Additional duties for accounting offices

Accounting Offices

Most people associate money laundering with the mafia world or action movies. However, if you are an entrepreneur and you entrusted your accounting to an accounting office, you have more to do with preventing this practice than you think. Pursuant to the provisions of the Anti-Money Laundering and Terrorism Financing Act of November 16, 2000, the accounting office has certain additional obligations related to the registration and reporting of transactions of settled entities.

Responsibilities for accounting offices - money laundering prevention

The fact that the accounting office counteracts money laundering is not due to its charity - it is its duty. The aforementioned act lists the institutions that are obliged to take measures to prevent this from happening. Pursuant to Art. 2, there are as many as twenty types of entities, including - sec. 1 lit. o - entities operating in the field of bookkeeping services.


It is worth noting that not every accounting office will be obliged to comply with the Anti-Money Laundering Act - the regulations indicate directly to entities keeping the books of accounts. If a specific office only settles taxpayers using simplified accounting, it is not subject to these regulations and is not the so-called the obligated institution.

What are the obligations of the obligated institution? Information on this issue is provided in Art. 8 of the Act, and in particular par. 1 and sec. 3. First of all, it will be necessary to carefully track and record the transactions carried out by customers, if their value exceeds 15,000 euros. Importantly, such a transaction does not have to be carried out once - you should also pay attention to such operations that:

  • can be related to each other,
  • have been divided into smaller ones, it could have been done with the intention of avoiding the obligation to register,
  • in total, they amount to at least EUR 15,000.

Sometimes an accounting office may also be required to register transactions with a value of less than € 15,000.Such a situation will take place when there are indications that the operation may be related to money laundering or terrorist financing.

The owner of an accounting office must not forget to create an internal anti-money laundering procedure. Such regulations should be made in writing and contain at least a description of the method of:

  • implementation of financial security measures,
  • transaction registration,
  • risk analysis and assessment,
  • providing information on transactions to the General Inspector,
  • suspending transactions, blocking the account and freezing property values,
  • accepting statements about whether a client of the office is a politically exposed person, if any,
  • information storage.

The employer is also obliged to provide his employees with specialized training on this subject.

Responsibilities for accounting offices - procedures

Since an accounting office should register suspicious transactions of its clients, it must have the appropriate tool. In this case, it will be a transaction register which should contain the following information:

  • the date of the transaction;

  • identification data of the parties to the transaction:

    • in the case of natural persons and their representatives - recording the features of the document confirming the identity of the person on the basis of separate regulations, as well as the name, surname, citizenship and address of the person making the transaction, and also the PESEL number or date of birth in the case of a person without a PESEL number, or the number of the document confirming the identity of the foreigner or country code if a passport is presented;

    • in the case of legal persons - saving current data from an excerpt from the court register or other document indicating the name (company), organizational form of the legal entity, seat and address, tax identification number, as well as name, surname and PESEL number or date of birth in the case of a person without a PESEL number, a person representing this legal person;

    • in the case of organizational units without legal personality - saving current data from a document indicating the name, organizational form, seat and its address, tax identification number, as well as name, surname and PESEL number or date of birth in the case of a person without a PESEL number, a person representing this unit ;

    • in the case of parties to the transaction who are not customers - entering their name (company) or first and last name and address, to the extent that the data may be determined by the obligated institution with due diligence;

  • amount, currency and type of transaction;

  • account numbers that were used to carry out the transaction, in the case of transactions involving such accounts;

  • justification and the place, date and method of placing the instruction in the case of providing information about the transaction referred to in Art. 8 sec. 3.

All the indicated information is necessary in the register - on their basis, reports should be made to the General Inspector of Financial Information. Such a report may be submitted to the inspectorate directly or sent. The accounting office has 14 days to deliver it from the end of each tax month, if it concerns transactions exceeding EUR 15,000, or immediately if a suspicious transaction is recorded, regardless of its value.

Responsibilities for accounting offices - pay attention to the consequences!

Since the obligation to take care of counteracting money laundering and terrorist financing stems directly from the act, owners of accounting offices should know that failure to do so has consequences.

Such consequences can be really serious - in a situation where an obligated institution unintentionally neglects the indicated duties, it is punishable by a fine. However, if registration, notification of the General Inspector of Financial Information or failure to introduce an internal protection system is omitted on purpose, the owner of the office may be punished with up to three years imprisonment.

As can be seen, also in this case there is an iron rule that ignorance of the law does not exempt from the obligation to apply it. Therefore, it is worth bearing in mind the obligations arising from the Act on counteracting money laundering and financing of terrorism, in a situation where the clients of the accounting office are people who settle accounts on full books.