Senior Legal Counsel – AML/CFT

Senior Legal Counsel – AML/CFT at PKO Bank Polski

PKO Bank Polski is seeking a Senior Legal Counsel to lead AML/CFT (Anti-Money Laundering / Combating the Financing of Terrorism) legal advisory within our Compliance Division. Based at our ul. Puławska headquarters in Warsaw, you will play a critical role in ensuring the bank's compliance with Poland's stringent AML regime.

About the Role

You will serve as the primary legal advisor on all matters relating to the Ustawa o przeciwdziałaniu praniu pieniędzy oraz finansowaniu terroryzmu (AML/CFT Act) and the EU Anti-Money Laundering Directives (AMLD 5 & 6). The role involves advising on customer due diligence (CDD), enhanced due diligence (EDD) for high-risk clients, suspicious transaction reporting to the Generalny Inspektor Informacji Finansowej (GIIF), and sanctions compliance.

You will work closely with the bank's AML operations team, oversee the legal aspects of transaction monitoring systems, and represent PKO BP in interactions with GIIF, KNF, and law enforcement authorities. Experience with the Central Register of Beneficial Owners (CRBR) and EU sanctions screening is essential.

• Provide legal advisory on all AML/CFT matters across the bank's operations
• Oversee legal compliance of CDD/EDD procedures and transaction monitoring systems
• Advise on suspicious transaction reporting to GIIF and coordinate with law enforcement
• Ensure compliance with EU and international sanctions through screening and policy updates
• Lead AML/CFT legal risk assessments and remediation programmes
• Represent the bank in KNF and GIIF supervisory proceedings related to AML
• Train compliance officers and business lines on AML legal requirements

• Qualified radca prawny with 6-10 years of experience in AML/CFT compliance at a bank or financial institution
• Expert knowledge of the Ustawa o przeciwdziałaniu praniu pieniędzy oraz finansowaniu terroryzmu and AMLD 5/6
• Experience with GIIF reporting procedures and KNF AML supervisory expectations
• Familiarity with EU and international sanctions regimes (OFAC, EU restrictive measures)
• Knowledge of the CRBR (Central Register of Beneficial Owners) and beneficial ownership verification
• Fluent Polish and English; CAMS or ICA certification a strong advantage