AML Legal Acts in Force
This reference page lists the legal acts that shaped anti-money-laundering and counter-terrorist-financing law in Poland and the European Union. It is a historical snapshot, useful for understanding how the current framework was built. Because the law keeps evolving, always confirm the current text before relying on it.
The EU directives
The base document for modern AML procedures is the fourth AML Directive (2015/849) of 20 May 2015, which replaced earlier rules. It was amended by the fifth AML Directive (2018/843) of 30 May 2018, which extended the framework to virtual currency exchange and strengthened beneficial ownership transparency.
A separate instrument, Regulation 2018/1673 of 23 October 2018, often called the sixth AML Directive, does not set out AML procedures for obliged institutions. Instead it harmonises criminal-law responses to money laundering.
The Polish AML Act
Poland implemented these requirements through the AML Act of 1 March 2018 (Dz.U. 2018 poz. 723), published on 12 April 2018. It replaced the previous act of 16 November 2000 and, among other changes, brought providers of virtual currency exchange services into the catalogue of obliged institutions.
The act was later amended, including by the law of 30 March 2021 (Dz.U. 2021 poz. 815), which addressed remaining fifth-directive requirements and changed the catalogue of obliged institutions, the PEP and beneficial owner definitions, and the CRBR rules. A consolidated text was published in 2021 (Dz.U. 2021 poz. 1132).
Reference table
| Common name | Number | Adopted | Implementation deadline |
|---|---|---|---|
| Fourth AML Directive | 2015/849 | 20 May 2015 | 26 June 2017 |
| Fifth AML Directive | 2018/843 | 30 May 2018 | 10 January 2020 |
| Sixth AML Directive (criminal law) | 2018/1673 | 23 October 2018 | 3 December 2020 |
| Polish AML Act | Dz.U. 2018 poz. 723 | 1 March 2018 | n/a |
Since then
The framework has moved on again. The EU AML package, built around Regulation 2024/1624 and the sixth AML Directive (2024/1640), is phasing in from 2027 and will apply directly in member states, reducing the need for national transposition in several areas. Institutions should track these dates when planning compliance work.
For keeping screening data current as the rules change, a platform such as Hyperflow updates its lists and checks continuously.
UK perspective
For the United Kingdom the core instrument is the Money Laundering Regulations 2017, as amended, supported by the Proceeds of Crime Act 2002 on the criminal side. Supervision is divided between the FCA, HMRC and OPBAS.