New reporting obligations - VASP in Poland

Questions:

1. Is entity entered in the VASP Register, related to conducting the activity mentioned in Article 2(1)(12)(a) of the Polish AML Act – (exchange between virtual currencies and means of payment)?
2. Does the entity actually conduct the activity mentioned in Article 2(1)(12)(a) of the law?
3. Date of commencement of the activity mentioned in Article 2(1)(12)(a) of the law?
4. Are there limits for clients regarding the number of transactions they can conduct with the entity in the context of the activity mentioned in Article 2(1)(12)(a) of the law?
5. What is the limit?
6. Are there limits for clients regarding the value of transactions they can conduct with the entity in the context of the activity mentioned in Article 2(1)(12)(a) of the law?
7. What is the limit converted to EUR?

[8-21  questions repeat the structure for different types of activities mentioned in Article 2(1)(12)(b), (c) of the law:

exchange between virtual currencies – Article 2(1)(12)(b);

intermediation in the exchange between virtual currencies and means of payment and between virtual currencies – Article 2(1)(12)(c)]

22. Is the entity in the register of activities related to virtual currencies, as mentioned in Article 129m of the law, registered for conducting the activity specified in Article 2(1)(12)(d) of the law – keeping maintaining the accounts in electronic form, of identifying data enabling the entitled persons to use virtual currency units, including the conduct of transactions of their exchange ?
23. Does the entity actually conduct the activity specified in Article 2(1)(12)(d) of the law?
24. What is the commencement date of the activity specified in Article 2(1)(12)(d) of the law?
25. Does the entity limit clients in the ability to open multiple accounts, as mentioned in Article 2(2)(17)(e) of the law (conducted in electronic form, a collection of identification data ensures authorized individuals the opportunity to use virtual currency units, including conducting transactions of their exchange)?
26. What is the limit on open accounts for one client?
27. Does the entity limit clients in the amount of balance they maintain for a specific client on the account or accounts, as mentioned in Article 2(2)(17)(e) of the law?
28. What is the limit converted to EUR?
29. Does the entity limit clients in the number of crypto asset transfers they can make using the account, as mentioned in Article 2(2)(17)(e) of the law?
30. What is the limit?
31. Does the entity limit clients in the value of crypto asset transfers they can make using the account, as mentioned in Article 2(2)(17)(e) of the AML law?
32. What is the limit converted to EUR
33. Number of active clients with low risk*
34. Number of active clients who are individuals with low risk*
35. Number of active clients who are individuals with low risk and do not have Polish citizenship*
36. Number of active clients who are not individuals with low risk, in which at least one ultimate beneficiary does not have Polish citizenship*

[37-44 questions repeat the structure for medium and high risk categories.]

45. Number of active clients with a residence or seat in Poland.
46. Utilizing the ISO-2 standard, provide the codes for 10 countries (excluding PL), where the residence or seat of the largest number of active clients of the entity is located, along with indicating the corresponding number of active clients for each country.
47. Number of active clients with a confirmed PEP status*
48. Number of identified ultimate beneficiaries with PEP status, excluding individual clients not conducting business activity.*

    ***

49. Number of clients subject to Article 117(2)(1) and (2) of the law, i.e., the application of specific measures to prevent terrorism and terrorism financing* it refers to application of special measures to persons and entities indicated on sanctions lists.
50.  Number of cases specified in Article 41(1)(1) of the law – refusal to establish a business relationship*
51. Number of cases specified in Article 41(1)(2) of the law – refusal to execute an occasional transaction*
52. Number of cases specified in Article 41(1)(4) of the law – termination of business relationships*
53. Number of notifications resulting from Article 41(2) of the law*

    Article 41. 1. Should the obligated institution be unable to apply one of the customer due diligence measures referred to in Article 34(1):
    1) it shall not establish a business relationship;
    2) it shall not perform an occasional transaction;
    3) it shall not conduct transactions through the bank account;
    4) it shall terminate a business relationship.
    2. The obligated institution shall assess whether the inability to apply the customer due diligence measures referred to in paragraph 1 forms basis for providing the General Inspector with the notification referred to in Article 74 or Article 86.

54. Number of clients reported to GIIF in connection with the application of Article 41(2) of the law*

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55. Number of cases specified in Article 86(10) of the law, in which the prosecutor suspended the transaction or imposed a block – suspension or account block for a period determined by the prosecutor despite the lack of GIIF notification*
56. Number of clients subject to Article 86(5) of the law, i.e., GIIF forwarded a request for suspension of transactions or account block to the obligated institution for a period not exceeding 96 hours*
57. Number of clients subject to Article 86(9) of the law, i.e., the prosecutor suspended the transaction or imposed a block for a specified period*
58. Number of clients subject to Article 87(1) of the law, i.e., GIIF issued a request for suspension of transactions or account block for a specified period*

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59. Number of clients subjected to analysis for the identification of suspicious circumstances or transactions (Number of clients requiring expert (manual) analysis, for whom the analysis was completed in the respective quarter. Including the number of clients resulting from reports of suspicious circumstances or transactions submitted to the AML/CFT unit or the person responsible for the AML/CFT area).
60. Number of individuals directly responsible for the current analysis of transactions (excluding employees dedicated exclusively to customer service)*
61. Number of reports of suspicious circumstances or transactions submitted to the AML/CFT unit, e.g., non-system reports (any channel) from branch employees, intermediaries, franchisees, distributors.
62. Number of notifications reported to GIIF based on Article 74(1) of the law* – notification of circumstances that may indicate suspicion of money laundering or terrorism financing.
63. Number of clients reported to GIIF based on Article 74(1) of the law* – notification of circumstances that may indicate suspicion of money laundering or terrorism financing.
64. Number of notifications reported to GIIF based on Article 86(1) of the law* – having reasonable suspicion that a specific transaction or specific financial values may be related to money laundering or terrorism financing
65. Number of clients reported to GIIF based on Article 86(1) of the law* – having reasonable suspicion that a specific transaction or specific financial values may be related to money laundering or terrorism financing.
66. Number of notifications reported to GIIF based on Article 90(1) of the law* – notification to the General Inspector via electronic communication means of the transaction mentioned in Article 86(1) when reporting was impossible before its execution.
67. Number of clients reported to GIIF based on Article 90(1) of the law* – notification to the General Inspector via electronic communication means of the transaction mentioned in Article 86(1) when reporting was impossible before its execution.
68. Number of notifications reported to the prosecutor based on Article 90(2) of the law* – notifying the relevant prosecutor of the transaction mentioned in Article 89(1) when reporting this transaction was impossible before its execution
69. Number of clients reported to the prosecutor based on Article 90(2) of the law* – notifying the relevant prosecutor of the transaction mentioned in Article 89(1) when reporting this transaction was impossible before its execution

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70. Number of clients for whom discrepancies in ultimate beneficiary data were reported, based on Article 61a(2) of the law* – submitting to the competent authority for the Register verified information about discrepancies with justification and documentation. Please include the types of clients mentioned in Article 58 of the law.

