Money laundering risk management in banking system (Zarzadzanie ryzykiem prania pieniedzy w systemie bankowym)

The issue of risks concerning the money laundering in the European banking system is discussed in the article. Two approaches used by regulators to prevent the mentioned phenomenon: rule-based approach and risk-based approach are described. The author also identified strategies used by banks as entities functioning to maximizing profit in conditions of full and incomplete information having by the FIU. Then, the European countries were analyzed in respect of participating reports on suspicious transactions in the total number of reports sent by all the obligated entities to the national financial intelligence units. Verified was also the value of two indicators: the quality of above-threshold transactions and the quality of financial penalties, which are imposed on banks for failure to comply with the rules on anti-money laundering. Some hypotheses were examined. With the increase in GDP per capita the maximum value of the mentioned financial penalties was increased. There is a negative correlation between the financial sanctions and the share of banks in the total of reported suspicious transactions, which is a result of an extension list of the obligated entities and the lack of the differentiation of sanctions in the various categories of such entities. In connection with the applying of transitional period for implementing the directive by the banks, there is an inverse relationship between the amount of the penalty, and the number of suspicious transactions reports. With the increase in the real value of the minimum amount of abovethreshold transactions, falls the value of the maximum penalty imposed on a financial institution.