A template organises questions and a tool finds evidence. Neither alone establishes every customer circumstance or replaces the obliged entity’s statutory decision. Understand what the output demonstrates, which data it uses and what remains to do. A general checklist is not proof of completed AML.
Input, finding and decision
A questionnaire records assertions. Verification needs the statutory method or suitable source for that step. A risk decision connects findings with circumstances. Distinguish declarations, verified fields and responsible staff judgement in the file.
An identification form prompts required information but filling a document field does not prove presentation or identity verification. An uploaded image is not automatically lawful remote identification. When using section 11 establish the particular route, conditions and availability of required information.
A list has limited scope
A sanctions-name search returns candidates or no matches in its data. It does not alone settle similar identities, indirect company control or restrictions on particular goods. Without time, source and scope it cannot establish the complete current sanctions position.
A beneficial-ownership register provides evidence, but section 9(2)(b) requires another source alongside the register for registrable customers. An automatic extract cannot resolve discrepancies or opaque structures. Copying data is not reasoning for accepting a conclusion.
Adapt to your service
A multiprofession form may fail to define your particular duties. Lawyers, address providers, accountants and precious-metal traders have different covered activities and special regimes. Distinguish requirements from recommendations, avoiding both unnecessary data collection and omitted decisive steps.
A risk template is not a universal statutory grade. Assess relevant customers, services, countries, delivery channels and transactions under your own duties. Default low-risk labels or generic business-income statements are insufficient where facts conflict.
Connect output to action
Check function scope, data currency and export contents. Do not assume an unverified feature is available in your version because of a generic description. Source failure is not a negative result. Recognise errors/incompleteness and add your own assessment.
Apply section 15 where cooperation or completion fails, and consider reporting suspicion under your statutory regime. A green label does not authorise ignoring your own findings. Store evidence, decisions and limitations so later reviewers understand the actual state.
Practical steps
- Define the specific tool task.
- Check output source, date and scope.
- Complete identification and due diligence.
- Resolve discrepancies and decide.
- Retain evidence and output limitations.
Illustrative scenario
A company-name search finds no match. Staff also identify a foreign majority owner and check their identity and relevant links, keeping the output as partial evidence rather than complete AML assurance.
When the situation differs
A business buys a blank form, obtains a signature and saves AML complete without checking identity, ownership or actual risk. The filename does not remedy the missing process.
What to document
- Tool scope and version
- Sources and additional checks
- Reasoned decision
Common pitfalls
- Uploaded image as completed identification
- Failure as no-match
- Template as statutory approval
Frequently asked questions
May I use a public template?
Yes, after checking currency and suitability and adding the actual process. Availability does not guarantee correctness.
Does the supplier take responsibility?
The obliged entity must ensure its statutory duties. Contractual arrangements may regulate the supplier relationship, but buying software alone does not complete those duties.
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
- Beneficial owners: establish first, then verify — Distinguish identifying a beneficial owner, verifying identity and substantiating why the person owns or controls the company.
- A name match: how to establish whether it is your client — A practical procedure for distinguishing a false match, confirmed identity and an unresolved sanctions alert.
Sources and legal references
- Zákon č. 253/2008 Sb., aktuální znění od 11. 1. 2026 ↗
§ 7–9, § 11, § 15–16, § 18 · 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.