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71. Can OI handle cash deposits or withdrawals?*
72. Number of cash withdrawals*
73. Value of cash withdrawals converted to PLN at the average NBP exchange rate from the last business day of the last quarter.*
74. Number of cash withdrawals carried out by individuals with citizenship other than Polish, including those with dual citizenship*
75. Value of cash withdrawals made by individuals with citizenship other than Polish, including those with dual citizenship, converted to PLN at the average NBP exchange rate from the last business day of the last quarter.*
76. Number of cash withdrawals made by clients with a confirmed PEP status or clients with identified ultimate beneficiaries with PEP status*
77. Value of cash withdrawals made by clients with a confirmed PEP status or clients with identified ultimate beneficiaries with PEP status, converted to PLN at the average NBP exchange rate from the last business day of the last quarter.*
78. Number of cash deposits*
79. Value of cash deposits converted to PLN at the average NBP exchange rate from the last business day of the last quarter.*
80. Number of cash deposits made by individuals with citizenship other than Polish*
81. Value of cash deposits made by individuals with citizenship other than Polish, converted to PLN at the average NBP exchange rate from the last business day of the last quarter.*
82. Number of cash deposits made by clients with a confirmed PEP status or clients with identified ultimate beneficiaries with PEP status*.
83. Value of cash deposits made by clients with a confirmed PEP status or clients with identified ultimate beneficiaries with PEP status, converted to PLN at the average NBP exchange rate from the last business day of the last quarter.*

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84. Does OI accept crypto asset transfers made to or from non-hosted addresses?
85. Does OI have tools to detect the use of mixers or tumblers within blocks?
86. Does OI allow the reception of crypto asset transfers from customers of crypto asset transfers that have passed through mixers or tumblers or the sending of crypto asset transfers to addresses associated with mixers or tumblers?
87. Number of incoming crypto asset transfers to OI clients from outside OI*
88. Value of incoming crypto asset transfers to OI clients from outside OI converted to EUR*
89. Number of crypto asset transfers from non-hosted addresses*
90. Value of crypto asset transfers from non-hosted addresses converted to EUR*
91. Number of crypto asset transfers from addresses associated with mixers or tumblers*
92. Value of crypto asset transfers from addresses associated with mixers or tumblers converted to EUR*
93. Number of outgoing crypto asset transfers from OI clients outside OI*
94. Value of outgoing crypto asset transfers from OI clients outside OI converted to EUR*
95. Number of crypto asset transfers to non-hosted addresses*
96. Value of crypto asset transfers to non-hosted addresses converted to EUR*
97. Number of crypto asset transfers to addresses associated with mixers or tumblers?*
98. Value of crypto asset transfers to addresses associated with mixers or tumblers converted to EUR*
99. Number of crypto asset transfers between OI clients within OI*
100. Value of crypto asset transfers between OI clients within OI converted to EUR*

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101. Does OI have tools to determine whether the exchange between virtual currencies and payment instruments is made to or from non-hosted addresses?
102. Does OI accept the exchange between virtual currencies and payment instruments to or from non-hosted addresses?

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103. Number of cases of exchange between virtual currencies and payment instruments (fiat money).
104. Number of cases of exchange between virtual currencies and payment instruments to or from non-hosted addresses*
105. Value of payment instruments involved in the exchange between virtual currencies and payment instruments converted to EUR*
106. Value of payment instruments involved in the exchange between virtual currencies and payment instruments to or from non-hosted addresses converted to EUR*

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107. Does OI have tools to determine whether the exchange between virtual currencies is made to or from non-hosted addresses?
108. Does OI accept the exchange between virtual currencies to or from non-hosted addresses?

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109. Number of cases of exchange between virtual currencies*
110. Number of cases of exchange between virtual currencies to or from non-hosted addresses*
111. Value of virtual currency sold by OI to the client involved in the exchange between virtual currencies converted to EUR*
112. Value of virtual currency sold by OI to the client involved in the exchange between virtual currencies to or from non-hosted addresses converted to EUR*

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113. Does OI have tools to determine whether the exchange between:

– virtual currencies and payment instruments or

– virtual currencies

in which OI intermediates is made to or from non-hosted addresses?

114. Does OI intermediate in exchanges between:

– virtual currencies and payment instruments or

– virtual currencies

to or from non-hosted addresses?

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115. Does OI have tools to determine whether the exchange between:

– virtual currencies and payment instruments or

– virtual currencies

in which OI intermediates is made to or from an address assigned to a mixer or tumbler?

116. Does OI intermediate in exchanges between:

– virtual currencies and payment instruments or

– virtual currencies

to or from an address assigned to a mixer or tumbler?

117. Number of cases in which OI intermediated in the exchange between:

– virtual currencies and payment instruments or

– virtual currencies*

118. Number of cases in which OI intermediated in the exchange between:

– virtual currencies and payment instruments or

– virtual currencies

to or from an address assigned to a mixer or tumbler*

119. Number of cases in which OI intermediated in the exchange between:

virtual currencies and payment instruments or

virtual currencies

to or from non-hosted addresses*

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120. Value of payment instruments involved in the exchange between virtual currencies and payment instruments, in which OI intermediated, converted to EUR*
121. Value of payment instruments involved in the exchange between virtual currencies and payment instruments to or from non-hosted addresses, in which OI intermediated, converted to EUR*
122. Value of payment instruments involved in the exchange between virtual currencies and payment instruments to or from an address assigned to a mixer or tumbler, in which OI intermediated, converted to EUR*

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123. Value of virtual currency sold to the client involved in the exchange between virtual currencies, in which OI intermediated, converted to EUR*
124. Value of virtual currency sold to the client involved in the exchange between virtual currencies to or from non-hosted addresses, in which OI intermediated, converted to EUR*
125. Value of virtual currency sold to the client involved in the exchange between virtual currencies to or from an address assigned to a mixer or tumbler, in which OI intermediated, converted to EUR*
126. Does OI function as a peer-to-peer exchange?
127. Does OI, within the function of a peer-to-peer exchange, provide an escrow account service holding virtual currencies or payment instruments?
128. Within the function of a peer-to-peer exchange and providing an escrow account service holding virtual currencies, is a specific virtual currency always held by OI at the same address in the distributed ledger?
129. For how many virtual currencies (types) does OI provide an escrow account service holding virtual currencies within the function of a peer-to-peer exchange?
130. Distributed ledger addresses on which OI provided escrow account services within the function of a peer-to-peer exchange. 5 distributed ledger addresses in descending order, starting from the distributed ledger address for the virtual currency in which the total transaction value was highest when OI performed the function of a peer-to-peer exchange?
131. Within the function of a peer-to-peer exchange and providing an escrow account service holding payment instruments, does OI always store specific payment instruments under the same payment account number?

