When can you be subject to AML checks as a company owner or board member in Poland?

If you are a shareholder, board member, or managing director of a company in Poland, you may be subject to Anti-Money Laundering (AML) verification.

Who is subject to AML checks?

Under Polish and EU AML regulations, AML checks apply to individuals who are considered beneficial owners or who hold senior management positions in a company. This includes:

• shareholders with direct or indirect ownership of more than 25% of shares or voting rights
• board members or managing directors who exercise control over the company
• individuals in senior positions when the actual beneficial owner cannot be clearly identified

When are AML checks triggered?

You may be subject to AML verification in the following situations:

• opening a bank account or financial relationship – banks and financial institutions are legally required to verify the identity of beneficial owners before establishing a business relationship.
• entering into a business relationship with an obligated institution – this includes law firms, notaries, accountants, real estate agents, and others subject to AML laws.
• company registration or changes in ownership – when registering a new company or updating the Central Register of Beneficial Owners (CRBR), your identity and role may be verified.
• Suspicious transaction monitoring – if a transaction realized i.a by your bank raises red flags (e.g., unusually high value, complex structure), AML checks may be initiated.
• Due Diligence by business partners – other companies may conduct AML checks as part of their internal compliance or risk management procedures.

What Does the Verification Involve?

AML verification typically includes:

• Identity and address verification
• Ownership structure analysis
• Source of funds or wealth checks
• Screening against sanctions and watchlists

Need help navigating AML compliance?

Our law firm provides expert guidance on identifying beneficial owners, preparing for AML checks, updating CRBR records and responding to inquiries