Financial Crime World

Here is the rewritten article in markdown format:

Financial Inclusion: Poland’s Anti-Money Laundering Measures

In an effort to combat financial crime, the Polish government has implemented strict anti-money laundering (AML) measures for obligated institutions. According to the Act of March 1, 2018, on the prevention of money laundering and terrorist financing, these entities are required to identify and report any suspicious transactions.

Who is Subject to AML Obligations?

In Poland, the following entities are considered obligated institutions:

  • Banks
  • Credit and financial institutions
  • Investment firms
  • Investment funds
  • Entrepreneurs providing services related to registered offices or business addresses
  • Accounting bookkeeping services

These entities must comply with all AML obligations, including:

  • Risk assessments
  • Customer verification
  • Employee training
  • Reporting suspicious transactions

The most critical internal document for obligated institutions is the risk assessment related to money laundering and terrorist financing. This document outlines potential threats and must be prepared or updated every two years.

Additionally, an internal AML procedure should also be implemented, outlining measures taken to mitigate risks and proper management of identified risks.

Customer Verification and Identification

Obligated institutions must exercise due diligence when establishing and maintaining business relationships with customers. This includes:

  • Identifying and verifying customer identities
  • Determining beneficial ownership
  • Assessing business relationships
  • Continuous monitoring of customer relationships

Employee Obligations

Obligated institutions must provide employees performing AML duties with training on data protection issues.

Employees should also be enabled to report actual or potential violations anonymously.

Reporting Violations

In specific situations, obligated institutions are required to report suspicious transactions to the General Inspector of Financial Information. This includes:

  • Reporting discrepancies in customer information
  • Confirming cash transactions exceeding EUR 15,000

Penalties for Non-Compliance

Failure to comply with AML obligations can result in:

  • Administrative penalties, including:
    • Publication of information on a government website
    • Cessation of specific actions
    • Revocation of concessions or permits
    • Fines
  • Criminal sanctions may also be imposed on individuals acting on behalf of or for the benefit of an obligated institution.

Conclusion

In conclusion, Poland’s anti-money laundering measures are designed to create a robust system for combating financial crime. Obligated institutions must comply with strict obligations to prevent money laundering and terrorist financing. Entrepreneurs in Poland should determine whether their company is considered an obligated institution and adjust their business activities accordingly to avoid potential penalties.