis of particular legal systems, it is essential to establish a coherent terminological framework. At the level of international law and comparative legal scholarship, no uniform conceptual vocabulary exists that precisely distinguishes among evidence characterized as “illegally,” “unlawfully,” “unfairly,” or “wrongfully” obtained—terms that are frequently employed interchangeably in both judicial decisions and academic literature. Nevertheless, three functional axes of distinction may be identified that recur throughout international jurisprudence and scholarly commentary.
A. The Nature of the Violated Norm
The first axis concerns the character of the norm transgressed in obtaining the evidence. Of fundamental significance is the distinction between violations of peremptory norms (ius cogens)—particularly the prohibition against torture and inhuman or degrading treatment—and other categories of legal violation. Evidence obtained through torture or treatment falling within the scope of Article 3 of the European Convention on Human Rights is subject to absolute exclusion under international law, irrespective of its probative value. Other violations—whether constitutional in nature (such as unlawful searches or invasions of privacy) or “ordinary” breaches of procedural rules—are subject to varying regimes ranging from automatic exclusion to discretionary balancing of circumstances.
B. The Identity of the Transgressor
The second axis relates to the identity of the party responsible for the violation. Most legal systems treat with considerably greater leniency those situations in which private actors, rather than state organs, violate the law in obtaining evidence. Convention standards (including the ECHR and UN Covenants) as well as constitutional exclusionary rules are addressed primarily to the state. Private wrongdoing becomes procedurally relevant only when the state subsequently utilizes such evidence in a manner inconsistent with fair trial requirements, or when the admission of the evidence would compromise the integrity of the proceedings.
C. Fairness and Procedural Integrity
The third axis concerns the overarching requirements of fairness and procedural integrity. In international law and numerous domestic systems, a distinct line of argumentation operates based upon the principle of fair trial—encompassing equality of arms, good faith, and the integrity of the administration of justice. The European Court of Human Rights examines whether proceedings as a whole were “fair” within the meaning of Article 6 ECHR. International arbitral tribunals apply tests of good faith and equality of arms. Common law courts inquire whether admission of evidence would “bring the administration of justice into disrepute.” This perspective has gained particular prominence in civil and arbitral proceedings.
III. The “Fruit of the Poisonous Tree” Doctrine
Among the most evocative conceptualizations in the law of evidence is the American doctrine of the “fruit of the poisonous tree.” Although the doctrinal foundations for excluding derivative evidence were established in Silverthorne Lumber Co. v. United States (1920), the metaphor itself was coined by Justice Felix Frankfurter nearly two decades later in Nardone v. United States (1939), which consolidated its application to wiretapping cases. The doctrine was subsequently developed in a series of decisions, most notably Wong Sun v. United States (1963), which extended its reach to derivative testimony.
The essence of the doctrine may be reduced to a simple metaphor: if the evidentiary “tree” is tainted, so too are its “fruits.” In other words, exclusionary rules encompass not only the direct products of illegal conduct but also derivative evidence—that is, evidence discovered by means of information obtained illegally.
The doctrine applies to physical evidence discovered during illegal searches, testimony and statements resulting from unlawful detention, materials obtained from wiretaps conducted without legal authorization, and documents and testimony constituting derivatives of primary violations.
The ratio legis of this doctrine is self-evident: were courts to exclude only evidence directly obtained through illegal means while admitting its derivatives, the primary exclusion would become illusory, and law enforcement agencies would retain incentives to engage in procedural violations.
IV. The American Model: Constitutional Imperative of Exclusion
The American system represents one of the most rigorous approaches in the world to evidence obtained illegally by state actors, although contemporary jurisprudence has rendered this approach largely prudential and deterrent in character rather than absolutely categorical. The exclusionary rule is a judicially created remedy designed to safeguard rights guaranteed primarily by the Fourth Amendment (protection against unreasonable searches and seizures), as well as the Fifth Amendment (privilege against self-incrimination) and the Sixth Amendment (right to counsel). Current jurisprudence emphasizes that the rule is not a “personal” constitutional right but rather an instrument serving to enforce these guarantees through deterrent effect.
The development of this rule proceeded through distinct phases. In 1886, it was established for federal forfeiture proceedings. In 1914, the Supreme Court extended it to federal criminal prosecutions in Weeks v. United States. The pivotal moment came in 1961 when the Court, in Mapp v. Ohio, applied the exclusionary rule to state criminal proceedings through the Fourteenth Amendment.
