Communication no. 7 on the manner of reporting of the information on above threshold transactions referred to in Article 72 of the Act of 1 March 2018 on counteracting money laundering and financing of terrorism (Journal of Laws, item 723, as amended) to the General Inspector of Financial Information in the case of changes in the data for reporting possessed by the obligated institution prior to submission.

Due to the enquires directed to the General Inspector of Financial Information in relation to the method of handling by the obligated institution in the case of discrepancies between identification data referred to in Article 72(6)(3) and (4) of the Act of 1 March 2018 on counteracting money laundering and financing of terrorism (Journal of Laws, item 723, as amended) between the instruction or an order to execute the transaction issued by a customer and the date of providing the General Inspector of Financial Information with the above-mentioned information by the obligated institution (e.g. due to informing about the change of the identity card number by the customer), I would like to inform that:

Pursuant to Article 72(1) of the above-mentioned Act the obligated institutions, excluding institutions referred to in Article 2(1)(11), (13)–(15) and (18),  provide the General Inspector of Financial Information with information on the so-called above threshold transactions executed by them. In accordance with Article 72(6) (3) and (4) of the above-mentioned Act the information subject to reporting contains enumeratively specified data, including, inter alia, identification data of the customer and parties to the transaction.

In the event of possible discrepancy between the data referred to in Article 72(6)(3) and (4) of the above-mentioned Act, at the date of the instruction or an order issued by a customer and the data at the date of submitting the above-mentioned information by the obligated institution, in the General Inspector of Financial Information’s opinion, reporting of the said data at the date of the instruction or an order issued by a customer is required.

At the same time I hereby inform that the obligated institution may include the information concerning these differences as additional data transferred in the information to the General Inspector of Financial Information (in box “Remarks” in the structure of the submitted information in accordance with a template of an electronic document). Just as in the case of every executed transaction the obligated institution is obliged to identify the risk related to a given transaction or a customer, in particular it is required to notify the General Inspector of Financial Information in the case of the circumstances which may indicate the suspicion of committing the crime of money laundering or financing of terrorism. A possible notification referred to in Article 74 or 89 of the above-mentioned Act neither influences the obligation of submitting the information in the mode of Article 72 of the above-mentioned Act nor gives rise to the obligation of providing the General Inspector of Financial Information with the adjustment of the information which had been already sent in the above-mentioned mode.