Start by inventorying actual services and processes. Transition is more than changing the law number on a template. Each change needs a legal basis, application date, responsible person, verified test and preserved historical evidence.
Inventory first
List real activities, customers, channels and contractual roles. An address provider may also form and sell shelf companies and temporarily represent customers. Accountants can have relationships and occasional services. One future form does not resolve all situations identically.
Record current identification, due diligence, risk assessment, suspicion procedures, contacts, training and archives. Identify evidence and current gaps. Fixing a present gap does not depend on future AMLR application.
Map duties individually
Link each current item to its future AMLR article, national rules and dependent standards. State confirmed basic act, verified final document or unresolved detail. Deadlines follow particular rules rather than one assumed date.
Assess owners, PEP, sanctions, enhanced measures, monitoring and approvals alongside identity fields. Form changes may require supplier contracts or access-role changes. Record dependencies between exports and secure archives.
Data and suppliers
Check information type, retention period, starting event and transition. A shorter future period must not erase earlier statutory files without assessment. Check export, post-termination availability and lawful deletion.
Give suppliers concrete field, source, version and evidence requirements. “AML 2027 supported” is not a test. Check unavailable sources, uncertain ownership and status changes during a relationship.
Synthetic tests and rollout
Use model cases without real personal data. Check activity scope, boundary values, remote methods, open issues, exports and both languages. Include failures; one simple company case does not demonstrate every exception.
Record version and limits. Once legal conditions are confirmed, assign changes, update instructions and evidence training. Internal tests are not external user validation or independent legal approval.
Practical steps
- Inventory activities and current duties.
- Map future rules and dependencies.
- Assign owners and conditional deadlines.
- Check data, suppliers and export.
- Test synthetic cases and document rollout.
Illustrative scenario
A small company service provider tests address, formation and shelf-company ownership changes separately, including temporal rules and export completeness, while applying current rules to current customers.
When the situation differs
A firm replaces “253/2008” with “2024/1624” on a cover page without assessing fields, triggers, archives or professional procedures. Transition is incomplete.
What to document
- Process inventory
- Transition and dependency map
- Test results and training
Common pitfalls
- Renaming templates only
- Deleting historical archives
- Supplier claims instead of testing
Frequently asked questions
Must I buy new software?
Not automatically. Identify changes and evaluate the current process first. Demonstrating duties matters more than a product’s label.
When is the checklist complete?
When applicable conditions are confirmed, changes implemented and tested, and open issues resolved. A completed plan alone is not rollout.
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
- Risk assessment and internal policies: what your business needs — Applicability, written form and exceptions for risk assessment and internal policies.
- AML service providers, DPA, incidents and exit — Provider roles, processor contracts, personal-data breaches and taking over files at exit.
Sources and legal references
- Zákon č. 253/2008 Sb., aktuální znění od 11. 1. 2026 ↗
§ 2, § 8–9, § 16, § 21–23; budoucí AMLR odděleně · accessed 2026-10-04 - AMLR 2024/1624 ↗
Čl. 9–11, 19–28, 77 a 90 · 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.