Compliance and AML for bookkeeping companies in PL, part I.

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Compliance and AML for bookkeeping companies in PL, part I.

The area of ​​financial services is subject to many regulations, one of the most important is directive and anti-money laundering and supporting terrorism act . They introduce many obligations for entities identified as “Obliged institutions”, which are obliged to apply the above-mentioned provisions – Art. 2 clause 1 of the Act.

One of the most numerous groups of obliged entities, apart from foundations, money changers and broadly understood persons providing legal services, are entities & nbsp; operating in the field of bookkeeping services. It is worth noting, therefore, that not all accounting offices are obliged to implement the provisions of the act , but only those that provide the so-called full accounting. Therefore, entities that provide services only in the field of PKPiR or revenue records, and entities that run staff are excluded. & Nbsp;

So what should we start with the implementation of the so-called AML?

The first step is to designate a compliance officer to come from senior management. In small accounting offices, the natural consequence will be the self-appointment of the owner, while in larger accounting offices it will be a practice to appoint a person from the employed staff. & Nbsp;

Second, the obligated entity must conduct an ML / TF risk analysis (assessment) related to their activities, including risk factors related to:

  • clients,
  • countries or geographic areas
  • products,
  • services,
  • transactions,
  • their delivery channels.

It is important, however, that the risk assessment is to be proportional to the nature and size of the obligated institution . For larger organizations, a risk management guide in the form of a standard is recommended PN-ISO 31000: 2018-08 . The analysis can also use the information contained in the applicable National Risk Assessment published by the General Inspectorate of Financial Information. The assessment prepared in this way may be recorded in paper or electronic form and updated if necessary, but at least every 2 years. The risk analysis is a document on the basis of which the remaining required AML documentation should be created. & Nbsp;


CeCert offers the service certification of AML solutions , and the conformity assessment process itself is performed by experienced experts in this field .

Although the Act does not require the AML system certification, we highly recommend this service due to:

  • getting more numerous administrative sanctions – penalties , which are received by controlled entities,
  • penalties imposed not only for failure to implement, but also for failure to adjust the system to the realities of a given entity.

Independent assessment of the AML system allows for corrective actions before official control takes place.

For larger entities we propose a certification solution Compliance Management System according to ISO 37301 , which also covers AML and whistle-blowers & nbsp;

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