A Temporary Foreigner Identity Certificate is a valid identity document for opening a bank account in Poland

The Polish Financial Supervision Authority (hereinafter referred to as the Financial Supervision Authority) sent a letter to supervised banks, emphasizing that these institutions (including banks) are required, when applying financial security measures under the Anti-Money Laundering Act, to consider all documents that may confirm the identity of a foreigner. The Authority specifically noted that a Temporary Foreigner Identity Certificate should be fully recognized as such a document.

This clarification was provided in response to a formal inquiry submitted by Pavel Latushka, Deputy Head of the United Transitional Cabinet and Head of the National Anti-Crisis Management (NAM). The inquiry was part of a broader communication effort involving the Ministry of Foreign Affairs, the Ministry of Interior, and the Financial Supervision Authority, coordinated by the NAM and the Office for the Transition of Power of the United Transitional Cabinet. These efforts were undertaken at the request of former political prisoners and the Belarusian Association of Former Political Prisoners "Da Voli".

This position establishes the Temporary Foreigner Identity Certificate as a legitimate basis for opening bank accounts for Belarusians who, due to the repressive policies of the Lukashenko regime, have been forced into exile in Poland and are currently awaiting international protection.

The Financial Supervision Authority also highlighted that, in light of sanctions imposed on Belarus, Belarusian nationals may fall into a group of clients considered at higher risk of money laundering and terrorist financing. However, "refusing to establish or deciding to terminate business relations cannot be justified solely on the grounds of classifying a client as high-risk".

Before making such decisions, banks must ensure they have considered all available risk mitigation measures. "Every decision to refuse or terminate business relations must be justified, documented, and made available to the supervisory authority upon request".

The Authority also stressed that it is inappropriate to automatically treat all clients from one group (in this case, Belarusian citizens) as equally high-risk without conducting an individual risk assessment of each potential client. Such an approach may be considered unjustified by the Financial Supervision Authority and may indicate ineffective risk management on the part of the financial institution.

The Financial Supervision Authority also reported that the Polish Travel Document for Foreigners is not considered a valid identity document and therefore cannot be used for opening a bank account. It was further noted that the Authority’s position on this matter has been forwarded to the Ministry of the Interior of Poland, with an indication that in order for the Travel Document for Foreigners to be recognized as a valid document for the identification and verification of identity when opening a bank account, appropriate amendments to the Act on Foreigners would be required. The National Anti-Crisis Management and the Office for the Transition of Power of the United Transitional Cabinetwill submit a follow-up request to the Ministry of the Interior of Poland, asking it to consider these matters positively.

Furthermore, the Financial Supervision Authority clarified that it is currently not possible to open a bank account solely based on a Belarusian passport with a humanitarian visa.

Banks have the right to request documents from potential clients confirming the purpose and nature of opening the account, as this is part of their legal obligations under existing regulations.

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