What this guidebook covers
Cars attract dirty money. A dealer that accepts €10,000 or more in cash becomes an obliged institution under the AML Act, and without procedures faces fines of up to the equivalent of €1 million, plus criminal liability. From 10 July 2027, the EU AML Regulation (AMLR) will cover sales of cars above €250,000 and cap cash payments at €10,000 across the EU.
This guidebook covers 5 AML standards for dealers, with 13 checkpoints: a cash policy, customer verification, reports to GIIF (the General Inspector of Financial Information), procedures and training, and readiness for AMLR 2027. The guidebook PDF is in Polish.
The 5 anti-money laundering standards
| Code | Standard | Ideal fix time |
|---|---|---|
| AML-01 | Cash policy | Immediate |
| AML-02 | Customer verification | Immediate |
| AML-03 | Reports to GIIF | Immediate |
| AML-04 | Procedure and training | 30 days |
| AML-05 | Ready for AMLR 2027 | 30 days |
How to run a Polish anti-money laundering audit, step by step
- Confirm what applies. Decide whether you stay below €10,000 in cash, counting linked payments, or apply full AML duties; most dealers avoid obliged institution status with a cash limit, and those selling cars above €250,000 should prepare for AMLR.
- Walk the site, standard by standard. Score each of the 13 checkpoints Pass, Fail or N/A. N/A only where the standard rules it out, with the reason recorded. Review 12 months of cash reports, adding up linked payments such as a deposit and balance, and check 5 transactions for ID, the beneficial owner (CRBR) and the source of funds.
- Capture the evidence. A pass counts only with proof captured at the time of the audit: cash reports, the written cash limit, customer files, the report register, the AML procedure and the AMLR plan.
- Give every fail an owner and a fix time. Record what you saw and who owns the fix. Each standard carries an ideal fix time, from immediate to 30 days, counted from audit submission (see the table above).
- Fix it, then prove it. The site fixes the cause and uploads proof of closure; the auditor checks the proof before closing the finding.
- Re-check at the next audit. Confirm closed findings stay closed, and look for the same fail at your other sites so one gap doesn't repeat across the network.
Who this guidebook is for
- Boards: setting the cash policy
- Sales and cash desk: the limits and warning signs
- Auditors: the cash desk and customer files to check
A reference document, not legal advice. Fines and rules change: check the current text with the regulator or your legal adviser before acting.
