- Funding Programme
- Year
- 2022
Strengthening the risk assessment mechanisms and the AML-CFT (Anti-Money Laundering-Counter-Financing of Terrorism) strategic analysis function of the Polish Financial Intelligence Unit
The commission assists Polish authorities to enhance the fight against money laundering and terrorist financing through strengthening the methodology for the National and the Sectorial Risk Assessment (NRA and SRA), the implementation of their findings, as well as through the reinforcement of the strategic analysis function. The project started in June 2022 and will conclude in September 2024.
Context
The European Union has constantly improved its regulatory framework to fight money laundering and terrorist financing and to align it with the recommendations from the Financial Action Task Force (FATF), the international standard setting body on anti-money laundering and countering the financing of terrorism. The Directive on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing (AMLD) has been amended four times, notably extending the scope of crimes, professions and activities covered. In addition, the European Commission has proposed in July 2021 an ambitious legislative package with three objectives:
- to strengthen EU anti-money-laundering rules and enhance their clarity while ensuring consistency with international standards and other EU legislation;
- to improve the effectiveness and consistency of anti-money-laundering supervision;
- to increase the level of cooperation and exchange of information among Financial Intelligence Units (FIUs).”
According to the first Money Laundering and Terrorist Financing (ML/TF) National Risk Assessment (NRA) conducted in 2019, Poland is exposed to medium money laundering and terrorism financing risks.
The 2021 MONEYVAL’s Mutual Evaluation Report (MER) on Poland, has concluded that the NRA should be developed in order to improve its contribution to the identification and assessment of ML/TF risks in the country. Moreover, it identified a need to introduce mechanisms for cooperation and coordination of issues related to the AML/CFT at an operative level. As one of the areas for further improvement, Poland should conduct sectorial risk assessment of virtual assets service providers (VASPs), in order to align more closely with the FATF Recommendation 15.
Support delivered
The project provides the Polish authorities with support in the following areas addressing MONEYVAL findings set out above :
- Review of the methodology for future Money Laundering/Terrorist Financing (ML/TF) National Risk Assessments
- Mapping of data available for the implementation of the NRA
- Assistance in updating the ML/TF National Risk Assessment and in conducting sectoral ML/TF risk assessment of VASPs to complement the NRA
- Review of the FIU’s strategic analysis function and development of a strategic analysis manual
- Review of current procedures and framework for exchange of information between the FIU and other AML/CFT competent authorities
- Provision of recommendations for the implementation of electronic suspicious activity reporting (eSAR) within the domestic financial regulatory and supervisory system.
This support is delivered in form of workshops, peer-to-peer exchanges, expert advice, reports and manuals.
Expected results
The expected long-term effect of this project is an enhanced AML/CFT regime in Poland in line with FATF recommendations and EU AML legislation that allows for an effective fight against financial crime.
The Outcomes of the Project are:
Outcome 1 Updated ML/FT National Risk Assessment
Outcome 2 Risk-based approach supervision of virtual assets introduced
Outcome 3 Strengthened capacities of the FIU to produce strategic analysis reports
Outcome 4 Enhanced cooperation among FIU, Law Enforcement Agencies and supervisors