New 2027 AML Rules - PESEL Number Required for Purchases

The AMLR Regulation - a Revolution in Buyer Verification from July 2027

In mid-July 2027, the EU AMLR regulation (Anti-Money Laundering Regulation) will come into force, fundamentally changing the way we make higher-value purchases. The new rules introduce mandatory identity verification of buyers for transactions exceeding certain thresholds - regardless of the form of payment. This means that even a transfer from an official bank account will no longer be sufficient proof that the funds are legitimate.

Existing anti-money laundering (AML) regulations differed significantly between EU Member States. Criminals exploited these discrepancies by moving their operations to countries with more lenient supervision. The AMLR is intended to close this loophole for good by establishing uniform verification rules applicable across the whole Union.

For Polish consumers, the most important change will be the need to provide detailed personal data - including the PESEL number - for purchases worth more than €10,000, which is roughly PLN 43,000. This is a threshold that many Poles may exceed when buying a car, electronic equipment or made-to-order furniture.

Who Is Affected by the New Verification Obligations?

One of the most groundbreaking changes introduced by the AML package is the radical expansion of the list of entities required to carry out Customer Due Diligence (CDD) procedures. Until now, the obligation to verify customers thoroughly was associated almost exclusively with banks and other financial institutions. From July 2027, this obligation will cover a much wider group of businesses.

The new rules impose verification obligations on, among others, the following entities:

• Luxury goods dealers - car showrooms, jewellers, and sellers of watches and premium clothing
• Real estate market - agents, developers and property managers
• Art market - galleries, auction houses and independent art dealers
• Crypto-asset service providers - cryptocurrency exchanges and digital wallets
• Crowdfunding platforms - community funding services
• Lending companies - entities providing non-bank loans
• Professionals - lawyers and legal advisers within a specified scope of services
• Sports clubs - in particular in the context of player transfers

For many of these sectors, implementing AML/CFT procedures will be entirely new. Experts stress that trading companies have only a year to adapt to requirements that financial institutions have spent a decade working on. This is a huge logistical, technological and legal challenge.

Two Verification Thresholds - Cash Under Special Scrutiny

The €10,000 Threshold - Full Verification for Every Form of Payment

The basic verification threshold set out in the AMLR is €10,000. Every transaction exceeding this amount - whether paid by transfer, card or cash - will require a full buyer identification procedure. The seller will be obliged to collect and verify data such as the PESEL number, tax identification number (NIP), IBAN, and in some cases also to identify the beneficial owner of the transaction.

This means that when buying, for example, a used car for PLN 50,000 from a dealer, we will have to go through a verification procedure similar to the one we know from opening a bank account. The seller will not only check our identity document, but will also have to document the entire transaction in case of a possible inspection.

The €3,000 Threshold - Simplified Verification of Cash Transactions

Even stricter limits are envisaged for payments made in cash. For transactions worth €3,000 (around PLN 13,000), a simplified CDD procedure will be required, provided the transaction carries a low risk of financial crime. In practice, this means the buyer's identity must be fully established even for relatively small cash purchases.

It is also worth remembering that the AMLR introduces an absolute ban on accepting cash payments above €10,000 by businesses. This limit applies both to single transactions and to series of linked operations, which is intended to prevent the artificial splitting of payments to circumvent the rules - a practice known as structuring or smurfing.

How to Prepare Your Business for the AMLR Requirements

Businesses whose activities will be covered by the new regulations should start preparing to implement the required procedures now. Time is pressing - there is little time left until July 2027, and the scope of obligations is considerable. Proper preparation requires action on several fronts at the same time.

First of all, it will be necessary to develop an internal AML procedure that sets out in detail the rules for identifying customers, monitoring transactions and reporting suspicious operations to the General Inspector of Financial Information (GIIF). This procedure must take into account the specific nature of the sector in which the entity operates and the level of risk associated with its customer base.

The next step is staff training in recognising warning signs that may indicate money laundering or terrorist financing. Employees who deal directly with customers must know what data to collect, how to verify it, and in which situations to refuse to carry out a transaction. Failure to meet these obligations may result in severe administrative and financial sanctions.

It is also worth considering technological solutions that automate verification processes. Platforms are available on the market that enable efficient customer identification, document verification and screening against sanctions lists and PEPs (politically exposed persons). Such tools can significantly shorten customer service time and minimise the risk of human error.

Consequences for Consumers and the Market - What You Should Know

The new AMLR rules will have a noticeable impact on the everyday shopping experience of Poles. Every transaction exceeding the threshold mentioned will take longer and require the disclosure of data that sellers have not previously collected. It is worth being prepared for the fact that buying a car, jewellery or a work of art will involve formalities previously reserved for financial institutions.

From a personal data protection perspective, an important question arises about the security of information collected by entities that previously did not have to manage such sensitive data. Businesses subject to the new obligations will have to ensure that their procedures comply not only with the AMLR, but also with the GDPR, which presents them with a double regulatory challenge.

At the same time, experts stress that harmonising the rules across the European Union should have a positive effect on the transparency of business transactions and make it harder for criminals to use legitimate commercial infrastructure to hide illicit funds. For honest market participants, these regulations may mean greater transaction security and confidence that their counterparties have been properly verified.

Need Legal Support with AML? Contact Us

Implementing the requirements of the AMLR is a complex process that requires specialist legal knowledge and an understanding of anti-money laundering regulations. Our firm offers comprehensive support in preparing AML procedures, training employees and providing ongoing advice on regulatory compliance.

Do not wait until the last minute - contact us today to discuss your company's situation and plan together the process of adapting to the new rules. Professional preparation will help you avoid sanctions and ensure continuity of operations once the regulations come into force.