Communication no. 8 on naming files containing 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) submitted to the General Inspector of Financial Information by the obligated institutions and on transferring files via electronic mail after 12 July 2019.

 

Due to the enquires directed to the General Inspector of Financial Information in relation to the requirements of naming files containing the information on above threshold transactions  referred to in Article 72 of the above-mentioned Act submitted to the General Inspector of Financial Information by the obligated institutions, I would like to remind you that the manner of preparing and submitting the above-mentioned information as well as the mode are governed by the provisions of the above-mentioned Act (Article 78(2) templates of electronic documents) and the Minister of Finance Regulation of 4 October 2018 on  submitting the information on transactions and the form identifying the obligated institution (Journal of Laws, item 1946).

 

These provisions do not impose an additional obligation in the scope of the manner of naming the files containing the information referred to in Article 72 of the above-mentioned Act on the obligated institutions reporting to the General Inspector of Financial Information. The defined principles of reporting do not require any additional regulation in terms of names of files. The obligated institution reporting this information can give any name to the file (i.e. the one that will be accepted by the ITC system in which the file containing the report is prepared).

In order to maintain an order in the stored/submitted information the obligated institution should apply an adequate method of naming the files for its own needs (e.g. for the purposes of the control process), nevertheless, the General Inspector of Financial Information does not impose any solution in this regard.

 

At the same time I would like to remind you that - in accordance with the principles stipulated in the provisions - from 13 July 2019 files containing transactions will be accepted only via a secure website of the GIFI ITC system or the interface software allowing the connection with a network service of the ITC system which means that the transfer of files  via electronic mail (e-mail) will not be possible.