Expert series: AML/CFT policy
9 July 2025 • Autor: Kancelaria Brysiewicz Bokina i Wspólnicy
We would like to present an exceptional series of articles on Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) policies, created by Bartłomiej Pietruszka , advocate at law, and Miachal Busz, assistant advocate at law – experts in the White-collar Crime practice at Brysiewicz, Bokina and Partners Law Firm. The AML/CFT series is the quintessence of legal knowledge for entrepreneurs operating in the so-called Obligated Institutions.
Learn about the obligations and requirements that must be met in order to legally comply with the
- AML/CFT Policy
What you will learn from the AML Cycle?
- What is the AML/CFT Policy
- Definitions of terms related to money laundering and combating the financing of terrorism
- What are Obligated Institutions and their basic catalogue What
- obligations must be met by Obligated Institutions
- What
- are the
- risks of non-compliance by IOs
- What are Financial Security Measures and their catalogue and
much more….
Each article in the series is accompanied by a handy pdf in the form of a filpbook, which contains a powerful dose of knowledge given in an accessible, condensed form.
And if you have any further questions, please feel free to contact Bartłomiej Pietruszka: bartlomiej.pietruszka@bbs-
Część 1.
As a business, do I need to put in place an AML/CFT policy?
- What is the AML/CFT Law
- what additional obligations it imposes on Entrepreneurs
- which regulations should be implemented in the organisation as part of the AML / CFT Policy
Część 2.
AML/CFT policy in Obligated Institutions
- how to establish an internal structure responsible for AML
- what are Financial Security Measures.
- How to implement and comply with them
- whatan internal AML procedure looks like how
- to cooperate with state authorities such as the GIIF or the Public Prosecutor’s Office
Część 3.
AML/CFT Policy – Financial Security Measures
- Are FSCs necessary to effectively counter money laundering (AML)?
- Which ones should be introduced in a particular company?
- What is the catalogue of FMLs?
- Who must apply them and when?
- What are the prerequisites for their application
Część 4.
AML/CFT policy – Politically Exposed Person (PEP) and the increased level of risk
- Why Obligated Institutions (OIs) must apply enhanced financial security measures for PEPs and associated persons.
- What is the difference between a foreign PEP and a domestic PEP?
- Who are the persons associated with PEPs and what procedures are required for these persons?
- Why is the verification of PEPs so important
- .
Część 5.
AML/CFT policy – How to perform a risk assessment effectively?
- Why does a risk assessment cover a financial institution as well as individual transactions?
- What factors should be taken into account in order to maximise the effectiveness of the FWAs undertaken?
- What key variables to take into account?
- What tools can help you assess risk
?
Część 6.
AML/CFT policy – How to perform a risk assessment effectively?
- What is a risk assessment in the context of AML/CFT?
- What are the main factors taken into account when conducting a risk assessment?
- Why is an AML/CFT policy update important, especially for new obligated institutions such as pawnshops?
Część 7.
AML/CFT Policy – How to effectively perform a risk assessment?
- What administrative penalties are provided for in the AML/CFT Act?
- What determines the selection and amount of the administrative penalty?
- Who can impose an administrative penalty on a company
?
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Część 8.
AML/CFT policy – Criminal liability for breach of AML/CFT procedures
- What are the most common types of offences related to violations of AML/CFT procedures?
- Who may be held criminally liable?
- What penalties have been provided for offences of violating AML/CFT procedures?
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