Anti-Money Laundering and Counter-Terrorism Financing (AML-CFT)

We have the competences and experience that allow us to provide AML/CFT consultancy in the broadest sense. We assist from the internal audit stage, through the implementation of solutions tailored to the client's business profile, to contacts with the General Inspectorate of Financial Information (GIIF) and law enforcement agencies - Bartłomiej Pietruszka

The criminal law team has experience in the development and implementation of AML/CFT procedures for clients: obliged institutions within the meaning of the AML/CFT Act, including the development of draft risk assessments for these institutions.

We offer our clients support in the verification of their status as an obliged institution, as well as in the development and implementation of the procedure, and in the subsequent consultancy related to its functioning. Our experience also allows us to provide advice in the context of control procedures, e.g. from the General Inspector of Financial Information, as well as in the implementation of post-control recommendations.

Bartłomiej Pietruszka

partner, advocate, approved AML officer

Bartłomiej Ambrożek

advocate

Michał Busz

advocate trainee

Our clients include:

Entities which, in connection with their activities, are obliged institutions within the meaning of the AML Act, in particular:

  • entities in the financial sector,
  • lending institutions,
  • insurance intermediaries, credit intermediaries
  • real estate agencies,
  • providers of tax advice, accounting, business support,
  • foundations
  • associations.

Zakres usług:

  • Verification of the client’s status with regard to the existence of an obligation to implement AML/CFT.
  • Analysis of AML/CFT risks and recommendation of appropriate security measures.
  • Development and implementation of adequate procedures in the obliged institution.
  • Training for employees tailored to the risk profile of the company, providing the client with the knowledge and information to enable it to properly fulfil its obligations in relation to the reporting of suspected money laundering, terrorist financing or other offences, including fiscal offences.
  • Proactive AML/CFT advice – responding to ongoing enquiries, providing opinions on planned activities;
  • Crisis management, particularly in the event of threats of reputational damage;
  • Client representation and cooperation with law enforcement authorities and the GIIF.

Completed activities:

 

  • Advising a financial services company on verification of its status as an obliged entity, assessment of the company’s obligations under the AML/CFT Act and implementation of an internal AML/CFT procedure;
  • Verification of the real estate company’s transactions in terms of their being subject to AML/CFT procedures, support in conducting risk assessment and communication with the GIIF and law enforcement authorities;
  • preparation and implementation of the AML/CFT procedure in the real estate and hotel company, support in the preparation of the risk assessment and conduct of training for employees;
  • Preparation of a legal opinion on the qualification of an entity in the catering industry as an obliged institution and the existence of obligations under the AML Act;