Big changes for crypto market

Poland: Registration requirement for crypto brokers came into force on 31.10.2021. Limit for anonymous transactions lowered to EUR 1.000

As of 31.10.2021 providing various services relating to cryptocurrencies requires an entry in a newly created register.

The registration requirement applies to the following services:

  • exchange between virtual currencies and fiat currencies;
  • exchange between virtual currencies;
  • intermediacy in exchanges mentioned under a and b above;
  • custodian wallets.

The prerequisites for obtaining an entry in the register are:

a) no criminal record with regard to the following crimes: against state and local government, against the administration of justice, against the credibility of documents, against property, against business and property interests in civil law transactions, against trading in currencies and securities;

b) experience or knowledge in the area of virtual currencies.

The experience prerequisite is deemed to be met by those conducting activity in the field of virtual currencies for at least one year.

The knowledge condition is deemed to be met by those who have completed training or a course covering legal or practical issues related to activity in the field of virtual currencies.

Both experience and knowledge must be evidenced by appropriate documentation. The law does not define more precisely the criteria which training and courses should meet to be acknowledged by the registration authority.

The requirements for registration apply to natural persons who provide virtual currency services as sole entrepreneurs and in the case of companies to managing directors.

The changes are accompanied by a new KYC (“know your customer”) threshold for transactions with virtual currencies. Previously, the threshold was EUR 15.000. As of 31.10.2021 customers have to be identified in the case of transactions over EUR 1.000. This change will mainly affect crypto ATMs. At the moment withdrawals are allowed only up to EUR 1.000 anonymously, whereas previously the amount was EUR 15.000.


Source: Act amending the Act on Prevention of Money Laundering and Financing of Terrorism and certain other acts of 30.03.2021 (Journal of Laws of 2021, item 815)

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