An update is more than changing a row. A new director, owner, payer or activity can change risk and require verification. Preserve prior information, record effective and discovery dates and assess impact before the next relevant transaction.
Change or correction
Explain typo corrections; a changed address needs legal or factual evidence. Discovery and effective dates may differ. Record both where known and mark uncertainty. A customer notification triggers verification rather than automatically completing it.
Identify a new person actually acting and verify authority under the relevant procedure. Registering a new director alone does not identify them for the particular transaction. An old contact should not continue authorising payments merely because previously verified.
Ownership as a structure
Share sales, transformations, holding layers or control changes can alter ownership and risk. Obtain updated evidence and another necessary source. For registrable owners section 9(2)(b) requires the register plus another source; a customer-provided name list may be insufficient.
For shelf companies keep before-transfer ownership, transfer documents and the new state. The original company owner is not automatically the buyer’s current owner. Distinguish the service customer and company sold, as temporary roles and continuing address services may differ.
Risk-based and event-based updates
Section 8(9) requires checking validity/completeness and recording changes at risk-based frequency and scope. Add events to scheduled reviews: management, origin-country, purpose, financing or unusual performance changes. A long history alone is not low risk.
New PEP, sanctions or unclear ownership can require further measures. Justify scope. Missing evidence requires the applicable refusal/continuation assessment and separate suspicion assessment; an empty updated field is not resolution.
Preserve history
Keep prior state, new state, source, date and impact decision. Do not regenerate old protocols with new information and old dates. Restrict access and link records to statutory archives. An update does not automatically alter every document’s retention period.
Practical steps
- Record change, effective and discovery dates.
- Verify new people and authority.
- Reassess owners, structure and risk.
- Resolve missing evidence before dependent steps.
- Keep history and new measures.
Illustrative scenario
A customer reports a foreign owner following a share transfer. The accountant preserves the old file, obtains transfer/registry evidence, verifies new owners and updates risk, linking discovery and effective dates.
When the situation differs
A worker overwrites the owner name in the old protocol without knowing the ownership date, verifier or PEP/sanctions impact.
What to document
- Before and after states
- Evidence and verification date
- Risk and measure reasoning
Common pitfalls
- Losing earlier states
- Relying only on assertions
- Unverified new directors
Frequently asked questions
Does a new address require a complete new file?
Not automatically. Verify the change and significance, justify further checks and preserve history.
May the change be found in a register?
Yes. Assess its contents, currency and further evidence necessary for the question.
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
- Client updates and refusal: changes and missing cooperation — Ongoing checks, requests for missing information and deciding when a transaction or relationship cannot proceed.
- Beneficial owners: establish first, then verify — Distinguish identifying a beneficial owner, verifying identity and substantiating why the person owns or controls the company.
Sources and legal references
- Zákon č. 253/2008 Sb., aktuální znění od 11. 1. 2026 ↗
§ 8 odst. 4–6 a 9, § 9 odst. 2 a 6, § 15–16 · 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.