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132. Does at least one payment service provider with whom OI has a contract for maintaining an escrow account holding payment instruments have its registered office in the Republic of Poland?
133. Number of payment service providers with whom OI has a contract for maintaining an escrow account holding payment instruments, having their registered office in the Republic of Poland
134. TAX ID numbers of payment service providers with whom OI has a contract for maintaining an escrow account holding payment instruments, having their registered office in the Republic of Poland
135. Does at least one payment service provider with whom OI has a contract for maintaining an escrow account holding payment instruments have its registered office in the European Economic Area other than the Republic of Poland?
136. Number of payment service providers with whom OI has a contract for maintaining an escrow account holding payment instruments, having their registered office in the European Economic Area other than the Republic of Poland
137. Two-letter country codes of the European Economic Area countries (other than the Republic of Poland) where payment service providers with whom OI has a contract for maintaining an escrow account holding payment instruments have their registered office.
138. Does at least one payment service provider with whom OI has a contract for maintaining an escrow account holding payment instruments have its registered office outside the European Economic Area?
139. Number of payment service providers with whom OI has a contract for maintaining an escrow account holding payment instruments, having their registered office outside the European Economic Area
140. Two-letter country codes according to the ISO-2 standard of the countries outside the European Economic Area where payment service providers with whom OI has a contract for maintaining an escrow account holding payment instruments have their registered office.
141. Number of transactions between OI clients in which OI intermediated in the role of a peer-to-peer exchange where the subject of the transaction was the exchange of virtual currencies for payment instruments?*
142. Value of transactions between OI clients in which OI intermediated in the role of a peer-to-peer exchange where the subject of the transaction was the exchange of virtual currencies for payment instruments converted to EUR*
143. Number of transactions between OI clients in which OI intermediated in the role of a peer-to-peer exchange where the subject of the transaction was the exchange between virtual currencies?*
144. Value of transactions between OI clients in which OI intermediated in the role of a peer-to-peer exchange where the subject of the transaction was the exchange between virtual currencies converted to EUR*
145. Did OI intermediate in the sale of NFTs?
146. In how many NFT sale transactions did OI intermediate?
147. Value of NFT sale transactions conducted by OI clients in which OI intermediated, converted to EUR*
148. Transaction hash for the transfer of crypto assets within NFT sale transactions in which OI intermediated. Hashes for the five NFT sale transactions in which OI intermediated, in descending order, starting from the hash of the transaction with the highest value when converted to EUR

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149. Does OI offer services to clients using ATMs?
150. Number of ATMs through which OI offers services to its clients?*
151. Number of ATMs through which OI offers services to its clients that are not owned by OI?*
152. Number of ATMs through which OI offers services to its clients located in the territory of the Republic of Poland?*
153. Number of ATMs through which OI offers services to its clients located in the territory of the European Economic Area countries other than the Republic of Poland?*
154. Number of ATMs through which OI offers services to its clients located outside the territory of the European Economic Area countries?*

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155. Number of customers using ATMs located in the territory of the Republic of Poland making cash deposits?*
156. Number of cash deposit transactions on ATMs located in the territory of the Republic of Poland?*
157. Value of cash deposit transactions on ATMs located in the territory of the Republic of Poland converted to EUR*

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158. Number of customers using ATMs located in the territory of the Republic of Poland making cash withdrawals?*
159. Number of cash withdrawal transactions on ATMs located in the territory of the Republic of Poland?*
160. Value of cash withdrawal transactions on ATMs located in the territory of the Republic of Poland converted to EUR*

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161. Number of customers using ATMs located in the territory of the European Economic Area countries other than the Republic of Poland making cash deposits?*
162. Number of cash deposit transactions on ATMs located in the territory of the European Economic Area countries other than the Republic of Poland?*
163. Value of cash deposit transactions on ATMs located in the territory of the European Economic Area countries other than the Republic of Poland converted to EUR*
164. Value of cash deposit transactions on ATMs located in the territory of the European Economic Area countries other than the Republic of Poland converted to EUR – using the ISO-2 standard, indicate 5 countries in descending order with the highest value of cash deposits made in the territory of each country, and the value for each country*

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165. Number of customers using ATMs located in the territory of the European Economic Area countries other than the Republic of Poland making cash withdrawals?*
166. Number of cash withdrawal transactions on ATMs located in the territory of the European Economic Area countries other than the Republic of Poland?*
167. Value of cash withdrawal transactions on ATMs located in the territory of the European Economic Area countries other than the Republic of Poland converted to EUR*
168. Value of cash withdrawal transactions on ATMs located in the territory of the European Economic Area countries other than the Republic of Poland converted to EUR – using the ISO-2 standard, indicate 5 countries in descending order with the highest value of cash withdrawals made in the territory of each country, and the value for each country*

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169. Number of customers using ATMs located outside the territory of the European Economic Area making cash deposits.
170. Number of cash deposit transactions on ATMs located outside the territory of the European Economic Area?*
171. Value of cash deposit transactions on ATMs located outside the territory of the European Economic Area converted to EUR*
172. Value of cash deposit transactions on ATMs located outside the territory of the European Economic Area converted to EUR – using the ISO-2 standard, indicate 5 countries in descending order with the highest value of cash deposits made in the territory of each country, and the value for each country*

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173. Number of customers using ATMs located outside the territory of the European Economic Area making cash withdrawals?*
174. Number of cash withdrawal transactions on ATMs or located outside the territory of the European Economic Area?*
175. Value of cash withdrawal transactions on ATMs or located outside the territory of the European Economic Area converted to EUR*
176. Value of cash withdrawal transactions on ATMs or located outside the territory of the European Economic Area converted to EUR – using the ISO-2 standard, indicate 5 countries in descending order with the highest value of cash withdrawals made in the territory of each country, and the value for each country*

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177. Are there cash deposit limits on ATMs?*
178. Amount of cash deposit limit on ATMs converted to EUR*
179. Are there cash withdrawal limits on ATMs*
180. Amount of cash withdrawal limit on ATMs converted to EUR*
181. Does the provision of services using ATMs require the identification of the customer making each transaction?
182. Does OI allow customers to use debit or prepaid cards linked to the account mentioned in art. 2 sec. 2 point 17 letter e of the law – a set of identification data providing authorized persons with the ability to use virtual currency units, including conducting transactions of their exchange?*
183. Number of customers using debit or prepaid cards linked to the account mentioned in art. 2 sec. 2 point 17 letter e of the law – a set of identification data providing authorized persons with the ability to use virtual currency units, including conducting transactions of their exchange?*
184. Value of transactions using debit or prepaid cards linked to the account mentioned in art. 2 sec. 2 point 17 letter e of the law – a set of identification data providing authorized persons with the ability to use virtual currency units, including conducting transactions of their exchange – converted to EUR*

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185. Does OI provide its customers with payment gateways based on DLT in which virtual currency is used?*
186. Number of customers provided with payment gateways based on DLT, in which virtual currency is used?*
187. Number of customers for whom the circumstances indicated in art. 43–46 of the law apply and who have been provided with payment gateways based on DLT, in which virtual currency is used?*
188. Value of transactions using payment gateways based on DLT in which virtual currency is used converted to EUR*
189. Value of transactions using payment gateways based on DLT in which virtual currency is used, provided to customers for whom the circumstances indicated in art. 43–46 of the law apply, converted to EUR*

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190. Does OI allow its customers to use privacy-supporting virtual currencies?*
191. Number of customers who have used privacy-supporting virtual currencies?*
192. Number of crypto asset transfers of privacy-supporting virtual currencies, affecting the account mentioned in art. 2 sec. 2 point 17 letter e of the law – a set of identification data providing authorized persons with the ability to use virtual currency units, including conducting transactions of their exchange, conducted by OI for its customers?*
193. Value of crypto asset transfers of privacy-supporting virtual currencies, affecting the account mentioned in art. 2 sec. 2 point 17 letter e of the law – a set of identification data providing authorized persons with the ability to use virtual currency units, including conducting transactions of their exchange, conducted by OI for its customers, converted to EUR*
194. Number of crypto asset transfers of privacy-supporting virtual currencies, flowing out of the account mentioned in art. 2 sec. 2 point 17 letter e of the law – a set of identification data providing authorized persons with the ability to use virtual currency units, including conducting transactions of their exchange, conducted by OI for its customers?*

