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Anti-Money Laundering (AML) compliance in Poland is not just a box-ticking exercise – it is a legal obligation under Polish law and a critical element of responsible business conduct. According to the Polish AML Act of 1 March 2018 (as amended), which implements the EU’s 4th and 5th AML Directives (and aligns with the 6th), a wide range of entities are classified as “obligated institutions” and must implement robust AML compliance in Poland procedures.
This includes not only banks and financial institutions, but also high-risk non-financial sectors such as real estate agencies, gambling operators, law firms, accountants, tax advisors, and dealers in high-value goods. Polish law clearly defines these categories, and the General Inspector of Financial Information (GIIF), along with sector-specific regulators (e.g. KNF for financial institutions or KAS for gambling), actively supervises AML compliance in Poland.
Non-compliance can lead to severe consequences, including administrative fines (up to up to the equivalent of EUR 5,000,000 (approximately PLN 21.5 million) or 10% of a company’s annual turnover), criminal liability, or temporary suspension of business activities. On the other hand, a well-structured AML compliance in Poland program helps fulfill legal obligations and protects your business from reputational harm, fraud, or being used — knowingly or unknowingly — for illicit purposes.
This guide outlines the key building blocks of an effective AML compliance in Poland system under Polish law, with a focus on sectors such as real estate and gambling, where regulatory expectations are increasing. Each element – from internal controls to risk assessment and suspicious transaction reporting – is explained in clear language, with practical tips to help you implement them.AML compliance in Poland is both a legal requirement and a strategic investment in your company’s integrity and long-term success
Poland’s primary legislation on anti-money laundering (AML) and counter-terrorist financing (CTF) is the Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing (as amended). This law transposes the EU’s 4th and 5th AML Directives and incorporates key elements of the 6th Directive, significantly expanding the scope of criminal liability and reinforcing AML compliance in Poland obligations for businesses.
It sets out the national framework for preventing and combating money laundering and terrorist financing and imposes detailed duties on a broad spectrum of entities operating in both the financial and non-financial sectors.
Under Polish law, “obligated entities” include not only traditional financial institutions — such as banks, credit unions, insurers, and investment firms — but also many non-financial service providers that may be exposed to money laundering risks. This includes, among others, real estate agencies and developers, virtual asset service providers and currency exchange offices, law firms and notaries (in certain types of transactions), tax advisors, accounting and auditing firms, company formation agents, and dealers in high-value goods. In addition, any person or entity — regardless of sector — that accepts or executes cash transactions equal to or exceeding EUR 10,000 (or the equivalent in other currencies) is also considered an obligated institution. This wide-reaching definition means that both domestic and foreign investors launching operations in Poland must evaluate at an early stage whether their activities fall within the scope of AML compliance in Poland regulations and take appropriate steps to ensure compliance.
Crucially, Polish AML law also reflects EU-level transparency requirements regarding beneficial ownership. All companies and partnerships registered in the Polish National Court Register (KRS) are required to submit information on their Ultimate Beneficial Owner (UBO) to the Central Register of Beneficial Owners (CRBR), and to update that information whenever changes occur. This obligation applies regardless of industry or company size and is designed to increase transparency and limit the misuse of legal entities for illicit purposes. Failure to meet UBO reporting obligations may result in financial penalties of up to PLN 1 million imposed on the company or its management. If your business qualifies as an AML-obligated institution in Poland, you are legally required to establish and maintain a full AML compliance in Poland system. These obligations apply across sectors and include conducting risk assessments, verifying customers and beneficial owners, monitoring transactions, filing suspicious transaction reports with the General Inspector of Financial Information (GIIF), and appointing a dedicated AML Compliance Officer. Whether you operate in financial services, real estate, professional advisory, or other high-risk industries, AML compliance in Poland is not only a regulatory requirement, but also a key safeguard protecting your business from reputational damage, regulatory exposure, and abuse by criminal actors.
Obligated institutions in Poland must apply a Risk-Based Approach (RBA) by assessing money laundering and terrorist financing risks — both at the institutional and client level. This includes reviewing customer types, services offered, delivery channels, and geographical exposure.
The assessment must be documented, regularly updated, and should shape your AML compliance in Poland controls, including due diligence and monitoring. Regulators such as the General Inspector of Financial Information (GIIF) expect businesses to demonstrate a clear understanding of their risk exposure.
We provide practical guidance on implementing an RBA later in this guide to support effective AML compliance in Poland.
