Preparation for MIP license

Preparing for an MIP licence requires the applicant’s organisation to comply with MIP requirements.

1. Necessary adjustments to the organisation
   • designation of individuals responsible for managing the entity’s activities in providing payment services, including the submission of reports and statements to the FSA,,
   • designation of individuals responsible for AML/CFT:
     • designation of senior management to be responsible for the implementation of AML/CFT (anti-money laundering and counter-terrorist financing) obligations
     • in case of companies operating with a board of directors – appointment of a member of the board of directors to be responsible for the implementation of the obligations set out in the AML Law,
     • appointment of an employee occupying a managerial position, responsible for ensuring that the entity’s activities and its employees comply with the AML/CFT regulations and for reporting to the GIIF and the public prosecutor
   • designation of a person to be responsible for risk management
2. Outsourcing and agents
   • proper qualification and treatment regarding outsourcing (which services used by the MIP are not subject to the outsourcing rules, which constitute outsourcing, which constitute qualified outsourcing, consequences, development of internal and contractual documentation)
   • proper qualification and dealing with agents (identification of partners who will have agent status, development of internal and contractual documentation)
3. Legal classification of products for particular payment services
   • proper legal classification of the services the trader intends to provide (which payment service, whether the service is regulated or exempted)
4. Adjustment of the product to the requirements
   • proper customer relationship process (onboarding)
   • activity exclusively at the territory of the Republic of Poland
   • limit on payment transactions (EUR 1 500 000 per month on average)
   • limit on funds held in the account for a user (EUR 2 000)
5. IT infrastructure and security
   • Identification of the IT systems which will be used for MIP activities
   • Drafting a description of the infrastructure and security processes
6. Identification of cloud solutions used by the Principal