Risk Assessment for Financial Institutions in Poland: New National Report Published by Ministry of Finance
Introduction
The Ministry of Finance in Poland has published a new national risk assessment on money laundering and terrorist financing, updating the previous assessment from 2019. This comprehensive report provides an overview of the Polish anti-money laundering (AML) and combating of terrorist financing system, highlighting the tasks of individual public administration bodies and market participants in combating money laundering and terrorist financing.
Importance for Financial Institutions
The new national risk assessment is crucial for financial institutions in Poland as it updates their need to review and modify their own risk assessments relating to their activities. Failure to do so may result in administrative penalties, including fines or withdrawal of authorization to operate.
Key Takeaways
- Obliged institutions should pay particular attention to Annex 2 of the report, which provides comprehensive conclusions on the threats and risks per sector.
- The annex identifies 14 sectors, including banking, insurance, foreign exchange, and real estate, and highlights specific money laundering and terrorist financing patterns in each area.
Guidance for Obliged Institutions
The report provides guidance for obliged institutions on how to mitigate these risks, with scenarios described for the use of obliged institutions in a given sector for money laundering or terrorist financing. Notably, the report identifies situations that may seem positive but pose significant risks, such as premature repayment of incurred liabilities.
Key Recommendations
- Leasing companies should focus on Annex 2, as they may be vulnerable to criminal activity.
- Analyze claims for reimbursement of overpayments by lessees and suspend refund requests where overpayments are not justified by customers’ business.
Assistance from AML Team
The AML team at [law firm] is available to assist financial institutions in Poland with any questions or concerns regarding the new national risk assessment and its implications. We can help you navigate the complexities of the report and ensure compliance with AML regulations.
Contact Us
If you have any questions or would like to discuss how this report affects your institution, please do not hesitate to contact us. We are here to help you stay compliant and protect your business from money laundering and terrorist financing risks.