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195. Number of types of virtual currencies supported by OI? i.e., the number of virtual currencies for which OI offers exchange for means of payment or for other virtual currencies or which it collects for customers in the account mentioned in art. 2 sec. 2 point 17 letter e of the law or for which it intermediates in the above-mentioned activities

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196. Does OI have stationary points serving customers?*
197. Number of stationary points serving customers in the territory of the Republic of Poland?*
198. Number of stationary points serving customers in the territory of the European Economic Area countries other than the Republic of Poland?*
199. Number of stationary points serving customers outside the territory of the European Economic Area countries?*
200. Does OI provide virtual assets services with a visit to the customer?*
201. Does OI have a website used to provide virtual assets services?*
202. URL of the website used to provide virtual assets services.*
203. Does OI have a mobile application used to provide virtual assets services?*
204. URL to download the mobile application for providing virtual assets services *

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205. Does OI have tools to determine that customers using the website or mobile application use solutions such as VPN or IP anonymizers?
206. Does OI block customers from using solutions such as VPN or IP anonymizers?
207. How many OI customers have used solutions such as VPN or IP anonymizers?

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208. Does OI have tools to determine that customers using the website or mobile application use solutions such as ring signatures?
209. Does OI block customers from using ring signatures?
210. How many OI customers have used solutions such as ring signatures?
211. Does OI use services mentioned in art. 2 sec. 1 point 16) letter c) of the law – providing a registered office, business address, or correspondence address, and other related services to a legal entity or organizational unit without legal personality?
212. Number of entities with which OI is using services mentioned in art. 2 sec. 1 point 16) letter c) of the law – providing a registered office, business address, or correspondence address, and other related services to a legal entity or organizational unit without legal personality?
213. NIP (Tax Identification Number) of entities with which OI is using services mentioned in art. 2 sec. 1 point 16) letter c) of the law – providing a registered office, business address, or correspondence address, and other related services to a legal entity or organizational unit without legal personality?

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214. Does OI provide services from art. 2 sec. 1 point 12 letter a) or b) – exchange or intermediation between virtual currencies and payment instruments – using intermediaries?
215. Does OI provide services from art. 2 sec. 1 point 12 letter a) or b) – exchange or intermediation between virtual currencies and payment instruments – using intermediaries based in Poland?
216. Number of intermediaries based in Poland used by OI to provide services from art. 2 sec. 1 point 12 letter a) or b) – exchange or intermediation between virtual currencies and payment instruments.
217. NIP of intermediaries based in Poland used by OI to provide services from art. 2 sec. 1 point 12 letter a) or b) – exchange or intermediation between virtual currencies and payment instruments.
218. Has OI implemented procedures to determine whether intermediaries based in Poland, through whom services from art. 2 sec. 1 point 12 letter a) or b) – exchange or intermediation between virtual currencies and payment instruments are provided, are authorized to provide intermediary services?

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219. Does OI provide services from art. 2 sec. 1 point 12 letter a) or b) – exchange or intermediation between virtual currencies and payment instruments – using intermediaries based in a country other than Poland within the EEA?
220. Number of intermediaries based in a country other than Poland within the EEA used by OI to provide services from art. 2 sec. 1 point 12 letter a) or b) – exchange or intermediation between virtual currencies and payment instruments.
221. Country codes – according to the ISO-2 standard – of the location of intermediaries based in a country other than Poland within the EEA used by OI to provide services from art. 2 sec. 1 point 12 letter a) or b) – exchange or intermediation between virtual currencies and payment instruments.
222. Has OI implemented procedures to determine whether intermediaries based in a country other than Poland within the EEA used to provide services from art. 2 sec. 1 point 12 letter a) or b) – exchange or intermediation between virtual currencies and payment instruments are authorized to provide intermediary services?

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223. Does OI provide intermediary services in providing services from art. 2 sec. 1 point 12 letter a) or b) – exchange or intermediation between virtual currencies and payment instruments – for entities based in Poland?
224. Number of entities based in Poland for which OI provides intermediary services in providing services from art. 2 sec. 1 point 12 letter a) or b) – exchange or intermediation between virtual currencies and payment instruments.
225. NIP of entities based in Poland for which OI provides intermediary services in providing services from art. 2 sec. 1 point 12 letter a) or b) – exchange or intermediation between virtual currencies and payment instruments.

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230. Does OI provide intermediary services in providing services from art. 2 sec. 1 point 12 letter a) or b) – exchange or intermediation between virtual currencies and payment instruments – for entities based in a country within the EEA other than Poland?
231. Number of entities based in a country within the EEA other than Poland for which OI provides intermediary services in providing services from art. 2 sec. 1 point 12 letter a) or b) – exchange or intermediation between virtual currencies and payment instruments.
232. Using the ISO-2 standard, enter the country codes of entities based in a country within the EEA other than Poland for which OI provides intermediary services in providing services from art. 2 sec. 1 point 12 letter a) or b) – exchange or intermediation between virtual currencies and payment instruments.

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233. Does the OI provide intermediary services in the provision of services from Article 2 (1) point 12 letter a) or b) of the Act – exchange or intermediary services between virtual currencies and means of payment – for entities domiciled outside the EEA?
234. The number of entities domiciled outside the EEA for which OI provides intermediary services in the provision of services from Article 2 (1) point 12 letter a) or b) of the Act – exchange or intermediary services between virtual currencies and means of payment.
235. Using the ISO-2 standard, enter the country codes of the entities domiciled outside the EEA for which OI provides intermediary services in the provision of services from Article 2 (1) point 12 letter a) or b) of the Act – exchange or intermediary services between virtual currencies and means of payment.

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236. Information accompanying crypto asset transfers – Does OI have mechanisms in place to provide accompanying information for crypto asset transfers to the service provider in the field of crypto assets supporting the recipient of crypto asset transfers?
237. For how many crypto asset transfers has OI provided accompanying information for these crypto asset transfers?
238. What was the value of crypto asset transfers for which OI provided accompanying information for crypto asset transfers converted to EUR?

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239. Information accompanying crypto asset transfers – Does OI have mechanisms in place to receive accompanying information for crypto asset transfers from the service provider in the field of crypto assets supporting the initiator of crypto asset transfers?
240. For how many crypto asset transfers has OI received accompanying information for these crypto asset transfers?
241. What was the value of crypto asset transfers for which OI received accompanying information for crypto asset transfers converted to EUR?
242. In how many different countries did initiators of crypto asset transfers reside in cases where OI received accompanying information for these crypto asset transfers?
243. Using the ISO-2 standard, indicate 5 country codes of residence of initiators of crypto asset transfers from which OI received the highest value of transfers converted to EUR, and the corresponding value of crypto asset transfers converted to EUR. Provide this data based on the accompanying information received by OI for crypto asset transfers.