The American model adopts the principle of excluding evidence obtained in violation of the enumerated constitutional guarantees; however, in practice, this principle is subject to numerous exceptions developed through case law. The contemporary approach of the Supreme Court rests upon a cost-benefit analysis: exclusion applies only when its deterrent function outweighs the costs of losing reliable evidence—see Hudson v. Michigan (2006) and Herring v. United States (2009). This jurisprudential evolution has significantly constrained the practical scope of the exclusionary rule.
A. Exceptions to the Exclusionary Rule
American courts have developed several exceptions permitting the admission of evidence notwithstanding its illegal provenance.
The good faith exception permits admission of evidence when officers acted in good faith reliance upon a warrant subsequently determined to be defective—see United States v. Leon (1984). The critical inquiry concerns the reasonableness of the officer’s conduct, not the technical validity of the warrant.
The independent source doctrine permits admission of evidence initially obtained illegally if it was subsequently discovered through an entirely independent, lawful procedure—see Murray v. United States (1988).
The inevitable discovery doctrine permits admission of evidence if it would inevitably have been discovered through lawful investigative activities, even absent the illegal conduct—see Nix v. Williams (1984). The burden of proof rests upon the prosecution.
The attenuation doctrine applies when the connection between the constitutional violation and the discovery of evidence becomes sufficiently attenuated or is interrupted by intervening circumstances—see Utah v. Strieff (2016). Courts examine the temporal proximity, the nature of intervening circumstances, and the purposefulness and flagrancy of the original violation.
The private party exception provides that the exclusionary rule applies exclusively to state action. Evidence obtained by private individuals not acting at the behest or under the direction of state authorities is admissible even if illegally procured.
The standing doctrine limits the class of persons who may challenge the admissibility of evidence to those whose constitutional rights were actually violated. If evidence infringes upon the rights of a third party but not those of the accused, the accused generally lacks standing to seek its exclusion.
B. A Critical Limitation: Civil and Tax Proceedings
Of fundamental significance is the fact that the American exclusionary rule does not extend to civil tax proceedings, civil proceedings generally, administrative proceedings, or—with certain exceptions—grand jury proceedings.
In the seminal decision United States v. Janis (1976), the Supreme Court held that the exclusionary rule should not be extended to federal civil tax proceedings where evidence was illegally obtained by a state officer in the course of criminal proceedings. In reaching this conclusion, the Court reasoned that the additional deterrent effect of such an extension would be merely marginal, given that the officer is already “penalized” by exclusion of evidence in criminal proceedings, and that imposing upon one sovereign the consequences of violations committed by another lacks sufficient justification.
The Court further emphasized that civil tax proceedings require efficiency, and broad subordination of tax administration to criminal exclusionary rules would unduly impair the realization of important fiscal objectives.
The practical consequence is significant: evidence excluded in a parallel criminal proceeding conducted by another sovereign (for example, documents or correspondence obtained through an illegal search by state police) may, as a general matter, be utilized in federal civil tax assessment proceedings, absent contrary restrictions arising from special provisions or evidentiary rules of the particular jurisdiction.
V. The European Standard: No Automaticity, the Fairness Test
The European Convention on Human Rights contains no detailed rules regarding the admissibility or exclusion of evidence. Article 6 guarantees the “right to a fair trial,” yet the European Court of Human Rights consistently holds that this provision “does not lay down any rules on the admissibility of evidence as such, that being primarily a matter for regulation under national law.”
Moreover, the Court has stated that “evidence gathered in breach of national law may be admissible” and that “the use of an illegal recording does not in itself conflict with the fairness principles embodied in Article 6.”
A. The Fairness Test: Situational Discretion
In lieu of a categorical exclusionary rule, the ECtHR requires domestic courts to examine the manner in which evidence was obtained in order to ensure the overall fairness of proceedings. The Court applies a multi-factor analysis encompassing: the nature of the alleged illegality and any violation of other Convention rights; the opportunity for the party to challenge the authenticity of the evidence; the opportunity to object to the use of the evidence; the significance of the evidence to the prosecution’s case; and whether its use would constitute a flagrant denial of justice.
B. Absolute Prohibitions and the Intensity of Violations
The fairness test is, however, subject to limits. The ECtHR adopts differentiated approaches depending upon the character of the violation.
