Financial Crime World

Poland Strengthens Money Laundering Detection Methods

In a move aimed at increasing transparency and combating financial crime, Poland’s President has signed an amendment to the country’s Anti-Money Laundering and Countering the Financing of Terrorism Law (AML Act). The changes, which come into effect on April 8, are designed to enhance the effectiveness of authorities in detecting funds derived from criminal activity or used for terrorist financing purposes.

Key Changes

  • The AML Act now includes a broader range of obliged institutions, including:
    • Entrepreneurs who provide services related to tax and customs laws
    • Those dealing in works of art and antiques
  • Definitions of beneficial owner (UBO) and politically exposed person (PEP) have been updated, requiring obliged institutions to collect more information about clients and verify their identity
  • New prerequisites for applying financial security measures to existing clients, including changes related to UBOs and PEPs

Enhanced Verification Requirements

  • Obliged institutions must now document the reasons why certain client information cannot be verified and take this into account when performing client risk assessments
  • Verification of UBOs has become more formalized, with obliged institutions required to obtain additional information and clarify discrepancies between client records and their own verification results

Expanded Reporting Requirements

  • The catalogue of entities that must report UBO details has been expanded, increasing the number of companies required to register their UBOs in Poland’s Central Register of Beneficial Owners
  • A list of PEP positions published by the Ministry of Finance will facilitate decision-making on PEP risk

Additional Measures

  • Obliged institutions are now required to include personal data protection aspects into AML training and awareness sessions
  • Review and update their AML policies regularly
  • Protect whistleblowers from negative actions

Navigating Changes with TMF Group

To help businesses navigate these changes, TMF Group offers a range of services, including:

  • Legal set-up and oversight
  • Regulatory filings
  • Accounting
  • Tax
  • Payroll

With 120 offices in 85 jurisdictions, our local teams are well-equipped to provide expert guidance on AML compliance challenges in Poland and beyond.