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Reputational risk associated with the identification of PZU’s activities with money laundering and terrorist financing or the risk of using PZU’s activities for money laundering or terrorist financing, compliance risk associated with inadequate implementation of the AML/CFT law into business and operational processes and failure to implement them correctly.
There is a separate owner of the AML/CFT area in PZU Życie, responsible for the entire process, monitoring its quality and effectiveness, adherence to existing internal procedures and setting standards for AML/CFT in the PZU Group. The Management Board Member overseeing the security area at PZU Życie is responsible for implementing the obligations for counteracting money laundering and terrorism financing prescribed by the AML Act. The AML area includes: The Security Threat Analysis Team, which implements the current AML/CFT processes, while the activity standards and target process, including the implementation of the IT system, is being developed under the AML Project.
: Security procedures in the area of anti-money laundering and terrorist financing in PZU Życie and the PZU Group, Rules for the protection of employees and affiliates of PZU Życie performing activities related to the implementation of certain anti-money laundering and terrorist financing obligations.
The security procedure in the area of counteracting money laundering and terrorism financing in PZU Życie
PZU Życie has a “Security Procedure in the Area of AntiMoney Laundering and Financing of Terrorism”, which sets out the steps the Company takes to ensure compliance with applicable regulations and to safeguard its business against establishing and maintaining business relationships with entities suspected of money laundering and financing of terrorism.
These activities include:
- a risk assessment of money laundering and financing terrorism related to the establishment of business relations or a transaction related to an insurance agreement;
- the application of financial security measures (assessment of the current situation and potential risks) of the client prior to the establishment of a business relationship and entitled when paying out funds under the insurance contract;
- applying financial security measures according to client risk, such as enhanced assessment of the current situation and potential risks for clients affiliated with high-risk countries or holding politically exposed positions;
- analysis of clients and their transactions in the context of identifying suspect transactions;
- employee training on counteracting money laundering and terrorism financing;
- monitoring existing business relationships.
Anti-Money Laundering and Countering the Financing of Terrorism in subsidiaries
The PZU Group has a group procedure in place for countering money laundering and terrorism financing. PZU is not subject to the AML Act, but as the parent company of the PZU Group, it has adopted a group procedure and established standards in the area of AML and rules for the exchange and protection of information between Group companies that safeguard the Group’s operations against money laundering and terrorism financing. The procedure covers all obliged institutions (obliged to apply the AML Law) in the PZU Group, both domestic and foreign.
| PZU Group units covered by the group procedure on countering money laundering and financing of terrorism | PZU Group | |
|---|---|---|
| 2021 | 2022 | |
| Companies | 19 | 18 |
| Investment funds | 15 | 15 |
Best practices of PZU and PZU Życie
Prevention activities – training
Detailed information on prevention and prophylactic security measures is set forth in the “Instructions regarding prevention and prophylactic security measures in PZU and PZU Życie”. It spans actions to raise the awareness of security risks in the following areas:
- information security;
- cybersecurity;
- physical safety;
- counteracting crime;
- counteracting money laundering and terrorism financing;
- business continuity.
Best practices of PZU and PZU Życie
Prevention activities – training
Risk awareness is a crucial part of the company’s security system functioning correctly; that is why all employees and intermediaries of PZU Życie, as an obliged institution, should be trained and have up-to-date knowledge of the applicable internal regulations and other necessary internal rules on fraud prevention, counteracting money laundering and terrorism financing. Therefore, a comprehensive training plan for employees and associates has been implemented:
- mandatory e-learning “Countering Money Laundering and Terrorism Financing” is being addressed to all newly hired employees and exclusive agents at PZU Życie,
- employees and agents from sales and client service units receive refresher training annually as part of their professional training.
In addition, in 2022, as the amendment to the AML Law came into effect, the content of the e-learning “Countering Money Laundering and Terrorism Financing” was updated and every PZU Życie employee was required to pass the aforementioned training.
The head of the organizational cell or unit in which the employee is employed is responsible for overseeing training. The head of the organizational cell or unit of the Head Office supervising a given structure is responsible for supervising the employees of local structures of divisions and tied intermediaries.
| E-learning: “Counteracting money laundering and terrorism financing” | PZU Życie and agents | |
| 2021 | 2022 | |
| Number of people trained | 437 | 9,601 |
Commentary to the 2021/2022 changes – in 2021, AML training was mandatory only for newly hired employees. In 2022, it was mandated to refresh the updated training for all PZU Życie employees.