Quarterly report of VASP in Poland, final form, Part III

Quarterly report of VASP in Poland, final form

Link to Part I questions indicated in quarterly report of VASPs in Poland

Link to Part II questions indicated in quarterly report of VASPs in Poland

Section 3 (Grupa 3)
Active clients
Total amount of active clients

  1. Total amount of VASP’s active clients.

Active client – a client to whom VASP applies simplified financial security measures, a client who has at least one product, or has active access to transaction services, or can complete a transaction without any additional activities

 

 

Section 3 (Grupa 3)
Active clients
Total amount of active clients with PEP status

  1. Number of active clients with a confirmed PEP status.
  2. Number of identified ultimate beneficiaries with PEP status, excluding individual clients not conducting business activity.

Section 3 (Grupa 3)
Active clients
Clients subject to Article 117

  1. 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

Section 3 (Grupa 3)
Active clients
Clients by address

  1. Number of clients with residential address or registered seat in Poland.
  2. Using the ISO-2 standard, indicate the codes of 10 countries (excluding Poland) where the largest number of active VASP clients have their residential or registered address and provide the number of active customers corresponding to a given country.

Section 3 (Grupa 3)
Active clients
Clients due to the risk

  1. Number of active clients who are individuals with low risk.
  2. Number of active clients who are individuals with low risk.
  3. Number of active clients who are individuals with low risk outside Poland (do not have Polish citizenship).
  4. Number of active clients who are not natural persons outside  individuals with low risk.
  1. Number of active clients who are individuals with medium risk.
  2. Number of active clients who are individuals with medium risk.
  3. Number of active clients who are individuals with medium risk outside Poland (do not have Polish citizenship).
  4. Number of active clients who are not natural persons outside  individuals with medium risk.

     

  5. Number of active clients who are individuals with high risk.
  6. Number of active clients who are individuals with high risk.
  7. Number of active clients who are individuals with high risk outside Poland (do not have Polish citizenship).
  8. Number of active clients who are not natural persons outside individuals with hih risk.

Section 3 (Grupa 3)
ATM devices
Total

  1. Does VASP offer services to clients using ATMs?
  2. Does VASP always requires identification of clients using it ATMs?

 

 

Section 3 (Grupa 3)
ATM devices
Number of devices

 

  1. Number of ATMs through which VASP offers services to its clients.
  2. Number of ATMs owned by VASP.
  3. Number of ATMs through which VASP offers services to its clients located in the territory of the Republic of Poland.
  4. Number of ATMs through which VASP offers services to its clients located in the territory of the European Economic Area countries other than the Republic of Poland.
  5. Number of ATMs through which VASP offers services to its clients located outside the territory of the European Economic Area countries.

Section 3 (Grupa 3)
ATM devices
Customer limits

  1. Are there cash deposit limits on ATMs?
  2. Amount of cash deposit limit on ATMs converted to EUR.
  3. Are there cash withdrawal limits on ATMs?
  4. Amount of cash withdrawal limit on ATMs converted to EUR.

 

Section 3 (Grupa 3)
ATM devices
Services in Poland 

  1. Number of customers using ATMs located in the territory of the Republic of Poland making cash deposits.
  2. Number of cash deposit transactions on ATMs located in the territory of the Republic of Poland.
  3. Value of cash deposit transactions on ATMs located in the territory of the Republic of Poland converted to EUR.
  4. Number of customers using ATMs located in the territory of the Republic of Poland making cash withdrawals.
  5. Number of cash withdrawal transactions on ATMs located in the territory of the Republic of Poland.
  6. Value of cash withdrawal transactions on ATMs located in the territory of the Republic of Poland converted to EUR.

Section 3 (Grupa 3)
ATM devices
Services in the EEA outside Poland 

  1. Number of customers using ATMs located in the territory of EEA outside Poland making cash deposits.
  2. Number of cash deposit transactions on ATMs located in the territory of EEA outside Poland.
  3. Value of cash deposit transactions on ATMs located in the territory of EEA outside Poland, converted to EUR.
  4. 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, converted to EUR.
  5. Number of customers using ATMs located in the territory of EEA outside Poland making cash withdrawals.
  6. Number of cash withdrawal transactions on ATMs located in the territory of EEA outside Poland.
  7. Value of cash withdrawal transactions on ATMs located in the territory of EEA outside Poland, converted to EUR.
  8. 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, converted to EUR.

