Anti-Money Laundering in Poland

AML Country Guide / Anti-Money Laundering in Poland

Poland has a high-income economy and is even the eighth largest economy in the European Union. However, as Poland is seen as a regional financial center, it is seen as a potential target for money laundering.

Overview of Money Laundering in Poland

According to the data announced by the Polish Government, activities such as organized crime and customs tax evasion are the biggest sources of illegal funds in Poland. Polish officials consider virtual currencies, especially bitcoin, as an important and effective way of money laundering in Poland. At the same time, the profits of organized crime elements in Poland, from tax evasion and from the sale of counterfeit goods through money transfers and couriers, are increasingly being remitted.

Most of the organized crime activity in Asia takes place at the China Trade Center in Wolka Kosowska, about 25 kilometers from Warsaw. The basic scheme of organized crime in Poland involves the extreme underestimation of imported goods through the falsification of invoices used to determine the customs value of products and the applicable value-added tax (VAT). Additionally, Polish authorities suspect counterfeit goods and illegal drug trafficking in these markets. 

Regulated Institutions in Portland

Many institutions in Poland may have money laundering risks and it would be wrong to limit these institutions to financial institutions such as banks. On top of that, many regulators have made their regulations obligatory for many institutions. In these institutions, money laundering activities can take place directly, and they can also act as any intermediary for organized crimes of money laundering. Regardless of the situation, these institutions are at risk and are prohibited from engaging in money laundering, aiding, and abetting these crimes in any way. Here are some of those institutions: Banks, investment firms, payment institutions, auction platforms, insurance companies, exchange offices, virtual currencies, some notaries and lawyers, real estate agents, postal operators, institutions operating in the field of gambling betting, lending institutions, etc.

AML Regulators and Regulations in Poland


  • The General Inspector of Financial Information,
  • Minister responsible for public finance,
  • Polish Financial Supervision Authority,
  • National Bank of Poland,
  • Supreme Chamber of Control


  • AML Act,
  • The Act of 16 November 2000 on Counteracting Money Laundering and Terrorism Financing,
  • Journal of Laws of 2010,
  • The Criminal Fiscal Code of 10 September 1999,
  • The Banking Act of 29 August 1997. 

AML Obligations in Poland

Implementing an internal AML compliance program to combat money laundering and financing of terrorism, implementing financial security measures for customers in certain circumstances; Performing Know Your Customer (KYC) procedures. Records of the customer recognition procedures performed should be kept within the specified periods, and these customer screening operations should be carried out not only in the first transaction but also in certain suspicious cases and in certain periods. Especially in case of doubt, necessary reports should be prepared (SAR) and these reports should be submitted to the Inspector General of Financial Information. As stated in the Polish AML Law, obliged institutions should also appoint a senior management person responsible for the implementation of the duties. In addition, training programs are required for responsible personnel covering the fulfillment of AML obligations. 

Poland's FATF Statüs

Poland is a member state obliged to comply with FATF recommendations but is also not included in the list of AML deficiencies set by the FATF. The last Mutual Assessment Report on the implementation of anti-money laundering and anti-terrorism financing standards was conducted by the FATF in Poland in 2013. According to this report of the FATF, the Polish FATF 40 Recommendations is in line with 6 of them and the 24 recommendations are largely in line.

Sanction Scanner Solutions

Some measures are taken within the scope of the recommendations of the regulations and within the scope of minimizing the risks, some of these measures are Know Your Customer (KYC), Customer Due Diligence (CDD), Enhanced Due Diligence (EDD), Transaction Screening, Transaction Monitoring. Sanction Scanner solutions include all these measures and the responsible institutions in Poland can easily comply with the existing regulations with our AML solutions in accordance with the regulations. Let us minimize the risks of your business and save you time. You can talk to us for more information.

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