In the context of the ongoing process of adapting  ITC systems of the obligated institutions obliged to the changes arising from the provisions of the Act of 1 March 2018 on counteracting money laundering and financing of terrorism (Journal of Laws, item 723, as amended), hereinafter referred to as “the AML/CFT Act” and the Regulation of the Minister of Finance of 4 October 2018 on submitting the information on transactions and the form identifying the obligated institution (Journal of Laws, item 1946), hereinafter referred to as “the Regulation on submitting the information”, including in particular changes concerning the obligated institutions’ submission of the information referred to in Article 72 of the above-mentioned Act on the so-called “above threshold transactions” (i.e. Transactions reported only due to their value, without stating “the suspicion element”), the General Inspector of Financial Information, hereinafter referred to as “the GIFI” hereby informs that:

1. The xml schemes referred to in Article 78 of the AML/CFT Act are published in the central repository of electronic document templates (link: http://crd.gov.pl/, numbers of templates: 2018/10/30/6031, 2018/10/19/5993, 2018/10/19/5992, 2018/10/19/5995). These templates contain schemes of the xml documents which are to be a basis for reporting of the information referred to in Article 72 of the AML/CFT Act.[1]
2. As a supplement to the xml schemes defining templates of electronic documents for the identifying form, the report on cash deposits/disbursements, the report on the transfer of funds, the report on the exchange of foreign currency, the report on a notarial deed, in communications the GIFI published descriptions of particular documents together with the description of relation between particular elements of the xml scheme (including the conditions of data coherence, using dictionary values, etc.). The above-mentioned descriptions in the current wording are attached to this communication.
3. Pursuant to § 5 of the Regulation on submitting the information, having submitted the information referred to in Article 72 of the AML/CFT Act, the GIFI ITC system generates an official acknowledgement of receipt. Based on the obligation arising from § 5(3) of the above Regulation, the GIFI attaches the information concerning the OAR logical structure.
4. Pursuant to § 4(5) of the Regulation on submitting the information, the information referred to in Article 72 of the AML/CFT Act is sent in encrypted form. In accordance with the obligation arising from § 4(5) of the Regulation, the GIFI attaches the description of the manner of encryption.
5. Pursuant to § 4(1)( 2 of the Regulation on submitting the information the information on transactions may be submitted via interface software. In accordance with the obligation arising from the above-mentioned provision, the GIFI indicates a network service address:

https://www.giif.mofnet.gov.pl/api/rest2018

(WADL API address: https://www.giif.mofnet.gov.pl/api/rest2018?_wadl)

The description of the interface allowing the connection with a network service of the GIFI ITC system can be found at https://www.giif.mofnet.gov.pl/api.

6. Before the transitional period ends and the reception of the information referred to in Article 72 of the AML/CFT Act begins solely according to the “new principles”, the GIFI plans to make available a portal for test data transfer in order to verify the correctness of the format and solve technical problems related to transfer thereof. The test environment will give the possibility to test the transfer of files via website in the GIFI ITC system and via interface software (making available forms on the website allowing direct filing in and providing the information on single transactions is not planned). It will also serve for developing the final solution which is optimal from the point of view of the convenience of the obligated institutions and the efficiency of providing the GIFI with the information. The expected date of launching the test environment is 1 April 2019. The detailed information on launching the test environment will be provided in the further GIFI communications.
7. Please sent any questions related to this communication, descriptions and templates of electronic documents as well as the planned test environment only to the following e-mail address dif.giif@mf.gov.pl . Individual consultations concerning the above-mentioned issues via phone are not anticipated.

 

Additional information and the list of attached files:

1. Link to templates of electronic documents:
   1. 1. http://crd.gov.pl/
      2. numbers of templates: 2018/10/30/6031, 2018/10/19/5993, 2018/10/19/5992, 2018/10/19/5995
      3. (numbers of templates make it easier to search for an appropriate template in the Central Repository - with the use of the <Filtruj ^>  [transl. <Filter^>] button one should enter an appropriate number in the form box ‘Nr wzoru’ [transl. ‘Template number’] and press the <Filtruj> [transl. <Filter>] button.
2. Descriptions of templates  of electronic documents together with the description of relation between particular elements of the xml schemas (including the conditions of data coherence, the use of dictionary values, etc.) - MS Excel workbook in the file opisy_schematów_informacji_o_tr_v05.xlsx  containing the following sheets:

Ogólny_schemat_dok  [transl. General_scheme_doc] – containing the description of a general structure of an electronic document including the information on transactions

tr_gotowka  [transl. tr_cash] – containing the description of an element “Karta” [transl. “Card”] for the payment/withdrawal transaction (Article 72(1)(1) of the AML/CFT Act)

tr_transfer – containing the description of an element “Karta” [transl. “Card”] for the transfer transaction (Article 72(1)(2) and Article 72(2) of the AML/CFT Act)

tr_wymiana  [transl. tr_exchange] –  containing the description of an element Karta [transl.  “Card”] for the purchase and sale transaction of foreign currency or intermediation in performing such transaction (Article 72(3) of the AML/CFT Act)

tr notarialna [transl. tr_notarial ] – containing the description of an element Karta [transl. “Card”] for the transaction of the notarial act type (Article 72(4) of the AML/CFT Act)

3. Information on the OAR logical structure  - the zip archive in the file SIGIIF_opis_UPO.zip containing the xsd and xsl scheme.
4. Description of the manner of encrypting  – Sposób_podpisywania_i_szyfrowania_plików_do_SIGIIF.docx  the MS Word file containing in particular the information on the allowable content encryption algorithms, the link to the certificate with a public key for encryption, the information on encryption algorithms of a symmetric key, required information in the contentType box of the encryptedContentInfo element.  Furthermore, the document contains the information on the acceptable formats of electronic signature and the possibility of compression of the transferred data.
5. Address and description of the interface allowing the connection with a network service of the ITC system. Network service address:

https://www.giif.mofnet.gov.pl/api/rest2018

(WADL API address: https://www.giif.mofnet.gov.pl/api/rest2018?_wadl)

The description of the interface  allowing the connection with a network service of the GIFI ITC system can be found at https://www.giif.mofnet.gov.pl/api.

 

[1] Nowadays there is a transitional period, during which the AML/CFT Act allows to provide the GIFI with the information referred to in Article 72 of the AML/CFT Act according to the “old” principles, with the use of binding manners of providing the GIFI with the information on the so-called “above threshold transactions” (vide Article 183 of the AML/CFT Act) under the repealed Act of 16 November 2000 on counteracting money laundering and financing of terrorism (Journal of Laws of 2017, item 1049 and of 2018, item 650).