Counterparty monitoring — checking once is not enough.
Counterparty monitoring — checking once is not enough.
A client checked a year ago may since have changed owners, entered restructuring or landed on a sanctions list. The Act requires ongoing monitoring — here is how to do it without a full-time hire.
- Sanctions: MSWiA, EU, OFAC
- KNF warnings
- Beneficial owners (CRBR)
- Financials and filings
- Bankruptcy, liquidation, KRZ
- VAT status and accounts
- Press coverage
- 0–100 risk score and PDF
Money back if the report cannot be generated
For companies: the first 2 reports free (in Polish)
What the Act says
Ongoing monitoring of the client's business relationship is one of the customer due diligence measures (art. 34(1)(4) of the AML Act) and covers:
- analysing the transactions carried out within the relationship — whether they are consistent with what the entity knows about the client, the type and scope of its business and its risk profile,
- examining the source of assets where the risk requires it,
- ensuring that the documents, data and information held about the client are kept up to date.
The intensity of monitoring follows the client's risk level (art. 33(4)); for a PEP client monitoring is enhanced (art. 46(2)(3)). The results of analyses are kept for 5 years (art. 49). The Act sets no deadlines in days — the entity sets the frequency in its own procedure and must be able to justify it. Full text: isap.sejm.gov.pl.
Five areas where a client changes.
Each is a separate register — and a separate reason to update the assessment.
Frequency by risk level
| Level of measures | Full client review | Sanctions lists | What triggers a review off-cycle |
|---|---|---|---|
| EDD — enhanced | every 30 days | at every transaction or every few days | any transaction of unusual value, any change in KRS |
| CDD — standard | every 12 months | at material transactions, no less often than at the review | a change of board or shareholders, a new counterparty country, a press signal |
| SDD — simplified | every 24 months | at the review | a change of legal form, loss of the status that justified SDD |
This is an example scheme, not a statutory rule — write your own deadlines into the procedure and keep to them. An inspection checks whether you do what you yourself declared.
How to run monitoring step by step
- A client list with risk level and last review date. A spreadsheet or a system module — what matters is that the next review date follows from the level.
- The review on time. Re-check the registers, the CRBR, sanctions lists, VAT status and financial statements. Compare with the previous state.
- Record the result. Including "no changes" — with date, source and signature. No entry means no monitoring.
- Respond to a change. A new shareholder, a sanctions hit, bankruptcy — update the risk assessment, change the level of measures if needed, and on suspicion notify the GIIF.
Where to start with hundreds of clients
Not all at once. Start with clients under enhanced measures and those whose last check is older than a year — they come up most often in inspection questions. Then clients in higher-risk industries and with complex ownership structures. Active clients with regular transactions come before dormant ones; relationships that have in fact ended should be closed formally, so they leave monitoring and the retention period starts. Write into the procedure in what order and at what pace you clear the backlog — a dated plan is a better argument at an inspection than no plan.
How the report helps
Order the complete AMLA dossier again for the same NIP — the new report shows the current state of all 18 sources as of the day of the check, with retrieval dates and a timestamp. Comparing two reports — the previous and the current one — answers "what has changed" in the board, shareholders, CRBR, KRZ, the lists and the financials. A report with no changes is evidence of continuous monitoring; a report with a change is the basis for updating the assessment. The packs of 20 and 100 reports with no expiry are priced for exactly these periodic reviews — see packs.
A subscription with a watch list and e-mail alerts about changes in KRS, KRZ and on sanctions lists is planned; for now you run monitoring by ordering a report at the date set in your procedure. See also: sanctions and PEP, 5-year records, KRZ.
Legal status as of October 2026. Information only, not legal advice.
Periodic reviews pay off in a pack.
The free check shows the registers. The full state of 18 sources with retrieval dates comes with the AMLA dossier — in a pack of 20 from PLN 14.94, of 100 from PLN 9.99 a report.
Questions about counterparty monitoring.
Check your clients again.
The current state of 18 sources with retrieval dates — a new report for a known NIP, in up to 3 minutes. Packs with no expiry.