POLAND Trends and Developments Contributed by: Marcin Olechowski, Wojciech Iwański, Tytus Brzezicki and Piotr Orłowski, Sołtysiński Kawecki & Szlęzak
The reform is in line with the worldwide trend of shifting away from Interbank Offered Rate-type benchmarks to risk-free rate (RFR)-type bench - marks. On 4 October 2024, it was announced that an additional round of public consultations will take place. It is said that WIRON (as well as WIRON+ and WRR) indices will not be taken into account, owing to their high volatility. The discussion will focus on new indices from the group of WIRF (Warsaw Index for Financial Market) indexes. Regulatory Developments In Poland, financial institutions are facing sig - nificant regulatory scrutiny, driven by a growing number of regulations both at local and EU lev - els, alongside proactive oversight from super - visory authorities. Recently, a number of new regulations have been enacted both at national and EU levels, with some already in effect and others set to take effect shortly. What follows is an overview of the most important regulations On 19 June 2024, the EU published the final ver - sion of the AML/CFT regulatory package. This comprehensive framework introduces significant changes for obligated entities across the EU. The regulations will be implemented gradually throughout the next few years, allowing organi - sations to adjust their internal policies accord - ingly. The AML/CFT package consists of the following three legal acts: • Directive (EU) 2024/1640 of the European Parliament and of the Council of 31 May 2024 on the mechanisms to be put in place by EU member states for the prevention for the banking sector. New AML/CFT package
of the use of the financial system for the purposes of money laundering or terrorist financing, amending Directive (EU) 2019/1937 and amending and repealing Directive (EU) 2015/849; • Regulation (EU) 2024/1624 of the European Parliament and of the Council of 31 May 2024 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing; and • Regulation (EU) 2024/1620 of the European Parliament and of the Council of 31 May 2024 establishing the Authority for Anti-Money Laundering and Countering the Financing of Terrorism and amending Regulations (EU) No 1093/2010, (EU) No 1094/2010 and (EU) No 1095/2010. A key component is the establishment of the Anti-Money Laundering and Countering the Financing of Terrorism Authority (AMLA). AMLA is expected to begin operations by mid-2025, focusing on enhancing co-ordination and over - sight of AML/CFT measures among EU member states. The new regulations will require obligated enti - ties to align their practices with the updated AML/CFT framework and comply with regula - tory technical standards developed by AMLA. By way of example, by 26 July 2026, AMLA will create Regulatory Technical Standards regarding customer due diligence processes. This neces - sitates significant adjustments to internal poli - cies and controls to maintain compliance across all operations.
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