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Poland’s AML Progress: Enhanced Measures and Positive Ratings

Poland has made significant strides in combating money laundering and terrorist financing (AML/CFT), according to the latest follow-up report by the Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism (MONEYVAL). This progress reflects the country’s growing commitment to aligning with international standards set by the Financial Action Task Force (FATF).

Poland’s AML Strategy Strengthens Compliance

Poland’s dedication to improving its anti-money laundering and counter-terrorist financing measures has been evident since the publication of its first enhanced follow-up report in 2023. The latest MONEYVAL assessment focuses on key FATF Recommendations, specifically Recommendations 1 (risk assessment and applying a risk-based approach), 15 (addressing new technologies), 26 (regulation of financial institutions), and 33 (statistical frameworks).

The findings underscore Poland’s proactive approach, particularly in:

Conducting a comprehensive national risk assessment.
Allocating additional resources to critical AML/CFT institutions, such as the Military Police, Financial Intelligence Unit (FIU), and the Financial Supervision Authority (UKNF).
Improving the granularity and management of money laundering and terrorist financing (ML/TF) statistics.

Notably, Poland achieved upgraded compliance ratings for Recommendations 1 and 33, reflecting the country’s focus on addressing earlier shortcomings.

Key Enhancements in AML/CFT Measures

1. Upgraded National Risk Assessment and Strategy Implementation

In line with FATF’s Recommendation 1, Poland developed and published an updated national risk assessment, identifying vulnerabilities and allocating resources to address them. This effort forms part of a broader strategy, backed by investments in financial, technical, and human resources.

To ensure these initiatives have tangible impacts, Poland fortified its Military Police, UKNF, and FIU with enhanced tools and training. These steps were crucial in addressing gaps highlighted in earlier evaluations, leading to an improved rating for Recommendation 1 from partially compliant to largely compliant.

2. Enhanced Data Collection and Statistical Management

Poland’s progress in statistical reporting has been another key area of improvement. For FATF Recommendation 33, MONEYVAL noted advancements in collecting and analyzing data on:

Suspicious activity reports (SARs).
Seized assets related to money laundering cases.
Requests for mutual legal assistance (MLA).
Extraditions tied to financial crimes.

This comprehensive approach not only meets FATF standards but also enhances the country’s ability to monitor and respond to financial crime trends effectively.

3. Improvements in Regulation and Oversight of Financial Institutions

While strides have been made in oversight, Poland’s compliance with FATF Recommendation 26 remains rated as partially compliant. Key developments include:

New registration requirements for non-bank lenders.
Ad-hoc ex-post suitability assessments for management and supervisory boards of banks.
Enhanced risk-rating methodologies applied by UKNF and the National Bank of Poland.

However, MONEYVAL emphasized the need for more robust mechanisms to fully meet the standards of Recommendation 26.

4. Addressing Emerging Technologies and Virtual Assets

FATF Recommendation 15, which addresses risks from new technologies and virtual assets, remains a challenging area for Poland. Despite providing guidance and feedback to virtual asset service providers (VASPs), gaps persist. Enhanced measures are necessary to ensure robust monitoring and regulatory compliance in this fast-evolving sector.

Room for Improvement: Key Recommendations

While Poland has achieved compliance or significant progress in 26 out of 40 FATF Recommendations, MONEYVAL’s report highlights areas requiring further action:

Virtual Assets Oversight: Developing stronger regulatory frameworks to address risks tied to cryptocurrencies and blockchain technology.
Institutional Coordination: Improving inter-agency cooperation to ensure consistent enforcement of AML/CFT measures.
Public-Private Collaboration: Encouraging collaboration between government institutions and private entities, particularly financial institutions and VASPs, to strengthen compliance.

Poland’s partially compliant ratings for Recommendations 15 and 26 underscore the need for additional reforms to achieve higher standards of technical compliance.

Conclusion: A Promising Path Forward

Poland’s progress in strengthening its AML/CFT framework reflects a clear commitment to international standards and domestic security. Upgrades in compliance for Recommendations 1 and 33 demonstrate the country’s ability to respond effectively to MONEYVAL’s findings and implement necessary reforms.

However, with 14 Recommendations still rated as partially compliant, Poland faces a critical juncture. Continued efforts to address gaps in technology oversight, financial regulation, and statistical analysis will be essential for achieving full alignment with FATF standards.

MONEYVAL has called on Poland to report back by December 2025, providing an opportunity for further improvements and demonstrating the country’s dedication to mitigating money laundering and terrorist financing risks.