Abstract

The assessment of business relationship is, pursuant to Art. 34.1.3) of the Polish Act of 1 March 2018 on counteracting money laundering and terrorist financing, one of the customer due diligence measures that constitute the primary tool for obligated entities to counter money laundering and terrorist financing. The provisions of the Act, as in the case of many other obligations imposed on obligated entities, do not specify exactly what the “assessment of business relationship” is to consist in, let alone how this assessment is to be carried out. Meanwhile, under the current supervisory practice, the Polish supervisory authorities seem to recognize this duty as one of the most frequently overlooked or neglected by obligated institutions.