Monitor Prawniczy

no. 9/2023

Financial Information System in the context of payment service providers

Mateusz Jagodziński
Autor jest radcą prawnym, Associate w Kancelarii Traple Konarski Podrecki i Wspólnicy sp.j.
Abstract

The article analyses selected issues related to the entry into force of the provisions of the Financial Information System Act of 1 December 2022, implementing so-called “Fifth AML Directive”, with particular emphasis on the subjective and objective scope of the addressees of these regulations on the part of payment service providers. The commented regulations provide for new obligations for such institutions, including, first and foremost, the obligation to provide information about payment accounts kept and their holders to the Financial Information System, and also introduce mechanisms for oversight, control and penalising failures in this regard.

Keywords
AML, CFT, Financial Information System, 5AMLD