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Dr hab. Anna Lichosik-Ślusarczyk
ORCID: 0000-0002-6727-6648

Assistant professor at the Faculty of Law and Administration of the University of Silesia in Katowice holding a postdoctoral degree in law. Her research focuses on issues related to the legal regulation of the capital market, particularly the functioning of public companies and investment fund companies. She applies her theoretical knowledge to supporting business transactions, currently managing the Supervisory Department of a bank investment fund company, and previously the Compliance Department and Legal Department. She holds degrees in law from the Faculty of Law and Administration of the University of Silesia in Katowice, management from the School of Management of the University of Silesia in Chorzów, and international economic relations from the Faculty of Economics of the University of Economics in Katowice. She completed her legal training at the District Chamber of Legal Counsel in Katowice and the Summer Institute of Law and Economics at the University of Chicago Law School (USA).

 
DOI: 10.33226/0137-5490.2026.2.4
JEL: K23

The possibility of concluding an arrangement before the Polish Financial Supervision Authority on the conditions for extraordinary easing of sanctions was introduced into the Polish legal system by Article 19 of the Act of 16 August 2023 amending certain acts in connection with ensuring the development of the financial market and the protection of investors on this market, which entered into force on 29 September 2023. Under this regulation, the provisions of Article 18k–18z were introduced to the Act on Financial Market Supervision, which regulate issues related to the arrangement on the conditions for extraordinary easing of sanctions. The introduction of this type of legal institution should still be treated as an innovative solution. It was not until the second half of 2024 that the Polish Financial Supervision Authority issued the first decisions ending administrative proceedings as a result of concluding an arrangement with supervised entities. The article attempts to analyse a new legislative tool in the form of an arrangement on the conditions for extraordinary easing of sanctions, including in particular an assessment of its chances for improving supervision exercised by the Polish Financial Supervision Authority, as well as potential threats resulting from the necessity inherent in the arrangement for the party to waive its constitutional rights in terms of the possibility of challenging an administrative decision issued by the body.

Keywords: arrangement; PFSA; administrative sanctions; voluntary submission to punishment