Leaving public office does not automatically end PEP measures. Section 54(8) of the AML Act requires at least 12 months and assessment of remaining PEP-specific risk. Both conditions must be considered.
Establish the actual end of office
Record when the relevant function actually ended and credible evidence. Elections, press releases or planned resignation may differ from the end of office. Check whether another prominent function began. For multiple roles, assess each relevant connection, not only the one a commercial database labels primary.
For connected persons, record links to the direct officeholder and changes. FAÚ guidance applies continued-status rules to connected PEPs as well. A surname, employment or registry change alone does not establish that the connection and specific risk ended.
Twelve months is a minimum
Duties and restrictions continue for at least 12 months and until the entity’s risk assessment excludes PEP-specific risk. An automatic one-year timer does not perform that assessment. Equally, claiming every PEP must retain the highest internal risk score forever is incorrect.
Assess continuing influence, former-institution links, wealth and transaction characteristics, new business roles and known circumstances. Adapt measures to risk within statutory limits. Investigate missing information rather than treating a blank database entry as proof that risk ended. Explain what changed and why it affects the relationship.
Record changes without overwriting history
Keep the former function, prior checks, new assessment, date and responsible role. If measures continue, set the next review trigger. If they end after conditions are satisfied, document why specific risk was excluded. Lower risk does not remove ordinary AML duties, sanctions or other suspicious circumstances. Reassess a new public function.
What a review after a year should contain
Do not begin review by asking whether a label can now be removed. First establish other relevant functions and continuing specific influence or links. Check current transaction types, explanations of funds, known public and business roles and file changes. State evidence used and information still missing. Absence of a recent report about the client differs from evidenced exclusion of risk.
The outcome may be continuing measures or ending them once statutory conditions are met. Explain specific continuation reasons and the next review trigger; justify exclusion of specific risk when ending measures. Preserve historical assessment to show why an older transaction had different measures. The client profile may show current status, while audit history retains the original function, its end and prior decisions.
Practical steps
- Verify end dates and other functions.
- Observe at least 12 months.
- Assess residual PEP-specific risk.
- Evidence regime changes and review triggers.
Illustrative scenario
After 14 months, a former officeholder retains documented decisive influence over related public contracts. The office documents continued measures.
When the situation differs
A calendar deletes status and evidence after 365 days without individual assessment.
What to document
- Evidence of the end of each relevant function.
- Assessment of residual influence and risk.
- Dated conclusion and retained history.
Common pitfalls
- Treating the minimum period as automatic exclusion.
- Overlooking a new role.
Frequently asked questions
Must measures end after one year?
No. One year is a minimum; evidenced exclusion of specific risk under Section 54(8) is also required.
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.