Financial Crime World

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Poland’s Efforts to Combat Money Laundering and Terror Financing: A Mixed Bag

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In its ongoing efforts to combat money laundering (ML) and terror financing (TF), Poland has made significant strides, but still faces several challenges. According to a recent report, the country is exposed to medium-level ML and TF risks, primarily emanating from:

  • Tax offences
  • Corruption
  • Organised criminal groups

The Role of the Financial Intelligence Unit (GIFI)

The GIFI plays a crucial role in monitoring suspicious transactions and reporting activities to relevant authorities. However, designated non-financial businesses and professions (DNFBPs) tend to avoid high-risk business relationships, limiting the implementation of effective due diligence measures.

Financial Institutions’ (FIs) Due Diligence Measures

While FIs employ comprehensive transaction monitoring systems, the reporting behavior of Reporting Entities (REs) is largely commensurate with their materiality and exposure to risks.

Supervision by the Polish Financial Supervision Authority (UKNF)

The UKNF has a robust approach, particularly in relation to:

  • Legal ownership
  • Beneficial ownership

Public Procurement Sector (NPO)

The National Bureau of Public Procurement (NPO) sector was not assessed from a TF perspective. However, authorities have identified investigations involving foreign NPOs.

Areas for Improvement

According to the report, Poland needs improvement in several areas, including:

  • Mechanism to systematically collect comparable statistics on AML/CFT effectiveness
  • Implementation of a more comprehensive risk assessment framework
  • Criminalization of TF and new technologies

Private Sector’s Application of AML/CFT Preventive Measures

While the private sector is generally advanced in applying AML/CFT preventive measures commensurate to their risks, there are still several issues remaining.

Conclusion

In conclusion, while Poland has made significant strides in strengthening its AML/CFT framework, it remains essential for the country to address these outstanding issues to effectively combat ML and TF.