In higher-risk situations — such as dealing with Politically Exposed Persons (PEPs) (e.g. senior public officials, politicians, judges, or heads of state-owned enterprises), clients from high-risk third countries, or those with complex structures or large cash transactions—you must apply Enhanced Due Diligence (EDD) as part of AML compliance in Poland.
EDD may include collecting additional identification documents, verifying the source of funds, obtaining senior management approval, and more frequent monitoring. Polish AML law requires that PEPs remain subject to EDD for at least 12 months after leaving office, unless ongoing risk is identified. All measures must be risk-based and properly documented and fully aligned with AML compliance in Poland standards.
Under Polish AML law, obligated institutions must apply effective KYC procedures as a part of AML compliance in Poland before starting a business relationship or executing an occasional transaction. This involves verifying the client’s identity, identifying the Ultimate Beneficial Owner (UBO) for legal entities, and understanding the purpose of the relationship.
You must also screen clients against sanctions lists, check for PEP status, and assess reputation risks. For corporate clients, verify the ownership structure and confirm the UBO’s identity using reliable sources. All information must be documented and retained for five years to ensure ongoing AML compliance in Poland. We explain when simplified or enhanced due diligence applies later in this guide.
All obligated institutions in Poland must establish internal AML compliance in Poland /CFT policies tailored to their business size, sector, and risk profile. These must be documented in writing, approved by senior management, and updated at least annually.
The internal program should describe how your company performs customer due diligence (CDD), risk assessments, transaction monitoring, record-keeping, and reporting to GIIF as part of AML compliance in Poland. It must also include procedures for internal controls, compliance testing, staff training, and whistleblower protections.
Some elements — like escalation procedures for high-risk clients — are mandatory regardless of industry to ensure comprehensive AML compliance in Poland.
One of the first key roles to establish within your AML compliance in Poland structure is the Compliance Officer, who bears responsibility for ensuring that your organisation meets its obligations under Polish anti-money laundering and counter-terrorist financing (AML/CFT) regulations. This person should hold sufficient authority, independence, and knowledge to effectively manage the day-to-day operation of the AML system. Core duties include implementing internal procedures, guiding staff on regulatory requirements, overseeing transaction monitoring, and serving as the primary contact with the General Inspector of Financial Information (GIIF). In regulated sectors such as banking, insurance, or investment services, Polish law requires the Compliance Officer to hold a management-level position. However, outside those sectors, it is sufficient to appoint a qualified individual — even in smaller firms — to clearly assume responsibility and ensure accountability for AML compliance in Poland.
Ongoing monitoring of customer transactions is essential to detect red flags under Polish AML law. Obligated institutions must implement procedures to identify unusual patterns in transaction size, frequency, or structure — signs that may indicate money laundering or terrorist financing — as part of AML compliance in Poland.
Examples of red flags include frequent transfers just below reporting thresholds, transactions that do not match the client’s profile, or use of intermediaries without clear economic purpose. For example, a real estate agent should investigate fragmented payments or offshore funding, while a currency exchange office should monitor repeated cash transactions by the same client. Additionally, all clients and their transactions must be screened against sanctions lists (EU, UN, OFAC). Screening must be ongoing and dynamic, not limited to onboarding to ensure continuous AML compliance in Poland. Failure to detect sanctioned individuals can lead to severe penalties.
Having internal AML policies is not enough — staff must be regularly trained to apply them in practice. Under Polish law, AML training is a legal requirement for all employees exposed to money laundering or terrorist financing risks — especially those involved in customer service, onboarding, transactions, or compliance — as a part of AML compliance in Poland.
Training should cover KYC procedures, red flag detection, internal reporting protocols, and sanctions screening. It must be provided at onboarding and regularly repeated, usually at least once a year. Records of training (dates, participants, topics) should be kept for inspection to demonstrate adherence to AML compliance in Poland. Well-informed staff are your first line of defence. Effective AML training not only supports compliance but also protects your business from financial and reputational harm. strengthening overall AML compliance in Poland.
Maintaining clear and accessible records is a key pillar of AML compliance in Poland. Obligated institutions must retain all documents gathered during customer due diligence — such as ID copies, company records, UBO declarations, and internal risk assessments — for at least five years after the business relationship ends or a one-off transaction is completed. Transaction records (e.g. contracts, invoices, payment confirmations) must also be kept for the same period. These records should be organized and easily retrievable in case of inspections by the General Inspector of Financial Information (GIIF) or other authorities. Proper documentation demonstrates effective AML compliance in Poland in practice and supports regulatory oversight.
