Do not use one threshold for galleries, antique dealers, jewellers and pawnbrokers. The Act distinguishes item type, authorisation, activity, value and payment method. One item can fall under several categories. Record the condition being assessed and other potentially applicable regimes.
Art and cultural objects
Trading or intermediation in Annex 3 artworks falls within section 2(1)(i) at a value of at least EUR 10,000. Cultural monuments and objects of cultural value are listed separately; do not import the artwork threshold into their category. The same point covers authorised storage in free zones under its own conditions.
A “decoration” or “collector’s item” label is not decisive. Use the item’s description and legal classification. In intermediation map the original seller and buyer; gallery staff or a platform cannot replace their roles with one order name.
Precious metals and stones
Section 2(1)(n) dealers assess Annex 1 items and a transaction value of at least EUR 10,000. Bank transfers do not exclude this category. Link goods, valuation, customer and payment. A bank account alone does not establish legitimate origins of funds or the item.
For bars, jewellery, stones or other products use the actual annex classification. Also assess used goods, intermediation and other services. Being below one threshold is not an automatic exemption from another provision.
Used goods, pawning and cash
Section 2(1)(j) covers authorised used-goods trading, intermediation and accepting collateral without a general EUR 10,000 classification threshold. Specified purchases, acceptance for intermediation and pawning trigger identification under section 7(2)(c) regardless of the general limit.
For another business or non-business legal entity a cash transaction of at least EUR 10,000 can create transaction-specific duties. Section 54 aggregates connected payments and extends the AML meaning of cash payment to specified commodities and virtual assets. Do not import that definition automatically into separate cash limitation legislation.
A limited regime still has duties
Section 28 sets a particular duty package for specified persons, including identification, due diligence, retention, reporting, information and confidentiality. Justify its application by exact classification. Provenance, unusual price or financing discrepancies may need explanation. Value alone must not be treated as proof of illegality.
Section 28 applies to the specified persons whose obliged status arises at the EUR 10,000 transaction threshold, with an exception for free-zone operators. Do not extend it automatically to every cultural object or an entire business carrying out several concurrent activities.
Practical steps
- Classify item and activity.
- Calculate connected consideration and currency.
- Identify customer parties and payment method.
- Apply the particular customer and record duties.
- Assess provenance, funding and suspicion.
Illustrative scenario
A dealer sells a new Annex 1 item for EUR 12,000 by bank transfer. Lack of cash does not exempt it from point n; it also documents whether used-goods classification applies.
When the situation differs
A pawnbroker accepts used jewellery for EUR 400 and skips identification by citing EUR 10,000. It overlooked another category and the special collateral trigger.
What to document
- Item legal classification
- Valuation and connected consideration
- Identity, provenance and payments
Common pitfalls
- One threshold for all goods
- Non-cash as a blanket exemption
- Splitting one transaction into small payments
Frequently asked questions
Does exactly EUR 10,000 count?
Yes where the provision says at least EUR 10,000 or EUR 10,000 or more. Distinguish classification from other identification triggers.
Must every item have origin evidence?
The relevant regime and risk determine the necessary scope. Record category and justification rather than applying a blanket claim to all items.
Put this guidance into practice
Choose a record for the step you are working on. Adapt it to your profession and actual case.
- New bookkeeping client checklist · PDF / Word
- Property sale checklist · PDF / Word
- Art, cultural heritage and free-zone storage →
- Precious metals and stones →
- Used goods and pawnbrokers →
Complete client information online
Where to go next
- AML monetary thresholds: value, currency and related transactions — Separate identification, due diligence and obliged-entity thresholds, including currency conversion and aggregation.
- 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 od 11. 1. 2026 ↗
§ 2 odst. 1 písm. i), j), n), odst. 2 písm. c)–d), § 7 odst. 2 písm. c), § 28, § 54; přílohy 1 a 3 · 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.