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244. Did OI enter into an agreement for the use of services of a third party when applying financial security measures, as referred to in Article 47 (1) of the Act – the possibility of using the services of a third party when applying financial security measures, provided that necessary information and documents regarding the applied financial security measures enabling the identification of the client and the beneficial owner, as well as the verification of their identity using electronic identification means, are promptly provided?
245. The number of agreements for the use of services of a third party when applying financial security measures, as referred to in Article 47 (1) of the Act – the possibility of using the services of a third party when applying financial security measures, provided that necessary information and documents regarding the applied financial security measures enabling the identification of the client and the beneficial owner, as well as the verification of their identity using electronic identification means – concluded with other obliged institutions.
246. Tax Identification Number (NIP) of obliged institutions with which OI has concluded an agreement for the use of services of a third party when applying financial security measures, as referred to in Article 47 (1) of the Act – the possibility of using the services of a third party when applying financial security measures, provided that necessary information and documents regarding the applied financial security measures enabling the identification of the client and the beneficial owner, as well as the verification of their identity using electronic identification means.
247. The number of agreements for the use of services of a third party when applying financial security measures, as referred to in Article 47 (1) of the Act – the possibility of using the services of a third party when applying financial security measures, provided that necessary information and documents regarding the applied financial security measures enabling the identification of the client and the beneficial owner, as well as the verification of their identity using electronic identification means – concluded with other entities having their registered office in the EEA other than the Republic of Poland (RP).
248. Using the ISO-2 standard, enter the country codes of the entities having their registered office in the EEA other than the Republic of Poland (RP) with which OI has concluded an agreement for the use of services of a third party when applying financial security measures, as referred to in Article 47 (1) of the Act – the possibility of using the services of a third party when applying financial security measures, provided that necessary information and documents regarding the applied financial security measures enabling the identification of the client and the beneficial owner, as well as the verification of their identity using electronic identification means.
249. The number of agreements for the use of services of a third party when applying financial security measures, as referred to in Article 47 (1) of the Act – the possibility of using the services of a third party when applying financial security measures, provided that necessary information and documents regarding the applied financial security measures enabling the identification of the client and the beneficial owner, as well as the verification of their identity using electronic identification means – concluded with entities having their registered office outside the EEA.
250. Using the ISO-2 standard, enter the country codes of the entities having their registered office outside the EEA with which OI has concluded an agreement for the use of services of a third party when applying financial security measures, as referred to in Article 47 (1) of the Act – the possibility of using the services of a third party when applying financial security measures, provided that necessary information and documents regarding the applied financial security measures enabling the identification of the client and the beneficial owner, as well as the verification of their identity using electronic identification means.
251. Did OI enter into an agreement for the delegation of the application of financial security measures and the conduct and documentation of the results of the ongoing analysis of transactions – an agreement referred to in Article 48 (1) of the Act – delegation of financial security measures and conducting and documenting the results of the analysis of transactions to a natural person, legal person, or organizational unit without legal personality acting on behalf and for the benefit of the obliged institution, if, based on a written agreement, the entity applying financial security measures is to be treated as part of the obliged institution?
252. The number of agreements for the delegation of the application of financial security measures and the conduct and documentation of the results of the ongoing analysis of transactions – an agreement referred to in Article 48 (1) of the Act – delegation of financial security measures and conducting and documenting the results of the analysis of transactions to a natural person, legal person, or organizational unit without legal personality acting on behalf and for the benefit of the obliged institution – concluded with entities having their registered office in the Republic of Poland (RP).
253. Tax Identification Number (NIP) of entities with registered office in the Republic of Poland (RP) with which OI has concluded an agreement for the delegation of the application of financial security measures and the conduct and documentation of the results of the ongoing analysis of transactions – an agreement referred to in Article 48 (1) of the Act – delegation of financial security measures and conducting and documenting the results of the analysis of transactions to a natural person, legal person, or organizational unit without legal personality acting on behalf and for the benefit of the obliged institution, if, based on a written agreement, the entity applying financial security measures is to be treated as part of the obliged institution.
254. The number of agreements for the delegation of the application of financial security measures and the conduct and documentation of the results of the ongoing analysis of transactions – an agreement referred to in Article 48 (1) of the Act – delegation of financial security measures and conducting and documenting the results of the analysis of transactions to a natural person, legal person, or organizational unit without legal personality acting on behalf and for the benefit of the obliged institution – concluded with other entities having their registered office in the EEA other than the Republic of Poland (RP).

255. Using the ISO-2 standard, enter the country codes of the entities having their registered office in the EEA other than the Republic of Poland (RP) with which OI has concluded an agreement for the delegation of the application of financial security measures and the conduct and documentation of the results of the ongoing analysis of transactions – an agreement referred to in Article 48 (1) of the Act – delegation of financial security measures and conducting and documenting the results of the analysis of transactions to a natural person, legal person, or organizational unit without legal personality acting on behalf and for the benefit of the obliged institution, if, based on a written agreement, the entity applying financial security measures is to be treated as part of the obliged institution.
256. The number of agreements for the delegation of the application of financial security measures and the conduct and documentation of the results of the ongoing analysis of transactions – an agreement referred to in Article 48 (1) of the Act – delegation of financial security measures and conducting and documenting the results of the analysis of transactions to a natural person, legal person, or organizational unit without legal personality acting on behalf and for the benefit of the obliged institution – concluded with entities having their registered office outside the EEA.
257. Using the ISO-2 standard, enter the country codes of the entities having their registered office outside the EEA with which OI has concluded an agreement for the delegation of the application of financial security measures and the conduct and documentation of the results of the ongoing analysis of transactions – an agreement referred to in Article 48 (1) of the Act – delegation of financial security measures and conducting and documenting the results of the analysis of transactions to a natural person, legal person, or organizational unit without legal personality acting on behalf and for the benefit of the obliged institution.

***

258. Is OI a commercial company?
259. Is OI a member of a capital group within the meaning of the Accounting Act?

     Capital group – this term refers to a dominant entity along with its subsidiaries;

     Dominant entity – this term refers to a commercial company or state enterprise exercising control over a subsidiary, in particular:
     a) directly or indirectly holding the majority of the total number of votes in the governing body of the subsidiary, also based on agreements with other voting rights holders who exercise their voting rights in accordance with the will of the dominant entity, or
     b) being a shareholder of the subsidiary and authorized to direct the financial and operational policy of the subsidiary independently or through individuals or entities designated by itself based on an agreement with other voting rights holders, including the dominant entity, holding the majority of the total number of votes in the governing body, or
     c) being a shareholder of the subsidiary and authorized to appoint and dismiss the majority of members of the management, supervisory, or administrative bodies of the subsidiary, or
     d) being a shareholder of the subsidiary, of which more than half of the composition of the management, supervisory, or administrative bodies in the previous financial year, during the current financial year and until the financial statements for the current financial year are prepared, are individuals appointed to perform these functions as a result of the exercise by the dominant entity of the voting right in the bodies of the subsidiary, unless another entity or person has rights in relation to the subsidiary as mentioned in points a, c, or e, or e) being a shareholder of the subsidiary and authorized to direct the financial and operational policy of the subsidiary based on an agreement with the subsidiary or the statute or agreement of the subsidiary;

     Subsidiary – this term refers to an entity that is a commercial company or an entity created and operating in accordance with the laws of foreign commercial law, controlled by the dominant entity.