While Polish law does not impose a universal obligation to appoint an independent AML audit function, it does require that all obligated entities implement effective internal control mechanisms to ensure compliance with anti-money laundering and counter-terrorist financing (AML/CFT) regulations as part of AML compliance in Poland.
Under Article 50 of Poland’s AML Act, every obligated institution must:
This review does not need to be carried out by an external party. However, in larger or more complex organizations, it is considered good practice to assign the task to an independent internal function (such as internal audit) or to engage an external AML advisor for periodic assessments.
Such reviews help ensure that:
Even for smaller firms, a voluntary AML review once a year can be a valuable preventive tool. It allows potential issues to be addressed early — before they become regulatory problems and ensures continuous AML compliance in Poland.
A central principle of Poland’s AML legislation — aligned with EU directives — is the Risk-Based Approach (RBA). This approach recognizes that not all clients, transactions, or services pose the same level of risk for money laundering or terrorist financing. As such, businesses are expected to focus compliance efforts where the risks are highest, ensuring that controls are proportionate, and resources are used efficiently in line with AML compliance in Poland requirements.
For foreign investors and business owners in Poland, understanding and applying RBA is crucial for meeting regulatory expectations and building a compliant, scalable AML compliance in Poland program.
A key theme in modern AML laws (Romania included) is the Risk-Based Approach (RBA). Simply put, regulators expect businesses to focus their efforts where the risks are highest. This approach acknowledges that not all customers, transactions, or products pose the same level of risk for money laundering. For investors and business owners, understanding RBA is crucial to allocate compliance resources efficiently and meet legal expectations. Under an RBA, your company should assess and categorize risks in several areas:
Customer risk profiling
During onboarding, each customer must be assessed for AML/CTF risk as part of AML compliance in Poland. Key risk factors include:
Based on these criteria, assign each customer a risk level (e.g. low, medium, high). This classification determines the scope of due diligence:
Geographical risk
As part of AML compliance in Poland, you must consider the risks associated with countries or regions involved in your business relationships. Poland’s AML law and EU directives pay special attention to transactions involving jurisdictions with weak AML/CFT regimes. If your client or their funds come from a country on the EU’s high-risk third countries list or one subject to international sanctions, that constitutes a red flag. Your risk assessment should document which countries are considered higher risk and ensure any dealings connected to those countries get extra scrutiny. Evaluate any exposure to high-risk jurisdictions. Polish and EU AML regulations pay particular attention to:
If a client, beneficial owner, or transaction is linked to such countries, enhanced scrutiny is mandatory, and the relationship should be carefully documented and monitored and continuously monitored to ensure effective AML compliance in Poland.
Service/product risk
Not all services carry equal risk under AML compliance in Poland. For example:
If your business provides these types of services, your AML procedures should reflect the elevated level of control required to maintain effective AML compliance in Poland.
In Poland, certain professions — such as real estate agents, legal advisors, and accountants — have sector-specific obligations recognizing their exposure to financial crime risks.
Transaction and delivery channel risk
How services are delivered also influences risk under AML compliance in Poland:
Your AML compliance in Poland framework should define what constitutes normal vs. suspicious activity and include thresholds for review or investigation.
Implementing the Risk-Based Approach (RBA) effectively requires that your business regularly conducts both institutional and client-level risk assessments as part of AML compliance in Poland, considering factors such as customer type, services offered, transaction channels, and geographical exposure. The methodology for evaluating and assigning risk levels must be clearly defined, well-documented, and regularly updated to reflect changes in your business model, regulatory environment, or emerging threats.
Where higher risks are identified, enhanced controls must be applied — such as more frequent KYC updates, senior management approval before onboarding high-risk clients, or stricter transaction monitoring. Conversely, simplified procedures may only be used in limited circumstances where explicitly permitted by law and only if supported by a documented risk assessment.
Importantly, the RBA is not optional — it is a legal requirement under Polish AML law. Your business must be able to demonstrate to supervisory authorities, including the General Inspector of Financial Information (GIIF), that its AML measures are risk-sensitive, proportionate, and properly documented to ensure full AML compliance in Poland. If you require assistance in building or reviewing your RBA framework, our legal advisory team is ready to support you in developing a compliant, effective, and business-appropriate model aligned with both Polish and EU regulatory standards, ensuring full AML compliance in Poland.
Achieving full AML compliance in Poland is a step-by-step process. For investors and entrepreneurs launching a new business, it is essential to integrate AML obligations from the moment of company formation. Compliance should not be treated as an afterthought, but rather as a core part of your operational structure and risk strategy. Below is a roadmap from incorporation to ongoing AML compliance in Poland.
