On 6 December 2023, a new National risk assessment for money laundering and terrorism financing was released by the General Inspector of Financial Information. This update follows the previous risk assessment issued in 2019.

This risk assessment is an extensive document presenting the functioning of financial and non-financial markets in Poland, analysing the phenomena of money laundering and terrorism financing. It holds particular significance for financial and non-financial institutions as it identifies risks associated with various products and transactions related to both money laundering and terrorism financing.

This new risk assessment covers multiple areas, including:

1. the Polish financial and non-financial market,
2. the phenomena of money laundering and terrorism financing,
3. systems combatting these threats,
4. specific risks associated with money laundering and terrorism financing,
5. risk assessment considering various aspects.

The Anti-Money Laundering Act allows institutions to consider the National risk assessment in their internal risk assessments, although it is not a mandatory requirement. While institutions have the choice to incorporate it or not, regulatory bodies recommend doing so, potentially leading to more frequent risk assessment updates than the mandated biennial updates according to legal regulations.

Hence, it’s crucial for financial and non-financial institutions such as banks, payment institutions, or accounting offices to analyse this new risk assessment and adjust their internal risk assessments accordingly. After conducting the analysis, updating the risk assessment and obtaining approval as per the existing procedures will be necessary.

You can access the content of the National Risk Assessment via this link: https://www.gov.pl/web/finanse/krajowa-ocena-ryzyka-prania-pieniedzy-oraz-finansowania-terroryzmu.