AML Outsourcing Services in Poland
We provide comprehensive Anti-Money Laundering (AML) support to Polish and international obliged institutions, covering the full range of operational AML processes.
About US
Why Choose Us for AML Outsourcing?
We support obliged institutions operating in Poland, including both domestic entities and international organizations active in the Polish market. We combine experience gained in the global financial sector with practical knowledge of local AML/CFT requirements.
Financial Sector Experience
Our team has gained experience at Goldman Sachs, HSBC, Interactive Brokers, as well as across the Polish financial market.
Knowledge of Polish Regulations
We have a strong understanding of local AML/CFT requirements and the operational realities faced by obliged institutions in Poland.
Support Tailored to Your Organization
We tailor the scope of our support to your business model, scale of operations, and risk profile.
What Our AML Outsourcing Services Include
We provide end-to-end operational support across key AML/CFT processes.
Client Onboarding
We manage the full client onboarding process, from collecting and verifying customer information to risk assessment and the final onboarding decision.
KYC and KYB
We perform KYC and KYB reviews for individuals and legal entities, including representatives and beneficial owners, in line with applicable AML/CFT requirements.
PEP and Sanctions Screening
We screen customers, beneficial owners, representatives, and other related parties against PEP and sanctions lists, as well as other relevant risk sources, and review potential matches.
AML Risk Assessment
We assess customer and business relationship risk to determine the appropriate risk classification and level of customer due diligence required.
Transaction Monitoring
We monitor customer activity, review transaction monitoring alerts, and identify transactions or behavioral patterns that require further investigation.
KYC Reviews and Updates
We conduct periodic KYC reviews and update customer information, documentation, and other AML/CFT-relevant data.
Alert Review and Investigation
We review AML alerts, document our findings, investigate potential risk indicators, and escalate cases that require further assessment or decision-making.
AML Reporting Support
We prepare case analyses, supporting documentation, and other materials required for internal escalation and AML/CFT reporting processes.
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How We Work
How the Engagement Works
We tailor the AML outsourcing model to your organization’s processes, operational scale, and specific needs – from the initial assessment through ongoing operational support.
We Get to Know Your Organization
We assess your business model, AML/CFT processes, case volumes, and areas where additional support is needed. This allows us to determine which activities we can effectively take over.
We Define the Scope of the Engagement
We agree on the processes to be outsourced, allocation of responsibilities, communication channels, and escalation procedures. The operating model is tailored to your organization’s internal procedures and working environment.
We Take Over Day-to-Day AML Operations
Our team performs the agreed AML/CFT activities, documents actions taken, and handles escalations in line with the established operating model. We also provide regular reporting and quality assurance.
Frequently Asked Questions
What Is AML (Anti-Money Laundering)?
AML stands for Anti-Money Laundering, which refers to measures designed to prevent money laundering.
The term itself breaks down as follows:
- Anti – prevention,
- Money – money,
- Laundering – laundering.
AML is a framework of policies, procedures, controls, and operational measures designed to prevent criminals from using legitimate financial and business systems to conceal the proceeds of crime. It includes, among other things, customer and beneficial owner identification and verification, risk assessment, transaction monitoring, PEP and sanctions screening, and the review of suspicious activity.
In Poland, AML obligations are implemented together with measures aimed at countering the financing of terrorism, commonly referred to as CFT.
What Is AML Outsourcing?
AML outsourcing involves assigning specific day-to-day AML/CFT activities to an external team. The team can operate in accordance with the organization’s internal procedures, risk methodology, and operating requirements, taking over operational work that would otherwise be performed in-house.
Under the Polish AML Act, certain AML activities may be entrusted to an external service provider, including the application of customer due diligence measures and the ongoing analysis and documentation of transactions, subject to the requirements set out in the Act.
Who Is AML/CFT Outsourcing For?
AML outsourcing is primarily intended for obliged institutions and other organizations operating in Poland that are subject to AML/CFT requirements. This includes, among others, entities in the banking, payments, investment, and insurance sectors, as well as businesses in other industries covered by the Polish AML Act.
AML outsourcing can be particularly valuable for organizations that need additional operational capacity, are handling a growing number of customers, or are establishing and scaling their operations in the Polish market.
Is AML Outsourcing Permitted Under Polish Law?
Yes. The Polish AML Act expressly allows certain AML activities to be entrusted to an individual, legal entity, or other organizational unit acting in the name and on behalf of an obliged institution.
Under the outsourcing model set out in Article 48 of the Act, the arrangement must be governed by a written agreement, and the service provider performing the outsourced activities is treated, for those purposes, as part of the obliged institution.
