RISK ASSESSMENT (ML/FT) OF THE OBLIGED ENTITIES – COMMENTS IN THE CONTEXT OF ART. 27 OF THE AML ACT

Abstract

The AML Act imposes on obliged entities the duty to identify and asses the risk of money laundering and terrorist financing (ML/FT) in relation to the operation of such entities. This Article offers an analysis of the provisions of the AML Act relating to that obligation, especially Art. 27 of the AML Act. The author indicates the subjective and objective scope of the obligation and its European origin. This study takes into consideration also the Position of the Office of the Polish Financial Supervision Authority of 15 April 2020 on risk assessment in obliged entities (collection of good practices in the area of implementation, by an obliged entity subject to supervision of the Polish Financial Supervision Authority, of appropriate risk assessment relating to the obliged entity referred to in Art. 27(1) of the AML Act) as an essential document for certain obliged entities.