Violations of absolute rights (Article 3 ECHR): Evidence obtained through torture or inhuman treatment (Article 3 ECHR) renders proceedings automatically unfair. In Gäfgen v. Germany (2010), the Grand Chamber confirmed that the use of such evidence against the accused violates Article 6, irrespective of its probative value—see also Jalloh v. Germany (2006).
Violations of qualified rights—the intensity test: In cases involving violations of qualified rights (such as privacy under Article 8), the ECtHR does not apply automatic exclusion but rather examines the intensity of the violation and its impact on the overall fairness of the trial.
In Schenk v. Switzerland (1988), the Court first articulated the cardinal principle: “While Article 6 of the Convention guarantees the right to a fair trial, it does not lay down any rules on the admissibility of evidence as such, that being primarily a matter for regulation under national law” (§ 46).
Although the telephone recording had been obtained in violation of Swiss criminal law (Article 179 ter of the Criminal Code), the ECtHR found no violation of Article 6, emphasizing that: (1) the applicant had been able to challenge the authenticity of the recording and to object to its use; (2) the recording was not the sole evidence against him; and (3) the domestic court had carefully evaluated the totality of the evidence.
The judgment on Article 6 § 1 was, however, adopted by a vote of 13 to 4. In their dissenting opinion, Judges Pettiti, Spielmann, De Meyer, and Carrillo Salcedo stated that “no court can, without detriment to the proper administration of justice, rely on evidence obtained not only unfairly but above all unlawfully,” and that compliance with the law in obtaining evidence “is not an abstract or formalistic requirement.”
In Khan v. United Kingdom (2000), the circumstances differed—the recording from a listening device installed by police constituted the sole evidence against the accused. The Court found a violation of Article 8 (absence of a statutory basis for the surveillance) yet nonetheless held, by a vote of 6 to 1, that there had been no violation of Article 6.
The ECtHR determined that the proceedings as a whole were fair, noting in particular that: (1) the applicant had full opportunity to challenge both the authenticity of the recording and the admissibility of the evidence at every stage of the proceedings—during the voir dire, before the Court of Appeal, and before the House of Lords (§ 38); (2) the domestic courts possessed discretionary authority to exclude the evidence under section 78 of PACE if they determined that its admission would lead to substantial unfairness (§ 39); and (3) the recording was regarded as very strong evidence, and its authenticity was not disputed by the applicant (§ 37).
The Court also addressed the aforementioned case of Schenk v. Switzerland (1988), in which significance was attached to the fact that the impugned recording was not the only evidence against the applicant. In Khan, the Court clarified that the significance of the existence of evidence other than the impugned evidence depends on the circumstances of the case. In the circumstances at hand—where the recording was regarded as very strong evidence and where there was no risk of it being unreliable—the need for supporting evidence was correspondingly weaker (§ 37).
In his dissenting opinion, Judge Loucaides argued that a trial cannot be “fair” within the meaning of Article 6 if guilt is established on the basis of evidence obtained in violation of Convention-guaranteed human rights. In his view, the exclusion of such evidence constitutes an essential corollary of the right to privacy, without which that right becomes illusory. He further emphasized that “breaking the law, in order to enforce it, is a contradiction in terms and an absurd proposition.”
The Khan judgment thus confirms the jurisprudential line inaugurated in Schenk: the mere fact that evidence was obtained in violation of Article 8 of the Convention does not automatically render the trial unfair within the meaning of Article 6. Only an accumulation of aggravating circumstances or a particularly egregious violation undermining the very essence of the right to a fair trial could lead to a different outcome—a conclusion the Court reached in neither Schenk nor Khan.
VI. The Polish Specificity: The Admissibility Principle Under Article 168a of the Code of Criminal Procedure
Article 168a of the Polish Code of Criminal Procedure, introduced with effect from July 1, 2015, and significantly amended by the revision of March 11, 2016, represents a distinctive compromise between two opposing tendencies: complete exclusion and complete permissibility of evidence obtained in violation of law.
The provision stipulates that evidence may not be deemed inadmissible solely on the ground that it was obtained in violation of procedural provisions or by means of a prohibited act as defined in Article 1 § 1 of the Criminal Code, unless the evidence was obtained in connection with the performance of official duties by a public official, as a result of: homicide, intentional infliction of bodily harm, or deprivation of liberty.
