An accounting job title alone does not determine AML status. An external business provider is an obliged entity. An employee keeping their employer’s accounts is not a separate obliged entity on that basis. Determine who supplies the service, to whom, under what arrangement and responsibility.
Three operating models
An independent accountant serves customers as a business. An accounting company serves them through staff, with the company holding the duties and arranging performance. An in-house employee works for their own employer as dependent employment. That work alone does not require personal internal AML procedures or a separate contact-person notification.
The employer may nevertheless be an obliged entity through another activity such as property trading. An accounting employee can then perform allocated AML tasks in its system. Distinguish personal professional status from workplace duties; internal accounting does not exempt the employer’s business.
Look beyond the contract label
“Administrative assistance” cannot conceal actual external bookkeeping. Equally, shared resources and costs among related companies are not automatically independent services to third-party customers. FAÚ refers to the CJEU judgment in C-3/24 MISTRAL TRANS distinguishing independent external services from resource-sharing among related companies. Czech classification must fit authorisation and actual activity.
For mixed models describe group services and market services separately. A related first customer does not establish a universal exemption. Record parties, work, authorisation, remuneration and organisational responsibility.
Responsibility for files
The obliged entity should allocate identification, ownership/risk assessment and decisions on missing cooperation. Grant access by role rather than to everyone. Training and records concern people involved in statutory tasks under the applicable regime. Access to invoices is not automatic permission to see internal suspicious-transaction reporting.
Changes in the model
Becoming an independent contractor, opening a shared centre to external customers or creating an accounting company alters the facts. Keep the earlier classification and change date. Data transfer from the old employer alone does not give the new provider a completed system.
When transferring engagements, check the legal basis for transferring particular customer records. The new provider needs assigned responsibility and access to evidence. Saying the same accountant continues working does not resolve the change in contractual entity.
Practical steps
- Identify contractual provider and recipient.
- Describe employment or business arrangements.
- Assess employer and supplier activities.
- Allocate tasks, access and training where AML applies.
Illustrative scenario
An accountant employed by an online shop works only on its operations. They are not a separate external-accountant obliged entity. If they start independently serving other companies, assess that business separately.
When the situation differs
An accountant invoices customers for “office support” while actually keeping their accounts. A different label does not exempt the service from assessment.
What to document
- Employment or service agreement
- Service/customer map
- Classification and staff responsibilities
Common pitfalls
- Using job titles as legal status
- Unexamined group-wide exemptions
- Unnecessary sharing of reporting information
Frequently asked questions
Can an employee be the AML contact person?
Yes, where the employer is obliged and designation conditions are met. This is a role in the employer’s system, not proof of separate accountant status.
Does an outside customer change the assessment?
It requires reassessment at least. A conclusion based exclusively on intragroup resource-sharing cannot remain without justification.
Put this guidance into practice
Choose a record for the step you are working on. Adapt it to your profession and actual case.
- New bookkeeping client checklist · PDF / Word
- Property sale checklist · PDF / Word
- External accountants →
Complete client information online
Where to go next
- Company, sole trader and customer: distinct AML roles — Distinguish the obliged entity, its staff and the customer asked for documents by a bank or adviser.
- Who is responsible for AML in a company? — Assign management, contact-person, staff and supplier roles without leaving a gap before a transaction.
Sources and legal references
- Zákon č. 253/2008 Sb., aktuální znění od 11. 1. 2026 ↗
§ 2 odst. 1 písm. e), odst. 3, § 21–23 · accessed 2026-10-04 - FAÚ: Účetní ↗
Interní účetní; externí účetní a C-3/24 · 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.