A firm performs AML through people and tools. Buying software or assigning work to one employee does not itself transfer statutory duties to a supplier. Tasks require authority, availability and demonstrable decisions.
Management needs a specific designation
Under Section 22a, an obliged entity designates a governing-body member in writing to ensure AML compliance. The deadline is 60 days after obliged status arises or the previous designated member ceases to hold office. If there is only one member, the statute deems that member designated. Check special provisions for your category.
This designated person is not automatically the Section 22 contact person. Management responsibility concerns supervision, processes and resources; the contact role concerns FAÚ communication and suspicious-transaction reporting. One individual may hold both roles where the conditions are satisfied.
Staff must know when to stop
Assign identity verification, ownership review, source-of-funds assessment and risk-factor assessment. Staff need accessible procedures and training relevant to their tasks. A “completed” record must reflect actual measures, not just filling in a form.
Give staff authority to stop internal case completion where necessary information is absent. Specify who assesses refusal of service, enhanced measures and suspicion. Do not wait for a regular meeting when the statutory action point occurs earlier.
Suppliers and contractors have different capacities
A supplier may collect data or provide technical screening. This does not itself constitute statutory reliance on identification. Section 11 provides different routes with their own conditions and retains the obliged entity’s responsibility.
A contact person must be an employee or governing-body member, or the sole trader themselves where justified. An external adviser cannot assume this role merely through a contractual label. An independent estate agent or accountant may also have separate AML status despite a shared brand.
Test cover arrangements and actual operations
Try a synthetic case during the contact person’s holiday or a system outage. Decision-makers must obtain documents and staff must know how to escalate securely. Management checks actual use of procedures, access roles and persistent deficiencies as well as the existence of documents. Preserve role-change history.
Practical steps
- Map roles and check Sections 22 and 22a applicability.
- Write down tasks, authority and cover arrangements.
- Train staff using relevant scenarios.
- Test stopping a case and accessing its evidence.
Illustrative scenario
A company with two managing directors designates one for AML in writing, appoints an employee as contact person and gives intake staff an escalation procedure for unclear ownership.
When the situation differs
A software supplier claims to “assume AML responsibility” and the firm stops assessing contradictions in customer documents.
What to document
- Written designation and organisational map.
- Contact-person authority and cover.
- Training, decisions and internal deficiency assessments.
Common pitfalls
- Merging every role into a vague “AML specialist” title.
- Appointing someone without document access or escalation authority.
Frequently asked questions
Can one employee perform every step?
There is no universal headcount. Arrangements must match scale and risks; even a small operation needs clear decisions and cover.
Does designation release everyone else from responsibility?
No. It specifies an internal role rather than universally removing duties from the company or other persons.
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
- FAÚ contact person: when and how to notify — Designation, notification exemptions, current deadlines and XML submission through a data box.
- What AML software can do and what people must assess — Limits of forms, registers, screening and risk scores in actual identification and due diligence.
Sources and legal references
- Zákon č. 253/2008 Sb. — aktuální znění e-Sbírky ↗
§ 11 odst. 4–5, § 21–23, § 22a, § 54 odst. 6 · 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.