Immigration law

KNF Guidelines – data required by Banks from payment services providers

On June 2nd 2020 Polish regulator Financial Supervision Committee (KNF) published guidelines for banks providing services to payment services providers. The main part of the guidelines is a questionnaire consisting of 87 detailed questions to be asked by Banks to their customers from fintech sector.

According to KNF, currently the scope of data obtained by banks from payment services providers is very (too) diverse. As a consequence, it is recommended to introduce unified standardized set of data and information to be required from payment services providers by banks. The main aim is to make sure that the fintech companies are not involved in money laundering and/or terrorism financing.

As mentioned above, the questions are numerous and very detailed. They are divided into nine main categories:

  1. organization form and general information
  2. bank – payment service providers relationship
  3. information on the AML / CFT Policy
  4. characteristics of the payment services provider
  5. risk assessment and financial security measures of the payment services provider
  6. information accompanying transfers of funds
  7. sanction lists
  8. internal control system
  9. administrative sanctions imposed on the payment services provider

Even though the KNF guidelines are not binding, they will surely be respected by all Polish banks.

We invite you to contact our Law Firm, which offers services such as:

  1. payment services,
  2. representation in front of KNF and banks,
  3. obtaining the status of small payment institution (MIP / SPI),
  4. obtaining the national payment institution license (KIP),
  5. legal design of internal systems and bye-laws so that they comply with EBA and KNF guidelines.
Author team leader DKP Legal Piotr Putyra
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