AML in Poland

Based on data released by the Polish Government, primary sources of illicit funds in Poland encompass activities like organized crime and the evasion of customs taxes. Notably, Polish authorities regard virtual currencies, particularly bitcoin, as a significant and efficient avenue for money laundering within the country. Concurrently, proceeds generated by organized criminal entities in Poland, stemming from tax evasion and the vending of counterfeit goods, are increasingly being funneled through money transfers and intermediaries.

The nucleus of organized crime endeavors in Asia is concentrated within the China Trade Center situated approximately 25 kilometers from Warsaw, specifically in Wolka Kosowska. The fundamental modus operandi of organized crime in Poland revolves around drastically undervaluing imported commodities through the falsification of invoices. These manipulated invoices are then employed to determine the customs valuation and the associated value-added tax (VAT). Furthermore, suspicions have been raised by Polish authorities regarding the presence of counterfeit goods and illicit drug trade in these marketplaces.

Numerous establishments within Poland are susceptible to the potential risks associated with money laundering, extending beyond the confines of solely financial institutions such as banks. Moreover, a multitude of regulatory bodies have enforced their guidelines across various sectors, obliging a wide spectrum of establishments to adhere. Within these entities, money laundering activities might transpire directly or potentially serve as intermediaries for orchestrating organized money laundering activities. Irrespective of the circumstances, these establishments remain exposed to risks and are unequivocally barred from partaking in money laundering, or assisting and abetting such criminal activities in any capacity. The following are among the institutions encompassed: Banks, investment enterprises, payment providers, auction platforms, insurance firms, currency exchange bureaus, virtual currency handlers, select notaries and lawyers, real estate agents, postal service providers, gambling and betting enterprises, lending establishments, and the like.

Establishing an internal program for Anti-Money Laundering (AML) compliance, aimed at countering money laundering and the financing of terrorism, involves the implementation of specific financial security measures for clients in specific scenarios. This encompasses the execution of Know Your Customer (KYC) protocols. Comprehensive records of the conducted customer verification processes must be maintained according to designated timeframes. These customer screening procedures are essential not only for initial transactions but also for select suspicious cases and at specified intervals. In instances of uncertainty, it is imperative to generate requisite Suspicious Activity Reports (SAR) and promptly submit these reports to the Financial Information Inspector General.

As mandated by the Polish AML Law, institutions bound by obligations must also designate a senior management figure entrusted with overseeing the fulfillment of duties related to AML. Moreover, a training regimen is compulsory for personnel tasked with these responsibilities, covering the entirety of AML obligations.