The account from which a payment arrives is not the origin of the money. AML checks may require understanding particular funds or how the client acquired their wealth.
What you are establishing
Source of funds explains how money or other assets involved in a transaction originated: revenue, a loan, a property sale or inheritance, for example. Source of wealth concerns the creation of wider assets, such as years of business activity followed by a company sale. A relationship with a politically exposed person expressly requires examining the origin of that person’s wealth.
Ordinary due diligence includes examining the sources of funds or assets involved in the transaction or relationship. It does not automatically require the complete history of every client’s possessions.
Ask about economic origin
“From a bank account” identifies a payment route. Ask how the money was generated. For a loan, establish the lender and circumstances; for savings, reasonably explain the income and period involved. If a third party pays, examine their connection to the client and reason for paying.
Not every amount needs identical evidence. Justify scope by value, service, client risk and context. A substantial payment inconsistent with known income needs more than a tick beside “savings”.
Connect explanations with evidence
Depending on circumstances, a sale agreement, loan contract, inheritance decision, financial statements or relevant account statement may help. Check the person, amount, timing and economic explanation. A statement may show a transfer without establishing where the funds originated before it.
Record statements separately from evidence. Redacting unrelated information must leave the facts required for due diligence readable. Do not demand unrelated sensitive details merely because they appear on the same document.
When the explanation does not fit
Identify the discrepancy and request clarification. A connected company can be a legitimate lender, but circular payments, inconsistency with activities or refusal to explain the lender increase risk. Assessing a suspicious transaction remains a separate question.
If mandatory due diligence cannot be completed, section 15 applies. For a transaction with a politically exposed person, the law expressly requires refusal where the origin of the funds or other assets used is unknown. Management approval cannot substitute for this missing information.
Practical steps
- Determine whether the inquiry concerns transaction funds or wider wealth.
- Obtain a specific economic explanation.
- Choose risk-appropriate evidence and compare its contents.
- Record conclusions, discrepancies and the decision on next steps.
Illustrative scenario
A client finances company formation by selling their own shareholding. The agreement and relevant account movement match the amount and timing. The file connects the sale with the new investment.
When the situation differs
A payment arrives from an EU bank, so staff automatically mark the origin as verified even though the actual payer and economic source remain unexplained.
What to document
- The source explanation and its provider.
- Relevant evidence with amounts, dates and connections checked.
- Reasons for the scope and resolution of discrepancies.
Common pitfalls
- Confusing a banking route with economic origin.
- Treating a declaration as universally conclusive.
- Demanding the client’s entire financial history without justification.
Frequently asked questions
Is a bank statement always necessary?
No single document is universally prescribed. Choose sources that reasonably explain and support the circumstances.
Is a declaration that the funds are lawful enough?
A generic statement may not explain their origin. Obtain a specific account and verify it as appropriate to risk.
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
- Developers and property traders →
- Art, cultural heritage and free-zone storage →
- Precious metals and stones →
Complete client information online
Where to go next
- Purpose and intended nature of the relationship: what to establish — Understand why the client needs the service, how the relationship will work and how to recognise later departures.
- Simplified and enhanced due diligence: evidence determines risk — When checks may be simplified and when additional information, verification and approval are legally required.
Sources and legal references
- Zákon č. 253/2008 Sb. — aktuální znění e-Sbírky ↗
§ 9 odst. 2 písm. e), f), odst. 3; § 9a; § 15 odst. 2 · 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.