The Act of 1 March 1 2018 on counteracting money laundering and terrorist financing states that certain obliged institutions, in particular entrepreneurs providing accounting services, are to inform the General Inspector of Financial Information about the deposits or withdrawals of funds with an equivalent value of more than 15,000 Euro. Despite publicly available information in this regard, these entrepreneurs remain in state of acute uncertainty concerning the correct interpretation of the obligation referred to in Article 72.1 of the cited law.
As a consequence of the often incorrect interpretation of the provision, they apply to the supervisory authority to include their behaviour in the category of the institution of active repentance. This article attempts to make a balanced interpretation of Article 72.1 of the Act on counteracting money laundering and terrorist financing regarding the possibility of an entrepreneur invoking the institution of active repentance.