Central Contact Point (CCP) in Poland – AML/CFT Compliance Support
A Central Contact Point is a local AML/CFT function for selected foreign, including European, payment institutions, electronic money institutions, CASPs (Crypto-Asset Service Providers), and other regulated entities operating in Poland through agents, distributors, or other local infrastructure, where the operating model requires a local contact or coordination function.
At Dueveris AML, we support the establishment and day-to-day operation of the CCP – from adapting procedures to Polish requirements and overseeing the local network to reporting to head office, preparing documentation, and coordinating communication with the relevant authorities.
SPEAK WITH A CCP EXPERTIs a Central Contact Point the Right Model for Your Organisation?
A Central Contact Point may be an appropriate solution for selected foreign, including European, payment institutions, electronic money institutions, CASPs, and other regulated entities operating in Poland through agents, distributors, or other local infrastructure, where the operating model requires a local contact or coordination function. The scope depends on the organisation’s local presence model, scale of operations, and AML/CFT risk profile.
It is worth considering this model when:
You Operate Through Agents, Distributors or Local Partners
Customer service and AML/CFT processes are carried out outside head office.
Your Head Office Is Based in Another EU Country
You need a local link between group policy and Polish processes.
Your Local Network Is Growing
The number of agents, partners, service points or transaction volumes is increasing.
Global Policies Do Not Reflect Local Practice
Group procedures do not fully address Polish roles, processes and escalation paths.
Documentation Is Fragmented
Information, registers and evidence of process delivery are difficult to compile quickly across the local network.
Head Office Does Not Have Full Visibility of AML/CFT Risk in Poland
Regular reporting on incidents, gaps and remedial actions is missing.
You Need Local Coordination of Communications with Authorities
Responses, documents and explanations require a single, structured point of responsibility.
You Are Preparing for Growth or Regulatory Change
You want to build an AML/CFT oversight model that can scale with your operations in Poland.
A Central Contact Point as a Local AML/CFT Oversight Function
A Central Contact Point connects group AML/CFT policies with their application in Poland. It coordinates oversight of the local network, identifies gaps, supports remediation and ensures information flows between agents, distributors, head office and competent authorities.
Head Office → CCP in Poland → Agents, Distributors and Local Processes
A CCP does not take over the institution’s regulatory responsibility. It does, however, provide local coordination of AML/CFT processes, documentation, reporting and escalations.
What Does CCP Support at Dueveris AML Cover?
We support the Central Contact Point as a local AML/CFT oversight function – from designing the operating model to ongoing reporting and supervision of the local network.
CCP Operating Model Design
Defining roles, responsibilities, data access and escalation paths.
Adapting AML/CFT Requirements to Poland
Translating group policies into local procedures, instructions and registers.
Oversight of Agents and Partners
Reviewing the application of AML/CFT rules across the local network.
Process Quality Assurance
Case reviews, analysis of errors, incidents and areas requiring improvement.
Reporting to Head Office
Regular reporting on risks, gaps, incidents and remedial actions.
Training for the Local Network
Training for agents, distributors and operational teams.
Coordination of Communications with Authorities
Support with preparing documents, responses and explanations within the agreed mandate.
Inspection Readiness
Organising documentation, evidence of process delivery and responsibilities for presenting it.
A Group AML Policy Is Not Enough Without Local Implementation
Group policy sets the standards. To work effectively in Poland, it must be translated into local roles, procedures, documentation and a framework for overseeing the network.
| Head Office | Central Contact Point | Local Network |
|---|---|---|
| Sets group-wide standards | Adapts them to Polish requirements | Applies them in day-to-day operations |
| Manages risk at group level | Monitors risks and gaps in Poland | Handles customers and transactions |
| Receives reports | Coordinates data, escalations and remedial actions | Provides documentation and information |
| Makes strategic decisions | Supports local AML/CFT compliance | Responds in line with procedures |
The Central Contact Point turns general group requirements into a local AML/CFT process that can be applied, monitored and demonstrated.
How Is a Central Contact Point Implemented?
1. We Analyse the Operating Model in Poland
We assess the network of agents and distributors, processes, products and existing AML/CFT controls.
2. We Map Local Risks and Obligations
We identify areas requiring oversight, documentation, reporting or changes to operating arrangements.
3. We Design the CCP Model
We define roles, responsibilities, data access, escalation paths and reporting to head office.
4. We Adapt Procedures and Supporting Materials
We prepare local instructions, registers, checklists and reporting templates.
5. We Implement the Model Across the Local Network
We communicate the operating requirements to agents, distributors and operational teams.
6. We Provide Ongoing Oversight
We carry out reviews, reporting, remedial actions and support with matters requiring escalation.
What Data and Documents Should Be Available to the CCP?
To oversee local operations effectively, the CCP needs access to information showing how the network applies AML/CFT requirements and where risks arise.
- A register of agents, distributors and partners
- Their roles and scope of activities
- Local AML/CFT procedures, instructions and registers
- Training records and results
- A register of incidents, breaches and remedial actions
- KYC, screening and alert data, to the extent necessary for oversight
- Quality assurance and review findings
- Reports submitted to head office
- Documentation and explanations prepared for competent authorities
Dueveris AML CCP Support Models
CCP Readiness Assessment
Analysis of the operating model, local network, risks and the scope of the required CCP function.
Central Contact Point Implementation
Design of roles, procedures, reporting, registers and oversight arrangements for local operations.
Ongoing CCP Support
Regular reporting, reviews, training, quality assurance and coordination of remedial actions.
Interim CCP Support
Support when entering the Polish market, expanding the network, reorganising operations or preparing for an inspection.
CCP, External AML Officer or AML/CFT Outsourcing?
Each model addresses a different organisational need.
| Organisational Need | Appropriate Model |
|---|---|
| Local AML/CFT oversight of agents, distributors or partners in Poland | Central Contact Point |
| Ongoing AML/CFT oversight and management support for decision-making | External AML Officer |
| Day-to-day delivery of KYC, KYB, screening, monitoring and alert-handling processes | AML/CFT Outsourcing |
Regulatory Outlook: 2027
The EU AML Directive provides for the possibility of requiring a Central Contact Point for electronic money issuers, payment service providers and crypto-asset service providers operating in another EU Member State through agents, distributors or other local infrastructure.
Member States are required to implement these rules by 10 July 2027. The final scope of obligations in Poland will depend on national implementing legislation and the institution’s operating model.
Do You Need Support in Establishing a Central Contact Point in Poland?
Let’s discuss the scope of obligations, the engagement model and a solution tailored to your organisation’s structure.
Email Us
office@dueverisaml.pl
