Poland Advances in Anti-Money Laundering and Counter-Terrorist Financing Compliance: Implications for the Financial Sector

Sergei MARKEVICH, B.Sc.

Partner / Business IT- and Compliance Officer, STARK TRUST

Quelle: KSIT

Poland Advances in Anti-Money Laundering and Counter-Terrorist Financing Compliance: Implications for the Financial Sector

Poland has made significant progress in strengthening its anti-money laundering (AML) and counter-terrorist financing (CFT) framework, according to a last released follow-up report from MONEYVAL, the Council of Europe’s monitoring body. The report highlights Poland’s efforts to comply with international standards set by the Financial Action Task Force (FATF), particularly in areas such as new technologies, regulatory guidance, and feedback.

Key Developments in Poland’s AML Compliance Framework

Since late 2021, Polish authorities have continuously provided targeted guidance and feedback to reporting institutions to reinforce their compliance mechanisms. Notable progress has been made in the virtual asset service provider (VASP) sector, where substantial regulatory improvements have been introduced. These measures include implementing a mandatory registration system for VASPs and suitability requirements for individuals involved in virtual asset-related activities, whether as business partners, management members, or beneficial owners. Furthermore, Poland has introduced penalties for VASPs that fail to meet the established standards.

This strategic step to strengthen compliance within the VASP sector reflects Poland’s awareness of new risks in digital finance. As regulatory frameworks continue to adapt to the rapid evolution of virtual asset markets, Poland’s approach sets a standard for other European countries aiming to bolster their own AML/CFT measures.

Improved Ratings and Areas for Further Progress

Thanks to these efforts, Poland has improved its FATF compliance ratings. MONEYVAL’s report upgraded Poland’s rating for Recommendation 34 (Guidance and Feedback) from Partially Compliant to Largely Compliant, indicating that Poland’s efforts to provide clear regulatory guidance have proven effective. However, Recommendation 15, which pertains to new technologies, remains rated as Partially Compliant, highlighting the need for further measures in this dynamic area to meet evolving standards.

Overall, Poland’s progress on FATF’s 40 Recommendations includes:

2 Recommendations rated as Compliant

22 Recommendations rated as Largely Compliant

16 Recommendations rated as Partially Compliant

Poland’s journey toward compliance underscores its commitment to international standards, though continuous improvements are essential in any AML/CFT system. MONEYVAL expects Poland to report back in December 2024 on further measures taken to strengthen its AML/CFT system, reflecting the ongoing nature of compliance and regulatory evolution in this field.

Implications for the Broader Financial Sector

Poland’s progress serves as an important case study for stakeholders in the financial and regulatory sectors. Countries across Europe face the challenges posed by the rapid development of digital assets and the related compliance hurdles. By proactively implementing standards for VASP registration and individual suitability, Poland addresses current risks and demonstrates a forward-looking approach to compliance.

In an increasingly interconnected financial world, Poland’s steps toward AML/CFT compliance provide a valuable example for companies, especially those operating in high-risk sectors or dealing with virtual assets. Financial institutions should closely monitor Poland’s regulatory advancements, as similar frameworks may soon be adopted across Europe and beyond, potentially requiring companies to quickly adapt to new compliance obligations.

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