- what is fraud and what categories of fraud may affect the Bank in the course of its business;
- who (which organizational unit of the Bank and which employee of this unit) is obliged to implement actions in the event of a fraud incident;
- how exactly fraud should be countered (catalog of activities to be carried out).
Ethics and corporate governance
Counteracting crime and countering money laundering and terrorist financing
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The Fraud Management Process and the implemented Business Instruction impose duties and powers on each Bank employee related to countering financial crime to the detriment of the organization itself and the Bank’s customers.
In accordance with the requirements of the Act of March 1, 2018 on Anti-Money Laundering and Countering the Financing of Terrorism, the Bank performs activities to counter financial crimes and terrorism. The key regulation in this regard is the Procedure for Prevention of Money Laundering and Financing of Terrorism at Bank Polska Kasa Opieki Spółka Akcyjna and the Procedure for Application of Financial Sanctions at Bank Polska Kasa Opieki Spółka Akcyjna.
These procedures specify, in particular: the principles of recognizing and assessing the risk of money laundering and terrorist financing, the principles of applying financial security measures, reporting and providing information to the General Inspector of Financial Information and the Head of the National Fiscal Administration, conducting analysis of transactions, training, conducting inspections.
In 2023, the financial sanctions compliance processes were particularly affected by Russia’s aggression against Ukraine, which significantly affected the process of analyzing transactions and customers linked to Russia and Belarus.