The Financial Action Task Force published a third enhanced follow-up report on Poland’s anti-money laundering and counter-terrorist financing framework, finding that Poland has improved its technical compliance with the standard on non-profit organisations. Recommendation 8 was upgraded from Partially Compliant to Largely Compliant, while the assessment of Recommendation 15 on new technologies did not result in a re-rating and remains Partially Compliant. The desk-based review focuses on laws and measures in force rather than effectiveness and records 3 FATF recommendations rated Compliant, 25 rated Largely Compliant and 12 rated Partially Compliant. Poland requested re-ratings for Recommendations 8 and 15, while a request for Recommendation 26 was not considered because the legal, operational and institutional framework had not changed since the last review. For non-profit organisations, the report cites progress including updated national risk assessment work and a risk-based supervision framework, but notes remaining gaps around policies to promote accountability and integrity in NPO management, donor education, sector involvement in best-practice development and structured inter-agency cooperation. For new technologies and virtual assets, key deficiencies include the absence of explicit requirements for obliged entities to assess and mitigate ML/TF risks from new products and technologies before launch, alongside outstanding issues around MiCA-related supervisory mandates, risk-based supervision and proportionate and dissuasive sanctions for virtual asset service providers. With two of the FATF big six recommendations, Recommendation 5 and Recommendation 20, still rated Partially Compliant, Poland was placed into step 1 of compliance enhancing procedures and is expected to report at the next plenary on progress against those shortcomings. Poland will remain in enhanced follow-up, with a further report-back recommended in one year.
Financial Action Task Force 2025-12-01
Financial Action Task Force upgrades Poland’s non-profit organisations rating to largely compliant and places it into compliance enhancing procedures
The Financial Action Task Force's third enhanced follow-up report on Poland highlights improvements in its anti-money laundering and counter-terrorist financing framework, upgrading Recommendation 8 to Largely Compliant. However, Recommendation 15 remains Partially Compliant, with deficiencies in addressing ML/TF risks from new technologies and virtual assets. Poland is in step 1 of compliance enhancing procedures due to ongoing issues with Recommendations 5 and 20, requiring further progress reporting.