Practical lessons for business from the Inspector General for Financial Information’s 2023 report
The General Inspector of Financial Information (GIIF) published its annual report for 2023. An increase in the number of notifications, actions taken ex officio, and an update of the national risk assessment are just some examples that show that there has been a lot going on in the AML/CFT (anti-money laundering/combating the financing of terrorism) field in the past year. The material provides a valuable indication of the supervisor’s practices.
Not only obliged institutions report transactions
As stated in the report, in 2023, the GIIF received 4746 descriptive notifications about suspicious activities and transactions, so-called Suspicious Activity Reports (SARs).
4381 notifications came from obliged institutions, 357 from cooperating units, while 8 had origins in “other sources.”
The cooperating unit as defined by AML/CFT regulations are:
- government administration bodies,
- bodies of local self-government units,
- other state organizational units,
- the National Bank of Poland (NBP),
- the Polish Financial Supervision Authority (KNF),
- Supreme Audit Institution (NIK).
Although the overall number of notifications is 5% higher than in 2022, in terms of notifications from cooperating units, the increase is more than 70% year-on-year. This indicates a significant activation of cooperating units in the notification of suspicious transactions.
Supervisor activities
In 2023, 3443 analytical proceedings were initiated, almost 60% more than in 2022. These investigations resulted in 473 notices of suspected money laundering to law enforcement authorities. The value of the assets involved in the notifications amounts to PLN 9.61 billion.
The GIIF blocked 679 accounts in connection with the notification of SARs by obliged institutions. Funds accumulated in these accounts showed a total value of about PLN 152 million. Compared to 2022, there was an increase of more than 73% in the number of blocked funds.
The supervisor stopped 52 transactions valued at PLN 4,3 million
The GIIF conducted 9 inspections in 2023. However, it is not the only entity overseeing the AML/CFT activities of the obliged institutions. Other supervisors also conducted inspections:
- the National Bank of Poland – 497 inspections,
- the Polish Financial Supervision Authority – 19 inspections,
- Customs and Tax Offices – 35 inspections,
- Ministries, provincial governors and starostas – 13 inspections,
- National Cooperative Savings and Loan Fund – 4 inspections,
- Presidents of the Courts of Appeals – 54 visits.
It is significant that in 2023 the GIIF has not received any notification of the imposition of specific restrictive measures by obliged institutions – freezing or withholding assets. Last year, for the first time, the GIIF placed two individuals on the national sanctions list. as explained in the body of Announcement No. 66 available here:
An important activity in 2023 was the development of the second national risk assessment.
Lessons for obliged institutions
It is clear from the figures presented that AML/CFT supervision of the market is being carried out actively and in proportion to its development. The increasing professionalization of obliged institutions, as well as the increasing regulatory requirements, translate into a higher number of notifications and actions taken. The data contained in the report, as well as in the National Assessment of Money Laundering and Terrorist Financing Risks, published late last year, can make an important contribution to building systems for countering money laundering and terrorist financing risks in companies and organizations that are obliged institutions.
DKP Legal