When establishing your company in Poland, you must first determine whether your business qualifies as an “obligated institution” under the Polish AML Act. This classification depends on the nature of your activity— if your business involves financial transactions, real estate services, accounting, legal or tax advisory, virtual assets, or the trade of high-value goods, you are likely subject to AML compliance in Poland obligations.
If your business qualifies as an obligated institution, you are required to complete certain initial compliance steps, including the submission of a UBO (Ultimate Beneficial Owner) declaration to the Central Register of Beneficial Owners (CRBR). This must be submitted within 7 days of company registration in the National Court Register (KRS). Failure to submit or update UBO information may result in fines of up to PLN 1 million imposed on the company.
At this stage, it is also advisable to assess whether your business requires internal AML procedures, the appointment of an AML Compliance Officer, and whether registration with oversight bodies such as the General Inspector of Financial Information (GIIF) may be necessary, depending on the nature and scale of your operations. While Polish law does not require a separate notification to GIIF at business startup, all obligated institutions must be prepared for inspections and reporting duties.
Completing these early formalities — proper business classification, UBO registration, and regulatory readiness — lays the foundation for a compliant and risk-aware AML framework from day one.
As part of your AML compliance setup in Poland, businesses classified as obligated institutions under the AML Act must formally appoint two distinct roles:
The AML Compliance Officer is responsible for developing, implementing, and enforcing the company’s AML framework. This individual must possess sufficient expertise in AML/CFT regulations and be granted access to internal systems and data necessary to carry out their duties. Responsibilities include overseeing customer due diligence (CDD), monitoring transactions, reporting suspicions to the General Inspector of Financial Information (GIIF) and coordinating staff training. In smaller businesses, this function may be combined with a management role, while larger organizations usually appoint a dedicated officer or team.
In addition, Article 6(3) of the Polish AML Act requires the formal designation of a senior-level employee who is accountable for approving and supervising the application of financial security measures. This includes reviewing decisions related to enhanced due diligence (EDD), onboarding high-risk clients, or applying exemptions when permitted by law. The designated person should hold a sufficiently high position — such as a board member, managing director, or equivalent — to provide effective oversight.
Although the two functions may be fulfilled by the same person in small entities, best practice — especially in higher-risk sectors — is to separate the roles. This ensures independent oversight, strengthens internal controls, and demonstrates to regulators that the business has a robust AML compliance in Poland structure in place.
As an obligated institution in Poland, you should prepare your internal AML policy early — this is the rulebook your staff will follow to maintain AML compliance in Poland. It must cover key topics such as KYC, risk assessment, enhanced due diligence for high-risk clients, transaction monitoring, internal reporting, and record-keeping. Clearly outline the role of the AML Compliance Officer and escalation channels for suspicious activity.
If your company operates across multiple sites or group entities, ensure the policy is applied consistently. You may use expert templates or legal support to align with Polish and EU regulations. The policy must be approved by senior management and updated regularly to reflect changes in your risk profile or the legal environment. A well-crafted AML manual demonstrates your commitment to a structured and effective AML compliance in Poland program from day one.
Once your internal AML policies are in place, the next key step is to carry out an institutional (business-wide) risk assessment. Under Polish AML law (Art. 27 of the Act of 1 March 2018), all obligated institutions must identify and assess the money laundering (ML) and terrorist financing (TF) risks associated with their operations as part of AML compliance in Poland.
This risk assessment should be tailored to your business model and must take into account the nature of products and services offered, customer types (e.g. individuals, legal entities, PEPs), transaction and delivery channels (e.g. face-to-face, remote, or online), and geographical factors, including exposure to high-risk jurisdictions or sanctioned countries.
For example, businesses offering services to non-residents, accepting large cash payments, or operating digital platforms open to international clients must recognise these as elevated risk factors. Early identification of such risks allows you to implement proportionate controls — such as enhanced due diligence, ongoing monitoring, or sanctions screening — supporting effective AML compliance in Poland.
The assessment must be documented in writing and should include both the rationale for risk classification and the mitigating measures applied. This document forms the foundation of your AML compliance in Poland framework and is often reviewed during inspections by the General Inspector of Financial Information (GIIF).
You are legally required to update the risk assessment regularly — at least annually or whenever your risk profile changes (e.g. due to entering new markets, launching new products, or responding to changes in threat levels). A well-documented risk assessment demonstrates that your business understands its exposure and has taken informed steps to manage it responsibly, ensuring ongoing, ensuring ongoing AML compliance in Poland.
