AML has no universal monetary limit. A value may determine obliged status, identification or due diligence. Identify the provision before comparing amounts.
Exceeding versus reaching
Basic identification under Section 7(1) applies once it is apparent that a transaction exceeds EUR 1,000. Exactly EUR 1,000 does not itself exceed it. However, an internal Section 7(4) threshold cannot be higher than the statutory amount, and other triggers may require identification independently.
Basic due diligence outside a relationship under Section 9(1)(a), point 1 applies at EUR 15,000 or more when Section 7(1) conditions are met. Exactly EUR 15,000 is included. Establishing a relationship and suspicious transactions have separate rules without that general value limit.
The same number may mean a different duty
At least EUR 10,000 matters for specified cash transactions by ordinary businesses, precious-metal and precious-stone transactions and specified art. The means-of-payment condition and activity scope differ. For estate-agency rental arrangements, the amount concerns monthly payments or the statutory monthly equivalent of proceeds, not the entire annual rent.
Funds transfers and gambling have specific Section 9 thresholds. Do not import banking or gambling limits into accounting practices. This map is introductory; assign the trigger to the actual category and product.
Date the conversion
Section 54(3) uses the Czech National Bank rate valid on the day the duty is performed; if unavailable, use the previous day’s rate. Record currency, value, rate, date and calculation. A bank’s commercial rate, monthly accounting rate or today’s rate for a historical check may be wrong.
For variable-value arrangements, track when reaching or exceeding the threshold becomes apparent. Do not wait for the final instalment if the price is already known.
Aggregate related performance
Section 54(4) adds the values of related separate acts within a divided transaction. Assess links using purpose, agreements, participants and sequence. AML aggregation is not restricted to one calendar day; that daily rule belongs to the separate cash-payments statute.
Also record why you consider acts separate and unrelated. Splitting documents or using different currencies does not remove their connection.
Practical steps
- Identify the legal category and specific trigger.
- Distinguish “exceeds”, “at least” and cases without a threshold.
- Aggregate related acts and apply the correct CNB rate.
- Perform measures as soon as the value is apparent.
Illustrative scenario
A EUR 1,200 service is paid in two EUR 600 instalments. The service value determines basic identification, not each instalment separately.
When the situation differs
A practice charging EUR 100 monthly waits for annual payments to exceed EUR 1,000 although a business relationship begins at the outset.
What to document
- Value calculation, exchange rate and its date.
- Evidence linking individual acts.
- Exact provision, internal threshold and measure-completion time.
Common pitfalls
- Describing every threshold as “over EUR 10,000”.
- Applying AML aggregation only within one day.
Frequently asked questions
Must I aggregate all of a customer’s transactions forever?
Not automatically. Section 54(4) addresses related acts of a divided transaction; relationship monitoring is a separate duty.
Can I act below the threshold?
Internal rules may set a lower risk-based threshold. Data collection must still have a purpose and be proportionate.
Put this guidance into practice
Choose a record for the step you are working on. Adapt it to your profession and actual case.
- Practice obligations map · PDF / Word
- Art, cultural heritage and free-zone storage →
- Precious metals and stones →
- Gambling →
Complete client information online
Where to go next
- Business relationships and occasional transactions — Distinguish continuing cooperation from an individual service and identify when customer measures are required.
- AML and cash: different statutes, different limits — Separate AML measures from restrictions on large cash payments and use the correct aggregation rules.
Sources and legal references
- Zákon č. 253/2008 Sb. — aktuální znění e-Sbírky ↗
§ 2 odst. 1 písm. d), i), n), odst. 2 písm. c)–d), § 7, § 9 odst. 1, § 54 odst. 3–4 · accessed 2026-10-04
Editorial work and source checks are not independent legal approval of your particular process. Compare the conditions and exceptions with your own circumstances.