Anti-money laundering and countering the financing of terrorism regulations apply primarily to obligated institutions and competent state authorities. This does not mean, however, that these regulations do not also apply to other categories of entities within the framework of specific solutions. The Polish law on this issue introduces and defines the concept of senior management, a group of specific individuals to whom subsequent provisions assign specific responsibilities, crucial both for the proper implementation of the AML/CFT process at the obligated institution and for ML/FT risk in general. Furthermore, the law also provides for far-reaching potential sanctions for this group of individuals. The aforementioned concept of senior management is inherently diverse. Due to the importance of this structure for the AML/CFT system, the author decided to conduct a broader analysis to assess its adequacy for AML/ CFT purposes and the achievement of the system’s objectives, with particular emphasis on the principles and scope of responsibility provided for in Polish law and EU legal acts. In order to answer this question, the author analyses the legal definition, the tasks of individual persons and the resulting roles in the AML/CFT system, as well as the principles of responsibility assigned to this group of persons.