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The PZU Group has a group procedure on preventing money laundering and financing of terrorism. 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. Also, each company has implemented its own anti-money laundering and counter-terrorist financing procedures.
There is a separate owner of the AML/CFT area in PZU Życie, who is responsible for the entire process, for 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 AML Department 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, and the AML Regulations and Processes Team which handles the control of how AML obligations have been implemented, while the activity standards and target process, including the implementation of the IT system, is being developed under the AML Project.
| PZU Group units covered by the group procedure on preventing money laundering and financing of terrorism | PZU Group | |
|---|---|---|
| 2022 | 2023 | |
| Companies | 18 | 19* |
| Investment funds | 15 | 32** |
**in addition to the investment funds of PZU TFI, the investment funds of Alior TFI and Pekao TFI were shown as well (in preceding years they were not included in the number of IOs).
The Security Procedure in the Area of Preventing Money Laundering and Terrorism Financing in PZU Życie
PZU Życie has a “Security Procedure in the Area of Anti-Money 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) with respect to the client prior to the establishment of a business relationship and with respect to the beneficiaries 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.
| E-learning: “Counteracting money laundering and terrorism financing” | PZU Życie employees and agents | |
|---|---|---|
| 2022 | 2023 | |
| Number of people trained | 9,601 | 9,153 |
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 obligated institution, should be trained and have upto-date knowledge of the applicable internal regulations and other necessary internal rules on preventing money laundering and terrorism financing. A comprehensive training plan for employees and associates has been implemented and it encompasses:
- mandatory e-learning course “Preventing Money Laundering and Terrorism Financing” for all the newly hired employees and exclusive agents at PZU Życie,
- employees and agents from sales and client service units receive a refresher course annually as part of their professional training.
The head of the organizational unit in which the employee is employed is responsible for supervision over the training. The head of the organizational unit of the Head Office supervising a given structure is responsible for supervising the employees of local structures of divisions and exclusive intermediaries.