Section 3 (Grupa 3)
ATM devices
Services outside the EEA 

  1. Number of customers using ATMs located outside the EEA making cash deposits.
  2. Number of cash deposit transactions on ATMs located outside the EEA.
  3. Value of cash deposit transactions on ATMs located outside the EEA land, converted to EUR.
  4. 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, converted to EUR.
  5. Number of customers using ATMs located outside the EEA making cash withdrawals.
  6. Number of cash withdrawal transactions on ATMs located outside the EEA.
  7. Value of cash withdrawal transactions on ATMs located outside the EEA, converted to EUR.
  8. 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, converted to EUR.

Section 3 (Grupa 3)
Payments (Płatności I zasilenia)
Basic information

  1. Number of types of virtual currencies supported by VASP? i.e., the number of virtual currencies for which VASP offers exchange between means of payment or between virtual currencies or which it collects for customers in the account mentioned in art. 2 sec. 2 point 17 letter e of the Polish AML Act or for which it intermediates in the above-mentioned activities.
  1. Does VASP allow its customers to use privacy-supporting virtual currencies? A privacy-friendly virtual currency is one that has functionalities that increase or enable anonymity and make it difficult or impossible to track transactions on the blockchain. Such virtual currencies include, for example, Monero, Zcash, Dash
  2. Number of privacy-friendly virtual currencies offered by VASP.
  3. Number of customers who used privacy-supporting virtual currencies.
  4. Number of transactions using privacy-friendly currencies.
  5. Value of transactions using privacy-friendly currencies, converted to EUR.
  6. Number of cryptoassets including privacy-supporting virtual currencies from accounts maintained by VASP.
  7. Value of transfers converted to EUR of cryptoassets including privacy-supporting virtual currencies from accounts maintained by VASP.
  8. Number of transfers of cryptoassets including privacy-supporting virtual currencies to accounts maintained by VASP.
  9. Value of of transfers of cryptoassets including privacy-supporting virtual currencies to accounts maintained by VASP, converted to EUR.

Section 3 (Grupa 3)
Payments (Płatności I zasilenia)
Echange between means of payment and virtual currencies

 

  1. Payment solution type:
    1. BLIK mobile payment system;
    2. Pay-by-link or Payment Initiation Service Offered by payment service providers in Poland;
    3. VISA SRC payment wallet;
    4. Masterpass payment wallet;
    5. Google Pay payment wallet;
    6. Apple Pay payment wallet;
    7. acceptance service for payment cards other than prepaid cards – issuer of the card with the seat in Poland;
    8. acceptance service for payment cards other than prepaid cards – issuer of the card with the seat outside Poland;
    9. acceptance service for prepaid cards;
    10. payment services offered by Paysafecard/Paysafecash;
    11. payment services offered by PayPal;
    12. payment services offered by Zen.com;
    13. payment services offered by Skrill;
    14. traditional bank transfer from bank with its seat in Poland;
    15. traditional bank transfer from bank with its seat outside Poland;
    16. other payment services offered by entity with its seat in Poland;
    17. other payment services offered by entity with its seat outside Poland;
    18. cash
  1. Number of customers who performed transaction of exchange between virtual currencies and means of payment using specified payment method.
  2. Number of transactions of exchange between virtual currencies and means of payment performed by using specified payment method.
  3. Value of transactions of exchange between virtual currencies and means of payment performed by using specified payment method by using specified payment method.

Section 3 (Grupa 3)
Payments (Płatności I zasilenia)
DLT-based payment gateways that use virtual currency

  1. Does VASP provide its customers with payment gateways based on DLT in which virtual currency is used?
  2. Number of customers provided with payment gateways based on DLT, in which virtual currency is used.
  3. Number of transactions provided with payment gateways based on DLT, in which virtual currency is used.
  4. Value of transactions using payment gateways based on DLT in which virtual currency is used converted to EUR.
  1. Number of customers for whom the circumstances indicated in art. 43–46 of the Polish AML Act (enhanced due diligence measures) apply and who have been provided with payment gateways based on DLT, in which virtual currency is used.
  2. Number of transactions provided to the customers for whom the circumstances indicated in art. 43–46 of the Polish AML Act (enhanced due diligence measures) apply and who have been provided with payment gateways based on DLT, in which virtual currency is used.
  3. 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

Section 3 (Grupa 3)
Payments (Płatności i zasilenia)
Cards linked to the account

  1. Does VASP allow customers to use debit or prepaid cards linked to the account mentioned in art. 2 sec. 2 point 17 letter e of the Polish AML Act (a set of identification data providing authorized persons with the ability to use virtual currency units, including conducting transactions of their exchange)?
  2. Number of customers using debit or prepaid cards linked to the account mentioned in art. 2 sec. 2 point 17 letter e of the Polish AML Act.
  3. Value of transactions using debit or prepaid cards linked to the account mentioned in art. 2 sec. 2 point 17 letter e the Polish AML Act, converted to EUR.

