AML Audit

Consulting and implementation on the full risk assessment and AML process.

  • AML Audit

We help verify if the institution and individuals responsible for AML processes are properly safeguarded against the imposition of high administrative fines.

AML skanNer

Independent AML audit

Compliance audit of the AML system (documentation, internal regulations, processes). Verification with the Anti-Money Laundering and Terrorist Financing Law and market practice (recommendations of the KNF, recommendations of the supervisor, communications of the GIIF) with particular attention:

Analysis of group and internal procedure.

Analyze processes for identifying and verifying the identity of customers, including establishing remote business relationships.

Analyze processes for identifying real beneficiaries.

Analysis of processes for identifying politically exposed persons.

Analysis of the procedure for reporting transactions to the GIIF.

    audyt AML

    The audit methods used are similar to those that the supervisory authority uses in its audits.

    Therefore, we conduct a post-implementation review of internal regulations primarily based on the documentation provided and information obtained from the project team of the Institution under review.



    The result of the audit will be a summary of the outcome of the work in the form of a report containing a legal opinion containing information on the potential level of risk of regulatory non-compliance in the areas to be audited. In addition, the report will include a comparison of the solutions adopted with current market practice in the context of the AML Law.
    Also included is the provision of recommendations for improving the AML system
    within the framework of the issues specified in the subject of the service.

    AML procedure

    A second phase is also offered as part of the audit, which is focused on the alignment of internal regulations with the recommendations and recommendations provided, the possible impact of the changes on related documents.

    The next step is a proposal to automate AML processes using dedicated IT tools that can be implemented by DataServe.

    Legal basis for the audit to be conducted:

    Law of March 30, 2021 on amendments to the Law on Prevention of Money Laundering and Financing of Terrorism and certain other laws (Journal of Laws of 2021, item 815);

    Directive 2018/843 of May 30, 2018 on preventing the use of the financial system for money laundering or terrorist financing, amending Regulation (EU) No. 648/2012 of the European Parliament and of the Council and repealing Directive 2005/60/EC of the European Parliament and of the Council and Commission Directive 2006/70/EC;

    EP and Council Regulation (EU) 2015/847 of May 20, 2015 on information accompanying funds transfers and repealing Regulation (EC) No. 1781/2006;

    Announcements of the GIIF and the UKNF on the application of the Law on Anti-Money Laundering and Financing of Terrorism.




    Workshops conducted with the project team (and the operational persons identified by the studied Institution who apply the revised regulations on a daily basis in the company's operations) will lead to a confrontation of the business model resulting from the documentation with practice at the Institution.


    Based on this, areas that need to be clarified within the framework of internal regulations will be identified.


    The scope of the offer also includes verification of the proper conduct and documentation of a risk analysis tailored to the Institution's operations, taking into account risk factors relating to customers, countries or geographic areas, products, services, transactions or their delivery channels.