AML training in EU – new guidelines in Poland

On February 13, 2025, the General Inspector of Financial Information (GIIF), the Office of the Polish Financial Supervision Authority (UKNF), and the National Bank of Poland (NBP) issued Joint Announcement No. 92 regarding the training obligation under the Anti-Money Laundering and Terrorist Financing Law. The announcement’s objective is to inform entrepreneurs about the requirements to follow when conducting AML/CFT training, as well as the repercussions of neglect in this area. The GIIF’s June 19, 2018 announcement for the e-learning course “Anti-Money Laundering and Countering the Financing of Terrorism” and preceding announcements have expired.

Who does the training duty apply to?

Article 52 of the AML Law requires obligated institutions to ensure staff participation in training programs. This applies primarily to payment service providers, banks, investment firms, currency exchange offices, and virtual currency entities (VASP and CASP).
This obligation includes not only employees under employment contracts, but also individuals working under civil law contracts, agents, and acting on behalf of the obliged institution. Board members in charge of anti-money laundering must also attend such training.
Employees who received AML/CFT training at a prior institution may be considered legitimate at their present employer with further training, depending on the nature, kind, and size of the organization.
When outsourcing financial security measures, it is important to include training obligations in the contract between the institution and the service provider.

Training programs.

The GIIF recommends training programs that prioritize practical aspects of duties. Articles 74(1), 86(1), and 89(1) of the AML Law require efficient and compliant performance of tasks, including recognizing and reporting relevant instances.
GIIF can be used to report suspected money laundering or terrorist financing, as well as suspicions that a transaction or assets may be related to these crimes. The competent public prosecutor can also be contacted if there is a reasonable suspicion that the property values in a transaction or account stem from a non-money crime.

Method of Training Delivery
To meet the training obligation, individuals undertaking AML/CFT activities can attend both internal and external training courses provided by their institution. Training sessions can be held both in-house and online. Prior to engaging in AML/CFT-related operations, individuals performing these obligations at obligated institutions must undergo the necessary training. Obligated institutions must demonstrate to controlling authorities that AML/CFT obligations were assigned to an employee only after they had completed the necessary training.
Inadequate documentation may be considered a failure to comply with the responsibilities outlined in Article 52 of the AML Law, potentially leading in an administrative penalty under Article 147(9) of the Law. The documentation should include details about the training program, the date of the session, and a list of participants.

Negligence has consequences.
Noncompliance with training responsibilities may result in serious legal and financial consequences for the organization. Assigning AML/CFT tasks to inexperienced staff is a violation of the law and may result in administrative penalties. Furthermore, insufficient training increases the likelihood of unintended involvement in money laundering or terrorist financing.
Please visit the Ministry of Finance’s official website for more information on the training obligation, as well as the entire text of Announcement No. 92.