Before entering a business relationship, obligated institutions under Polish AML law must establish practical Know Your Customer (KYC) procedures as part of AML compliance in Poland. These should clearly outline how customer identity will be verified — whether in person, via official registers (e.g. PESEL, KRS), or through electronic tools for remote onboarding.
Key identity data must be collected, including:
All clients must be screened against sanctions lists (EU, UN, OFAC) and checked for PEP (Politically Exposed Person) status before onboarding.
To ensure consistency, companies should use a standardized KYC checklist or onboarding form and clearly assign responsibility for document collection and flagging red flags. It’s also important to define default risk levels and escalation procedures for high-risk clients — typically requiring approval by the Compliance Officer.
Turning your KYC policy into a structured, operational process is essential to prevent onboarding clients who may pose regulatory or reputational risk and to maintain robust AML compliance in Poland.
In Poland, companies must maintain accurate and current information on their Ultimate Beneficial Owners (UBOs) in the Central Register of Beneficial Owners (CRBR). Any changes must be reported within 7 days of their occurrence. Non-compliance may result in penalties of up to PLN 1 million.
When dealing with corporate clients, obligated institutions must obtain and verify their UBO data, typically by consulting CRBR extracts or official corporate documentation. If the client provides information that differs from the register, you are required to report the discrepancy to the General Inspector of Financial Information (GIIF).
Integrating UBO verification into your KYC process — and ensuring updates when client ownership changes — is essential for regulatory compliance and helps safeguard your business from engaging with opaque or high-risk structures.
An effective AML program in Poland requires ongoing monitoring of transactions to detect suspicious or unusual activity — such as large cash movements, irregular transfers, or transactions inconsistent with the customer’s profile. Your business must have procedures or systems in place to flag such anomalies for internal review.
You are also obligated to screen clients and transactions against sanctions lists (EU, UN, OFAC) and identify politically exposed persons (PEPs). Screening must occur at onboarding and be repeated regularly throughout the customer relationship, with data kept up to date to ensure continuous AML compliance in Poland.
Even small firms are expected to have clear internal criteria for detecting and reviewing red flags. Larger or higher-risk businesses should consider automated solutions or external screening tools to meet regulatory expectations and maintain effective AML compliance in Poland.
Regular monitoring and screening help demonstrate that your business is proactively managing risk, not just formally meeting AML requirements — and they reduce the chance of inadvertently engaging with sanctioned or high-risk entities.
Under Polish AML law, businesses must establish a clear internal process for reporting suspicious activity as part of AML compliance in Poland. Employees — especially those in client-facing roles or handling transactions — should be trained to recognize red flags and know how to escalate concerns to the AML Compliance Officer.
Set up a standard reporting form or a secure internal channel (such as encrypted email or a dedicated compliance system) to facilitate reporting. Ensure whistleblower protections are in place so staff can report in good faith without fear of retaliation.
If a suspicion is confirmed, it is the Compliance Officer’s responsibility to file a Suspicious Transaction Report (STR) with the General Inspector of Financial Information (GIIF).
To promote a culture of compliance, provide regular training with practical examples, and emphasize that management supports and values internal reporting as a key part of effective AML compliance in Poland.
Under Polish AML law, if a transaction appears suspicious or exceeds statutory thresholds, you are legally obligated to report it promptly to the General Inspector of Financial Information (GIIF) as part of AML compliance in Poland. This includes both:
Reports must be submitted within 7 days of the transaction, via GIIF’s secure AML/CFT IT system, accessible only to authorized and registered users.
You must also monitor for large transactions, especially cash-based, and ensure that reporting obligations are fulfilled in a timely and accurate manner. In smaller organizations using manual processes, responsibility for this task should be clearly assigned and documented.
Maintain secure records of all reports filed with GIIF. Timely and accurate reporting is not only a legal requirement — it also serves as a key defense in the event of regulatory inspection or investigation, supporting robust AML compliance in Poland.
Under Polish AML regulations, obligated institutions must retain all key compliance records — such as customer identification data, due diligence documents, risk assessments, transaction logs, internal reports, and training records — for a minimum of five years from the end of the business relationship or completion of the transaction, as part of AML compliance in Poland.
Records must be securely stored to protect personal data, but also easily retrievable in the event of an audit or request from the General Inspector of Financial Information (GIIF). Clients should be informed — consistent with GDPR obligations — that their data is retained for legal compliance purposes.
