GIIF Reporting – AML/CFT Reporting Support
GIIF is the General Inspector of Financial Information, Poland’s Financial Intelligence Unit.
GIIF reporting is specialist support for obliged entities that need to assess cases appropriately, gather relevant data and documentation, and submit required AML/CFT information. Dueveris AML supports case analysis, preparation of reports and notifications, communication with GIIF, and decision documentation – within a model tailored to your organisation’s processes, systems and risk profile.
SPEAK WITH AN EXPERT ABOUT GIIF REPORTINGIs Your GIIF Reporting Process Ready for Complex Cases?
GIIF reporting begins well before information is submitted. It requires effective analysis, complete data collection, a clear decision and documentation showing why the case was escalated.
The process may need strengthening when:
An Alert Requires Enhanced Analysis
The case cannot be closed without gathering further information and assessing its context.
There Is Uncertainty About the Next Step
The team lacks clear criteria for closing, escalating or preparing a case for reporting.
Data and Documentation Are Fragmented
Information from KYC, transactions, screening and customer communications must be compiled from multiple sources.
Reports Require Manual Data Collection
Preparing the material involves multiple people and increases the risk of gaps or delays.
There Is No Clear Approval Path
It is unclear who analyses the case, who makes the decision and who is responsible for approval.
GIIF Requests Information or Documentation
The organisation must quickly gather complete materials and provide them in a structured format.
Documentation Does Not Show the Full Decision History
It is difficult to demonstrate what was reviewed, what the findings were and why a particular action was taken.
The Organisation Is Preparing for an AML Inspection
The process needs to be structured so that decisions, reports and follow-up actions are consistent and demonstrable.
Not Every Alert Results in a GIIF Notification
An alert is a signal that certain activity requires review. It does not automatically indicate suspicion or require information to be submitted to GIIF.
Only analysis can connect the alert with the customer profile, relationship history, transactions and available documentation. The outcome may be case closure, further analysis, a KYC update, escalation or preparation of information for GIIF.
Risk signal → case analysis → data collection → decision and escalation → information submission → follow-up actions
A notification to GIIF is the result of a well-founded AML decision – not an automatic response to every alert.
What Does GIIF Reporting Cover?
The scope of obligations depends on the type of case and the organisation’s activities. Reporting is not limited to submitting data – it requires collecting, verifying and properly assessing information, as well as documenting the decision.
Information on Reportable Transactions
Preparation and completeness checks for data relating to transactions subject to reporting requirements.
Suspicious Activity and Suspicious Transaction Reports (SARs/STRs)
Case analysis, evidence gathering and preparation of a rationale where circumstances may indicate money laundering or terrorist financing.
Cases Involving a Specific Transaction or Assets
Support in assessing and preparing materials where there is reasonable suspicion that a specific transaction or assets are linked to AML/CFT risk.
GIIF Communications and Information Requests
Coordinating responses, compiling documents and preparing information required during the case.
Quarterly Reporting to GIIF
Preparation and submission of quarterly AML/CFT statistical reports by obliged institutions subject to this requirement.
How Does Dueveris AML Support GIIF Reporting?
We support organisations at every stage of a case – from the initial review of a risk signal to preparation of materials, decision documentation and follow-up actions. Support can cover selected stages or the full process.
We support the preparation of suspicious transaction notifications / SARs and STRs, periodic reports, quarterly statistics – where applicable to the relevant entity – as well as other required information and explanations for the competent authorities. Our support is provided with due regard to confidentiality requirements and restrictions on disclosing information about an analysis or notification.
Case Assessment
We assess whether an alert, transaction or other information requires further analysis, escalation or preparation of materials for GIIF.
Customer, Transaction and Context Analysis
We combine KYC or KYB data, relationship history, transaction activity, screening results and available documentation.
Preparation of the Case Rationale
We organise the facts, identify risk indicators and describe actions taken during the analysis.
Data and Document Collection
We help gather information from systems, operational teams, customer service, accounting, risk and compliance functions.
Preparation of Submission Materials
We support the preparation of complete materials in line with the organisation’s reporting and approval process.
Escalation and Allocation of Responsibilities
We structure roles, approval levels and rules for handing cases between analysts, compliance, the AML Officer and authorised decision-makers.
Documentation and Audit Trail
We maintain a structured record of findings, decisions, documents and follow-up actions.
Process Quality Assurance
We review the completeness of materials, consistency of rationales, documentation quality and timely handling of cases.
A Good GIIF Submission Starts with Sound Analysis
Information submitted to GIIF should not merely be a collection of data. It should clearly show what gave rise to concern, what was reviewed and why the organisation took a particular decision.
Facts
Who carried out what activity, when and how – including relevant transactions, assets and parties involved.
Context
The customer profile, purpose of the relationship, declared use of the service and relationship history.
Analysis
Elements that differ from expected behaviour, together with information that confirms or explains the risk.
Decision
Actions taken, the rationale for escalation or reporting, and the next steps in the case.
How Does Dueveris AML Manage the GIIF Reporting Process?
We support your organisation from identifying a case through to preparing complete materials and documenting the decision. We work in line with the agreed allocation of responsibilities, procedures and approval path.
1. Case Identification
We analyse an alert, unusual activity, a KYC discrepancy or other information requiring further action.
2. Data and Document Collection
We compile information on the customer, relationship, transactions, screening and communications related to the case.
3. Analysis and Risk Assessment
We assess whether the activity has a reasonable explanation, which elements give rise to risk and whether further information is required.
4. Decision and Escalation
We prepare a recommendation for the next steps and refer the case to the appropriate approval level.
5. Preparation of Submission Materials
We organise the data, rationale and documentation required to submit the information in line with the organisation’s procedures.
6. Documentation and Follow-Up Actions
We maintain the full case history, support responses to further requests and identify actions required after the analysis is complete.
GIIF Reporting and Other Dueveris AML Services
GIIF reporting is a stage that may follow findings from transaction monitoring, KYC, KYB and other AML/CFT processes. Its purpose is to make the appropriate decision, prepare complete materials and document the organisation’s actions.
| Service | Primary Role |
|---|---|
| AML/CFT Transaction Monitoring | Identifying and analysing alerts related to customer activity. |
| Individual KYC Verification | Assessing an individual’s identity, profile and risk. |
| Business KYB Verification | Analysing a company, its representation, ownership structure and beneficial owners. |
| GIIF Reporting | Case assessment, decision-making, documentation and preparation of information for submission. |
| AML/CFT Outsourcing | Operational delivery of multiple AML/CFT processes. |
| External AML Officer | Oversight of risk, procedures, process quality and AML/CFT decisions. |
What Does a Well-Managed GIIF Reporting Process Change?
It enables your organisation to identify cases requiring escalation more quickly, collect information from the right sources and make decisions based on a complete view of the customer and their activity.
It also provides a clear allocation of responsibilities, consistent documentation and a complete audit trail for each case. This leaves the organisation better prepared for GIIF requests, AML inspections and complex cases requiring prompt action.
Need to structure your GIIF reporting process or prepare materials for a complex AML/CFT case?
Let’s discuss a support model tailored to your procedures, systems, volumes and risk profile.
Email Us
office@dueverisaml.pl
