Continuing our series on possible reasons for refusal to open a bank account in Poland and account blocking, it is worth taking a closer look at the KYC and AML procedures used during client verification.
KYC/AML procedures are mandatory checks that every bank in Poland is legally required to perform when entering into a service agreement with a client. In this article, we will explain in detail what KYC and AML are, which laws they are based on, how your business is verified, and what you can do to pass the process successfully.
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🔍 What are KYC and AML? Complex topics in simple terms
AML (Anti-Money Laundering) is a set of measures to combat money laundering and terrorist financing. It is an international system of rules designed to prevent criminals from legitimising illegally obtained income through the banking system.
KYC (Know Your Customer) is the practical tool for implementing AML policy. In simple terms, it means “know your customer”. This is the process in which a bank collects and verifies information about you and your business to ensure that you are who you claim to be and that your activities are legal. In other words, AML is “why we do it”, and KYC is “how we do it”.
How do banks practically verify clients as part of the procedure?
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Each bank maintains a list of high‑risk jurisdictions; they may refuse to work with citizens of those countries (for example, PKO BP lists Bulgaria, Latvia, and Romania).
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The client is checked against pan‑European databases for legal violations.
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Verification of a residential or correspondence address in Poland.
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Determination of whether the client is a US tax resident.
⚖️ Legal framework: which laws regulate this?
The activities of Polish banks in the area of AML/KYC are regulated by several levels of legislation.
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Polish Act of 1 March 2018 on counteracting money laundering and terrorist financing.
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European Union Directives (AMLD4, AMLD5 and new ones).
Polish legislation is harmonised with EU standards. The Fourth Directive (2015/849) established basic financial monitoring requirements, the Fifth Directive (2018/843) expanded access to beneficial ownership registers, and the new AML package (2024) introduces uniform rules across the EU. -
EU sanctions regulations.
Banks are obliged to check clients and their counterparties against EU sanctions lists (e.g., against Russia and Belarus). This directly affects the ability to open accounts and process transactions.
📋 KYB: When not only the individual but also the business is verified
For corporate clients, the term KYB (Know Your Business) is used. This is a more complex procedure than KYC for individuals, as it requires analysis of the company structure, ownership chain, and ultimate beneficial owners.
| Stage | What is checked |
|---|---|
| 1. Registration confirmation | Verification of the company in the public KRS register; obtaining an up‑to‑date extract. |
| 2. Identification of beneficial owners (UBO) | Identification of natural persons who directly or indirectly (through a chain of companies) hold more than 25% of shares or otherwise control the company (CRBR register). |
| 3. Representation confirmation | Who is authorised to sign documents on behalf of the company (board members, commercial proxies). |
| 4. Verification of representatives | Identity check of the persons actually coming to open the account. |
| 5. List checks | Checking the company, beneficial owners and representatives against sanctions lists, PEP (politically exposed persons) lists, and for adverse media presence. |
| 6. Collection of additional data | Information on expected turnover, average transaction amounts, countries of operation, counterparties. The bank checks whether the declared activity matches the actual business model. |
| 7. Risk assessment | Based on all collected data, the bank assigns a risk category (low, standard, high). |
| 8. Ongoing monitoring | Checks do not end after account opening. The bank continuously monitors changes in registers, sanctions lists, and client behaviour. |
Enhanced Due Diligence (EDD)
Applies when the client or situation is assessed as high risk. This is mandatory if:
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The client is a politically exposed person (PEP) or is linked to one.
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The client or transaction involves countries on the FATF or EU “blacklist”.
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A complex or non‑transparent ownership structure is identified.
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The client plans transactions aimed at concealing the identity of the beneficiary (suspicion of nominee services).
Under EDD, the bank will request additional information, including confirmation of the source of funds.
⏱️ How long does KYC verification take?
The timeline depends on the complexity of your structure and how quickly you respond to requests.
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Simple cases (Polish founders, transparent structure) – may take just a few minutes.
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Complex cases (foreign founders, holding structures, companies from “risky” jurisdictions) – may stretch over several days.
The KYB process for complex structures involves not just checking a single register but building an entire “ownership tree”, sometimes spanning multiple countries. This is manual work by analysts and takes time.
⚠️ Why can you be refused? Red flags
A bank has the right to refuse to open an account if it cannot fulfil its AML obligations or assesses the risk as too high. Common reasons for refusal include:
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Non‑transparent ownership structure. The UBO cannot be reliably identified and verified, especially if the chain includes offshore companies or nominee arrangements.
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Sanctions risks. Direct or indirect exposure to EU sanctions.
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High‑risk activity. Cryptocurrencies, financial services, arms trade, dual‑use goods, precious metals, gambling.
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Connection with high‑risk countries. Clients or counterparties from FATF‑listed countries.
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Data discrepancies. Inconsistencies between the CRBR, company documents, and the application forms.
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Lack of connection to Poland. No office, employees, contracts; it is unclear why the company is in Poland.
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Complex structure combined with a “young” company. A startup with a complex holding structure represents double risk for the bank.
✅ Conclusion
KYC/AML is not a “glass ceiling” for foreign businesses, but a system of rules that can and should be taken into account when planning. Polish banks are required to apply these measures to protect the financial system and themselves from fines. The key is to understand the bank’s logic:
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Transparency – we must see who stands behind everything.
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Clarity – we must understand what you do.
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Predictability – we must know where the money comes from and where it goes.
If your business is built with these principles in mind, KYC verification will become a formality rather than an obstacle.
Need help preparing to open an account or communicating with the bank? Contact us – we will help you get through KYC/AML verification quickly and without unnecessary questions! 🚀
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