An old protocol evidences a check at its stated time and scope, not today’s sanctions status. Listings, removals, identifier changes or ownership links may require reassessment. Keep the historical result and add the new one instead of rewriting the past.
Dates and results
Distinguish query time, source snapshot and legal effect. Consolidated lists help research, but prohibitions derive from the applicable legal act. Formatting changes may not change legal effect, and secondary sources may update at different times.
Record the version used. Without it, the file does not firmly establish what data were compared. A new check cannot retrospectively supply missing historical evidence; disclose the earlier limitations.
Identity and context
Compare relevant identifiers again. Names may identify different people, while a new alias may reveal an earlier missed record. Do not carry forward exclusions automatically after evidence changes. Record the candidate and reasons.
Check ownership/control, subject matter and sector too. Removing a direct name does not prove all other measures or asset links have ceased. List work is part of sanctions analysis, not its entirety.
Ongoing relationships
Section 8(9) requires risk-based checking of information validity and completeness. Section 9 includes ongoing monitoring. Do not invent one universal statutory interval. Alongside scheduled reviews define legal-change, owner-change, payer-change and unusual-transaction triggers.
For confirmed relevant sanctions apply the particular regime and reporting duties. A match affecting today’s deal cannot simply wait for next month’s review. Separate legal assessment from public labelling of customers.
Change record
Link old and new results by case ID. State whether law, source data, customer information or matching method changed. Attach evidence and measures. Preserve the original decision and its then-existing limitations.
If the decision changes, explain which new information caused the different outcome and from when it affects your actions. Different colours in two exports are not reasons. The record should remain understandable to staff who did not handle the original case.
Practical steps
- Identify trigger and legal change.
- Verify source and data date.
- Assess identity, links and subject matter.
- Decide current measures.
- Link the new record to the original.
Illustrative scenario
A June check found no match. In October an owner becomes subject to an applicable measure. Staff reassess before further performance and retain the June result as historical evidence.
When the situation differs
A tool replaces the old protocol with new data while retaining its June date, falsely implying October data were available earlier.
What to document
- Old and new protocols
- Legal act and identifiers
- Impact and measures
Common pitfalls
- Historical no-match as current certainty
- Unsupported repeated exclusions
- Rewritten dates and history
Frequently asked questions
Is the old check useless?
No. It evidences the earlier process within its scope but does not establish today’s position.
Must every format change trigger a full recheck?
Assess relevant data or legal changes and whether earlier evidence remains demonstrable. A technical change differs from a new sanction.
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
- 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.
- 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 od 11. 1. 2026 ↗
§ 6 odst. 2, § 8 odst. 8–9, § 9 odst. 2 písm. d), § 16 · 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.