How is the GIIF's on-site control of AML/CTF institution carried out?
- Admin
- Aug 20, 2024
- 2 min read
The General Inspector of Financial Information (GIIF) plays a crucial role in ensuring compliance with anti-money laundering and counter-terrorist financing (AML/CTF) regulations in Poland. The GIIF conducts controls of institutions obligated to implement AML/CTF measures, mainly under the Polish AML Act. The process of control follows a procedure which consists of several stages:
Preparation Stage
The GIIF initiates the control process by selecting the institution to be controlled based on risk analysis and other relevant factors.
An controllers team is appointed, and a notification letter is sent to the controlled institution, informing of the upcoming control.
Preliminary Stage
The controllers team conducts a preliminary analysis of the institution's documentation, including internal AML/CTF procedures, risk assessments, and transaction records. This stage helps the controllers understand the institution's operations and identify potential areas of concern.
On-Site Inspection
The controllers conduct an on-site inspection at the institution's premises. During this stage, they review documentation, observe processes, and interview relevant personnel to assess the effectiveness of the institution's AML/CTF measures.
Controllers may also request additional information or documentation as needed.
Post-Inspection Stage
After the on-site inspection, the controllers team analyzes the collected data and prepares a draft control report. The draft report is shared with the controlled institution, allowing to provide explanations or clarifications.
Final Report and Recommendations
Based on the institution's response and any additional information provided, GIIF finalizes the control report. The report outlines the control findings, identifies any deficiencies or non-compliance issues, and provides recommendations for improvement.
If significant violations are found, GIIF may impose administrative sanctions or refer the case to law enforcement authorities.
Follow-Up and Monitoring
GIIF monitors the implementation of the recommendations provided in the control report. The controlled institution is required to take corrective actions and provide periodic updates on their progress.
GIIF may conduct follow-up controls to verify the effectiveness of the implemented measures.
Throughout the process of control, GIIF shall adhere to principles of transparency, objectivity, and confidentiality. The control’s aim is to identify potential risks, assess the adequacy of AML/CTF measures and ensure that institutions comply with relevant laws and regulations.
