Article 50 of the Polish AML Act requires every obligated institution to maintain a written internal procedure covering the full range of its AML and CFT obligations. The provision is satisfied by a document that translates the Act into the specific operational reality of the institution, namely, its customer base, its product set, its risk profile, and its governance structure.

These templates are built on the analytical framework developed across the Salwius & Lazareva AML Training Programme. They are customisable by institutions according to their industry specific operations. Every template carries explanatory notes in the margin identifying the statutory basis for each provision and the supervisory expectation it must meet.

The suite extends into the annex documentation that regulatory inspections usually expect to see in the institution's procedural file, namely, the risk assessment worksheets, the CDD records, the SAR escalation templates and the training register that demonstrates the programme is not just documented but conducted thoroughly.

Master Procedure Template

• Risk methodologies through to GDPR interface

• CDD and EDD procedural workflows with decision trees

• Hard Stop protocols

• SAR escalation chain

• Tipping-off prohibition controls

• Five-year retention policy and GDPR interface

• Annual review and amendment protocol

Sector-Specific Addenda

• 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

Annex Document Set

• Employee AML training acknowledgment form

• Client risk assessment worksheet (five factor matrix)

• Ultimate beneficial owner identification and verification record

• Source of Funds / Source of Wealth documentation checklist

• Internal SAR escalation memo template

• PEP identification and EDD authorisation record

• Hard Stop decision record

• Sanctions screening log template

• AML training register

• Annual AML risk assessment review record

1. The obligated institutions building their AML programme for the first time, typically professional services firms (legal, accounting, tax advisory, real estate etc.). These templates provide a statutory grade starting point, eliminating the blank page problem and the risk of omitting provisions.

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

3. 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.

These materials does not constitute legal, regulatory, financial or compliance advice. The operational implementation of these materials is the exclusive fiduciary responsibility of your Management Board and designated compliance officers. Your institution's specific compliance posture may require the engagement of its own legal and compliance advisors.