What actions would VASPs typically take after GIIF Control?

After undergoing an inspection by the General Inspector of Financial Information (GIIF) to assess compliance with anti-money laundering (AML) and counter-terrorist financing (CTF) regulations, Virtual Asset Service Providers (VASPs) in Poland would usually take the following actions:

Review the Report from control

Review the control report provided by the GIIF controllers, which outlines their findings, identifies any deficiencies or non-compliance issues, and provides recommendations for improvement.

Address Identified Deficiencies

Address any deficiencies or non-compliance issues highlighted in the report. Develop and implement an action plan to rectify these issues within the specified timeframe.

Implement Recommendations

Analyze and implement the recommendations provided by the GIIF controllers.

Update Policies and Procedures

Based on the inspection findings and recommendations, review and update your AML/CTF policies, procedures, and internal controls. Ensure that these documents are aligned with the latest regulatory requirements and industry best practices.

Provide Progress Reports

The GIIF may require you to submit progress reports detailing the actions taken to address the identified deficiencies and implement the recommendations. Provide these reports in a timely and comprehensive manner.

Enhance Risk Management

Review and strengthen your risk management framework, taking into account the insights gained from the GIIF inspection. Regularly assess and mitigate potential AML/CTF risks associated with your business operations.

Maintain Open Communication

Maintain open communication with the GIIF and promptly respond to any additional requests or inquiries. Cooperation and transparency are essential for building a positive relationship with the regulatory authority.

By taking these actions, VASPs can demonstrate their commitment to compliance and address any identified weaknesses in their AML/CTF program. Failure to take appropriate corrective measures may result in further regulatory actions, including potential penalties or sanctions.