Implementation Of AMLD V – New KYC Procedures And Registers

The recent implementation of the AML V Directive to the Polish Act on Counteracting Money Laundering and Terrorist Financing will have a significant impact on business and the approach taken by state bodies to certain transactions. The main changes are as follows:

1. List of obliged institutions

The list of institutions obliged to report certain information to relevant authorities has been extended to:

1.1 entrepreneurs providing services, including tax, customs advisory, e.g. keeping tax books, preparing tax forms. It is worth noting that they do not have to be licensed as tax advisors or auditors to be classified as an obliged institution. Tax law enables third parties to act as attorneys-in-fact. Such attorneys-in-fact may as well be deemed as obliged institutions;