New AML/CFT legislation: what will change in 2025?

The Polish government plans to work on a draft amendment to the Anti-Money Laundering and Terrorist Financing Act (“AML Act”).

What is the purpose of the new regulations?

The purpose of the new draft is to supplement the AML Act with regulation related to restrictive measures used to counter the proliferation of weapons of mass destruction and the financing of this process.

The requirement to establish restrictive measures to counter the proliferation of weapons of mass destruction (WMD) is part of the international standard for countering money laundering, terrorist financing and proliferation established by the Financial Action Task Force (FATF standard).

In addition, the provisions of the so-called EU AML/CFT package, i.e., a set of regulations on preventing the use of the financial system for the purpose of money laundering or terrorist financing, were adopted on May 30 this year. Consequently, it is admitted that, in order to implement the requirements arising from the legal acts included in this package (6AMLD, AMLR, AMLAR, TFR) into the national legal order, the bill will also include provisions correcting selected elements of the existing AML Act regulations.

What changes will the bill introduce?

The most important changes include:

• expanding the scope of the law’s subject matter to include rules and procedures for applying restrictive measures to counter the proliferation of weapons of mass destruction and their financing,
• introduction of administrative penalties for non-compliance with proliferation financial sanctions,
• improving the functioning of cooperation between national authorities,
• supplementing the risk assessment of mandatory institutions with new elements,
• improving the functioning of the Central Register of Beneficial Owners.

 When will the new regulations come into force?

The government announces that the draft law will be published by the first quarter of 2025. This is a key date for obliged institutions, which will have to adapt their procedures to the new requirements.

More information about the draft can be found on the government’s official website.

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