Financial Services Regulatory

For years, we have been handling complex regulatory projects and proceedings before the Polish Financial Supervision Authority (KNF), the National Bank of Poland (NBP), the Government Institute for Financial Market Supervision (GIIF), the Financial Ombudsman, and the President of the Office of Competition and Consumer Protection (UOKiK). Our banking and financial services law department is recognized in rankings such as IFLR 1000 and Chambers Europe.

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Our Approach

In our advisory services, we effectively combine an interdisciplinary approach with in-depth industry knowledge and a keen understanding of the regulator’s expectations and practices.

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We serve as a regular advisor to the Polish Bankers Association (ZBP) and participate in the work of many of its working groups. Our attorneys also gain up-to-date knowledge of the operations of regulated entities through secondments.

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How can we help?

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Licensing Proceedings

• We represent clients in licensing proceedings before the Polish Financial Supervision Authority (KNF)—both in standard licensing proceedings and in precedent-setting cases (including two instances of obtaining banking licenses).
• We assist clients with initial and ongoing communication with the KNF.

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Acquisitions of Regulated Entities

• We have advised on dozens of transactions involving the direct or indirect acquisition of regulated entities—in the banking, investment, insurance, and payments sectors.
• We assist Polish and foreign clients in planning transactions in accordance with local regulatory requirements.
• We conduct due diligence on the regulated entities being acquired.

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Cross-Border and Branch Operations

• We have unique experience in providing legal advice to branches of regulated entities—we support more than a dozen branches of credit institutions, investment firms, and EU insurance companies in various capacities, including through secondment arrangements.
• We advise on the “passporting” of branches of regulated entities and on foreign operations.
• We assist foreign clients with projects aimed at adapting their product offerings to local requirements.

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Regulated Outsourcing

• We draft and negotiate agreements subject to specific regulatory regimes (regulated outsourcing, DORA, NIS2).
• We advise regulated entities on drafting outsourcing provisions.
• We assist service providers (both global and local) in preparing product offerings and documentation used in their dealings with regulated entities.

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Client Documentation

• We prepare, review, and update model client documentation—for both consumers and business clients.
• We advise on consumer matters—including the Consumer Credit Act.
• We represent regulated entities in investigative proceedings, administrative proceedings, and court proceedings related to consumer protection.

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We work closely with our consumer protection team, which is recognized as one of the best and most effective in Poland.

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AML

We are leading Polish experts in the field of AML/CFT. Members of our team have completed additional training in AML/CFT, including courses organized by the GIIF and the Compliance Polska Association, and have obtained AML/CFT officer certifications.

• We have had the opportunity to lead AML/CFT projects for various types of regulated institutions, including banks, credit institutions, insurance groups, entities in the leasing, factoring, and lending industries, payment institutions, postal operators, as well as shared services providers that maintain accounting records, which has allowed us to gain broad-based experience in the AML/CFT field.
• We have conducted implementations and compliance audits within the regulatory frameworks of AMLD 3, AMLD 4, and AMLD 5.
• We regularly conduct compliance reviews.
• We also represent our clients in supervisory and enforcement proceedings before both the GIIF and the KNF. As a result, we possess practical knowledge regarding the expectations of supervisory authorities in the area of AML/CFT.
• We also have experience in preparing regulated institutions for periodic evaluations conducted by Moneyval.