Audit and alignment of procedures and policies with revised AML regulations
Amendments to the aml procedure implementation of changes in the aml and cft procedure.
The Polish legislator, apart from the changes resulting from the amendment of the EU law, is very creative. Thus, proper functioning on the domestic market requires constant adaptation to changes. It is also important to adapt processes and procedures to the needs and current activities of a given company in order to operate properly and in accordance with the current state of the law.
We carried out a project involving a comprehensive audit and adjustment of the Company’s existing procedures and policies to the requirements of the amended legislation introduced by the Act of 30 March 2021 on amending the law on anti-money laundering and terrorist financing (AML), which implemented into our legal order the provisions of Directive of the European Parliament and of the Council (EU) 2018/843 of 30 May 2018 amending Directive (EU) 2015/849 on the prevention of the use of the financial system for the purpose of money laundering or terrorist financing and amending Directives 2009/138/EC and 2013/36/EU), the so-called AML V Directive.
In addition to adapting the already existing procedures to the changing legal situation, the challenge was to simultaneously implement the rules and assess the risks associated with the Company’s new loan product aimed at customers from across our country’s eastern border.
The advice in the present case included not only the creation of audit documentation, but also:
- adapting existing documentation to the requirements related to the AML Directive V;
- creation of new document templates necessary for proper operation;
- and the implementation of revised AML and Counter Financing of Terrorism procedures.
See also:
For our client, during regular legal advice, we developed documentation for an anti-money laundering and counter-terrorist financing system (hereinafter “AML/TF system”, maximum penalty for violating those laws may result in financial penalty up to 5 million EUR).
As part of our ongoing cooperation with a client, a small payment institution, providing payment services including issuing of credit cards and providing payment credit to consumers, we represent the client in the proceedings for obtaining a license to provide payment services as a national payment institution.