TRANSAKCJE PONADPROGOWE W BIURACH RACHUNKOWYCH A INSTYTUCJA CZYNNEGO ŻALU. ZARYS PROBLEMATYKI
SUPRATHRESHOLD TRANSACTIONS IN ACCOUNTING OFFICES AND THE INSTITUTION OF ACTIVE REPENTANCE: OUTLINE OF THE ISSUES

Summary/Abstract: The Act of 1 March 1 2018 on counteracting money laundering and terrorist financing states thatcertain obliged institutions, in particular entrepreneurs providing accounting services, are to informthe General Inspector of Financial Information about the deposits or withdrawals of funds with anequivalent value of more than 15,000 Euro. Despite publicly available information in this regard,these entrepreneurs remain in state of acute uncertainty concerning the correct interpretation of theobligation referred to in Article 72.1 of the cited law.As a consequence of the often incorrect interpretation of the provision, they apply to the su-pervisory authority to include their behaviour in the category of the institution of active repentance.This article attempts to make a balanced interpretation of Article 72.1 of the Act on counteractingmoney laundering and terrorist financing regarding the possibility of an entrepreneur invoking theinstitution of active repentance.

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