The Impact of AML Requirements on Customers of Obligated Institutions

In her analysis for Future Finance Poland, Monika Szpakowska highlights a growing challenge for the financial sector: as AML/CFT regulations expand, customers face increasingly complex and burdensome KYC procedures. While stricter documentation requirements are a response to more sophisticated criminal activity, many clients struggle to understand why institutions repeatedly request additional information, declarations or proofs of fund origin – or why previously submitted documents no longer suffice.

A central source of friction is the beneficial ownership (UBO) process, which has become one of the most demanding elements of AML compliance. Clients report difficulties accessing registers, the need to translate documents, inconsistent national rules affecting multinational groups, challenges obtaining data from companies deep in ownership chains, and document expiry during lengthy verification procedures. Frequent changes in ownership structures only intensify these obligations.

This creates a dual burden for obligated institutions: they must meet ever-increasing regulatory expectations while ensuring that onboarding or periodic reviews do not feel like intrusive interrogations. Customer dissatisfaction – reflected in NPS results – is a growing risk factor. Yet the forthcoming EU AML package is unlikely to ease these pressures; instead, it will require even more extensive UBO data and documentation.

In this context, Monika Szpakowska stresses that customer education becomes essential. Transparent communication about regulatory drivers, process changes and the rationale behind documentation requests is currently the only way institutions can mitigate frustration and build understanding.

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