An AML business relationship need not involve a lengthy written agreement. What matters is whether duration or recurring performance is apparent at the outset. Calling an invoice “one-off” cannot change the substance.
Assess expectations at the outset
Section 4(2) concerns a relationship between an obliged entity acting in that capacity and another person for handling its assets or providing services, where duration or recurring performance is expected. Regular bookkeeping and continuing registered-office services typically indicate a relationship.
An occasional transaction may be an isolated service without expected continuation. Establish the agreement’s scope, planned follow-up work and product nature. Section 54(7) always treats certain cases as relationships, including account agreements and one-off deposits.
Different triggers, not a customer choice
Identification when establishing a relationship under Section 7(2)(b) is independent of EUR 1,000. Section 9(1)(b) due diligence follows before the transaction at the latest and continues throughout the relationship. A small monthly price is therefore not an exemption.
Transactions outside relationships have value and other triggers. The basic identification threshold is a value exceeding EUR 1,000, and due diligence has, among other triggers, a threshold of at least EUR 15,000. Special reasons and professional regimes also apply. Suspicious transactions trigger identification regardless of that basic threshold.
Recurring and divided services
Regular invoices, renewed orders and framework arrangements are significant indicators. Dividing a related transaction into invoices does not remove aggregation under Section 54(4). However, an unforeseen later order does not automatically prove that the first service was already a relationship.
Record initial expectations and subsequent changes. Once cooperation becomes continuing, apply relationship due diligence and monitoring. For further transactions with an identified customer, verify identity appropriately and keep information current.
Keep a timeline
Record the start, classification reason, completion of required measures, changes and end of the relationship. These affect retention too. Contract termination, the last invoice and the last known act may fall on different dates; your retention date must be explainable.
Practical steps
- Determine whether services are expected to continue or recur.
- Check cases statutorily treated as relationships.
- Apply the correct identification and due diligence trigger.
- Record regime changes and relevant dates.
Illustrative scenario
A year-long registered-office service is a continuing relationship even when its entire fee is paid once.
When the situation differs
A firm treats twelve monthly EUR 80 accounting invoices as unrelated transactions below the threshold. Expected regular cooperation constitutes a relationship.
What to document
- Agreement or description of arrangements and expected continuation.
- Classification date and reasons.
- Pre-transaction measures and ongoing update records.
Common pitfalls
- Equating one payment with no continuing relationship.
- Splitting planned cooperation into individual invoices.
Frequently asked questions
Must the relationship be in writing?
The AML definition in Section 4(2) does not itself require a written agreement. Substance and expected duration or recurrence matter.
Does every returning customer create a new relationship?
Not automatically. Review the original arrangement, interruption, expectations and record currency, and document your conclusion.
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
- AML monetary thresholds: value, currency and related transactions — Separate identification, due diligence and obliged-entity thresholds, including currency conversion and aggregation.
- New customers: from initial information to documented due diligence — A practical onboarding timeline from the legal trigger through verification, decision and records.
Sources and legal references
- Zákon č. 253/2008 Sb. — aktuální znění e-Sbírky ↗
§ 4 odst. 1–2, § 7 odst. 1–2, § 8 odst. 9, § 9 odst. 1, § 54 odst. 7, § 54 odst. 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.