Art, cultural heritage and free-zone storage

When the obligation applies

Trading or intermediation in Annex 3 artworks worth at least EUR 10,000.
Trading or intermediation in cultural monuments or objects of cultural value; the artwork threshold is not a general exemption for these objects.
Authorised storage of these items in free zones; for Annex 3 artworks at least EUR 10,000.

Exceptions and important distinctions

The limited section 28 regime requires obliged status arising at the EUR 10,000 transaction threshold and excepts free-zone operators; cultural monuments and objects of cultural value do not automatically have this limited regime.
Storage outside a free zone alone is not point 2; other activities may create a different status.
Read the category with section 2(3): the activity must form part of the business, subject to statutory exceptions for non-business legal entities, lawyer partners and the specified trust activity.

From first engagement to retention

Read this workflow with the scope and exceptions for this profession. Evidence of a measure follows its actual performance.

1. Before starting: verify scope

Record the actual service, parties and why it falls within the scope above. Assess exceptions for each measure, rather than applying them to the entire client relationship.

2. While providing the service: apply sector steps

Classify the item under the annexes and cultural heritage legislation.
Consider connected payments and both sides of the transaction.
Review the item’s provenance, customer, price and financing.

When the service, party or relevant circumstances change, revisit the affected step. This profession’s special regime takes precedence over a generic checklist.

3. Closure: document the outcome under the applicable regime

Description, provenance and valuation
Legal classification of the item
Identification, due diligence and payment records

Determine which records to retain and under what legal basis. For a customer of an obliged entity this concerns cooperation, not taking over the provider’s duties.

§ 2 odst. 1 písm. i) body 1–2; § 28

Prepare client information in the AML form →