Software can speed up information collection and recordkeeping. Legal conclusions still depend on data coverage, lawful methods and context assessment. A report describes operations performed, not automatic completion of every AML duty.
Useful functions have a defined scope
A tool can validate a business-ID format, retrieve corporate data, compare names with a list or flag missing fields. Each function needs a source, timestamp and limitations. A valid-format ID does not establish a representative’s authority, and a register entry does not complete beneficial-owner verification.
Online questionnaires collect declarations. They constitute identification only if an admissible statutory method is actually completed and its measures recorded. Uploading an ID photograph alone does not satisfy this requirement.
People assess contradictions and purpose
Due diligence requires understanding why the customer needs the service, who stands behind it and how funds fit the case. Conflicting agreements, extracts and explanations must not simply become points in a score. Staff must obtain further information and decide whether due diligence can be completed.
An automated name match is a candidate for assessment. No match means no result within particular data and a particular method, not a guarantee that no sanctions duty exists. Ownership, control and non-list restrictions may require separate analysis.
Rules must permit stopping a case
A score can organise work but cannot override mandatory enhanced measures or Section 15. Unclear identity or missing necessary cooperation cannot be resolved by clicking “accept risk”. Include incomplete, information-required, escalated and reasoned-decision states.
Statutory reliance on another entity or use of staff or agents has its own Section 11 conditions. A supplier’s marketing claim cannot replace them. The obliged entity needs evidence access and must be able to demonstrate its measures.
Test exports, currency and outages
Before use, check that exports retain inputs, sources, timestamps, methodology, results and decisions. Source failure must appear as failure rather than an empty list. Review updates and the effect of terminating the service on your own archive.
Set a secure fallback for outages. Temporary case storage in a tool is not the obliged entity’s statutory archive. Ensure usable Section 16 records for the applicable period.
Practical steps
- Describe what each function actually establishes.
- Separate declarations, verification and human decisions.
- Set mandatory escalation and prevent completion without necessary measures.
- Test complete exports, data currency and fallback procedures.
Illustrative scenario
A tool flags two possible sanctions records. Staff compare identifiers, retain sources and explain why neither concerns the customer.
When the situation differs
A source outage produces “no match”, which a practice presents as completed sanctions screening.
What to document
- Function, data-source and limitation specifications.
- Technical results and human-assessment records.
- Verified export and own recordkeeping rules.
Common pitfalls
- Treating technical validation as a legal conclusion.
- Hiding missing data behind a green score.
Frequently asked questions
Can software identify customers remotely?
Yes, if it performs a specific statutory method with every condition. A form alone is not that method.
Is a supplier certificate sufficient?
It does not demonstrate measures performed for your customer. Examine functionality, use conditions and available evidence.
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
- Identification and customer due diligence are different — Identity, purpose, beneficial ownership and funds: assign the correct customer measures.
- No match found: what the result actually means — How to interpret a negative sanctions result and recognise incomplete data, incorrect queries and restrictions outside lists.
Sources and legal references
- Zákon č. 253/2008 Sb. — aktuální znění e-Sbírky ↗
§ 8–9a, § 11 odst. 4–5, § 15–16, § 21a · 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.