KRS Law Firm · Compliance
AML — Anti-Money Laundering
Anti-money laundering and counter-terrorist financing rules impose on obliged entities a range of duties whose breach attracts some of the most severe compliance sanctions, including administrative fines, criminal liability in some cases and the loss of permission to operate. We help determine whether your business is an obliged entity, implement required procedures and keep them aligned with changing law. We are based in Łódź and advise clients throughout Poland.
We provide AML support as part of a broader compliance system — AML duties are closely linked to beneficial ownership identification, data protection and whistleblowing procedures.
KRS
01
Who Is Subject to AML Obligations?
The Act of 1 March 2018 identifies a range of obliged entities, progressively expanded by amendments. These include banks, payment institutions, accountants, law firms, estate agents, cryptoasset businesses and businesses accepting cash above the statutory threshold. The first step is always a careful assessment of whether the rules apply to the business — obliged-entity status is not always obvious, and overlooking it can be costly.
02
What Does the AML Act Require?
The duties fall into several groups. The first is risk assessment — preparing and updating the business’s money laundering risk assessment. The second is customer due diligence (KYC): identifying and verifying customers and beneficial owners, assessing customer risk, monitoring transactions, identifying politically exposed persons (PEPs) and checking sanctions lists.
The third group is cooperation with the General Inspector of Financial Information (GIIF) — reporting suspicious transactions and, generally, transactions above the threshold, and providing information on request. The fourth comprises organisational duties: appointing responsible persons, including the AMLRO, internal AML and anonymous reporting procedures, record retention and cooperation with inspections.
03
Training and Liability
The Act also requires regular training for those performing AML duties. Both failing to train and providing training that does not meet statutory requirements create risks. Breaches, particularly failing to report suspected money laundering or obstructing inspections, may attract sanctions against the business and the individuals acting for it.
04
Beneficial Ownership and the Central Register
AML obligations include identifying and reporting the beneficial owner — the individual who ultimately controls the entity. Identifying them requires analysis of the ownership structure, so we work with our corporate legal services, which handles corporate and registration matters. Beneficial ownership findings and filings can therefore remain consistent with other company records.
05
Support as an AML Officer
For many obliged entities, it is most cost-effective to outsource AML support. As an external AML Officer, we prepare risk assessments and internal procedures, verify customers, support GIIF reporting, train staff and prepare for inspections. This gives access to practitioners familiar with current guidance without building an internal specialist team.
We provide this as part of comprehensive legal support for businesses.
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Contact Us
Unsure Whether AML Rules Apply to Your Business, or Want Procedures in Place Before an Inspection? Get in Touch. We will assess your business’s status and propose support appropriate to its scale.