AML Policy

Internal policy on anti-money laundering

In order to reduce the phenomenon of money laundering, the Website Administrator takes measures to ensure the security of transactions and compliance with applicable law. The administrator of the website was designated as an institution in force under the law of 1 March 2018 on the prevention of money laundering and financing of terrorism, hereinafter referred to as the Act. The Polish Law constitutes the implementation of Directive (EU) 2015/849 of the European Parliament and of the Council of 20 May 2015 on the prevention of the use of the financial system for money laundering or terrorist financing, and the Financial Action Task Force (FATF) recommendations on the aforementioned issues. The administrator of the site, as an obliged institution, is obliged to fulfill the obligations under the provisions of the Act. To this end, it implements a domestic policy on anti-money laundering, in particular, including:

  1. the implementation of an internal procedure laying down the rules of conduct of the site in order to ensure compliance with the obligations set out in the Act. The procedure is an inside document and the Administrator undertakes to exercise diligence by controlling the proper application of the procedure by the persons employed by the company;
  2. ensuring those carrying out anti-money laundering duties participate in relevant training programmes;
  3. identification and assessment of the risks associated with the possibility of using the site's activity for money laundering purposes, updated no less often than every 2 years;
  4. the use of financial security measures, consisting in particular in identifying Users and beneficiaries and verifying their identities, ongoing monitoring of transactions, keeping a register of transactions, as part of an agreement concluded between the User and the Service at the time of registration of the User Account and acceptance of the Terms and Conditions of the Service. The conditions for the application of financial security measures are set out in detail in §7 of the Terms and Conditions. Detailed conditions for the identification and verification of the identity of Users are set out in §4 of the Terms and Conditions;
  5. storage of information obtained under the application of financial security measures for a period of 5 years, from the first day of the year following the year of termination of the agreement concluded between the User and the Service. Detailed conditions for the storage of personal data are set out in the Website Privacy Policy.
  6. providing information to the General Inspector of Financial Information (GIIF) regarding circumstances likely to indicate suspicion of a criminal offense of money laundering or terrorist financing and a reasonable suspicion that a particular transaction or property resources may have a connection to such a crime. In addition, the Website Administrator is obliged to provide information about the accepted payment or cash payment equivalent or higher than EUR 15.000;
  7. withholding transactions in accordance with the provisions of the Act and the guidelines received from the GIIF, on a reasonable suspicion of committing an offense of money laundering or terrorist financing;
  8. direct cooperation with law enforcement offices and authorities, in particular the prosecution, in the event of reasonable suspicion that a particular transaction or specific property values may be related to a crime other than money laundering or terrorist financing. Any action taken to carry out these duties shall be in accordance with generally accepted good practices and applicable law, in particular concerning the protection of personal data. The administrator of the site is subject to the control of the GIIF or the customs and tax office in respect of fulfilling its duties as a compulsory institution. The administrator of reserves the right to refuse to carry out transactions with entities on the sanction lists or suspected of committing a criminal offense. Therefore, any information on a suspicion of non-compliance of the Service activity or its Users with applicable law should be passed immediately to the Administrator at [email protected] Detailed conditions for the operation of the Service and the execution of transactions and their security are laid down in the Terms and Conditions. This internal policy shall apply from 05.07.2019.