As the deadline for Q3 2024 approaches, Virtual Asset Service Providers (VASPs) in Poland are once again preparing to submit their quarterly reports to the General Inspector of Financial Information (GIIF). The statistical report must be submitted by 18/10/2024, and it remains a critical compliance requirement for all companies engaged in services in the field of crypto assets in Poland.
The Regulatory Environment for VASPs
Since the introduction of quarterly reporting requirements in 2024, the regulatory landscape for VASPs in Poland has continued to evolve. A significant development is the forthcoming implementation of the Markets in Crypto-Assets (MiCA) regulation, which is expected to reshape the compliance landscape for crypto businesses across the European Union, including Poland.
Unfortunately, new Polish regulation on Crypto Assets Market is not final yet and it is still at consultations stage. Our Law Firm in Poland keeps our current and new Clients informed in that regard ongoing basis:
MiCA in Poland updates:
Key Areas to Cover in the Q3 Report
The quarterly report for Q3 2024 should address several essential areas:
- Scope of Activities: An overview of the virtual asset services provided, including any changes since the previous report.
- AML Officer Information: Verification that the information about the designated AML Officer is accurate.
- AML Procedures: A summary of anti-money laundering measures in place, with an emphasis on any recent updates or improvements.
- Suspicious Transactions: Reporting any cases of suspected money laundering or terrorism financing.
- Statistical Data: A detailed account of transaction volumes, types of clients, and any relevant trends.
Best Practices for Q3 Reporting
To ensure a smooth reporting process, VASPs should:
- Review Past Reports: Identify any areas where previous submissions could be improved.
- Update AML Policies: Make sure that AML-related policies are current, especially in light of any recent regulatory guidance.
- Internal Audits: Verify the accuracy of transaction data and customer information before submission.
- Seek Professional Advice: Consult with compliance experts if there are uncertainties or complex situations, to ensure full adherence to the requirements.
- Delegating the Submission of Quarterly Reports to Professionals: In most cases, using the services of a third party may be the best solution to fulfill reporting obligations.
Access to the GIIF System and Submission Requirements
The report must be submitted via the GIIF’s online portal at https://www.giif.mofnet.gov.pl/#/glowna. Access to the system requires a qualified electronic signature for submission. Note that the Polish Trusted Profile is not sufficient for this purpose.