Establish a policy for periodic review and secure deletion of records that exceed the retention period, unless a legal basis (e.g. ongoing investigations) justifies keeping them longer. Strong record-keeping not only fulfils your legal obligations—it also ensures readiness for inspections and supports a defensible compliance posture.
While Polish AML law does not mandate formal independent audits for all entities, obligated institutions must regularly assess the effectiveness of their AML systems. This includes internal checks to ensure that policies are applied in practice and remain appropriate given the company’s current risk exposure.
Larger or higher-risk businesses often choose to perform voluntary audits — either internally by staff independent of day-to-day compliance, or externally through AML specialists. These assessments typically review KYC files, risk assessments, training records, transaction monitoring procedures, and internal reporting mechanisms.
Although not legally required, conducting an annual AML review is widely regarded as best practice. It allows you to identify and correct gaps early and shows GIIF or other supervisory bodies that your organization maintains a proactive compliance culture. Many firms also schedule mock inspections to prepare for potential regulatory reviews, supporting robust AML compliance in Poland.
The AML landscape in Poland and across the EU is continuously evolving. New directives, national amendments, and risk typologies are introduced regularly. To maintain effective AML compliance in Poland, your business must proactively track legal developments and adjust internal procedures accordingly.
Subscribe to regulatory bulletins, engage with legal or compliance experts, and review your AML policy and institutional risk assessment at least annually — or sooner if significant changes occur (e.g. entering new markets, onboarding new customer types, or updates to PEP classifications or sanctions lists).
Staff training should also be refreshed to reflect current risks and regulatory expectations. Keeping your team informed about emerging red flags and typologies reinforces everyday compliance practices.
By regularly updating your AML framework, you demonstrate to regulators and financial partners that your business is committed to ongoing — not just static — AML compliance in Poland.
In Poland, the General Inspector of Financial Information (GIIF) is the central authority for AML/CFT supervision. As the country’s Financial Intelligence Unit (FIU), GIIF receives and analyses Suspicious Transaction Reports (STRs), cooperates with law enforcement, and oversees the functioning of the national AML system. Ensuring proper AML compliance in Poland helps businesses meet GIIF’s expectations and reduce regulatory risk.
GIIF also acts as a regulator and supervisor, especially for sectors without dedicated financial regulators—such as real estate agents, law firms, accounting practices, and art dealers. In these cases, GIIF may conduct inspections or request documentation to verify that the entity has implemented appropriate AML policies and controls.
For regulated sectors like banking, insurance, or investment services, AML oversight is carried out by sectoral supervisors (e.g. the Polish Financial Supervision Authority – KNF) in coordination with GIIF. However, all STRs and threshold transaction reports must still be submitted directly to GIIF.
Non-compliance — such as failure to report suspicious activity, implement internal procedures, or update UBO information — can result in administrative fines, restrictions on operations, or even criminal liability in serious cases. GIIF is empowered to issue penalties or escalate matters to the prosecutor’s office.
The best defense against regulatory action is a robust, well-documented, and actively managed AML compliance in Poland program, ready for inspection and aligned with current legal requirements.
In Poland, the General Inspector of Financial Information (GIIF) has broad authority to supervise AML compliance in Poland and enforce regulatory obligations. GIIF may initiate administrative proceedings against businesses that violate AML rules, which can lead to formal warnings, financial penalties, or — where warranted — referral to law enforcement.
GIIF is empowered to request documentation, conduct on-site inspections, and issue remedial orders requiring companies to correct deficiencies. If a suspicion of money laundering or terrorist financing arises — either from a Suspicious Transaction Report (STR) or inspection — GIIF refers the matter to the Public Prosecutor’s Office for potential criminal proceedings.
In urgent cases, GIIF can impose a temporary suspension or block on transactions for up to 96 hours, allowing time for further investigation and to prevent the movement of potentially illicit funds.
Administrative fines for AML breaches can be significant—up to PLN 21.5 million or 10% of a company’s annual turnover, depending on the nature and severity of the infraction. Strong and well-documented AML compliance in Poland programs help businesses mitigate the risk of such penalties.
Failure to comply with AML requirements can lead to severe legal, financial, and reputational consequences for both companies and responsible individuals making strong AML compliance
in Poland essential:
In summary, Polish authorities actively enforce AML regulations, and ignorance of the law is not a defense. For investors and business leaders, AML compliance in Poland should be treated as a core risk management function, not a formal checkbox. Investing in a robust, risk-based compliance framework is significantly less costly than facing enforcement, prosecution, or exclusion from the financial system.
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