A grammatical interpretation leads to the conclusion that virtually all illegally obtained evidence is admissible, regardless of who obtained it or under what circumstances.
Meanwhile, doctrine and jurisprudence—invoking the imperative of pro-constitutional interpretation—have introduced distinctions that simply do not appear in the text of the provision: a separate standard for public officials, a requirement of connection with official duties, and a fairness test for the proceedings as a whole. These interpretive constructions are axiologically sound and consistent with Strasbourg standards, yet they are difficult to derive from the plain language of Article 168a.
VII. Tax Proceedings: Distinct Standards
A. European Practice: Conditional Admissibility
European tax jurisdictions adopt more protective approaches, though still distinct from the rigors of criminal law.
Of landmark significance is the judgment of the French Court of Cassation of December 22, 2023. In civil tax proceedings, the Court held that illegality or unfairness in obtaining evidence does not necessarily result in automatic exclusion. Instead, judges must balance the right to evidence (the party’s need to prove its case), competing fundamental rights (privacy, trade secrets, banking secrecy), and the availability of alternative, less prejudicial evidence.
This proportionality test asks: Is the evidence necessary for the party to vindicate its rights, and is any infringement strictly proportionate to the intended objective? Evidence obtained through unfair methods (such as recordings made without consent) may be excluded if less prejudicial alternatives exist.
In VAT matters, the Court of Justice of the European Union in Case C-310/16 Dzivev and Others (2019) examined whether unlawfully intercepted telecommunications could be utilized in VAT evasion proceedings. The Court held that while Member States must effectively prosecute VAT fraud, they are not required to disregard domestic rules excluding illegally obtained evidence. The effectiveness of EU law encounters limits when it collides with fundamental rights.
VIII. Civil Proceedings: Minimal Exclusionary Standards
A. The Common Law Model
In English civil procedure, illegally obtained evidence is, as a general rule, admissible. The Civil Procedure Rules provide that courts may refuse to admit evidence upon which a party seeks to rely, but only if the circumstances of its procurement have been examined, admission would adversely affect the fairness of the proceedings, and the court exercises discretion taking into account all circumstances.
In practice, courts rarely exclude evidence solely on grounds of illegal procurement; instead, they may impose costs sanctions, refuse interest on damages, or apply other sanctions. A party engaging in illegal evidence procurement “may suffer serious consequences, particularly as to costs. Although the court will not usually allow the substantive merits of a claim to be defeated by illegally obtained evidence,” the deterrent effect of costs remains significant.
B. The Evolution of French Law
France illustrates the evolving European civil practice. Historically, evidence obtained unfairly (without consent, through deception) was excluded from civil proceedings. However, the aforementioned Court of Cassation judgment of December 22, 2023 aligned civil law with criminal law standards.
Evidence obtained unfairly or illegally need not be excluded if two conditions are satisfied. First, necessity—the evidence is essential for the party to vindicate its right to proof. Second, proportionality—any infringement of competing rights is strictly proportionate to the intended objective.
The rationale is pragmatic: courts recognized that automatic exclusion of unfairly obtained evidence may deprive litigants of the sole means of proving their rights—particularly in cases involving employer misconduct, spousal wrongdoing, or business malfeasance, where evidence may be difficult to obtain through lawful means.
IX. Key Variables Determining Admissibility
The admissibility of evidence across jurisdictions and types of proceedings depends upon several vectors that may be presented in synthetic form.
In criminal proceedings, automatic exclusion is frequently applied, judicial discretion is limited to exceptions, the fairness test applies, state action is a requisite factor, fundamental rights constitute a blocking rule, and the necessity of evidence is generally not required.
In civil tax proceedings, automatic exclusion is rarely applied, judicial discretion is the default rule, the fairness test may apply, state action is of secondary significance, fundamental rights carry significant weight in the balancing analysis, and the necessity of evidence is increasingly required.
In civil proceedings, automatic exclusion is rarely applied, judicial discretion is the default rule, the fairness test may apply, state action is not required, fundamental rights are subject to balancing, and the necessity of evidence is required (particularly in France).
In VAT/hybrid proceedings, automatic exclusion is limited, outcomes are case-dependent, the ECHR fairness test applies, state action is required according to CJEU jurisprudence, fundamental rights constitute a blocking rule, and the necessity of evidence is required pursuant to CJEU case law.
