A firm may be a bank’s customer and an obliged entity for its own services. A sole trader can be obliged just like a company. Assess each role separately; a bank’s information request does not transfer its statutory duties to the customer.
Legal form is not decisive
A self-employed external accountant and an accounting company may both fall within Section 2. Duties attach to the specific service provider. Employees perform measures for their employer under its procedures; this alone does not give them independent business status as an obliged entity.
Independent contractors may be different. An estate agent with their own authorisation is not necessarily merely a member of an agency’s staff. A cooperation agreement or shared brand does not itself determine who must comply.
Customers provide necessary cooperation
Under Sections 8 and 9, customers provide necessary identification information, explanations and documents. A company acts through an individual whose authority must also be established. A firm may explain its financing to its bank and its ownership to its accountant.
Cooperation does not require the customer to perform the bank’s due diligence or register every employee as an FAÚ contact person. Requests must relate to the specific service and necessary scope of due diligence.
Your own AML duties run alongside this
A registered-office provider is a customer of its bank and also checks the companies it serves. Completing the bank’s form does not create its own customer-acceptance system. Nor does a customer’s bank account prove that a bank checked that customer for your service.
Lawful reliance on certain measures under Section 11 may assist, but requires real information, access to documents and verification of the conditions. The relying obliged entity remains responsible. “My bank already verified me” is insufficient.
Create a role map
Assign a provider, customer, representative and decision-makers to each service. Separate customer contacts from your FAÚ contact person and designated governing-body member. One individual may hold several roles, but the legal meaning of each must remain clear.
Practical steps
- Identify the contractual provider and its statutory category.
- Describe the customer and representative in each transaction.
- Separate your own customer duties from cooperation with another obliged entity.
- Review independent contractors’ arrangements and access to evidence.
Illustrative scenario
A sole-trader accountant identifies a new corporate customer while her bank requests information on her own income. These are separate assessments of different relationships.
When the situation differs
A furniture manufacturer calls itself an obliged entity solely because its bank sent an AML questionnaire. Without a relevant Section 2 activity, that conclusion is wrong.
What to document
- Provider–customer–representative map for each service.
- Independent business authorisations and employment arrangements.
- Record of any lawful reliance on another entity’s measures.
Common pitfalls
- Confusing a customer contact with your FAÚ contact person.
- Confusing corporate responsibility with an employee’s assigned task.
Frequently asked questions
Can a sole trader be their own contact person?
Yes, where justified by the scale of their activities, Section 22(1) allows them to designate themselves.
May I ask why a document is needed?
Yes. Clarifying purpose and secure delivery is sensible, but refusing all information does not replace necessary statutory cooperation.
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
- Am I an obliged entity? Activities matter, not just a business ID — Map actual services to the Czech AML Act and identify conditions, authorisations and exemptions.
- Legal entities and their representatives — Four separate checks: company existence, personal identity, representation authority and beneficial ownership.
Sources and legal references
- Zákon č. 253/2008 Sb. — aktuální znění e-Sbírky ↗
§ 2, § 8 odst. 11, § 9 odst. 7, § 11, § 22a, § 54 odst. 1 · 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.