Bank Gospodarstwa Krajowego was one of the first state-owned companies, which in mid-September 2024 announced the completion of internal audits covering its activities from 2015 to 2023. This was to be a kind of opening report related to the change of management following the change of government. The audit procedures, most of which were carried out by the Bank's own staff, covered six areas: foundations, marketing, HR, capital investments, internal operations and IT. What attracted particular attention was the almost 100-fold increase in donations made by four BGK foundations – from PLN 1.8 million to PLN 103 million.

On this basis, acting on behalf of the BGK Management Board appointed in the spring of this year, lawyers from four DZP practices carried out a review to assess the conduct and liability of members of the bank's management in connection with irregularities involving the foundations.

The first stage of the review was of a preliminary nature and covered an analysis of BGK's internal reports and a Supreme Audit Office report of 15 January 2024 and was aimed at assessing whether the breaches identified by BGK could constitute a crime. This stage ended in May with the issuance of an opinion in which DZP's lawyers confirmed the breaches (and potential liability) and recommended further investigation based on source material. Further work culminated in the presentation to the Management Board of a memorandum in which the persons potentially liable for specific breaches were identified and source documents were provided to verify this liability. As a consequence of this in-depth investigation, the DZP team also prepared a report summarising the work, which was delivered on 24 September.

The audit was carried out by experts in banking law and advising financial institutions – Magdalena Skowrońska and Paweł Rudolf, advisers on legislation and compliance – Anna Hlebicka-Józefowicz and Gniewomir Wycichowski-Kuchta, labour law – Agata Mierzwa and Justyna Tyc-Brzosko, and litigation lawyers – Rafał Karbowniczek and Małgorzata Karasińska – specialists in criminal business proceedings.

As a result of the investigation, on the request of BGK's Management Board, on 16 October Rafał Karbowniczek and Małgorzata Karasińska filed with the District Public Prosecutor's Office in Warsaw a notice of suspicion of crimes having been committed to the bank's detriment covered by Article 258(1) of the Criminal Code, Article 296(3) of the Criminal Code read with Article 12(1) of the Criminal Code, i.e. suspicion of involvement in an organised criminal group and causing damage to the economy by abuse of power.