Rola przepisów odnoszących się do przeciwdziałania praniu pieniędzy w inkluzji finansowej na rynku usług płatniczych
The role of anti-money laundering regulations in financial inclusion in the payment services market

Summary/Abstract: Regulations on anti-money laundering and counter-terrorist financing (AML/CFT) play a crucial role in the global financial system, yet their implementation poses challenges in terms of financial inclusion. This article examines the relationship between AML/CFT requirements and financial inclusion, focusing on the basic payment account as an instrument supporting individuals at risk of financial exclusion. The study aims to assess the impact of AML/CFT regulations on limiting access to financial services and to identify mechanisms that balance system security with broad banking accessibility. The analysis covers issues related to the refusal to open a payment account, customer identification, and the application of simplified financial security measures. The research is based on an analysis of legal acts, recommendations from international supervisory institutions, and regulatory guidelines. Findings indicate that strict AML/CFT regulations may contribute to financial exclusion, particularly for individuals lacking full identity documentation. The application of simplified financial security measures and flexible regulatory approaches, such as those implemented for Ukrainian refugees, demonstrate the possibility of adapting AML/CFT requirements to specific social and economic conditions. The conclusions suggest the need for further regulatory adjustments to reduce barriers to financial services while maintaining the integrity of the financial system. In particular, developing standards that enable customer identification with limited documentation is crucial.

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