The Czech national list of PEP functions

Where to find the list and what to retain

FAÚ publishes the national list as an annex to Methodological Guideline 7. At checking time, the index identifies the version dated 17 July 2024. That is not a date of current officeholders. Retain the annex version and do not claim screening against all PEPs when only reading a functions overview.

FAÚ treats the Czech national list as an exhaustive list of functions establishing direct domestic PEP status. It links categories to institutions and powers. If a client uses an abbreviation or different title, establish whether the actual function belongs to a listed category. A similar name alone is insufficient. Under this guidance, an unlisted function does not establish direct domestic PEP status.

Applying it to a client

Obtain the title, institution, start and end dates and evidence of the officeholder’s identity. Use relevant official announcements or institutional pages. Avoid confusing namesakes. Separate whether a role is prominent from whether your client holds it. The list supports the first question but does not itself answer the second.

Derived status requires evidence of a statutory relationship to a direct PEP. For EU and relevant international-organisation functions, also use the Commission’s consolidated official functions list. For other foreign roles, apply Section 4(5) and comparable prominence. The Czech annex is not a complete foreign-functions list. Establish country and institution before drawing conclusions from absence in the Czech list.

Classifying the function begins the process

Confirmed status leads to proportionate enhanced due diligence and further measures. Former functions require retained history and Section 54(8) assessment. The list does not verify wealth, authorise transactions or replace sanctions screening. Internal procedures need subsequent decision points, responsible roles and evidence, not only an annex link.

Similarly named functions require substantive assessment

A client may give only “director” or “council member” as a title. Add the institution’s name, public or private character and actual powers. Neither classify all directors as PEPs nor automatically exclude them. Use the function list for the Czech category and the applicable legal rule for foreign roles and current evidence for verifying the particular holder. These three steps require different evidence.

After an institutional rename or reorganisation, verify whether the actual function still corresponds to a listed category. Exact title matching is not the whole test, but prominence of a new Czech role does not permit arbitrarily expanding FAÚ’s exhaustive list. Resolve uncertainty through current official evidence and record reasons. Separate function classification, officeholder verification and transaction measures. Process annex changes with dates without overwriting historical checks.