Anti-Money Laundering and Counter Financing of Terrorism (AML/CFT)

Businesses qualified as so-called obliged entities, including banks, investment firms, insurance intermediaries and accounting firms, must ensure compliance with a number of duties relating to anti-money laundering and counter terrorist financing (AML/CTF).

Among the AML/CTF requirements that Polish businesses face are:
• identification and assessment of AML/CTF risks,
• implementation and maintenance of customer due diligence measures (to counteract money laundering and terrorist financing),
• collection and submission of required information to the General Financial Information Inspector (GIIF),
• development and implementation of an internal AML/CTF procedure and a whistleblowing policy providing options for anonymous reporting of AML/CTF violations,
• provision of AML training to employees.

While these duties are often complicated to comply with, violations may lead to criminal and administrative liability (with the penalty potentially reaching as high as PLN 1 million).
To meet the expectations of the business community, Sendero offers support in AML/CTF compliance. In particular, we can:
• identify your specific AML/CTF compliance duties,
• provide advice in relation to AML/CTF compliance,
• propose an internal AML/CTF procedure and a whistleblowing policy providing options for anonymous reporting of AML/CTF violations,
• ensure these procedures and policies are updated when the law changes,
• provide AML/CTF compliance training.
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Why SENDERO?

• We have a proven track-record of serving businesses in AML/CTF compliance matters.
• We have provided a number of training workshops on AML/CTF compliance.
• We have developed many internal AML/CTF procedures.
Also, at your request, we will be pleased to deal with any similar matters related to this area.