Announcement No. 105 was recently published on the website of the Ministry of Finance, informing that pursuant to Resolution No. 75 of the Council of Ministers of 26 February 2026 (Monitor Polski of 2026, item 247), the Strategy for Combating Money Laundering and Terrorism Financing.
This Strategy was developed by the General Inspector of Financial Information (GIIF) and constitutes an action plan to reduce the risks associated with money laundering and terrorism financing by minimizing previously defined risks and implementing the recommendations developed as part of the National Risk Assessment (KOR). Implementation of the priorities set out in the Strategy will take at least two years, with the planned actions expected to be completed in 2027.
What is the National Strategy for Combating Money Laundering and Terrorism Financing (KSPPPFT)?
The National System for Combating Money Laundering and Terrorism Financing (KSPPPFT) is a mechanism that brings together public institutions and private sector entities to detect and combat money laundering and terrorism financing. The mechanism's operation is based on a risk-based approach and collaboration between institutions responsible for the country's financial security.
The General Inspector of Financial Information (GIFI) is the central entity of the mechanism, primarily serving as an analytical center, collecting, analyzing, and then forwarding information on suspicious financial transactions to the appropriate authorities. Data collected by GIFI comes primarily from obligated institutions (banks, financial institutions, national payment institutions), which monitor and identify transactions that may indicate a risk of crime.
If an institution has reasonable suspicion, the information is forwarded to the General Inspectorate of Financial Information (GIFI), which then analyzes it. If the analysis confirms a risk of a crime being committed, the materials are forwarded to the appropriate law enforcement authorities for initiation of proceedings.
KSPPFT development priorities
The results of the latest National Money Laundering and Terrorism Financing Risk Assessment (KOR) showed that the following threats arise from:
- the current geopolitical situation (war in Ukraine, hybrid activities of Russia and Belarus, influx of refugees and migrants);
- changes in the financial market ("investing funds by individuals and business entities in allegedly highly profitable currency investments on the Forex market or purchasing closed-end investment fund certificates (FIZ) , which can also be used in tax avoidance schemes. The risk is also increased by the development of new and the scale of use and acceptance of already known cryptocurrencies, online currency exchange offices and payment institutions , where there may be cases of operations on accounts opened on the basis of fictitious documents or through so-called "dummies". Crowdfunding activities and the increased activity of non-residents in Poland in recent years increase the level of threat present in the system.")
- transactions related to sectors of the economy that are particularly susceptible to irregularities (e.g. trade in works of art, energy certificates, provision of IT services).
This necessitates modification of the KSPPPFT by adapting areas with increased crime risk to appropriate security standards. The strategy's foundation is solutions aimed at achieving the following priorities:
- Strengthening and increasing the effectiveness of operations and analyses conducted by GIIF and cooperating units in accordance with the principles of a risk-based approach.
- Strengthening structures dedicated to counteracting money laundering and terrorism financing in obligated institutions by counteracting identified risks and providing expert support.
- Harmonization and development of principles of supervision and control over obligated institutions.
- Review and optimization of access, mode, scope and quality of information exchange.
- Implementation of an effective system of training and exchange of experiences in the area of counteracting money laundering and terrorism financing.
- Modification of national law in connection with the identification of new risks and local needs in the area of counteracting money laundering and terrorism financing and the need to harmonize national law with European Union law and other international standards.
This alert is for informational purposes only and does not constitute legal advice.
Legal status as of March 19, 2026.
author:
