Cryptocurrency Regulations in Poland: A Guide

Reporting Requirements

In Poland, Virtual Currency Service Providers (VCSPs) are required to submit external reports to the General Inspectorate of Financial Information (GIFI) and track internal investigations and escalations.

Submission of External Reports

• The Anti-Money Laundering Officer is responsible for submitting external reports to the GIFI.
• The submission of external reports shall not:
  • Allow for attributing a lower risk of money laundering and terrorist financing to the customer
  • Limit the application of customer due diligence measures
  • Exempt the company from applying enhanced due diligence measures
  • Exempt the company from terminating business relationships with customers who cannot be properly identified

Reporting Obligations for VCSPs

• VCSPs must report:
  • Accepted payments or executed withdrawals of virtual currency exceeding EUR 15,000
  • Executed transfers of virtual currency exceeding EUR 15,000 (with some exemptions)
  • Purchase and sale transactions of foreign currency with a value exceeding EUR 15,000

Suspicious Transactions

VCSPs should report suspicious transactions identified by:

Identifying Suspicious Transactions

• Noting activities that may be related to money laundering or terrorist financing
• Conducting customer and beneficial owner identification
• Ongoing monitoring of the business relationship

Reporting Suspicious Transactions

• Reports to the GIFI shall be made using a relevant reporting template and sent via their website or email.

Infringement Reporting

Any VCSP employee or person performing activities for the VCSP who becomes aware of real or potential infringements of Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CTF) provisions must report the conduct using an infringement report form.

Making Infringement Reports

• The infringement report may only be done in good faith, and it is prohibited to knowingly make a false report.

Estate Planning and Testamentary Succession

There are no specific regulations in place that directly address cryptocurrencies in the context of estate planning and testamentary succession in Poland. However, general principles of Polish inheritance law would apply to cryptocurrencies as they would to other types of assets.

General Principles

• The rules governing estate planning and testamentary succession for cryptocurrencies will be determined by the same laws and regulations as those applicable to other types of assets.