260. How many entities are part of the capital group within the meaning of the Accounting Act to which OI belongs?
261. How many entities from the capital group within the meaning of the Accounting Act to which OI belongs have their registered office outside of Poland?

***

262. Is any individual or anyone else:

– other than OI, a member of a capital group within the meaning of the Accounting Act, to which OI belongs,

– the beneficial owner of OI, or

– a person designated under Article 6, 7, 8 of the AML Act – appointment of top-level management responsible for performing duties specified in the law, management, or other governing body, or an employee holding a managerial position responsible for ensuring compliance with the institution’s activities and its employees or individuals performing activities for this institution obligated by anti-money laundering and counter-terrorism financing regulations, and the implementation of obligations specified in the law,

registered in the register of activities in the field of virtual currencies referred to in Article 129m of the Act – provision of services in the field of virtual currencies, is a regulated activity and can be carried out after obtaining entry in the register of activities in the field of virtual currencies?

263. How many:

– members of the capital group within the meaning of the Accounting Act, to which OI belongs (other than OI),

– beneficial owners of OI, or

– persons designated under Article 6, 7, 8 of the AML Act – appointment of top-level management responsible for performing duties specified in the law, management, or other governing body, or an employee holding a managerial position responsible for ensuring compliance with the institution’s activities and its employees or individuals performing activities for this institution obligated by anti-money laundering and counter-terrorism financing regulations, and the implementation of obligations specified in the law,

are registered in the register of activities in the field of virtual currencies referred to in Article 129m of the Act – provision of services in the field of virtual currencies, is a regulated activity and can be carried out after obtaining entry in the register of activities in the field of virtual currencies?

264. Tax Identification Number (NIP):

– members of the capital group within the meaning of the Accounting Act, to which OI belongs (other than OI),

– beneficial owners of OI, or

– persons designated under Article 6, 7, 8 of the AML Act – appointment of top-level management responsible for performing duties specified in the law, management, or other governing body, or an employee holding a managerial position responsible for ensuring compliance with the institution’s activities and its employees or individuals performing activities for this institution obligated by anti-money laundering and counter-terrorism financing regulations, and the implementation of obligations specified in the law, in OI,

registered in the register of activities in the field of virtual currencies referred to in Article 129m of the Act – provision of services in the field of virtual currencies, is a regulated activity and can be carried out after obtaining entry in the register of activities in the field of virtual currencies.

265. Is any individual or anyone else:

– other than OI, a member of a capital group within the meaning of the Accounting Act,

– the beneficial owner of OI, or

– a person designated under Article 6, 7, 8 of the AML Act – appointment of top-level management responsible for performing duties specified in the law, management, or other governing body, or an employee holding a managerial position responsible for ensuring compliance with the institution’s activities and its employees or individuals performing activities for this institution obligated by anti-money laundering and counter-terrorism financing regulations, and the implementation of obligations specified in the law,

an obliged institution within the meaning of Article 2(1) points 1)-11) and 13)-26) of the Act?

271. Is any individual or anyone else:

– other than OI, a member of a capital group within the meaning of the Accounting Act,

– the beneficial owner of OI, or

– a person designated under Article 6, 7, 8 of the AML Act – appointment of top-level management responsible for performing duties specified in the law, management, or other governing body, or an employee holding a managerial position responsible for ensuring compliance with the institution’s activities and its employees or individuals performing activities for this institution obligated by anti-money laundering and counter-terrorism financing regulations, and the implementation of obligations specified in the law,

a subject obligated within the meaning of Article 2(1) point 1) or 2) of AMLD4 with its registered office in the EEA country other than RP?

272. How many:

– members of the capital group within the meaning of the Accounting Act, to which OI belongs (other than OI),

– beneficial owners of OI, or

– persons designated under Article 6, 7, 8 of the AML Act – appointment of top-level management responsible for performing duties specified in the law, management, or other governing body, or an employee holding a managerial position responsible for ensuring compliance with the institution’s activities and its employees or individuals performing activities for this institution obligated by anti-money laundering and counter-terrorism financing regulations, and the implementation of obligations specified in the law,

are subjects obligated within the meaning of Article 2(1) point 1) or 2) of AMLD4 with their registered office in the EEA country other than RP?

273. Using the ISO-2 standard, enter the country codes of residence or domicile:

– members of the capital group within the meaning of the Accounting Act, to which OI belongs (other than OI),

– beneficial owners of OI, or

– persons designated under Article 6, 7, 8 of the AML Act – appointment of top-level management responsible for performing duties specified in the law, management, or other governing body, or an employee holding a managerial position responsible for ensuring compliance with the institution’s activities and its employees or individuals performing activities for this institution obligated by anti-money laundering and counter-terrorism financing regulations, and the implementation of obligations specified in the law,

being subjects obligated within the meaning of Article 2(1) point 1) or 2) of AMLD4 with their registered office in the EEA country other than RP?

274. Is any individual or anyone else:

– other than OI, a member of a capital group within the meaning of the Accounting Act,

– the beneficial owner of OI, or

– a person designated under Article 6, 7, 8 of the AML Act – appointment of top-level management responsible for performing duties specified in the law, management, or other governing body, or an employee holding a managerial position responsible for ensuring compliance with the institution’s activities and its employees or individuals performing activities for this institution obligated by anti-money laundering and counter-terrorism financing regulations, and the implementation of obligations specified in the law,

a obligated subject within the meaning of Article 2(1) point 3) lit a) – f), i), and j) of AMLD4 with its registered office in the EEA country other than RP?

275. How many:

– members of the capital group within the meaning of the Accounting Act, to which OI belongs (other than OI),

– beneficial owners of OI, or

– persons designated under Article 6, 7, 8 of the AML Act – appointment of top-level management responsible for performing duties specified in the law, management, or other governing body, or an employee holding a managerial position responsible for ensuring compliance with the institution’s activities and its employees or individuals performing activities for this institution obligated by anti-money laundering and counter-terrorism financing regulations, and the implementation of obligations specified in the law,

an obligated subject within the meaning of Article 2(1) point 3) lit a) – f), i), and j) of AMLD4 with their registered office in the EEA country other than RP?

276. Using the ISO-2 standard, enter the country codes of residence or domicile:

– members of the capital group within the meaning of the Accounting Act, to which OI belongs (other than OI),

– beneficial owners of OI, or

– persons designated under Article 6, 7, 8 of the AML Act – appointment of top-level management responsible for performing duties specified in the law, management, or other governing body, or an employee holding a managerial position responsible for ensuring compliance with the institution’s activities and its employees or individuals performing activities for this institution obligated by anti-money laundering and counter-terrorism financing regulations, and the implementation of obligations specified in the law,

an obligated subject within the meaning of Article 2(1) point 3) lit a) – f), i), and j) of AMLD4 with their registered office in the EEA country other than RP?

277. Is any individual or anyone else:

– other than OI, a member of a capital group within the meaning of the Accounting Act,

– the beneficial owner of OI, or

– a person designated under Article 6, 7, 8 of the AML Act – appointment of top-level management responsible for performing duties specified in the law, management, or other governing body, or an employee holding a managerial position responsible for ensuring compliance with the institution’s activities and its employees or individuals performing activities for this institution obligated by anti-money laundering and counter-terrorism financing regulations, and the implementation of obligations specified in the law,

authorized to conduct activities in the field of virtual currencies in a country outside the EEA?

