Abstract

The Act on Counteracting Money Laundering and Financing of Terrorism imposes upon obligated institutions (including banks) the obligation, crucial in relation to the other requirements specified in the Act in question, to implement appropriate procedures enabling the identification of clients or their actual beneficiaries as Politically Exposed Persons (PEP). The identification of a client as a PEP status person means that increased financial security measures need to be applied to him/her and his/her family members and close associates on account of potentially greater risk of money laundering, financing of terrorism or corruption. Consequently, in the author’s view and in light of the provisions of the Act on counteracting money laundering, a Sejm Deputy and his/her immediate family members may be obligated by the bank to submit a declaration on the source of the client’s property and assets at the client’s disposal as part of business relationships or transactions.

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