The coming Sunday, 31 October 2021, is the effective date of a recent round of changes to the Polish AML/CTF regulations.

The changes affect mainly the central register of beneficial owners, called CRBR.

Outline of new regulations:

  • Identification of CRBR reporter and its rights
  • Duty for beneficial owners to report their particulars to obliged entities and to update them
  • Duty to disclose all citizenships held
  • Wider range of institutions obliged to report beneficial owner particulars
  • Obliged institutions must verify CRBR disclosures and note discrepancies
  • Duty to act to identify root causes of discrepancies
  • Duty to report confirmed discrepancies to Finance Minister
  • The regulations on fines have been elaborated and new fines introduced:
  • a fine of up to PLN 1 million on an obliged entity which fails to update CRBR entries or reports false information,
  • a fine of up to PLN 50,000 on a beneficial owner who fails to report or update information for an obliged entity.


We recommend revisiting your CRBR entries and making the required updates and revisions as quickly as possible.


WARNING! Last-minute changes possible!

The Sejm is working to potentially change the effective date of some of the AML amendment regulations. The deadline for additional obliged entities to file their CRBR reports may be postponed (till February 2022). The effective date may also be moved for the new duties of beneficial owners and for the failed data update fine. Interestingly, the news is based on a mention in a legislative proposal to amend the VAT Act. There are nearly two days left for the bill to be enacted and signed by the President.

If you have any questions, do not hesitate to make contact with and seek assistance from Anna Skowron, Paweł Michalski, or Dagmara Rajca-Erd.