The UKNF publishes new guidelines: How to develop an AML/CFT procedure?

The Office of the Polish Financial Supervision Authority (UKNF) has published a position on the processes carried out by obliged entities in the area of anti-money laundering and counter-terrorist financing (AML/CFT) that should be regulated in internal procedures.

The document serves as a comprehensive guide to the minimum requirements that must be met by the internal AML/CFT regulations of entities supervised by the KNF.

AML/CFT under the supervision of the UKNF: 11 mandatory procedural requirements

The UKNF position discusses in detail eleven key areas that an AML/CFT procedure should cover, including the organisation of the AML/CFT process and the appointment of an AMLRO.

It also addresses institutional risk assessment, client classification, the application of financial security measures, handling of PEPs, correspondent relationships, and reporting obligations to the GIIF (General Inspector of Financial Information).

The UKNF emphasises that the procedure should constitute a coherent and mutually complementary set of elements, the absence of even one of them may render the procedure impracticable.

AML/CFT customer due diligence: The Polish Financial Supervision Authority sets specific deadlines

An important element of the position is the indication of client review frequencies deemed acceptable by the UKNF: annually for high-risk clients, every 3 years for normal-risk clients, and every 5 years for low-risk clients. 

At the same time, the UKNF draws attention to the upcoming requirements under Regulation (EU) 2024/1624, according to which the period between client data updates may not exceed one year for higher-risk clients and five years for all others.

The growing scale of AML/CFT non-compliance and new expectations of the UKNF

Particularly telling are the data from KNF inspection statistics. The share of irregularities relating to internal AML/CFT procedures has been steadily increasing, from 7.54% in 2021 to as much as 19.39% in 2024. 

The UKNF expects supervised entities to promptly analyse the compliance of their procedures with the requirements of the position and to take remedial action. Implementation of the position will be verified as part of KNF’s supervisory and analytical activities, and its requirements will also apply to entities seeking licences or entry into registers maintained by the KNF.

Additionally, the UKNF position was consulted with the General Inspector of Financial Information.

Our Firm’s Support

We provide comprehensive consulting services regarding compliance analysis and the adaptation of AML/CFT procedures to the current regulatory requirements of the Polish Financial Supervision Authority (KNF).

Our support includes auditing internal regulations, developing and implementing necessary procedural changes, as well as preparing your organization for inspections and analytical activities conducted by the Polish Financial Supervision Authority (KNF). Contact us to discuss the scope of support tailored to the specific needs of your organization.