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Mandatory update of internal AML/CFT procedures


by Łukasz Napiórkowski

30 September 2021


The existing laws on counteracting money laundering and terrorist financing will be amended on 31 October 2021.

Scope and deadlines

Polish lawmakers have identified the need to update the existing internal procedures of the obliged institutions to:

  • determine the rules for addressing discrepancies between information disclosed in the UBO Register (Polish abbreviation: CRBR) and information about client's beneficial owners established in connection with the application of the AML Act;
  • define the rules for documenting difficulties in verifying the identity of a beneficial owner and the actions taken to identify a natural person holding a senior management position as a beneficial owner;
  • specify new obligations related to client identification and verification of their identity.


Under the new laws, senior management has to approve the updated procedures.
The deadline for updating internal procedures will be 31 October 2021. Failure to introduce or update the internal procedure by the above deadline puts the obliged institution at risk of administrative fines.

New obligations

The obliged institutions should also be aware of the new statutory obligations, including in particular:

  • adding to their training programme also issues related to personal data protection;
  • introducing regulations on counteracting behaviour of a repressive nature or worsening the legal or factual situation or involving threats, in particular actions adversely affecting working or employment conditions, against employees and other persons who are engaged in activities for the obliged institution consisting in:
    -  reporting actual or potential AML/CFT breaches,
    -  notifying relevant institutions or authorities of AML/CFT related circumstances;
  • introducing new circumstances associated with a higher risk for the client.

This is the first such significant amendment to the AML/CFT Act in a long time, requiring compliance by the obliged institutions. It is advisable for the obliged institutions to review their existing internal procedures.


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Łukasz Napiórkowski

Attorney at law (Poland)

Associate Partner

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