Poland Urged to Improve Anti-Money Laundering and Terrorism Financing Efforts

Strasbourg, February 1, 2022

The Council of Europe’s MONEYVAL Committee has released a scathing report highlighting Poland’s shortcomings in combating money laundering (ML) and terrorism financing (TF). The report calls on Polish authorities to take immediate action to strengthen their efforts and improve their legal framework.

Key Findings

• While Poland’s legal framework provides transparency for legal persons and beneficial ownership, there is still much work to be done.
• The private sector has shown effectiveness in implementing ML and TF prevention measures, but authorities must do more to understand ML threats and vulnerabilities.
• The Polish Financial Intelligence Unit (FIU) plays a crucial role in gathering financial intelligence, but its analysis is not being sufficiently exploited at the investigative stage.

Recommendations

• Take procedural and institutional measures to improve ML detection and investigation, including:
  • Adopting guidelines for parallel financial investigations
  • Tasking law enforcement agencies with ML probes
• Improve cash control mechanisms at the border by providing a legal basis for stopping suspicious assets.
• Clarify that TF is a standalone crime and not just a byproduct of terrorism.
• Address gaps in preventing criminal control of obliged institutions, provide resources for effective supervision, and conduct a risk assessment on non-profit organizations (NPOs) exposed to TF risks.

Additional Recommendations

• Establish a supervisory system, including a sanctioning regime, to combat proliferation financing.
• Prioritize awareness-raising activities to educate entities about their obligations under anti-money laundering regulations.

Consequences

Poland will be subject to MONEYVAL’s enhanced follow-up reporting process as a result of the report. The authorities must take immediate action to address these shortcomings and improve their efforts to combat ML and TF.