Financial Crime World

Stricter Due Diligence Measures for Financial Institutions in Poland

To combat money laundering and terrorist financing, Poland’s Anti-Money Laundering Act (AML) has introduced stricter due diligence measures for financial institutions.

Obligated Situations

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

  • Establishing a business relationship with a customer
  • Conducting an occasional transaction worth €15,000 or more
  • Transferring funds exceeding €1,000
  • Conducting cash transactions worth €10,000 or more
  • Suspecting money laundering or terrorist financing

Politically Exposed Persons (PEPs)

In addition to these situations, obligated institutions must also apply due diligence measures when dealing with PEPs. This includes:

  • Obtaining approval from senior management
  • Enhancing the application of financial security measures

Customer Identification and Information Gathering

Financial institutions must verify the identity of customers and gather specific information, including:

  • Full name
  • Residential address
  • Citizenship
  • Date and place of birth

For corporate entities, this information includes:

  • Company name
  • Organizational form
  • Registered office or principal place of business
  • Tax identification number
  • Commercial registration number
  • Date of registration

Reporting Requirements

The AML Act stipulates that obligated institutions must report certain transactions to Poland’s General Inspector of Financial Information (GI). This includes:

  • Reporting payments or disbursements exceeding €15,000
  • Transfers of funds exceeding €15,000

Information must be reported within seven days of the transaction and include specific details such as:

  • Unique transaction identifier
  • Date and time
  • Contractor identification data
  • Transaction type

Suspicion Reporting

Financial institutions are also required to notify the GI of circumstances that could indicate a suspicion of money laundering or terrorist financing, as well as cases where they have a justified suspicion that a given transaction or property values may be associated with these crimes.

Conclusion

The AML Act aims to strengthen Poland’s anti-money laundering and anti-terrorist financing framework by introducing stricter due diligence measures for financial institutions. These measures will help to prevent the misuse of the financial system and ensure a safer and more transparent economy.