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Polish Financial Institutions Must Implement Customer Due Diligence Measures to Combat Money Laundering and Terrorist Financing

In a bid to combat money laundering and terrorist financing, Poland’s Anti-Money Laundering Act (AML Act) requires financial institutions to implement customer due diligence measures in certain situations. These measures aim to ensure that customers are properly identified and transactions are monitored to prevent illegal activities.

When Do Financial Institutions Need to Implement Customer Due Diligence Measures?

Financial institutions must apply customer due diligence measures in the following scenarios:

  • Establishment of business relationships with a duration element, such as opening an account or conducting a series of transactions.
  • Conducting an occasional transaction valued at €15,000 or more, regardless of whether it’s a single operation or multiple related operations.
  • Conducting an occasional transfer of funds exceeding €1,000.
  • Conducting an occasional cash transaction valued at €10,000 or more.
  • Suspicions of money laundering or terrorist financing.

Additionally, financial institutions must apply customer due diligence measures when dealing with a politically exposed person (PEP). This includes obtaining senior management approval for establishing or continuing business relationships with PEPs and enhancing the application of financial security measures.

What Are Customer Due Diligence Measures?

Customer due diligence measures involve verifying a customer’s identity and gathering additional information. For natural persons, this includes collecting data such as:

  • Full name
  • Residential address
  • Citizenship
  • Date and place of birth
  • Tax identification number (TIN)

For corporate entities, this includes collecting data such as:

  • Business name
  • Organizational form
  • Registered office or address of conducting business
  • TIN
  • Commercial registration number
  • Date of registration

Verification of identity can be based on documents proving a person’s identity, excerpts from relevant registers, or other reliable sources. Financial institutions must also monitor transactions to detect suspicious activity and report any findings to the General Inspector of Financial Information (GIFF).

What Are Financial Institutions Required to Report?

Financial institutions are required to report certain transactions to GIFF within seven days of receiving payment or making a disbursement. These reports include information such as:

  • Transaction identifier
  • Date and time
  • Contractor identity
  • Amount and currency
  • Transaction type
  • Description
  • Account numbers

In addition, financial institutions must notify GIFF of any circumstances that could indicate money laundering or terrorist financing suspicions. They are also required to report cases of justified suspicion to the competent prosecutor.

By implementing customer due diligence measures and reporting suspicious transactions, Poland’s financial institutions play a critical role in combating money laundering and terrorist financing.