Joanna Werner
Reporting of suspicious transactions: Who, how and when
The EU’s Anti–Money Laundering Regulation changes the rules for reporting of suspicious transactions. In place of the three reporting channels now familiar to Polish obliged entities, with varying reporting deadlines, the AMLR introduces a single, unified track for reporting suspicions, with a duty to act promptly. The AMLR also requires obliged entities to refrain from carrying out reported transactions. Meanwhile, the AMLA, a new EU-level authority, is working to develop standard reporting forms, which should make it easier for obliged entities to perform their tasks.
Reporting of suspicious transactions under new rules
One of the fundamental duties of obliged entities under anti–money laundering regulations is to report suspicious transactions to the authorities. The current AML Act in Poland provides for three separate procedures in this regard, with differing grounds, addressees of notifications, and legal consequences for the obliged entity and for the transactions or assets. This multi-track model will change radically from 10 July 2027, when the EU’s AMLR begins to apply. In this article we examine selected changes step by step.
Remote onboarding of new customers: New rules starting in July 2027
A year might seem like a long time, but it’s not much for rebuilding processes for remote identification and verification of customers’ identity for anti–money-laundering purposes. In 2027, institutions will face two related reforms. First, the AMLR (Regulation (EU) 2024/1624) will begin to apply directly, along with the regulatory technical standards for due diligence of customers. Second, 2027 will be a key year for application of the changes under eIDAS 2.0 (Regulation (EU) 2024/1183), implementing the European Digital Identity Wallet (EUDIW). What will change for obliged entities?
Intragroup services: Is there any chance for exemption from AML obligations?
Shared-services centres functioning within a group may formally have the status of an “obliged entity” under anti money laundering and countering financing of terrorism regulations, even though the AML/CFT risk associated with their operation is minimal in practice. Is there any chance that the EU’s AMLR, which enters into force on 10 July 2027, can change this situation?
Poland is implementing the NPL Directive. What will change for market participants?
The Act on Credit Servicers and Credit Purchasers of 20 December 2024 was published in the Journal of Laws on 4 February 2025. It implements Directive (EU) 2021/2167 on credit servicers and credit purchasers, known as the NPL Directive.
