AML in Poland
Since 2018, I have been advising Polish and foreign companies on anti-money laundering regulations in Poland.
My experience in AML in Poland developed through work with businesses operating in the crypto-assets and payment services sectors. In addition to providing AML legal services through Law Firm in Poland as a Polish attorney-at-law, I serve as an AML Officer (MLRO) for obliged entities.
Over the years, AML compliance has become one of the core areas of my legal practice, alongside corporate law.
More information about my professional experience in AML may be found in my article “10 Years of Law Firm in Poland”.
AML services in Poland
As part of my legal practice at Law Firm in Poland, I provide comprehensive legal services covering the full scope of AML/CFT matters in Poland. I assist obliged entities with individual AML matters and provide ongoing legal support, depending on their needs.
AML framework
Design and implementation of AML frameworks for obliged entities, tailored to the nature, scale and risk profile of their activities and aligned with applicable AML/CFT requirements.
AML Policies
Preparation, review and updating of internal AML policies, procedures and supporting documentation, including assessment of their completeness and compliance with the Polish AML Act.
AML legal opinions and regulatory advice
Preparation of formal legal opinions for internal and external use. Assessment and interpretation of specific AML/CFT issues.
Onboarding support
Support during onboarding with banks, payment institutions and other financial partners, including responding to AML-related enquiries, preparing onboarding documentation and addressing compliance requirements raised during the process.
Customer due diligence
Advice on the adequacy, scope and application of customer due diligence (CDD) and enhanced due diligence (EDD) measures, referred to in the Polish AML Act as financial security measures.
Ongoing AML legal support
Ongoing legal support to obliged entities in interpreting and applying AML/CFT requirements in their day-to-day business operations.
AML Officer (MLRO) services
Provision of AML Officer (MLRO) services to obliged entities, including the performance of the statutory function required under Article 8 of the Polish AML Act.
Suspicious activity assessment and reporting
Assessment of business relationships, transactions and other circumstances to determine whether they may indicate money laundering or terrorist financing, followed by preparation and submission of the relevant notifications to GIIF under the Polish AML Act.
Contact with public authorities
Handling AML-related correspondence with public authorities, including preparing responses to requests for information and documents from the Police, the Public Prosecutor's Office, GIIF and other competent authorities.
AML training
AML/CFT training for management board members and employees of obliged entities, covering their statutory responsibilities and obligations under the Polish AML Act.
External AML audits
Conducting external AML/CFT audits for obliged entities, including assessment of the completeness and effectiveness of their AML frameworks, internal procedures and controls against the requirements of the Polish AML Act.
Representation during AML inspections
Representation of obliged entities during AML inspections conducted by GIIF and other competent Polish authorities.