AML Outsourcing

APOG provides Compliance Officers and AML Reporting Specialists (MLROs) to ensure continuous, effective control systems (Continuous Customer Due Diligence, Quality Monitoring and Testing)), channels for disclosure of information to state administration bodies and prosecutor's offices, including notifications of transactions above threshold and suspicious transactions (SARs), documentation and training in the field of anti-money laundering.

We specialize in implementing, reviewing, streamlining, and testing the quality of AML programs and Know-Your-Customer (KYC) verification tools, ensuring that the delivered work meets not only quality standards, but also the requirements of efficient and effective processing.

As part of our Know-Your-Transaction (KYT) services, we assess and monitor transactions, their amounts and frequency, as well as the parties involved, in order to document due diligence and increase the financial security of the company.

Outsourcing AML

AML outsourcing is a convenient solution for the entrepreneur. You do not have to employ several specialists who will monitor the course of the transaction and check the credibility of customers and contractors. Our company deals with the ongoing control of compliance with AML regulations, at the same time not requiring the creation of a new position in the company for the person responsible for this issue. Cooperation is carried out within the scope agreed with the client – most often we are responsible for implementing, improving and testing the quality of procedures.

Suspicious Transaction Reporting

The scope of our services includes, reporting suspicious transactions. Polish and European law does not provide a detailed definition of such an operation. Therefore, the entrepreneur must determine on his own whether a given transaction carries a risk related to the Anti-Money Laundering and Countering the Financing of Terrorism Act. We relieve business owners of issues related to the analysis of each operation.

Article 86(1) of the Anti-Money Laundering and Countering the Financing of Terrorism Act stipulates that the institution is obliged to notify the GIIF of suspicious transactions each time. There must be a reasonable suspicion that the operation may be related to illegal activity.

When can a transaction be considered suspicious? There is no clear definition of this practice, but it is usually referred to as an operation carried out in connection with a crime committed. Such a transaction is often also referred to as doubtful, unusual, unclear or extraordinary. Overall, this is a very different action from the previous one.

Reporting of above-threshold transactions is required by applicable regulations. A given institution should not only report such an operation to the GIIF, but also suspend it, e.g. by temporarily freezing funds. Currently, reporting suspicious transactions is possible online – using a special online system.

Penalties for failing to report suspicious transactions

Failure to report a suspicious transaction has a number of serious consequences. Most often, these are high financial penalties – they can amount to several hundred thousand zlotys, depending on the size of the company and the scale of the transaction. Polish law also provides for criminal sanctions.

It happens that the trader has doubts about the possibility of classifying a given transaction as suspicious. Then our help turns out to be invaluable. We have extensive experience in the Polish and foreign markets. Our specialists have extensive expert knowledge in the field of AML regulations and know what situations can be described as suspicious transactions. They are quick to respond to events that may seem perfectly legitimate at first glance. Thanks to this, the trader can protect himself from the consequences of not reporting a transaction above the threshold.

Quality control of AML processes

We carry out constant quality control of AML processes. The implementation of this system is not enough. Later, it is necessary to monitor how the selected processes are going and to make any changes. Our company supervises the functioning of the company and indicates areas that require improvement or changes. We make sure that AML regulations are properly complied with and that the owner of the company does not expose the company to serious legal and financial consequences.

In many companies, we carry out ongoing activities in the field of counteracting money laundering and terrorist financing. We act as a specialist who analyzes all transactions and reports suspicious ones. Thanks to us, there is no need to hire a new employee to monitor compliance with the AML system. It's cheaper, more flexible and much safer. Our many years of experience allow us to efficiently provide services to companies from the banking and banking-related sectors.

KYC Procedure – Implementation and Monitoring

As part of our ongoing cooperation, we also monitor the course of the KYC procedure. We assess the credibility of a given client, which is very important in the case of entities such as:

• accounting offices,
• banks
• postal operators,
• insurance companies and intermediaries,
• investment funds,
• payment service companies.

The KYC procedure allows you to verify customers and contractors to ensure the security of transactions. Our goal is to make sure that the operations undertaken by the entity in question are lawful and will not use our client's resources for money laundering, terrorist financing or violating international and Polish laws.

Risks and KYC verification

KYC verification applies to risks such as money laundering, terrorist financing, VAT fraud, tax evasion, or the implementation or circumvention of international sanctions. Sometimes, a given transaction could involve these risks despite the lack of ill will on both sides. This is the case, m.in, in the case of sanctions – it happens that a given entrepreneur is not aware that the operation carried out could violate them. Therefore, KYC verification allows you to ensure greater security of transactions.

What parameters do we monitor?

Anti-money laundering and countering the financing of terrorism requires analysing many details related to the transaction. We determine why the customer needs your company's products or services and how they intend to use them. We also focus on the contractor's business and check that they are not involved in non-compliant relationships or transactions.

We also make sure of the legality of the source of money, the client's tax status and their legal situation. We collect FATCA and CRS statements and identity documents of interested parties. We also check who has the right to represent a given entity. We prepare full AML documentation and determine whether a given operation can be carried out in accordance with the regulations.

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