Updated Polish National AML/CTF Risk Assessment

Polish AML laws are based on EU regulations, but there are some local specifics that should also be observed. On of them is Polish National Assessment of the Risk of Money Laundering and Financing of Terrorism, which has recently been updated. The 2023 National AML/CTF Assessment is available in Polish at: https://buff.ly/3vjguvE. In light of this update, according to Polish law, entities covered by AML requirements in Poland shall review and update, if necessary, their internal Institution AML risk assessments.

The previous version of National AML/CFT Assessment was published in 2019, so indeed a lot has happened since then in terms of potential risks relevant to Poland. The 2023 edition of the Assessment focuses on emerging threats to the Polish financial system, including the development of the cryptocurrency market, the Russian aggression on Ukraine and changes in the real estate market. 

For AML covered institutions, it's crucial to note that the 2023 National AML/CFT Assessment doesn't just describe general phenomena of money laundering and terrorist financing, but also pinpoints specific risks associated with various financial products and types of transactions. In line with Article 27 section 3 of the AML Act, institutions are required to update their risk assessments in response to situations outlined in the legislation, with the update of the National AML/CFT Assessment being a key trigger for such updates.  The text itself also encourages a thorough review of the entity's AML/CFT risk assessments.

Follow us for more insights on AML and if you want to talk about this specific update, get in touch with on of our team members!