AML does not end at onboarding. Material changes may require reassessment; a signature on an old form cannot resolve information that mandatory checks require.
Checks throughout the relationship
During a relationship, verify that identification data remain valid and complete and record changes. Due diligence includes ongoing monitoring and comparison of transactions with the known client profile. There is no single statutory annual interval for every client; choose intervals and triggers according to risk.
Distinguish scheduled reviews from event-driven updates. A new director, owner, significant country, service or unusual payment pattern may require action before the next activity. The next calendar review does not defer that action.
Make requests for cooperation specific
Explain what information is missing and what it needs to clarify. Request proportionate evidence and accept a usable alternative where it establishes the same facts. Record requests, responses and unresolved discrepancies.
A short delay in one response is not automatically a suspicious transaction. Nevertheless, mandatory checks cannot be postponed beyond the point when they are required. Internal response deadlines must respect that legal timing.
When refusal or termination applies
Section 15 addresses refusal to undergo necessary identification, demonstrate authority or cooperate, inability to complete mandatory identification or due diligence, and doubts about information truthfulness or document authenticity. Depending on the circumstances, the obliged entity refuses the transaction or establishment of a relationship, or terminates it unless a special law prevents termination.
The decision must reflect its actual reason. You need not label the client an offender: missing evidence can itself prevent compliance. For existing relationships consider professional rules and appropriate termination arrangements, while avoiding activities that breach AML duties.
Suspicion and communication are separate
Refusal does not replace a suspicious transaction report. Assess the circumstances and any reporting duty separately. If a report is made, observe confidentiality: do not tell the client that a report has been or will be submitted or that related inquiries are taking place.
Routine communication can state factually that information needed for statutory duties was not provided. Retain the decision, evidence and correspondence. Ending cooperation does not shorten the legal retention period for AML records.
Practical steps
- Record the change and update the profile and risk.
- Request specific missing information before the relevant activity.
- Assess section 15 grounds and any special-law restrictions.
- Assess suspicion separately and preserve confidentiality.
Illustrative scenario
A client changes owners and refuses to explain the new structure. The office records its requests, incomplete due diligence and why the next relevant activity cannot proceed.
When the situation differs
An office waits for the annual review despite already knowing of a new director and an unclear beneficial owner.
What to document
- Changes and the dates they became known.
- Requests for cooperation and responses.
- Reasons for continuation, refusal or termination and a separate suspicion assessment.
Common pitfalls
- Replacing ongoing monitoring with an annual form.
- Continuing simply because the client already pays.
- Disclosing a suspicious transaction report to the client.
Frequently asked questions
Must every client be updated annually?
The law sets no uniform interval for all clients. Use a risk-based schedule and respond to significant changes.
Does refusal always mean reporting to FAÚ?
Not automatically. Assess the actual circumstances; refusal neither creates a reporting duty in every case nor replaces it.
Put this guidance into practice
Choose a record for the step you are working on. Adapt it to your profession and actual case.
- Individual and sole trader information · PDF / Word
- Legal entity and beneficial owner information · PDF / Word
Complete client information online
Where to go next
- New customers: from initial information to documented due diligence — A practical onboarding timeline from the legal trigger through verification, decision and records.
- Purpose and intended nature of the relationship: what to establish — Understand why the client needs the service, how the relationship will work and how to recognise later departures.
Sources and legal references
- Zákon č. 253/2008 Sb. — aktuální znění e-Sbírky ↗
§ 8 odst. 9; § 9 odst. 1 písm. c), odst. 2 písm. d); § 15; § 18; § 38 · accessed 2026-10-04 - FAÚ: Metodický pokyn č. 9 — kontrola klienta ↗
Účel vztahu, zdroje prostředků a průběžná kontrola · 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.