Does AML Outsourcing Relieve a Company of Its AML/CFT Responsibilities?
No. Outsourcing AML activities to an external service provider does not transfer regulatory responsibility from the obliged institution to the outsourcing provider. The organization remains responsible for ensuring that its AML/CFT obligations are properly fulfilled.
For this reason, the scope of the engagement, oversight arrangements, documentation requirements, and allocation of operational responsibilities should be clearly defined. The Polish AML Act expressly provides that outsourcing the application of customer due diligence measures does not relieve the obliged institution of responsibility for their proper application.
Does AML Outsourcing Relieve a Company of Its AML/CFT Responsibilities?
No. Outsourcing AML activities to an external service provider does not transfer regulatory responsibility from the obliged institution to the outsourcing provider. The organization remains responsible for ensuring that its AML/CFT obligations are properly fulfilled.
For this reason, the scope of the engagement, oversight arrangements, documentation requirements, and allocation of operational responsibilities should be clearly defined. The Polish AML Act expressly states that outsourcing the application of customer due diligence measures does not relieve the obliged institution of responsibility for their proper application.
Can You Outsource Only Selected AML Processes?
Yes. AML outsourcing can cover a single process, such as KYC/KYB, PEP and sanctions screening, periodic customer reviews, or alert analysis. The scope can be structured on a modular basis and expanded as the organization’s needs evolve.
Do You Need to Outsource Your Entire AML Function?
No. AML outsourcing does not have to mean transferring the entire AML/CFT function to an external team. You can outsource only selected operational activities while keeping other processes, oversight, and decision-making in-house.
When Does It Make Sense to Outsource AML?
AML outsourcing can be particularly useful when customer and transaction volumes are increasing, KYC or alert review backlogs are building up, internal teams are understaffed, a company is launching operations in Poland, or additional support is needed for more complex cases.
It can be used either as a long-term operating model or as temporary support for an internal AML team.
Can AML Outsourcing Help During Temporary Increases in Workload?
Yes. An external AML team can provide additional capacity during periods of increased onboarding activity, higher alert volumes, periodic review cycles, organizational changes, or temporary staff absences.
This allows the organization to scale its operational capacity without permanently expanding its internal team.
Can an External AML Team Work Directly in Our Systems?
Yes. The engagement can be structured so that the external AML team works directly within the client’s systems and operating environment, subject to appropriate access permissions and agreed security requirements.
This allows AML processes to be carried out using the same tools and systems the organization already uses in its day-to-day operations.
Can AML Outsourcing Be Performed in Line with Our Internal Procedures?
Yes. An external AML team can perform the outsourced activities in accordance with the client’s AML/CFT procedures, risk assessment methodology, documentation requirements, and agreed escalation framework.
This helps ensure consistency with the organization’s existing compliance framework.
Is AML Outsourcing Suitable for Foreign Companies Operating in Poland?
Yes. AML outsourcing can be particularly valuable for companies that are part of international groups and operate in Poland, where they are required to meet local AML/CFT obligations.
An external AML team can handle local operational processes while ensuring alignment with the standards and requirements applied across the wider group.
Can AML Outsourcing Be Aligned with Global Group Standards?
Yes. The operating model can combine requirements arising from global group standards with the procedures and obligations applicable to the Polish entity.
The Polish AML Act also includes requirements relating to group-wide AML/CFT procedures and the exchange of information within the group.
Can the Scope of AML Outsourcing Be Scaled Up or Down as Needed?
Yes. The scope of the engagement can be adjusted as customer volumes, transaction volumes, alert volumes, or project requirements change.
This can include expanding the size of the external team or the number of AML processes covered, as well as scaling support back once the period of increased demand has ended.
Can AML Outsourcing Be Used on a Temporary Basis for a Specific Project or Increased Workload?
Yes. AML outsourcing can be used on a temporary basis to support a specific project, clear backlogs, reorganize a process, implement changes, or handle a temporary increase in case volumes.
It does not require permanently transferring the process to an external team.
Can an External AML Team Help Clear KYC or Periodic Review Backlogs?
Yes. AML outsourcing can be used to address growing backlogs in client onboarding, KYC updates, periodic reviews, or alert analysis.
External resources can be assigned to a specific backlog and work through it in line with the client’s internal procedures.
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Let’s Talk About AML Outsourcing
Tell us briefly about your organization and the support you need. We’ll answer your questions, discuss the most suitable engagement model, and identify which day-to-day AML processes we can take over.
Get in Touch
office@amloutsourcing.pl