AutoSmart GuidebooksWhat 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
Open a standard to see the law behind it, what is checked, what it can cost and the evidence. Ideal fix times are counted from audit submission.
AML-01Cash policyImmediate
- The law
- Act on Counteracting Money Laundering and Terrorist Financing (2018) · EU AMLR from 10.07.2027 · obliged institutions: businesses accepting cash payments of €10,000 or more
- What we check
- The company has a written rule: either it doesn't accept cash of €10,000 or more (including in linked transactions), or it applies the full AML obligations.
- What it can cost
- Being an obliged institution without procedures: fines of up to the equivalent of €1 million.
- Evidence
- Cash reports
AML-02Customer verificationImmediate
- The law
- Act on Counteracting Money Laundering and Terrorist Financing (2018) · EU AMLR from 10.07.2027 · customer due diligence: identifying the customer and the beneficial owner
- What we check
- In transactions covered by AML, the customer is identified, and the beneficial owner (CRBR register) and the source of funds are checked.
- What it can cost
- GIIF fines and criminal liability.
- Evidence
- Customer files
AML-03Reports to GIIFImmediate
- The law
- Act on Counteracting Money Laundering and Terrorist Financing (2018) · EU AMLR from 10.07.2027 · reporting above-threshold and suspicious transactions
- What we check
- Above-threshold and suspicious transactions are reported to GIIF on time, and the customer isn't warned.
- What it can cost
- Criminal liability for staff.
- Evidence
- Register
AML-04Procedure and training30 days
- The law
- Act on Counteracting Money Laundering and Terrorist Financing (2018) · EU AMLR from 10.07.2027 · internal procedure, risk assessment, training
- What we check
- If the company is an obliged institution, it has a risk assessment, an internal procedure, a designated person and trained staff. Applies to companies accepting cash of €10,000 or more, or covered by the AMLR from 2027.
- What it can cost
- A fine of up to the equivalent of €1 million.
- Evidence
- Procedure
AML-05Ready for AMLR 202730 days
- The law
- Act on Counteracting Money Laundering and Terrorist Financing (2018) · EU AMLR from 10.07.2027 · Regulation (EU) 2024/1624 (AMLR): applies from 10.07.2027
- What we check
- The company is preparing for the AMLR: car sales above €250,000, a €10,000 cash limit across the EU, and checks on cash payments of €3,000.
- What it can cost
- New obligations and fines from July 2027.
- Evidence
- Plan
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.
