Immigration law /

AML – customer definition extended

On March 1st 2021 a novel to the Polish AML Act will enter into force. The new wording brings a new, extended understanding of what a customer of obliged institution is. The introduced change is closely related with the compulsory stock dematerialization in joint stock companies.

According with the novel, by a customer one should understand: an individual, a legal person or an organizational unit having no legal personality for which an obliged institution provides services or performs operations falling within the scope of the professional activity it carries out, including the one with which the obliged institution establishes business relationships or upon whose order it conducts an occasional transaction; in the case of an insurance contract, the customer of an obliged institution shall be deemed to be the policyholder, and in the case of a contract for maintaining a register of shareholders of a simple joint-stock company referred to in Polish Commercial Companies Code, the customer of an obliged institution shall be deemed to be only a shareholder, pledgee or user of shares, said persons being subject to entry in this register in connection with a transaction constituting the grounds for making the entry.

Please note that we provide services related with compulsory stock dematerialization. For more information, please check:

Author team leader DKP Legal Piotr Putyra
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