AML Policy
Last updated: 6 November 2026
1. Our commitment
ARGOCLOUD Sp. z o.o. applies a zero-tolerance approach to money laundering, terrorist financing, bribery and sanctions evasion. This policy follows the Polish Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing, EU Directive 2015/849 (as amended) and EU sanctions regulations.
2. Know Your Customer (KYC)
Before entering into a business relationship we verify the client's identity: company name, registration number (KRS/VAT), registered address and authorised representatives. We identify the ultimate beneficial owners, including through the Central Register of Beneficial Owners (CRBR), and may request supporting documents.
3. Sanctions and PEP screening
All clients and beneficial owners are screened against EU, UN, UK and US (OFAC) sanctions lists and checked for politically exposed person (PEP) status. We do not do business with sanctioned persons or entities, or in embargoed jurisdictions.
4. Risk-based approach
Each client receives a risk rating based on country, sector, ownership structure and transaction profile. Higher-risk relationships are subject to enhanced due diligence, including source-of-funds verification and management approval.
5. Payments
We accept payments only by bank transfer from accounts held in the name of the contracting client. We do not accept cash, cryptocurrencies or third-party payments, and every invoice is linked to a signed order.
6. Monitoring and reporting
We monitor business relationships on an ongoing basis. Suspicious transactions are reported to the General Inspector of Financial Information (GIIF) and, where relevant, to law enforcement authorities. We may suspend or refuse a transaction if due diligence cannot be completed.
7. Record keeping and training
KYC records and transaction documentation are kept for 5 years after the end of the relationship. Employees receive regular AML and sanctions training, and the policy is reviewed at least once a year by the Management Board.
8. Contact and whistleblowing
Questions or reports concerning AML compliance can be sent confidentially to contact@argocloud.pl (subject: “AML”). Whistleblowers are protected in accordance with the Polish Act on the Protection of Whistleblowers.