The purpose of a business relationship is more than “provision of services” copied from a contract. Understand why the client approaches you, what they expect and whether those expectations fit their activities.
From the contract to the client’s operations
The law requires information on the purpose and intended nature of the transaction or relationship and the nature of the client’s business. For recurring accounting, establish actual activities, markets, customers and management. For company formation, also understand the proposed activities and reasons for the structure.
Adjust the scope to risk. A small local service differs from a new company planning international transfers without staff. Avoid imposing every imaginable question on every client; explain which answers matter for the particular service.
Questions that produce a usable profile
Ask who will issue instructions, which activities will be usual, whether cash is expected and which countries or other entities will be involved. Expected turnover, transaction volumes, duration or initial financing may be relevant depending on the service. Estimates are a reference point, not a guarantee or contractual undertaking.
Clarify unusual requests. A registered office without operating premises is not itself evidence of wrongdoing. Combined with unclear activities, repeated director changes and requests to receive other people’s money, it calls for closer explanation.
Supporting information
Use the agreement, business description and client explanations; compare them with websites, registers, authorisations or transaction documents where risk warrants it. Registered business activities may be broad categories and do not establish what the company actually does.
Record your own clear summary of expected operations. Distinguish the client’s statements from verified facts. For a new venture, record the plan and its financing without presenting planned operations as an established business.
Make the profile useful over time
Ongoing due diligence compares transactions with your knowledge of the client. A new market or growing turnover may be legitimate, but significant departures need explanation and possibly a revised risk assessment. Focus on changes visible through your service; a profile does not itself require access to every bank account.
Request missing information specifically. If mandatory due diligence cannot be completed, apply the refusal or termination rules in section 15. Assess suspicion separately: an implausible answer does not automatically require a report, but a signed questionnaire does not resolve it.
Practical steps
- Describe the service and actual client activities.
- Record expected cooperation and relevant transaction volumes.
- Add evidence appropriate to the identified risk.
- Determine which changes will trigger reassessment.
Illustrative scenario
An accountant onboards a distributor and records its products, main supplier countries, expected payments and the person issuing instructions. Later transfers unrelated to distribution can be compared with this profile.
When the situation differs
Every file says only “the purpose is accounting”. Nobody knows whether the client sells goods, holds property or receives funds for other people.
What to document
- A concise profile of activities and expected cooperation.
- Dates and information sources, distinguishing statements from verification.
- Explanations of material departures and profile updates.
Common pitfalls
- Confusing the contractual service with the actual relationship purpose.
- Demanding identical evidence regardless of risk.
- Treating a signed profile as permanently current.
Frequently asked questions
Must the client predict annual turnover exactly?
There is no universal requirement for an exact estimate in every relationship. Where volume matters to risk, record reasonable expectations and subsequent changes.
Is a public website sufficient?
It can be one source. It does not by itself establish the purpose of this cooperation or verify every client statement.
Put this guidance into practice
Choose a record for the step you are working on. Adapt it to your profession and actual case.
- Individual and sole trader information · PDF / Word
- Legal entity and beneficial owner information · PDF / Word
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.
- Source of funds and source of wealth: two different questions — Distinguish the funds used in a particular transaction from the creation of the client’s wider wealth, and assess supporting documents.
Sources and legal references
- Zákon č. 253/2008 Sb. — aktuální znění e-Sbírky ↗
§ 9 odst. 2 písm. a), d), odst. 3; § 15 · accessed 2026-10-04 - FAÚ: Metodický pokyn č. 9 — kontrola klienta ↗
Účel vztahu, zdroje prostředků a průběžná kontrola · 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.