Categories of institutions conducting controls over AML/CTF regulations in Poland

In Poland, tackling money laundering and terrorist financing (AML/CTF) is considered as a key aspect of maintaining the integrity of the financial system.

Several institutions are tasked with conducting controls to verify the implementation of AML/CTF obligations, although this does not always directly result from the Polish AML Act:

• General Inspector of Financial Information – Control activities are carried out under Chapter 12 of the Act on AML, and Chapter 5 of the Entrepreneurs' Law. Subjective scope of control: all obligated institutions concerned with AML/CTF obligations.

• Heads of customs and tax offices – Control activities are carried out on the basis of Section 5 of Chapter 1 of the National Tax Administration Act - customs and fiscal control. Subjective scope of control: All obligated institutions as indicated in the AML/CTF Law.

• Voivodes - Control activities are carried out on the basis of Chapter 12 of the AML Act and Chapter 5 of the Entrepreneurs' Law. Subjective scope of control: Associations of local government units.

• District Heads (starostowie) - Inspection activities are carried out on the basis of Chapter 12 of the AML Act and Chapter 5 of the Entrepreneurs' Law. Subjective scope of control: Associations and foundations.

• Ministers - Inspection activities are carried out on the basis of Chapter 12 of the AML Act and Chapter 5 of the Entrepreneurs' Law. Subjective scope of control: Foundations.

• Polish Financial Supervision Authority – Inspection activities carried out on the basis of sectoral acts providing for the control of the Polish Financial Supervision Authority over a given sector. Subjective scope of control: Financial institutions under the supervision of the Polish Financial Supervision Authority.

• The President of NBP – Inspection activities carried out pursuant to Chapter 9 of the Foreign Exchange Law. Subjective scope of control: Entities conducting currency exchange activities within the meaning of the said Act,

• Presidents of courts of appeal – Inspection activities carried out on the basis of the Regulation of the Minister of Justice on the procedure for exercising supervision over the activities of notaries and notarial self-government bodies. Subjective scope of control: notaries;

• National Credit Unions on the basis of the Act on Cooperative Savings and Credit Unions in relation to cooperative savings and credit unions. These are the only institutions from the private sector authorized to perform this type of control.