278. How many:

– members of the capital group within the meaning of the Accounting Act, to which OI belongs (other than OI),

– beneficial owners of OI, or

– persons designated under Article 6, 7, 8 of the AML Act – appointment of top-level management responsible for performing duties specified in the law, management, or other governing body, or an employee holding a managerial position responsible for ensuring compliance with the institution’s activities and its employees or individuals performing activities for this institution obligated by anti-money laundering and counter-terrorism financing regulations, and the implementation of obligations specified in the law,

are authorized to conduct activities in the field of virtual currencies in a country outside the EEA?

279. Using the ISO-2 standard, enter the country codes (outside the EEA) of residence or domicile:

– members of the capital group within the meaning of the Accounting Act, to which OI belongs (other than OI),

– beneficial owners of OI, or

– persons designated under Article 6, 7, 8 of the AML Act – appointment of top-level management responsible for performing duties specified in the law, management, or other governing body, or an employee holding a managerial position responsible for ensuring compliance with the institution’s activities and its employees or individuals performing activities for this institution obligated by anti-money laundering and counter-terrorism financing regulations, and the implementation of obligations specified in the law,

in which they are authorized to conduct activities in the field of virtual currencies.

266. How many:

– members of the capital group within the meaning of the Accounting Act, to which OI belongs (other than OI),

– beneficial owners of OI, or

– persons designated under Article 6, 7, 8 of the AML Act – appointment of top-level management responsible for performing duties specified in the law, management, or other governing body, or an employee holding a managerial position responsible for ensuring compliance with the institution’s activities and its employees or individuals performing activities for this institution obligated by anti-money laundering and counter-terrorism financing regulations, and the implementation of obligations specified in the law,

are obliged institutions within the meaning of Article 2(1) points 1)-11) and 13)-26) of the Act?

267. Tax Identification Number (NIP):

– members of the capital group within the meaning of the Accounting Act, to which OI belongs (other than OI),

– beneficial owners of OI, or

– persons designated under Article 6, 7, 8 of the AML Act – appointment of top-level management responsible for performing duties specified in the law, management, or other governing body, or an employee holding a managerial position responsible for ensuring compliance with the institution’s activities and its employees or individuals performing activities for this institution obligated by anti-money laundering and counter-terrorism financing regulations, and the implementation of obligations specified in the law,

being obliged institutions within the meaning of Article 2(1) points 1)-11) and 13)-26) of the Act?

268. Is any individual or anyone else:

– other than OI, a member of a capital group within the meaning of the Accounting Act, to which OI belongs,

– the beneficial owner of OI, or

– a person designated under Article 6, 7, 8 of the AML Act – appointment of top-level management responsible for performing duties specified in the law, management, or other governing body, or an employee holding a managerial position responsible for ensuring compliance with the institution’s activities and its employees or individuals performing activities for this institution obligated by anti-money laundering and counter-terrorism financing regulations, and the implementation of obligations specified in the law,

authorized to conduct activities in the field of virtual currencies in the EEA country other than RP?

269. How many:

– members of the capital group within the meaning of the Accounting Act, to which OI belongs (other than OI),

– beneficial owners of OI, or

– persons designated under Article 6, 7, 8 of the AML Act – appointment of top-level management responsible for performing duties specified in the law, management, or other governing body, or an employee holding a managerial position responsible for ensuring compliance with the institution’s activities and its employees or individuals performing activities for this institution obligated by anti-money laundering and counter-terrorism financing regulations, and the implementation of obligations specified in the law,

are authorized to conduct activities in the field of virtual currencies in the EEA country other than RP?

270. Using the ISO-2 standard, enter the country codes of residence or domicile:

– members of the capital group within the meaning of the Accounting Act, to which OI belongs (other than OI),

– beneficial owners of OI, or

– persons designated under Article 6, 7, 8 of the AML Act – appointment of top-level management responsible for performing duties specified in the law, management, or other governing body, or an employee holding a managerial position responsible for ensuring compliance with the institution’s activities and its employees or individuals performing activities for this institution obligated by anti-money laundering and counter-terrorism financing regulations, and the implementation of obligations specified in the law,

in which they are authorized to conduct activities in the field of virtual currencies in the EEA country other than RP.

The subsequent sections (265-270) appear to be a continuation of similar inquiries, with additional questions regarding authorization to conduct virtual currency activities in the European Economic Area (EEA) and the registration of relevant individuals and entities in the specified register. If you have further questions or need more translations, feel free to ask.

280. Is any or any person:

– other than OI, a member of a capital group within the meaning of the accounting act, to which OI belongs,

– a real beneficiary of OI, or

– a person designated under art. 6, 7, 8 of the Polish AML Act – appointing top-level management responsible for performing duties specified in the law, management, or other managing body, or an employee holding a managerial position responsible for ensuring compliance of the institution’s activities and its employees or persons performing activities for this institution, with the provisions on anti-money laundering and combating the financing of terrorism, and implementing obligations specified in the law,

is a financial institution within the meaning of the glossary of the FATF Recommendation from 2012 in a country outside the EEA?

281. How many:

– members of the capital group within the meaning of the accounting act, to which OI belongs (other than OI),

– real beneficiaries of OI, or

– persons designated under art. 6, 7, 8 of the Polish AML Act – appointing top-level management responsible for performing duties specified in the law, management, or other managing body, or an employee holding a managerial position responsible for ensuring compliance of the institution’s activities and its employees or persons performing activities for this institution, with the provisions on anti-money laundering and combating the financing of terrorism, and implementing obligations specified in the law,

are financial institutions within the meaning of the glossary of the FATF Recommendation from 2012 in a country outside the EEA?

282. Using the ISO-2 standard, enter country codes (outside the EEA) of the:

– members of the capital group within the meaning of the accounting act, to which OI belongs (other than OI),

– real beneficiaries of OI, or

– persons designated under art. 6, 7, 8 of the Polish AML Act – appointing top-level management responsible for performing duties specified in the law, management, or other managing body, or an employee holding a managerial position responsible for ensuring compliance of the institution’s activities and its employees or persons performing activities for this institution, with the provisions on anti-money laundering and combating the financing of terrorism, and implementing obligations specified in the law,

in which they are financial institutions within the meaning of the glossary of the FATF Recommendation from 2012.

283. Is any or any person:

– other than OI, a member of a capital group within the meaning of the accounting act, to which OI belongs,

– a real beneficiary of OI, or

– a person designated under art. 6, 7, 8 of the Polish AML Act – appointing top-level management responsible for performing duties specified in the law, management, or other managing body, or an employee holding a managerial position responsible for ensuring compliance of the institution’s activities and its employees or persons performing activities for this institution, with the provisions on anti-money laundering and combating the financing of terrorism, and implementing obligations specified in the law,

is a designated entity or profession providing non-financial services within the meaning of the glossary of the FATF Recommendation from 2012 in a country outside the EEA?

