Verifykatorcompany checks by NIP

Customer risk assessment — factors, levels and proof on paper.

art. 33 of the Polish AML Act

Customer risk assessment — factors, levels and proof on paper.

An obliged entity assesses the risk of every client and matches the due diligence measures to it: simplified, standard or enhanced. Here are the factors you must consider and how to record the result.

Sample report

The Verifykator report shows:
  • 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)

✓GDPR · servers in the EU✓Report in up to 3 minutes✓Przelewy24 payments✓PLN 39.36 incl. VAT
4 groups
Of risk factors in the Act
3 levels
SDD · CDD · EDD
0–100
Score in the report's 5 domains
5 years
Retention of the assessment

What the Act says

An obliged entity identifies the money-laundering and terrorist-financing risk attached to a business relationship or an occasional transaction and assesses its level (art. 33(1)–(2) of the AML Act). The assessment considers in particular factors relating to:

  • the customer — type, legal form, ownership structure, industry, purpose of the relationship, time in business;
  • the country or geographic area — the client's seat, the owner's country, the counterparties' countries;
  • the product, service or transaction — cash, virtual currencies, real estate, anonymity, unusual value;
  • the delivery channel — a relationship established remotely or through an intermediary (art. 33(3)).

The assessment is documented (art. 33(4)). It is tied to the entity-wide risk assessment under art. 27 — where the entity describes which factors it treats as raising risk and how it weighs them. The intensity of the measures follows the result: standard measures under art. 34, simplified at lower risk (art. 42), enhanced at higher risk (art. 43). Full text: isap.sejm.gov.pl.

Risk factors in practice

GroupWhat to look atWhat raises the risk
Customerlegal form, company age, PKD code, structure, boardan LLC set up a few months ago, minimum capital, frequent board changes, a foreign shareholder, a cash-heavy industry
Countryseat, owners, counterpartiesa country on the EC or FATF high-risk list, a tax haven, a sanctioned country
Producttype of service, value, form of paymentcash, virtual currencies, real estate, gold trading, transactions with no visible rationale
Channelhow the relationship was establisheda purely remote relationship, through an intermediary or attorney, no contact with the owner

Levels of measures

SDD — simplified (art. 42): allowed when the risk is lower — e.g. the client is a listed company, a public-finance entity or an EU obliged entity. You still identify the client and monitor the relationship, but with less intensity. SDD is not allowed where money laundering is suspected.

CDD — standard (art. 34): the default set — identification and verification of the client and the owner, assessment of the purpose of the relationship, ongoing monitoring.

EDD — enhanced (art. 43): mandatory, among others, for a PEP client, a client from a high-risk third country, an unusually complex ownership structure, transactions of unusual value or without rationale, and relationships whose context points to higher risk. In practice: extra documents, source of wealth and funds, management approval, more frequent monitoring.

An example assessment card

Client: a construction LLC registered 8 months ago, share capital PLN 5,000, sole shareholder a Cypriot company, a one-person board, relationship established remotely, payments by bank transfer, service: bookkeeping.

FactorFindingEffect
Customeryoung company, minimum capital, foreign shareholderraises
Countryseat in Poland, owner established via the CRBR, EU citizenneutral
Productbookkeeping, bank transfers, no cashlowers
Channelremote, no meeting with the ownerraises

Result: elevated risk, CDD with extra actions — confirm the owner with a document from the Cypriot register, ask about the purpose of the relationship and expected turnover, review after 6 months. Reasoning, date, signature.

Common mistakes

Four mistakes in customer risk assessment.

A GIIF inspection does not question the result — it questions the missing reasoning.

1
The same rating for everyone
"Low risk" entered for every client is no assessment
The rating has to follow from the factors, not a template
2
No reasoning
A level without the factors that led to it
Record factor → weight → result
3
No update after a change
A new foreign shareholder, a new industry, a PEP on the board — that is a new assessment
A three-year-old rating with no review is stale
4
EDD with no extra actions
Writing "enhanced" without source of wealth and management approval
The level must carry specific actions

How the report helps

The complete AMLA dossier gives a ready basis for the assessment card: a 0–100 score in five domains — I Identification, II Structure and UBO, III Sanctions and PEP, IV Financials, V Reputation — where 0 means no signals, and every point is tied to a factor and the source it came from. The rules are deterministic: the same NIP on the same day gives the same result, with no AI. At the end the report proposes a level of measures — SDD, CDD or EDD — and a list of recommended actions, such as "request a source-of-funds document" or "clarify the CRBR discrepancy".

You carry the report's factors onto your own card: customer (form, age, PKD, structure), country (seat and owners), and add what you know from the relationship for the product and channel factors. The final rating and signature are yours — the report is the evidence of what you based it on. The scoring method is in the methodology. See also: customer identification, financial standing, 5-year records.

Legal status as of October 2026. Information only, not legal advice.

Pricing

The 0–100 score and the proposed level are in the full report.

The free check shows the registers. Risk factors with points, the proposed SDD/CDD/EDD level and the action list are in the AMLA dossier.

Free
Basic check
PLN 0
No account, no card — NIP and e-mail
Included:
KRSName, KRS number, status, legal form, address
Included:
White List of VAT taxpayersVAT status, REGON, bank accounts reported to the Ministry of Finance
Included:
GUS REGONMain PKD code, employee range, registration date
Included:
VIESEU VAT number validity
Not included:
Sanctions, PEP and KNF warnings
Not included:
Beneficial owners (CRBR)
Not included:
Financials, insolvency, KRZ
Not included:
0–100 score and PDF report
Full report
Complete AMLA dossier
PLN 39.36
PLN 32.00 + 23% VAT · packs of 5/20/100 from PLN 9.99 a report
Included:
Everything in the basic checkKRS, VAT White List, GUS REGON, VIES
Included:
Sanctions and warningsOpenSanctions (incl. the Polish MSWiA list), EU list, OFAC SDN, KNF — the company and its owners
Included:
Beneficial ownersCRBR and shareholders from KRS
Included:
FinancialsRevenue, net result, equity, filing dates, MSiG and KRZ notices
Included:
ProceedingsBankruptcy, liquidation, restructuring, compulsory administration, UOKiK decisions
Included:
ReputationPress coverage, domain age, BDO register
Included:
0–100 score in 5 domainsPDF report by e-mail, recommended next steps
FAQ

Questions about customer risk assessment.

As the basis — yes: you carry the factors, points and sources onto the assessment card. The decision on the risk level and the signature are yours; the report is not a compliance decision.

Assess a client's risk by NIP.

Factors with points and sources, a proposed SDD/CDD/EDD level and an action list — in one PDF, in up to 3 minutes.

Complete AMLA dossier · PLN 39.36 incl. VAT · Przelewy24 · PDF by e-mail