Krzysztof Teofilski – GC Powerlist
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Poland 2026

Information technology

Krzysztof Teofilski

Group head of legal and compliance | Match-Trade Technologies Group

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Poland 2026

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Krzysztof Teofilski

Group head of legal and compliance | Match-Trade Technologies Group

What are the key projects that you have been involved in over the past twelve months?

In recent months, the Match-Trade Technologies Group has grown significantly in terms of the range of services offered, the number of clients, and financial results.

The client base currently includes corporate entities from six continents. Services are provided globally, complementing the financial market, including the development of advanced trading systems for the capital market, the provision of Virtual Asset Exchange services, and acting as a market marker, prime broker, and liquidity provider.

From a legal perspective, the three most interesting projects handled over the past twelve months included the DORA compliance process for regulated investment firms and a IT company providing technology services to the financial sector; obtaining a Virtual Asset Exchange license; and expanding the liquidity offering for the growing market of prop trading companies, enabling the hedging of clients who have reached the funded stage with a given entity.

What are the key trends that in-house counsel should be monitoring in 2026?

In 2026, in-house counsel operating in the fintech sector – in particular within regulated investment firms, VASPs and IT service providers – should primarily focus on three closely interconnected areas. First, continued intensification and fragmentation of digital asset regulation will remain a defining feature of the regulatory landscape. Regulatory frameworks are moving decisively into the phase of practical application, with supervisory authorities increasingly assessing not merely the formal holding of licences, but the substantive effectiveness of operating models, governance arrangements and risk controls. For VASPs and regulated investment firms, this entails managing regulatory divergence between the EU, the UK, the United States and non-European jurisdictions, as well as closely monitoring evolving supervisory expectations in areas such as custody, market abuse, consumer protection and stablecoins. In-house counsel will be required to act as regulatory intermediaries between legal, business and technology functions, ensuring that products and services are designed and implemented in a manner that embeds regulatory compliance from the outset.

Secondly, AML/CFT obligations and the accountability of senior management for their effectiveness are expected to come under increased scrutiny, particularly in relation to VASPs and technology providers supporting financial services. The implementation of standards developed by the Financial Action Task Force, including the Travel Rule, is increasingly examined not only at the level of systems and controls, but also in terms of organisational decision-making, outsourcing arrangements and oversight of third-party providers. As a result, the role of the legal function is shifting from reactive incident management towards active involvement in the design of AML frameworks, contractual allocation of responsibilities with RegTech vendors and internal governance structures.

In-house counsel should anticipate heightened enforcement activity, increased administrative sanctions and a growing risk of personal liability for senior executives where deficiencies in financial crime controls are identified. Thirdly, the regulation and governance of artificial intelligence and advanced technologies will have an increasingly material impact on regulated activities, particularly where such technologies are deployed in KYC, AML, fraud detection and client assessment processes. The entry into force and operationalisation of instruments such as the EU AI Act will require in-house counsel to oversee not only regulatory compliance, but also issues relating to algorithmic transparency, bias mitigation, accountability for automated decision-making and the allocation of liability in relationships with AI model providers.

For IT providers servicing the financial sector, this will translate into enhanced contractual and compliance obligations, while for investment firms and VASPs it will necessitate the establishment of coherent technology governance frameworks that align financial regulation, data protection requirements and emerging technology law.

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