AML API Poland: 5 key elements & long way to AML in less than a second

Anti-Money Laundering (AML) API, also often called Know Your Customer (KYC) API or Due Diligence API, makes the verification of a new and current contractor last less than a second. In each country, it looks a bit different, depending on the adopted regulations. Today, we tell you what key elements are included in the AML API for Poland.

Transparent Data
Blog Transparent Data ENG
5 min readJul 4, 2019

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API AML Poland: 5 key elements

In the beginning, let's say one thing - it will not be an article in the style of AMLove, with relaxing live music and warm cocoa. Due diligence, counter-terrorism, and KYC, it’s not about engaging in meditation to distance yourself from all worries and troubles. Because why worry and wonder how not to worry when we can just protect ourselves well?

It won’t be also a text explaining what an API is. We have written about it many times before (e.g. HERE & HERE).

What gives AML API is the integration of real-time aggregated information from various credible sources, in order to be able to check whether all data obtained from the contractor is true, whether we are dropping into a puddle or if someone is pulling us into one.

It used to take hours of human work. Now, the key word is process automation, thanks to modern RegTech solutions. And one of those let's take a look today.

5 key elements of AML API Poland

AML API Poland — official national registers

AML API Poland element #1

Information from the official national registers of Poland — KRS & CEIDG

The official trade registers of a specific country are always the number one source to check, when we face the task of comparing whether the information provided by the customer is true or not, what is the legal form, ownership structure, company registration addresses, identification numbers, how many years the company exists on the market, whether it was suspended, etc.

In Poland, there are two business registers - CEIDG (pol.: Centralna Ewidencja i Informacja o Działalności Gospodarczej, Central Register and Information on Business) respectively for 1-person small businesses, which currently has more than 5.2 million registered entities, and for all the other companies, associations, and foundations, KRS (pol.: Krajowy Rejestr Sądowy, National Court Register), which includes more than 0.7 million of companies.

AML API Poland — basic risk assessment

AML API Poland element #2

Basic Risk Assessment

As usual, each AML API includes some information and risk analysis, prepared by the data provider.

In our case, the last 6 years in the RegTech industry have taught us one thing — all of our Clients have their own risk assessment algorithms and they take very different information into account. Therefore, they do not trust the ready risk analyzes contained in trade reports and on the websites of the business intelligence and data providers.

Hence, our Transparent Data AML API includes something else. The Basic Risk Assessment Report that we deliver by integrating real-time 50 different sources.

For each company, it consists of just a few A4 pages, listing the questions and answers most frequently asked during the verification of the subject.

We are calling it "quick basic risk assessment", because scanning it takes a minute, and the controller immediately sees, among others:

  • the age of individual board members,
  • are company addresses real or virtual,
  • does the entity have a website,
  • was this company established only this year,
  • do the management board members have over 50% of shares,
  • whether the examined entity has arrears inscribed in the 4th section of the National Court Register, is entered in the National Debt Register or appears on the list of KNF warnings,
  • has the company's share capital been reduced recently?

This document thus allows to quickly qualify or to disqualify a given contractor.

AML API Poland — ultimate beneficial owner

AML API Poland element #3

Information about the ultimate beneficial owner and related companies

The ultimate beneficial owner (a natural person who in fact benefits from the operation of a given economic entity, which owns or controls it) is not always visible in public registers.

Before the first Polish UBO Register (CRBR, Centralny Rejestr Beneficjentów Rzeczywistych) is going to appear publicly, our tech company extracts UBO information from the integration of two polish registers (KRS & CEIDG), thanks to which, we are able to discover the chain of connections between individuals and companies.

AML API Poland — sanctions lists

AML API Poland element #4

Data from Sanctions lists

Sanctions lists (lists of entities and persons associated with terrorist activities, covered by specific restrictive measures in accordance with the Act on Counteracting Money Laundering and Terrorism Financing) are also a key element of the AML API.

The obligation resulting from the regulation is to check whether our contractor on the list is listed or not.

Our standard AML API (sometimes expanded depending on the client's requirements) includes, for example, the 12 largest global sanctions lists.

AML API Poland — PEP lists

AML API Poland element #5

Data from PEP lists

The last mandatory element of the AML APIs is PEP list, i.e. lists of people on politically exposed positions.

MPs, senators, ambassadors, judges of tribunals, members of monetary councils, voivods, etc. — they are all PEPs.

Verification, whether a given member of the management board or a business owner is a PEP, is also a regulating AML obligation.

Our company provides our own database of Polish PEPs and information from major foreign policy lists.

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