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PEPs and country risk

FATF increased monitoring and calls for action

Differences between FATF’s two statements and their use in risk assessment.

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

FATF publishes two separate statements. Increased monitoring supports remediation of strategic deficiencies. Calls for action may require enhanced due diligence or countermeasures according to the jurisdiction. Read the text, date and applicable Czech legal framework.

Increased monitoring is not a universal ban

The 19 June 2026 statement explains that monitored countries work through agreed action plans. FATF does not call for enhanced due diligence solely because of this category and rejects blanket de-risking instead of risk-based treatment. That does not switch off Czech statutory enhanced due diligence triggered by other relevant grounds.

Consider the country’s specific deficiencies, transaction connections and reliable evidence. Legitimate humanitarian or nonprofit activity should not be automatically cut off based on a colour label. Its facts, sanctions and statutory conditions still require assessment. Delisting does not establish low risk for every client.

    Calls for action have separate branches

    The June 2026 statement distinguishes countermeasure calls from a call for proportionate enhanced due diligence. Identical action cannot be assigned to all countries. Assess the wording and its reflection in applicable law and sector rules. Record the statement title rather than only the informal black-list label.

    National rules may require additional steps beyond FATF wording. The Czech high-risk third-country definition is not limited to the EU list. Link international evidence to the statutory branch and measures in internal assessments. Enhanced due diligence is not automatically sanctions freezing or a transaction ban.

      Process changes with dates and reasons

      As of 4 October 2026, the official index identified the 19 June 2026 publication. Before later use, open the current page; an article title does not guarantee ongoing freshness. Preserve earlier assessments, new statement dates and impacts on existing clients. Verify EU-list synchronisation separately.

        Practical effect of a statement change

        For a new edition, compare country status and wording of requested actions. An unchanged list title need not mean unchanged content. Identify clients with a relevant geographic link and add revised assessments to their files. Do not infer the link solely from citizenship if the actual service or funds connection lies elsewhere. For each measure, distinguish international recommendations from a mandatory Czech legal basis.

        For existing clients, merely raising scores in bulk without explanation may be inappropriate. Assess reported deficiencies and their relevance to your product, channel and transaction. Set feasible actions such as supplementing source-of-funds evidence, verifying structure or more frequent review as needed. Retain reasons and implementation. Removal is a review trigger, not automatic erasure of previously identified individual risks.

          Practical steps

          1. Open both current FATF statements.
          2. Identify the country-specific branch.
          3. Link it to Czech risk assessment and law.
          4. Record changes and required action.

          Illustrative scenario

          After a FATF update, an office adjusts geographic factors and separately checks whether effective EU law changed.

          When the situation differs

          All countries in both statements receive the same legal transaction-ban label.

          What to document

          • Versions of both statements.
          • Country-specific wording and legal connection.
          • Change-impact assessment.

          Common pitfalls

          • Informal colour without measure wording.
          • Automatically transferring FATF changes to EU data.

          Frequently asked questions

          Does FATF call for EDD for every monitored country?

          Not for increased monitoring in the June 2026 statement. Other statutory or individual EDD grounds remain relevant.

          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. FATF: Jurisdictions under Increased Monitoring, 19 June 2026 ↗
            význam zvýšeného sledování a risk-based approach · accessed 2026-10-04
          2. FATF: High-Risk Jurisdictions subject to a Call for Action, 19 June 2026 ↗
            rozlišení EDD a countermeasures · accessed 2026-10-04
          3. 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

          Editorial work and source checks are not independent legal approval of your particular process. Compare the conditions and exceptions with your own circumstances.