X. Practical Implications
A. Defense Strategy in Criminal Cases
In jurisdictions with mandatory exclusionary rules, practitioners should file motions to exclude illegally obtained evidence at an early stage, demonstrate standing through direct violation of rights, challenge warrants lacking particularity or independent judicial oversight, invoke attenuation and inevitable discovery doctrines where applicable, and preserve issues for appeal in the event of denial of exclusion motions.
In ECHR and EU jurisdictions with discretionary approaches, practitioners should develop comprehensive proportionality arguments emphasizing fairness to the accused, highlight the gravity and deliberate character of violations, demonstrate the inadequacy of alternative evidence, cite fairness precedents and fundamental rights violations, and seek procedural safeguards (the right to challenge authenticity, adversarial presentation).
B. Tax Practice and Asset Protection
Tax advisors must recognize the risk of parallel proceedings—evidence excluded in criminal proceedings may remain admissible in civil tax assessment (the American model). Tax authorities may obtain and utilize illegally procured evidence if they were not directly involved in the illegality. European tax proceedings offer greater protection through proportionality analysis. Challenges to evidentiary admissibility must be raised at the appropriate juncture—sometimes before assessment, sometimes in administrative review.
C. Civil Disputes
Civil practitioners should recognize that procedural illegality does not preclude substantive justice (the common law tradition), anticipate costs sanctions rather than evidentiary exclusion as the enforcement mechanism, argue necessity and proportionality with precision in proportionality-based systems, distinguish between evidence obtained by the party itself and that obtained by the state, and raise illegality as an issue affecting credibility and sanctions rather than as a categorical bar.
XI. Conclusion
The legal treatment of illegally obtained evidence reflects deep jurisprudential divisions concerning the objectives of procedural law. Criminal systems emphasize deterrence and constitutional protection through exclusion; tax systems prioritize revenue collection and administrative efficiency; civil systems focus on substantive justice between private parties with cost-based deterrence.
The global standard does not entail uniform exclusion but rather differentiated protection based upon the type of proceeding (criminal proceedings receive the strongest protection), the nature of the violated rights (absolute rights trigger automatic exclusion in every context; qualified rights are subject to proportionality analysis), state involvement (state action is subject to scrutiny; private action is treated more leniently), fairness analysis (increasingly central in ECHR and EU jurisprudence, supplanting categorical rules), and necessity and proportionality (emerging as universal balancing factors).
For practitioners in international contexts, the cardinal observation is that the same evidence may be admissible in civil proceedings, inadmissible in criminal proceedings, and again admissible in parallel tax proceedings. A strategic understanding of these distinctions—and of the evolving proportionality frameworks transforming European civil and tax law—is indispensable for contemporary legal practice across jurisdictions.
The 2023 judgment of the French Court of Cassation and ongoing EU jurisprudence suggest a broader turn toward proportionality-based balancing rather than categorical exclusion. However, fundamental rights limitations—particularly those concerning torture, absolute human rights violations, and systematic procedural abuses—remain inviolable across all systems and types of proceedings.
Publications by Kancelaria Prawna Skarbiec on Illegally Obtained Evidence
Robert Nogacki: Illegally Obtained Evidence in Tax Proceedings
Tax authorities cannot uncritically accept evidentiary materials transmitted by prosecutors or intelligence services. Where key evidentiary material—including wiretap recordings—was obtained through operational activities, the tax authority should independently verify its legality before utilizing it as a basis for its determination.
Robert Nogacki: May One Sign a Document on Behalf of Another Person?
December 3, 2025: In the basement of the White House, in a room accessible to only a handful of officials, stands an unremarkable device the size of a small printer. It has a mechanical arm into which nearly any pen or stylus may be inserted. Upon receiving a signal, the arm comes to life and traces a signature—fluid, confident, with appropriate pressure on the paper. The signature of the President of the United States.
Robert Nogacki: Wiretaps and Recorded Conversations in Tax Cases
January 26, 2026: How surveillance materials find their way into tax cases—from Wall Street to Polish administrative courts. Al Capone was not apprehended during an armed robbery. Raj Rajaratnam, the billionaire from Wall Street, was not caught in the act of insider trading. Both were brought down by something far more prosaic: financial documents and—in Rajaratnam’s case—thousands of hours of intercepted telephone conversations.
