Outsourcing of AML officer functions

/ Rafał Kufieta

Outsourcing of AML officer functions

The Act on Counteracting Money Laundering and Terrorist Financing imposes a number of obligations on obliged institutions. New regulations cause problems for entrepreneurs – it is necessary to develop new procedures, adapt the process to the requirements of the Act, train and raise awareness among employees. Can these services be outsourced to a third party?

The legislator provided for such a possibility. As a law firm employing AML specialists, we provide services in this area. Outsourcing of financial security services is a convenient solution for entrepreneurs – it ensures high quality of implemented solutions and allows for effective implementation of AML/CFT procedures.


What services can be outsourced? The legislator allows the possibility of ordering the application of financial security measures consisting in:

  1. customer identification and verification,
  2. the identification of the beneficial owner,
  3. the evaluation of economic relations.


In addition, our Law Office helps to develop AML/CFT procedures tailored to the scope of your company’s activities. A general AML procedure, an anonymous whistleblowing procedure or a risk assessment procedure are all documents that certainly need to be developed and implemented.


Each obligated institution must also conduct a risk assessment of its operations with respect to their use in money laundering and terrorist financing. This assessment must be documented. It is worth using the knowledge of the AML officer of our organization in the implementation of this solution.


One of the statutory obligations is also the training of employees – our trainers will prepare materials that will make your employees learn what money laundering and terrorist financing means in practice and what their obligations are. It is important that trainings are conducted regularly and in a way that ensures knowledge and high awareness of employees. This is because in the case of supervisory control, it is verified. Moreover, an effective AML/CFT system is characterised by knowledge and appropriate actions taken by employees. Training is a basic source of knowledge for your people.


The AML Act also imposes an obligation on institutions to report certain events to supervisory authorities, in this case the General Inspector of Financial Information (GIIF). If you have not done so  far, we can help and train the employees responsible for these processes in order to properly implement the statutory obligation.


In the case of an institution obliged to implement the AML/CFT obligations, the responsibility for the implementation of the duties of the AML/CFT lies with the highest management, so it is worth protecting against irregularities in this area and using the assistance of experienced professionals.


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