 

Section 3 (Grupa 3)
Agreements (Umowy)
Agreements according to Article 47 (1) of Polish AML Act

  1. Did VASP 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?

Article 47. 1. The obligated institutions may use services of other entity while applying the customer due diligence measures referred to in Article 34(1)(1)-(3), subject to such entity immediately providing, on request of the obligated institution, the required information and documents related to applied customer due diligence measures, including copies of documents acquired while applying the customer due diligence measures consisting in identification of a customer and a beneficial owner and verification of their identity, in particular with the use of electronic identification means and trust services enabling electronic identification within the meaning of Regulation 910/2014.

  1. Indicate Tax Identification number of entities with which VASP enter into such agreement.
  2. Indicate entities in EEA outside Poland.
  3. Indicate entities outside EEA.

Section 3 (Grupa 3)
Agreements (Umowy)
Agreements according to Article 48 (1) of Polish AML Act

  1. Did VASP enter into an agreement for the use of services of a third party when applying financial security measures, as referred to in Article 48 (1) of the Act? 

Article 48. 1. The obligated institutions may entrust the application of the customer due diligence measures as well as maintaining and documenting the results of the current analysis of conducted transactions referred to in Article 43(3) to a natural person, a legal person or an organisational unit without legal personality acting for and on behalf of the obligated institution if the entity to which the application of the customer due diligence measures has been entrusted under a written agreement should be regarded as a part of the obligated institution. 

  1. Indicate Tax Identification number of entities with which VASP enter into such agreement.
  2. Indicate entities in EEA outside Poland.
  3. Indicate entities outside EEA.
 

Section 3 (Grupa 3)
Customer service (Obsługa klienta)
Stationary points

  1. Does VASP have stationary points serving customers?
  2. Number of stationary points serving customers in the territory of the Republic of Poland.
  3. Number of stationary points serving customers in the territory of the European Economic Area countries other than the Republic of Poland.
  4. Number of stationary points serving customers outside the territory of the European Economic Area countries.

 

Section 3 (Grupa 3)
Customer service (Obsługa klienta)
Services with on-site visit to the clients

  1. Does VASP provide virtual assets services with a visit to the customer?

Section 3 (Grupa 3)
Customer service (Obsługa klienta)
Websites

  1. Does VASP have website?
  2. Indicate VASP’s website URL.

Section 3 (Grupa 3)
Customer service (Obsługa klienta)
Mobile applications

  1. Does VASP have mobile application?
  2. Indicate VASP’s mobile application’s URL.
 

Section 3 (Grupa 3)
Customer service (Obsługa klienta)
IP anonymizer

  1. Does VASP have tools to determine that customers using the website or mobile application use solutions such as IP anonymizers?
  2. Does VASP block customers from using solutions such as IP anonymizers?
  3. How many VASP’s customers have used solutions such as IP anonymizers?

Section 3 (Grupa 3)
Customer service (Obsługa klienta)
Ring signatures 

  1. Does VASP have tools to determine that customers using the website or mobile application use solutions such as ring signatures?
  2. Does VASP block customers from using solutions such as ring signatures?
  3. How many VASP’s customers have used solutions such as ring signatures?

Section 3 (Grupa 3)
Customer service (Obsługa klienta)
Registered seat lease services

  1. Does VASP 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?
  2. Indicate entities and its’ Tax Identification Number which provide VASP 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?
 

Section 3 (Grupa 3)
Services using intermediaries (Usługi z wykorzystaniem pośredników)

  1. Does VASP provide services using intermediaries?
  2. Does VASP provide services using intermediaries based in Poland?
  3. Has VASP implemented procedures to determine whether intermediaries based in Poland, through whom services are provided, are authorized to provide intermediary services?
  4. Does VASP provide services using intermediaries based in a country other than Poland within the EEA?
  5. Does VASP implemented procedures to determine whether intermediaries based in a country other than Poland within the EEA, through whom services are provided, are authorized to provide intermediary services?
  6. Does VASP provide services using intermediaries based in a country outside EEA?
  7. Does VASP implemented procedures to determine whether intermediaries based in a country outside EEA, through whom services are provided, are authorized to provide intermediary services?
 

Section 3 (Grupa 3)
Services using intermediaries (Usługi z wykorzystaniem pośredników) 

  1. Indicate Tax Identification Number of intermediaries based in Poland used by VASP to provide services.
  2. Indicate 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 VASP to provide services.
  3. Indicate country codes – according to the ISO-2 standard – of the location of intermediaries based outside EEA used by VASP to provide services.

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