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New AML obligations




Łukasz Napiórkowski

20 May 2021


An act amending the Anti-Money Laundering Act became law on 30 March 2021. Some of its provisions took effect from mid-May.


Changes relevant for enterprises


The amended Act extends, among others, the list of obliged institutions, i.e. entities required to fulfil the obligations provided for in the Act.


Changes related to the verification of beneficial owners (UBO) and data reported to the Central Register of Beneficial Owners (CRBR) are also relevant for enterprises.


The amended Act clarifies and supplements:

  • the UBO verification process and process documentation;
  • the list of entities that must report the beneficial owner to the CRBR;
  • the scope of data reportable to the CRBR (e.g. each citizenship of a management board member and a beneficial owner will have to be reported);
  • the obligations of enterprises to provide information on their beneficial owners to obliged institutions;
  • the rules for verifying beneficial owners (you cannot rely solely on the entry in the CRBR).

A new procedure for clarifying discrepancies between a client's CRBR entry and the result of the obliged institution's own verification process has been established. This means that entries in the CRBR will be subject to even more detailed verification.


Other key changes introduced by the amended Act include:


  • redefined UBO and politically exposed person (PEP);
  • new grounds for applying financial security measures to existing clients and changes in the application of enhanced financial security measures;
  • changed scope of data collected when verifying the client's identity;
  • redefined politically exposed persons or persons entrusted with prominent public functions (PEP) and a newly-created list of PEP;
  • changed retention period for client data and transaction information;
  • clarified obligation to review and update the internal AML procedure on an ongoing basis;
  • added elements to the mandatory AML training;
  • changed procedure for anonymous reporting of AML violations;
  • obligatory registration for obliged institutions operating for the benefit of companies or trusts or in the field of virtual currencies. 


In view of the introduced modifications it is recommended to review internal AML procedures that are currently in force in obliged institutions and to review data entered by enterprises in the CRBR.


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Łukasz Napiórkowski

Attorney at law (Poland)

Associate Partner

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