284. How many:

– members of the capital group within the meaning of the accounting act, to which OI belongs (other than OI),

– real beneficiaries of OI, or

– persons designated under art. 6, 7, 8 of the Polish AML Act – appointing top-level management responsible for performing duties specified in the law, management, or other managing body, or an employee holding a managerial position responsible for ensuring compliance of the institution’s activities and its employees or persons performing activities for this institution, with the provisions on anti-money laundering and combating the financing of terrorism, and implementing obligations specified in the law,

are designated entities or professions providing non-financial services within the meaning of the glossary of the FATF Recommendation from 2012 in a country outside the EEA?

285. Using the ISO-2 standard, enter country codes (outside the EEA) of the:

– members of the capital group within the meaning of the accounting act, to which OI belongs (other than OI),

– real beneficiaries of OI, or

– persons designated under art. 6, 7, 8 of the Polish AML Act – appointing top-level management responsible for performing duties specified in the law, management, or other managing body, or an employee holding a managerial position responsible for ensuring compliance of the institution’s activities and its employees or persons performing activities for this institution, with the provisions on anti-money laundering and combating the financing of terrorism, and implementing obligations specified in the law,

in which they are designated entities or professions providing non-financial services within the meaning of the glossary of the FATF Recommendation from 2012.

***

286. Has authorization to provide virtual currency services been revoked for any:

– member of the capital group within the meaning of the accounting act, to which OI belongs,

– real beneficiary of OI, or

– persons designated under art. 6, 7, 8 of the Polish AML Act – appointing top-level management responsible for performing duties specified in the law, management, or other managing body, or an employee holding a managerial position responsible for ensuring compliance of the institution’s activities and its employees or persons performing activities for this institution, with the provisions on anti-money laundering and combating the financing of terrorism, and implementing obligations specified in the law?

287. How many:

– members of the capital group within the meaning of the accounting act, to which OI belongs,

– real beneficiaries of OI, or

– persons designated under art. 6, 7, 8 of the Polish AML Act – appointing top-level management responsible for performing duties specified in the law, management, or other managing body, or an employee holding a managerial position responsible for ensuring compliance of the institution’s activities and its employees or persons performing activities for this institution, with the provisions on anti-money laundering and combating the financing of terrorism, and implementing obligations specified in the law,

have had their authorization to provide virtual currency services revoked?

288. Using the ISO-2 standard, enter country codes of the:

– members of the capital group within the meaning of the accounting act,

– real beneficiaries of OI, or

– persons designated under art. 6, 7, 8 of the Polish AML Act – appointing top-level management responsible for performing duties specified in the law, management, or other managing body, or an employee holding a managerial position responsible for ensuring compliance of the institution’s activities and its employees or persons performing activities for this institution, with the provisions on anti-money laundering and combating the financing of terrorism, and implementing obligations specified in the law,

for whom the authorization to provide virtual currency services has been revoked, along with the date of revocation.

***

289. Has any of the following:

– members of the capital group within the meaning of the accounting act, to which OI belongs,

– real beneficiaries of OI, or

– persons designated under art. 6, 7, 8 of the Polish AML Act – appointing top-level management responsible for performing duties specified in the law, management, or other managing body, or an employee holding a managerial position responsible for ensuring compliance of the institution’s activities and its employees or persons performing activities for this institution, with the provisions on anti-money laundering and combating the financing of terrorism, and implementing obligations specified in the law,

withdrawn their application for authorization to provide virtual currency services?

290. How many:

– members of the capital group within the meaning of the accounting act, to which OI belongs,

– real beneficiaries of OI, or

– persons designated under art. 6, 7, 8 of the Polish AML Act – appointing top-level management responsible for performing duties specified in the law, management, or other managing body, or an employee holding a managerial position responsible for ensuring compliance of the institution’s activities and its employees or persons performing activities for this institution, with the provisions on anti-money laundering and combating the financing of terrorism, and implementing obligations specified in the law,

have withdrawn their application for authorization to provide virtual currency services?

291. Using the ISO-2 standard, enter country codes of the:

– members of the capital group within the meaning of the accounting act, to which OI belongs,

– real beneficiaries of OI, or

– persons designated under art. 6, 7, 8 of the Polish AML Act,

who have withdrawn their application for authorization to provide virtual currency services, along with the date of withdrawal.

***

292. Data of appointment in OI of a person under art. 8 of the Act – an employee responsible for ensuring compliance of the obliged institution’s activities, its employees, and other persons performing activities for this institution with the provisions on anti-money laundering and combating the financing of terrorism, as well as reporting.

293. Does the person designated under art. 8 of the Act have a PESEL?

294. PESEL number of the person designated under art. 8 of the Act.

295. First name, last name, citizenship, date of birth, and countries of birth of the person designated under art. 8 of the Act – in case there is no PESEL number.

296. Date of preparing the risk assessment referred to in art. 27 para 1 of the AML Act – identification and assessment of the risk associated with money laundering and terrorism financing related to their activities, taking into account the risk factors of clients, countries or geographic areas, products, services, transactions, or channels of their delivery proportionally to the nature and size of the obliged institution.

297. Date of the last update of the risk assessment referred to in art. 27 para 1 of the AML Act.

298. Does OI check the presence of individuals on the lists indicated in art. 118 para 1 of the Act – lists of persons and entities related to threats to international peace and security caused by terrorist acts – before entering into economic relations or conducting transactions with them?

299. How often is the customers’ (with which OI has established economic relations) checked against the lists specified in art. 118 para 1 of the Act?

300. How does OI ensure compliance with art. 119 para 1 of the Act, i.e., freezing the financial values or not providing financial values to persons from art. 118 para 1 of the Act?

Article 118 [Scope of Application]

1. Obligated institutions apply specific restrictive measures against individuals and entities listed:
   1. in lists announced by the General Inspector based on resolutions of the United Nations Security Council issued under Chapter VII of the United Nations Charter, concerning threats to international peace and security caused by terrorist acts, particularly in the lists referred to in paragraph 3 of resolution 2253 (2015) of the United Nations Security Council or in paragraph 1 of resolution 1988 (2011) of the United Nations Security Council,
   2. in the list referred to in Article 120(1), published in the Public Information Bulletin on the minister’s website responsible for public finance matters.
2. The lists mentioned in paragraph 1, along with their updates, are published without delay.
3. The General Inspector may disseminate, using mass media, a communication, in a form and time specified by the General Inspector, about the application of specific restrictive measures against individuals or entities.

301. Does the automatic IT solution scanning the customer and potential customer databases, and individuals with whom a transaction is to be concluded, use fuzzy matching?

302. The number of cases in which financial funds, funds, or economic resources were frozen.*

303. How does OI exchange payment funds for virtual currency by its customers? Please indicate the number of customers, the number of transactions, and the total value of transactions in PLN for specific payment solutions used by OI to provide payment funds, which are exchanged for virtual currency.

Payment solution type:

– Blik, Cash, PayPal, Skrill, Zen, Debit card/Credit card, Bank transfer, Other

Number of customers who exchanged using the payment method for virtual currency.

Enter the number.

Number of transactions using the payment solution.

Enter the number.

Value of funds in PLN, the value of which was converted and valued in PLN – conversion from the transaction date; in case the payment funds were other than PLN, please use the NBP exchange rate on the transaction date.

Round the value to the nearest whole Polish zloty.

Enter the value.