Due diligence — one standard, three acts.
Due diligence — one standard, three acts.
The same concept appears in AML (due diligence measures), in VAT (the 2018 Ministry of Finance methodology and the right to deduct) and in sanctions. The common denominator: you must show what you checked and when.
- 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)
Three views of one concept
Due diligence is not defined in a single provision. It is a standard of conduct expected of a business by three different legal regimes — and in each the question is the same: before the transaction, did you check what a reasonable business in your position would have checked, and can you show it.
| View | Basis | What to check | Consequence of failing |
|---|---|---|---|
| AML | Act of 1 March 2018, art. 33–43 | identification of the client and representative, beneficial owner, sanctions lists, PEP, risk assessment, monitoring | administrative fines under art. 150, liability of senior management |
| VAT | VAT Act, Tax Ordinance, Ministry of Finance methodology of 25 April 2018 | white list and VAT status, KRS/CEIDG registers, formal criteria (contract, account, licences) and transactional ones (price, payment, terms) | refusal of the right to deduct VAT, joint liability, expense not deductible |
| Sanctions | EU regulations, Act of 13 April 2022 | the company, board, shareholders and owners on the lists; the 50% ownership-and-control rule | freezing, a fine, criminal liability |
AML applies to obliged entities and is the most formalised: the Act lists the due diligence measures and requires them to be documented. VAT applies to every taxpayer — the authority may refuse the deduction if the taxpayer knew or should have known that the transaction was linked to fraud; the Ministry of Finance methodology of 2018 describes which actions by a buyer the authorities treat as due diligence. Sanctions apply to everyone — the ban on making funds available to listed persons does not depend on obliged-entity status.
Evidence that counts
- The date and source of every check — not "I checked KRS", but "KRS extract retrieved on 14 March, printout no.".
- The list version — for sanctions: which list, as of which day; without it a "no hits" result is not evidence.
- A document identifier — something that shows the document was not altered after the fact: a number, hash, timestamp, verification with the issuer.
- The decision and its reasoning — who decided on the transaction and why, despite or in the absence of warning signs; signed.
Order matters: evidence of due diligence is a check made before the transaction. A check made afterwards shows, at most, that it could have been detected.
The minimum before the first transaction
For a new counterparty, whichever view you apply, collect before the first invoice:
- the KRS extract or CEIDG entry — does the company exist, who represents it, is it in liquidation;
- the VAT white-list status and the account number from the register — above PLN 15,000 a transfer to another account means a lost tax cost and joint liability;
- the owners from the CRBR and the shareholders from KRS — plus the result of screening the company and those people against sanctions lists;
- warning signs: VAT removal, a KRZ notice, no financial statements, a freshly registered domain, a price well below market, payment in cash or to a third party's account.
For an ongoing relationship repeat the set at the cycle written into your procedure; the rules are on the counterparty monitoring page.
Four ways due diligence fails an inspection.
Each appears in the reasoning of authorities' decisions and court judgments.
How the report helps
The complete AMLA dossier gathers in one document what all three views require: register data from KRS or CEIDG, the status on the VAT white list and in VIES, the account number from the register, owners from the CRBR and shareholders from KRS, screening of the company and its people against sanctions lists, financial standing from the statements, KRZ and MSiG notices, UOKiK decisions, the BDO register, press coverage and domain age — 18 sources, each with a retrieval date. The PDF carries an identifier and a timestamp, and its authenticity can be confirmed on the verification page. The report does not cover debts from BIG or KRD, nor foreign companies beyond the validity of an EU VAT number.
The report is evidence of the checks performed — not legal advice and not a decision. You record the decision on the transaction and its reasoning yourself. See also: VAT white list, 5-year records, sanctions and PEP, AML penalties.
Legal status as of October 2026. Information only, not legal advice.
One document for three acts.
The white list, KRS, REGON and VIES cost nothing. The people, sanctions lists, financials and the score with the retrieval date of every source are in the AMLA dossier.
Questions about due diligence.
Document due diligence with one report.
18 sources, a retrieval date for each, an identifier and a timestamp — evidence of the check for AML, VAT and sanctions, in up to 3 minutes.