Countries of the client, funds origin and transaction

Build a map rather than one label

For individuals, separate nationality, residence, actual activity and economic connections. A company’s registered office may differ from its main operations. The payment account may be elsewhere than the funds’ origin. Record the economic source and transaction link; bank location alone does not explain sale proceeds, business income or other sources.

For company formation or office provision, assess planned activities and relevant owners. Czech addresses and new Czech accounts do not establish that all activities and funds are Czech. Map recipients, transit and onward use in cross-border transactions. Explain data requirements through relevant connections rather than requesting every country in the client’s life.

Assign each source its legal significance

Distinguish FATF evidence, the effective EU high-risk-country list and sanctions regimes. Czech Section 9a assesses relevant country of origin or transaction connections. One automated score cannot replace statutory triggers. A country outside public lists may still present individual risk through other evidenced circumstances.

Assess the credibility and importance of connections. Citizenship without other relevant facts is not a universal service ban. Unsupported funds-origin claims differ from residence in a country. Mark unknown information and the plan to obtain it; empty fields must not automatically generate the lowest risk.

The map changes during a relationship

Update the map after changes in owners, activities, banks, payment routes or target markets. Explain impacts on measures and retain historical versions. New transactions may differ from onboarding connections. Do not rely on a years-old questionnaire where commercial facts materially changed.

Example of a Czech company with foreign links

A new Czech company requests an office address and gives a Czech account. Its owner operates elsewhere and funds reportedly come from a business sale in a third country. Record links separately and determine how they relate to the service and planned activity. A Czech account may facilitate tracing payment but does not explain its economic source. Choose questions based on the flow, not a foreign-client label.

If the company later operates in another country or receives payments from different entities, assess the effect on the original assessment. Not every minor change requires complete onboarding again, but material change needs appropriate review and explanation. Record information source, significance and supplements. Address genuinely unknown source of funds separately rather than hiding it behind a low score for the Czech registered office.