RYNEK USŁUG APTECZNYCH A POLSKI SYSTEM PRZECIWDZIAŁANIA PRANIU PIENIĘDZY. ZARYS PROBLEMATYKI
THE PHARMACY SERVICES MARKET AND THE POLISH ANTI-MONEY LAUNDERING REGIME: OUTLINE OF THE ISSUES

Summary/Abstract: The Act of March 1, 2018 on counteracting money laundering and fi nancing of terrorism obliges every entrepreneur to comply with it to the extent that he accepts or makes payments for goods in cash with a value equal to or exceeding the equivalent of EUR 10 000. Importantly, this obligation exists regardless of whether such a transaction is carried out as a single operation or several operations that appear to be interrelated. Therefore, this catalog also includes entrepreneurs operating in the fi eld of broadly understood pharmacy services. However, the degree of their preparation for the application of the Act is not satisfactory. One possible reason for this may be that Article 2 of the Act does not explicitly state that entrepreneurs providing pharmacy services are to be identifi ed with the obliged institution. This state of aff airs may albo stem from the fact that the Polish AML/CFT system is flawed and generates doubts about its functioning.

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