In connection with impending expiry of the time limit of the transitional period in the process of providing the GIFI with the information which arises from the Act of 1 March 2018 on counteracting money laundering and financing of terrorism (Journal of Laws of 2019, item 1115), hereinafter referred to as “the AML/CFT Act” and thus reaching a target status in the system of receiving files containing the information referred to in Article 72 of the AML/CFT Act after 13 July of the current year, I hereby inform about the rules concerning the process of validating the information in files sent to the GIFI ITC system.

A file sent by the obligated institution to the GIFI ITC system (website address https://www.giif.mofnet.gov.pl) is registered and after the registration it receives the “Z” status („Zarejestrowany “)[ translation:  “Registered”].

Statuses of the files sent are visible:

- in the case of using interface software allowing connection with a network service of the GIFI ITC system in order to submit the data; by means of this software.

- in the case of using the website of the GIFI ITC system in order to submit the data; in the tab „Status rejestracji transakcji”  [translation: “Transaction registration status”] after logging in to the GIFI ITC system.

Having registered in the GIFI ITC system, the file is decrypted and checked.

The following elements are checked: the logical structure of the electronic document in terms of compliance with the template of electronic documents required for a given type of transaction, compliance with validation and data coherence requirements stipulated in the description of schemas (https://www.gov.pl/web/finanse/raportowanie-transakcji-giif) as well as uniqueness of the element <IdentyfikatorTr> (in the case of an original transaction). In the case of the information on the transaction adjustment it is checked whether the original transaction was submitted to the system (identified by the same <IdentyfikatorTr> translation:”<IdentifierTR>]). Next, the validity of electronic signature or stamp is verified - at this stage the file in the system has the “O” status („Podpis oczekuje na sprawdzenie [translation (“Signature is waiting for being checked”)]. After the positive conclusion of the verification the file obtains the “P” status („Plik poprawny”) [translation (“Correct file”)].

Next, the process of reading the information on transactions to the base of the GIFI ITC system begins.

After the completion of this process the file obtains the “R” status („Transakcje z pliku zostały wczytane”) [translation “Transactions from the file have been read”].

In the case of using interface software allowing connection with a network service of the GIFI ITC system in order to submit the data, the download of the Official Acknowledgement of Receipt (OAR) is possible from the moment of obtaining the “P” status by the file.

In the case of using the website of the GIFI ITC system in order to submit the data the download of the Official Acknowledgement of Receipt (OAR) is possible from the moment of obtaining the “R” status by the file.

The reporting institution may download the OAR in the „Status rejestracji transakcji” [translation “Transaction Registration Status”] tab after logging in to the GIFI ITC system or in the case of using interface software allowing connection with a network service of the system - by means of this software.

Should the irregularities occur at one of the above-mentioned stages of the file acceptance process, the file will receive the “X” status („Plik niepoprawny”) [translation “Incorrect file”] and the irregularity code will be generated and the information on the file (available in the „Status rejestracji transakcji” [translation “Transaction registration status”] tab after logging in to the GIFI ITC system or through the interface software allowing connection with a network service of the system) will be accompanied by a commentary indicating the kind of detected irregularity.

These irregularities may concern:

- file damage and as a result the impossibility of its decrypting,

- invalidity/inappropriateness of the electronic signature or stamp which the file has been signed with,

- inappropriate file logical structure (non-compliance with the template of electronic document),

- lack of data coherence or non-compliance with the rules of validation.

Generating the irregularity code by the system at any stage of data acceptance (i.e. from the time of obtaining the “P” status by the file - „Plik poprawny” [translation  “Correct file”] is equivalent to the necessity of resubmitting all information contained in the file - after prior adjustment of the data resulting in the occurrence of irregularities. In particular, if the generated irregularity code concerns the coherence/validation of parts of transactions, the data of which is contained in a file, this means that all information in the questioned file (the file is accepted/rejected as a whole) needs to be submitted in another (adjusted) transfer (or transfers). The adjusted data may be sent in one or more files. The correct file may be sent under the same name (the system does not impose the rules of the file naming - cf. Communication no. 8 on naming the files submitted to the GIFI by the obligated institutions ( https://www.gov.pl/web/finanse/komunikat-nr-8-w-sprawie-nadawania-nazw-plikom-przekazywanym-przez-instytucje-obowiazane-do-generalnego-inspektora-informacji-finansowej-zawierajacym-informacje-o-transakcjach-ponadprogowych-o-ktorych-mowa-w-art-72-ustawy ).

In exceptional cases the file in the GIFI ITC system may obtain the “W” status („Niepoprawny wyjaśniony”) [translation “Incorrect explained”]. This concerns files which in the process of validation have been regarded as incorrect (the “X” status) and next recognised as duplicates of the previously sent files and as such they were rejected. Furthermore, the file may obtain the “W” status (“Incorrect explained”) when the obligated institution explains with the GIFI the circumstances of sending a file which obtained the “X” status in the system.