Start by determining your statutory category and services. Then choose the customer procedure. AML involves several separate tasks: identification, customer due diligence, risk management and recordkeeping each have their own conditions.
Define your activities first
Section 2 of Act No. 253/2008 Coll. defines obliged entities. These include financial institutions, external accountants, specified legal services, real estate activities and providers of registered offices and company formation services. A business identification number or the label “consulting” does not settle the question. List your actual services, authorisations, customers and remuneration.
Check activities performed alongside your main service. A registered-office provider cannot postpone AML merely because it only occasionally forms companies. An employee keeping accounts for their employer does not automatically become a separate obliged entity.
Separate the customer measures
Identification establishes and verifies the identity of the customer and the person acting on its behalf using a lawful method. Section 9 due diligence adds the purpose of the service, beneficial ownership, ownership and management structure, funds and ongoing monitoring where relevant. A customer declaration is an input; a staff member must assess it.
Establishing a business relationship triggers identification irrespective of price and due diligence before a transaction. For an occasional transaction, check its value, other triggers and special professional rules. A small amount does not justify ignoring suspicion.
Prepare operations before accepting customers
Assign responsibility for collecting information, verifying it and deciding on discrepancies. Establish risk assessment, applicable internal procedures, cover arrangements, training and secure records. Preparing written internal rules and submitting them to an authority are separate duties and do not apply identically to every category. The same is true of contact-person requirements.
For professions with special provisions, examine Sections 26–29b. Add profession-specific duties to the general checklist; do not turn it into an automatic compliance certificate. An escalation route must be available before executing a difficult transaction.
Record what actually happened
The file must show what was done, when, using which source and why the scope was proportionate. Retain unresolved questions and subsequent updates. A green score or an exported empty questionnaire cannot replace this trail. Monitor changes in the customer and in rules affecting the procedure.
Practical steps
- Map every service to Section 2 and document any exemptions.
- Determine whether the case concerns a relationship or an occasional transaction and identify the applicable trigger.
- Choose lawful identification and complete necessary due diligence before the relevant act.
- Record decisions, responsibilities, retention and triggers for further checks.
Illustrative scenario
A firm starts providing registered offices. Before the first agreement it establishes its Section 2(1)(h) status and sets up identification of the representative and corporate due diligence covering ownership and service purpose.
When the situation differs
A firm purchases a template, asks the customer to tick a declaration and provides the registered office without verifying identity. The form does not prove that the measures were performed.
What to document
- Service map with statutory provisions and exemption reasoning.
- Identification and due diligence records, sources and staff decisions.
- Internal roles, applicable procedure versions and retention arrangements.
Common pitfalls
- Treating a small fee as an exemption from relationship due diligence.
- Assuming a bank’s checks satisfy your own duties without lawful reliance.
Frequently asked questions
Must every small firm prepare the same documents?
No. The statutory category, actual activity and exemptions determine the duties. Small operations do not by themselves remove customer measures.
When must I finish?
Before the moment specified by the applicable trigger. When establishing a relationship, necessary measures cannot wait until the first large invoice.
Put this guidance into practice
Choose a record for the step you are working on. Adapt it to your profession and actual case.
Complete client information online
Where to go next
- Am I an obliged entity? Activities matter, not just a business ID — Map actual services to the Czech AML Act and identify conditions, authorisations and exemptions.
- Identification and customer due diligence are different — Identity, purpose, beneficial ownership and funds: assign the correct customer measures.
Sources and legal references
- Zákon č. 253/2008 Sb. — aktuální znění e-Sbírky ↗
§ 2, § 7–9a, § 15–16, § 18, § 21–23, § 28–29b · 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.