Simplified due diligence does not mean no due diligence. Enhanced due diligence is more than a longer form. Both must meet legal conditions and the actual risk.
Start with ordinary requirements and risk
Start from identification and due diligence duties and your risk assessment. Record relevant facts such as client type, countries, service, structure and communication method. “Domestic companies are low risk” does not establish eligibility for simplification.
Section 13 allows simplified identification and due diligence where its conditions are satisfied. Assess and document the lower risk. It cannot be used where enhanced checks are required or the statutory restrictions connected with risk assessment apply.
What remains when checks are simplified
Simplification still includes collecting and recording identification data, relevant PEP and sanctions findings and establishing the beneficial owner. Carry out further measures to the extent needed for the lower risk. Verify eligibility: doubts about meeting the conditions rule this regime out.
Specify what you reduced and why. Reliable information and low risk may justify a different extent of additional documentation. A form labelled “simplified” without an actual assessment is insufficient.
When enhancement is mandatory
Section 9a requires enhanced due diligence where risk is increased. It also expressly requires it for specified relationships and transactions connected with a high-risk third country and for a transaction or relationship with a politically exposed person. Assess the precise geographic and personal connection, not the client’s language.
The law lists additional information, multiple trustworthy sources, enhanced monitoring, approval by the governing body or an authorised person, a specified first bank payment and other appropriate measures. This is not a free choice of one checkbox in every case.
Minimum measures depend on the trigger
For the specified high-risk-third-country connections, section 9a(4) requires at least measures under subsection 3(a)–(d) and (f). For PEPs, the minimum comprises additional source-of-funds and wealth information under (a), point 3, enhanced monitoring under (c), and the relevant approval under (d). Identified risk determines further measures.
Approval to establish or continue the relationship must genuinely precede the relevant decision. Record who approved it, their evidence and the monitoring arrangements. Enhancement is not an automatic ban, but cannot override incomplete due diligence or a sanctions prohibition.
Practical steps
- Determine risk and any statutory enhancement trigger.
- Verify eligibility before using simplification.
- Apply the mandatory minimum for the particular enhancement trigger.
- Add further measures and record approval and monitoring.
Illustrative scenario
The client is a PEP. The office establishes relevant sources of funds and wealth, obtains authorised approval and arranges enhanced relationship monitoring.
When the situation differs
A worker selects “low risk” because the client has a Czech business identifier, although the beneficial owner is a PEP and the structure is unexplained.
What to document
- Specific reasons for the risk category.
- Verified simplification conditions or completed enhanced measures.
- Relevant approval and ongoing monitoring arrangements.
Common pitfalls
- Treating simplification as a complete exemption.
- Selecting one enhanced measure where several are mandatory.
- Using an outdated high-risk-country list.
Frequently asked questions
Is every foreign client high risk?
No. Assess actual risk and statutory connections, not nationality alone.
Is director approval sufficient for a PEP?
No. Source information and enhanced monitoring are also needed; other identified risks may require more.
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 ↗
§ 9a; § 13; § 21a · 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.