Establishing PEP status needs a proportionate process rather than just a checkbox. “I don’t know” requires clarification. Do not automatically convert it into either no status or confirmed status; establish the relevant function, connection and timing.
Ask understandable questions
Clients may not know the abbreviation or Czech definition. Explain prominent public functions with a few role examples without naming individuals. Separate personal functions, close persons and known close business relationships. Ask about former functions and changes during the relationship. Identify relevant individuals for companies; a corporate answer does not replace beneficial-owner identification.
For uncertainty, ask what role, institution or relationship is involved and when it existed. Do not demand a complete family tree or political opinions without justification. You need facts relevant to statutory status. Record the answer, explanation provided and remaining uncertainty. Distinguish refusal to cooperate from honest uncertainty.
Declarations are supplemented with sources
Use institutional pages, appointment announcements, registries or other credible evidence according to circumstances. Commercial databases can help but may show outdated roles, mistaken identity or a different status definition. Assess dates and identifiers. An unresolved name alert must not become a public claim about the client.
FAÚ’s national list contains functions, not every current officeholder. A missing name is therefore not negative screening. Set investigation scope according to risk and reliability. Resolve discrepancies between declarations and official evidence, retaining the explanation; signing a questionnaire does not remove the conflict.
Close the assessment and assign the next step
Record confirmed status, reasons for exclusion or unresolved questions. For confirmed PEPs apply Sections 9 and 9a. Material evidence gaps require assessment of whether due diligence can be completed and possible Section 15 action; urgency does not automatically permit approval. Track role changes during relationships and do not claim database completeness guarantees.
Working with an incomplete answer
For an “I do not know” response, establish what is unknown: the term’s meaning, scope of a family link, a business partner’s function or its end date. Each gap needs a different question. Repeatedly sending the same unexplained question is unhelpful. Give examples relevant to the client and ask for specific known facts. Assessing statutory status remains the obliged entity’s task.
Where information conflicts, describe both items without prematurely alleging a false answer. Official evidence may be old, the client may have misunderstood, or another person may share the name. Verify identity and period, obtain necessary supplements and record resolution. If unresolved, identify missing evidence and its effect on completing due diligence. Do not automatically replace an empty field with “no”.
Practical steps
- Explain the definition and separate relationship types.
- Clarify uncertainty with specific questions.
- Check relevant official sources and dates.
- Record conclusions, evidence and review triggers.
Illustrative scenario
A client is unsure whether a relative’s regional public role qualifies. The office checks powers and tenure against the definition.
When the situation differs
A form automatically converts a blank answer into no PEP status.
What to document
- Declaration and clarification.
- Dated role and identity evidence.
- Reasoned uncertainty assessment.
Common pitfalls
- Treating an unresolved name alert as fact.
- Treating a signed declaration as the whole assessment.
Frequently asked questions
Must uncertainty mean rejecting a client?
Not automatically. Clarify facts first; the key is whether statutory due diligence can be completed properly and what risks emerge.
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
- Politically exposed persons: direct PEPs and persons connected to them — Recognising prominent public functions and connected persons under Czech AML law.
- Close persons and other connections to PEPs — Assessing family and business connections without automatically extending status to every acquaintance.
Sources and legal references
- Zákon č. 253/2008 Sb., znění od 11. 1. 2026 ↗
§ 4 odst. 5, § 8 odst. 8, § 9, § 9a, § 15 odst. 2, § 54 odst. 8 · accessed 2026-10-04 - FAÚ: MP č. 7 – Opatření vůči PEP, vnitrostátní seznam funkcí ↗
definice, odvozené PEP, přiměřená opatření a trvání statusu; příloha 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.