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Sanctions and matches

The Czech national sanctions list

Where to find the original Czech list, what to read in an entry and how to handle a change in its data structure.

Redakce eAML.czLegal position: 2026-10-04Editorial check: 2026-10-04

The Ministry of Foreign Affairs maintains and publishes the original Czech national sanctions list. Its open CSV can support screening. A decision on a particular transaction also requires the content of the entry, the measures imposed and their timing.

Start at the publisher’s page

The ministry publishes the list under Sanctions Policy and separately under Open Data. Its page explains that entries contain identifiers, a description of the relevant conduct, the scope of restrictive measures and publication dates. Read these together. A name without its measures is insufficient for deciding what action to take.

An open-data catalogue link helps locate a distribution but does not establish that your application downloaded and processed the current file correctly. For manual checks, record the original URL and access time. For automated imports, track the source URL, download status, size, checksum and content date. These technical records support rather than replace legal assessment.

    A Czech entry is not an EU entry

    The national list is based on Czech Act No. 1/2023 Coll. It is not a copy of the EU consolidated financial sanctions list. A person may appear in the sources at different times and under different legal grounds. Preserve the Czech provenance and link to the entry even if the same person also appears on an EU list.

    For confirmed identity, establish which measures affect your assets or services and the duties they entail. An AML obliged entity must also assess its reporting obligations; Sections 6(2) and 18 are relevant to sanctions circumstances. An ordinary business must address sanctions duties even without that AML status.

      CSV changes must be visible in operations

      The ministry flagged a structural change with its 23 July 2026 update: columns were removed or replaced and the display of amended entries changed. Imports based on old column positions can appear successful while producing incorrect screening. Validate the schema, required fields and handling of amended entries. If validation fails, use the original page and record the failure.

        A historical row is not automatically a current entry

        MFA’s CSV distribution for 23 July 2026 includes entry history and status. An import must not treat every non-empty row as a currently sanctioned person. Distinguish valid, cancelled and amended entries using the published fields and verify the current wording on the list page. Preserve older versions in audit history, but do not present them without explanation as today’s measures.

        If only the scope of measures changes, the person’s identity can remain the same while your service decision still needs reassessment. For cancellation, verify date and effects; deleting a local row does not resolve previous actions. Conversely, a historical match must not block a client indefinitely because the tool cannot distinguish it from an active entry. Separate current screening from evidence of past status.

          Practical steps

          1. Open the ministry’s current original attachment.
          2. Resolve identity and read the measures.
          3. Check EU, UN and other relevant regimes.
          4. Save timing, entry content and the decision.

          Illustrative scenario

          An office provider finds a Czech alert for the client’s owner and saves the entry with its measures, despite no result in the EU feed.

          When the situation differs

          After a schema change, software reads an empty column as the name, reports zero matches and leaves import status green.

          What to document

          • Original attachment and retrieval time.
          • Schema and completeness validation result.
          • Entry retaining the full scope of measures.

          Common pitfalls

          • Treating the Czech list as an optional EU add-on.
          • Downloading an old URL without checking the version.

          Frequently asked questions

          Is another application’s copy sufficient?

          It can support checking when provenance and freshness are known. Verify a relevant alert with the ministry and preserve the original legal context.

          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

          Sources and legal references

          1. MZV: Vnitrostátní sankční seznam ↗
            zveřejnění seznamu podle zákona č. 1/2023 Sb. · accessed 2026-10-04
          2. MZV: Otevřená data a změna struktury k 23. 7. 2026 ↗
            CSV a poznámka k aktualizaci · accessed 2026-10-04
          3. FAÚ: Informační zdroje k sankcím ↗
            oficiální rozcestník CZ/EU/OSN a TARIC · accessed 2026-10-04
          4. Zákon č. 253/2008 Sb., znění od 11. 1. 2026 ↗
            § 6, § 8 odst. 8, § 9 odst. 2, § 16, § 18 · accessed 2026-10-04
          5. MZV: CSV vnitrostátního seznamu, 23. 7. 2026 ↗
            distribuce se stavy a historickými zápisy; technická kontrola importu · 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.