Suspicious-transaction reporting is a specific legal procedure. An ordinary obliged entity reports to FAÚ; five specified professions use a chamber route. Set the recipient and secure submission method in advance so an urgent case is not delayed by finding a form.
Without undue delay
Section 18 requires reporting without undue delay. Where circumstances require it, such as a risk from delay, report immediately after discovery. The historical general five-day deadline is not the current rule. The timeline starts with discovering suspicious circumstances, not completing administration. If some information is missing, describe available facts and uncertainties; completeness must not become an excuse for delay.
The report includes known identifying information on participants, material circumstances and other relevant information. Describe the action, amount or value, time, structure, economic purpose, inconsistencies and available sources. For sanctions-related cases, Section 18(5) requires specific emphasis and information about the affected assets. Do not include details of the employee who discovered the transaction. This does not make the reporting obliged entity anonymous.
Five professions use a chamber route
Section 26(3) routes auditors through the Chamber of Auditors of the Czech Republic, enforcement officers through the Chamber of Enforcement Officers of the Czech Republic, and tax advisers through the Chamber of Tax Advisers of the Czech Republic. Section 27(3) routes attorneys through the Czech Bar Association and notaries through the Notarial Chamber of the Czech Republic. Do not confuse an employee’s professional title with the reporting obliged entity’s legal capacity.
The chamber assesses the statutory protection of information and the further procedure. Its statutory reporting deadline to FAÚ is without undue delay and no later than seven calendar days from discovery of the suspicious transaction. This is not seven days from delivery to the chamber or a general permission for a member to wait a week. Sections 26(1) and 27(1) exceptions depend on the specific protected activity and circumstances; professional secrecy does not automatically cover every transactional service.
Submission must be secure and demonstrable
Section 19 governs written and secure electronic submission. Use FAÚ’s current official procedure on its reporting page or the chamber procedure applicable to you. Ordinary unsecured email or a message to a software vendor does not replace statutory submission. In an urgent situation, arrange secure contact directly with the relevant recipient. Retain the submitted version and confirmation, including receipt time where relevant to further measures.
Record supplements and subsequent cooperation as well. Postponement under Section 20 is assessed separately; filing a report does not impose a universal prohibition on every action. Client exports must not automatically include the internal report or investigation information. If an application only prepares evidence, identify who actually submits the report and verifies receipt.
Practical steps
- Determine FAÚ or the relevant chamber.
- Record discovery and urgency.
- Submit available facts securely.
- Retain receipt, supplements and further measures.
Illustrative scenario
An external accountant reports to FAÚ. A tax adviser acting in that professional capacity uses their chamber; both know the secure procedure in advance.
When the situation differs
A business leaves a case untouched for a week because an old template mentions a five-day deadline.
What to document
- Discovery time and urgency reasons.
- Submitted version and confirmation.
- Legal basis for the chamber route or specific exception.
Common pitfalls
- Counting seven days from chamber receipt.
- Confusing application preparation with submission.
Frequently asked questions
Does the chamber route cover every accounting service?
No. The statutory profession and obliged entity’s capacity determine it; similarity of services alone does not create a chamber route.
Put this guidance into practice
Choose a record for the step you are working on. Adapt it to your profession and actual case.
- Internal suspicion escalation record · PDF / Word
- Tax advisers, auditors and other authorised tax assistance →
- Lawyers and notaries →
- Insolvency and restructuring practitioners →
Complete client information online
Where to go next
- AML and cash: different statutes, different limits — Separate AML measures from restrictions on large cash payments and use the correct aggregation rules.
- How to retain and securely transfer AML evidence — Statutory records, retention triggers and secure export from temporary tools.
Sources and legal references
- Zákon č. 253/2008 Sb., znění od 11. 1. 2026 ↗
§ 18–19, § 26 odst. 1 a 3, § 27 odst. 1 a 3, § 38–39 · accessed 2026-10-04 - FAÚ: Oznámení o podezřelém obchodu ↗
aktuální oznamovací povinnost, obsah a bezpečný způsob podání · accessed 2026-10-04 - FAÚ: MP č. 4 – Oznámení podezřelého obchodu ↗
bez zbytečného odkladu, obsah oznámení, profesní odlišnosti · 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.