Robert Nogacki: The Limits of Police Entrapment
February 27, 2023: Police provocation is intended to detect crimes, not to induce them and entangle individuals so as to provoke their commission. John DeLorean, the American engineer and inventor, founder of the automobile company immortalized in the film “Back to the Future,” fell victim to entrapment similar to that which occurred in Poland involving “Agent Tomek.” DeLorean was acquitted after a three-year trial, but his company DMC had declared bankruptcy and ceased operations in the interim.
Robert Nogacki: Does the End Justify the Means?
Gustave Le Bon—the French sociologist and psychologist—wrote that a political assembly is the only place on Earth where personal abilities matter least—only appropriate eloquence counts. This thought comes to mind when reading the interpretation of criminal procedure provisions offered by Minister Ziobro. The Minister responsible for the judiciary and codification of criminal law discusses the provisions in a manner that earns him applause but would certainly not earn him a passing grade on a law school examination (…)
Robert Nogacki: The Tax Authorities Have Treated an Entrepreneur as a Criminal for Six Years. They Gather Evidence Against Him in an Unreliable and Unlawful Manner
December 27, 2019: In its summary of a report on “Legal Barriers to the Development of Family Businesses in Poland” published on January 2, 2019, the Supreme Audit Office stated: “The audit of tax offices and the Ministry of Finance demonstrated that the complicated nature of legal provisions and their frequent amendments may continue to constitute the main barrier to conducting business activity.” In its report, the SAO noted, inter alia, a high number of errors committed by tax officials. In the examined period of Q1 2018, the SAO found that 55% of individual interpretations issued by tax authorities were annulled by administrative courts, and 29.1% of tax decisions were annulled by second-instance authorities, with 16.1% of those decisions annulled by voivodeship administrative courts (a combined annulment rate of 45% of tax authority decisions; similar values appeared in the SAO’s 2015 report on tax inspection office activities). In the case of one client of the Warsaw-based Kancelaria Prawna Skarbiec, the authority has been doggedly conducting audit proceedings for six years, despite another, higher-instance authority having twice annulled its erroneous decisions during that period.
Robert Nogacki: Controversies Surrounding Police Entrapment
December 8, 2022: The question of police inducement has long been the subject of lively controversy. The central dilemma concerns police investigations that lawfully require the use of undercover agents, informants, or other covert practices and are fundamentally not conducted passively. The type of influence exerted in this manner upon an individual culminates in the commission of an offense that might otherwise not have occurred.
Robert Nogacki: Authorities Collect Data on Entrepreneurs and Citizens, Though They Know It Violates EU Law
January 18, 2023: Authorities and intelligence services will check what you discuss through internet messengers and chat applications. They will review your email correspondence and search history. On January 12, 2023, the first reading of the draft Electronic Communications Law took place in the Sejm—a bill that in reality constitutes an attempt to legalize nearly unrestricted state surveillance of citizens. Additionally, beginning in 2024, the tax authorities will receive your purchase invoices, from which they will learn what, how much, and how often you buy.
Robert Nogacki: Big Brother Is Watching, or What the General Inspector of Financial Information Knows About Us
The annual report on the activities of the General Inspector of Financial Information permits an estimation of what information about citizens our government collects in connection with anti-money laundering efforts and the fight against terrorism financing.
Founder and Managing Partner of Skarbiec Law Firm, recognized by Dziennik Gazeta Prawna as one of the best tax advisory firms in Poland (2023, 2024). Legal advisor with 19 years of experience, serving Forbes-listed entrepreneurs and innovative start-ups. One of the most frequently quoted experts on commercial and tax law in the Polish media, regularly publishing in Rzeczpospolita, Gazeta Wyborcza, and Dziennik Gazeta Prawna. Author of the publication “AI Decoding Satoshi Nakamoto. Artificial Intelligence on the Trail of Bitcoin’s Creator” and co-author of the award-winning book “Bezpieczeństwo współczesnej firmy” (Security of a Modern Company). LinkedIn profile: 18 500 followers, 4 million views per year. Awards: 4-time winner of the European Medal, Golden Statuette of the Polish Business Leader, title of “International Tax Planning Law Firm of the Year in Poland.” He specializes in strategic legal consulting, tax planning, and crisis management for business.
