Article 50 of the Polish AML Act requires every obligated institution to keep a written internal procedure covering its AML and CFT obligations in full. This requirement is satisfied by the documents that best demonstrate how an institution actually operates including who its customers are, what it sells, where its risk sits, and how it is governed.

This suite of fifty-nine documents comes out of the curriculum behind Salwius & Lazareva's AML/CFT Training Programme. Each template is written for adaptation to your own operations, and each carries explanatory notes that name the statutory basis for its provisions and the supervisory expectation behind them.

It also includes the annex documentation an inspection expects to find on record, including the risk-assessment worksheets, the CDD records, the SAR escalation templates, as well as the training register that shows a programme actually being run.

Fifty-nine documents, in parallel English and Polish, across three layers:

The Core Procedure Framework (33 procedures)

• The master internal procedure your board adopts under Art. 50

• Institutional and customer risk methodology, built on the Six-Factor Matrix

• Standard, simplified and enhanced due diligence, with decision trees

• Beneficial ownership and politically exposed person controls

• The Hard Stop on incomplete due diligence

• Transaction monitoring and the suspicious-activity reporting chain to the GIIF

• Sanctions screening, the asset-freeze procedure, and freeze notification

• Role designations, the tipping-off prohibition, and five-year retention

• Staff training, self-audit, group procedure, and inspection response

• A dedicated GDPR interface reconciling AML duties with data-protection law

Sector-Specific Addenda (9 sectors)

• Accounting and bookkeeping firms

• Law firms and legal advisers

• Tax advisers

• Real estate intermediaries

• Notaries

• Corporate service providers and TCSPs

• Virtual asset service providers

• Art dealers

• Commercial real estate lessors

Operational Forms and Companion Tools (17 documents)

• Client Risk Assessment Worksheet (Six-Factor Matrix)

• Ultimate Beneficial Owner Identification and Verification Record

• Source of Funds / Source of Wealth checklist

• Internal SAR Escalation Memo

• PEP Identification and EDD Authorisation Record

• Hard Stop Decision Record

• Sanctions Screening Log and AML Training Register

• Annual AML Risk Assessment Review Record

• The two Know Your Customer questionnaires (corporate and individual)

• Plus the procedure-to-article cross-reference, the decision tree, the working-day calendar, the step-by-step adoption guide, and an annotated worked case

1. For the following obligated institutions across the range defined by the Polish AML Act:

• Accounting and bookkeeping firms

• Tax advisers

• Law firms and legal advisers

• Notaries

• Real-estate intermediaries and commercial lessors

• Corporate and trust service providers

• Currency exchange and virtual-asset service providers

• Art dealers and dealers in high-value goods

• Any other business handling qualifying cash transactions

These templates provide a statutory grade starting point, eliminating the blank page problem and the risk of omitting provisions.

2. For institutions requiring procedural documentation that reflects the current and updated statutory standard.

3. For compliance professionals (compliance officers, AMLROs, etc.) who are preparing for a thematic inspection and who need to verify that their institution's procedural file contains documentation hygiene.

These templates serve as both a gap analysis tool and a remediation instrument.

1. Purchase and download the full suite in editable Word file format.

2. Populate the customisation fields with your institution's own details, customers, products, and risk profile.

3. Your management board adopts the master procedure under Art. 50, and the suite goes into your procedural file.

Delivered in editable Microsoft Word, bilingual throughout, and grounded in the current consolidated text of the AML Act. The suite is designed for institutional self-adoption, with customisation fields for your own details. We recommend that the adapted procedures be reviewed by qualified counsel before formal adoption.

Your purchase licenses the suite for internal use by your institution, including the onboarding of your own clients. Redistribution, resale, or sharing with other institutions is not permitted. One purchase covers one obligated institution.

1. Does this guarantee my institution will pass an inspection?

No template can promise that and any that claims to, should be treated with suspicion. This suite gives you a complete methodology drafted to current law, with the statutory basis for each provision set out. How well an inspection goes also depends on how faithfully you adapt the procedures, operate them, and keep your records.

2. What happens when the law changes?

The suite reflects the consolidated text current at the edition date shown on the title page. When the Act is amended, your adapted procedures should be reviewed and updated to match.

3. Can I use it for more than one institution?

Your purchase covers a single obligated institution, including the onboarding of that institution's own clients.

4. Is it genuinely bilingual?

Yes. Every document is provided in parallel English and Polish, drafted in proper legal register in both. It is not machine-translated.

5. How is it delivered?

As editable Ms Word files, ready for you to populate the customisation fields and adopt.

These materials do not constitute legal, regulatory, financial, or compliance advice. Following adaptation, the implementation and operation of the procedures rest with the institution's management board and its designated compliance officers, who remain responsible for the institution's compliance posture and may, depending on circumstances, need to engage their own legal and compliance advisers. To the fullest extent permitted by Polish law, Salwius & Lazareva sp. z o.o. accepts no liability for regulatory outcomes arising from the adaptation or use of these materials.