Poland has emerged as a significant player in the European anti-money laundering (AML) regime. At the heart of Poland’s AML framework is the General Inspector of Financial Information (Generalny Inspektor Informacji Finansowej, or GIFI), which serves as the central financial intelligence unit (FIU).
GIFI is appointed and dismissed by the Prime Minister upon the recommendation of the Minister of Finance and operates with the support of the Financial Information Department within the Ministry of Finance. Together, they form the official financial analytical unit as defined by EU directives.
The Role of GIFI in Poland’s AML Framework
As outlined in Article 12 of Poland’s AML Law, GIFI is entrusted with key responsibilities including the collection and analysis of suspicious activity reports (SARs), risk assessment of money laundering (ML) and terrorist financing (TF), and the authority to halt transactions or freeze accounts. GIFI plays a pivotal role in coordinating with law enforcement agencies, financial institutions, border services, and customs. These entities must report suspicious transactions or transactions exceeding statutory thresholds to GIFI. Upon request, they must also block accounts and provide all necessary documentation.
GIFI receives cross-border transaction data from customs and border services and collaborates with Poland’s central bank, the Financial Supervision Authority (KNF), and other regulatory bodies. In cases of confirmed ML/TF suspicion, GIFI refers the matter to the prosecutor’s office, which must inform GIFI of the investigation’s outcome.
Poland’s AML Legislation and EU Integration
The cornerstone of AML regulation in Poland is the Act of March 1, 2018, on Counteracting Money Laundering and Terrorism Financing. This law transposes the 4th, 5th, and 6th AML Directives of the European Union. It defines a wide array of obligated entities under Article 2, including both financial and select non-financial institutions.
These entities must perform comprehensive risk assessments and adopt risk-based financial security measures. Requirements include Know Your Customer (KYC) procedures, monitoring politically exposed persons (PEPs), and identifying ultimate beneficial owners (UBOs). The law mandates the use of beneficial ownership registries and fosters information-sharing mechanisms aligned with EU standards.
Additionally, obligated institutions must report suspicious transactions (STRs) and large cash operations over €15,000. They are required to implement internal AML procedures, appoint a compliance officer, and conduct regular staff training. Sanctions-related monitoring and enhanced scrutiny for TF risks are also integral to the legislation.
Business Obligations: Banks, Lawyers, and Crypto Firms
The law imposes significant AML duties on various business sectors. Banks, law firms, and since recently, virtual asset service providers (VASPs), are all subject to GIFI oversight. According to Article 34, financial security measures must include KYC procedures, including verification of the customer and their beneficial owner.
Based on risk assessments, entities must understand the purpose of transactions and gather relevant data. Employees must immediately report suspicious circumstances to GIFI under Article 74. STRs must also be filed post-transaction if the operation raises red flags.
Article 72 obliges institutions to report high-value transactions above €15,000, whether in cash or through wire transfers. Each institution must establish a tailored internal AML/CTF program under Article 50, outlining procedures for risk analysis, customer due diligence, transaction monitoring, and STR handling.
Furthermore, according to Article 52, all personnel engaged in AML functions must undergo regular training, which includes both staff and executive-level managers responsible for compliance.
Challenges in AML Supervision and Implementation
Despite its robust framework, Poland faces numerous challenges in AML enforcement. One key issue is the growing volume of reports amid limited automation in filtering and analyzing transactions. Another is resource scarcity: GIFI faces staffing and budget constraints. According to audits by the Supreme Audit Office (NIK), some staff leading compliance inspections lack formal auditing qualifications, and cases are often delayed due to the volume and complexity of documentation.
Additionally, the evolving sophistication of money laundering schemes, including cross-border transactions, use of virtual currencies, and offshore structures, poses severe hurdles. Cryptocurrencies, in particular, present anonymity to bad actors. While Poland aims to improve oversight of crypto markets, technological advances often outpace regulatory responses.
Penalties for AML Violations in Poland
Poland enforces a dual system of administrative and criminal penalties. Regulatory bodies, including GIFI, may impose administrative sanctions for non-compliance. Sanctions range from public disclosure of the violation in the Public Information Bulletin to suspension of licenses and removal of entities from official registers. Directors can also be banned from holding executive positions for up to one year.
Fines depend on the illegal gain derived. Article 150(2) of the AML Law allows fines up to twice the illicit profit or €1 million if the amount is indeterminate. In more severe cases, criminal liability applies for active money laundering or its facilitation.
Future AML Reforms and Strategic Initiatives
Poland is actively pursuing reforms to bolster its AML framework. A draft law regulating the crypto asset market, driven by the EU’s MiCA regulation, is under development. Meanwhile, the Ministry of Finance and GIFI are modernizing internal IT systems to enhance data processing and streamline oversight.
Organizationally, Poland is developing a National AML/CFT Strategy and risk analysis plans. Though NIK has noted delays in publishing these documents, work is ongoing. The country is also introducing professional AML standards and expanding cooperation between GIFI, law enforcement, and supervisory agencies.
Following MONEYVAL recommendations, Poland has intensified training efforts and improved its statistical and oversight mechanisms, especially regarding managerial accountability in the financial sector.
As conclusion
Poland’s AML regime reflects a serious and evolving commitment to tackling financial crime. With GIFI at its center, the country balances EU compliance, national enforcement, and cross-sectoral engagement. Although challenges persist, particularly around crypto regulation and resource limitations, Poland continues to strengthen its institutional and technological capacity.
Manimama Law Firm supports companies operating in Poland’s demanding AML environment. We assist clients with GIFI compliance, risk policy development, crypto licensing, and STR filing strategies. Our experts ensure your business meets all AML requirements while remaining agile in a fast-changing regulatory climate.
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