Banks and credit unions

When the obligation applies

Banks.
Savings and credit cooperatives.

Exceptions and important distinctions

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

Check authorisation and the product actually supplied.
Configure identification, due diligence, ongoing monitoring and reporting for the product.
Determine the Czech National Bank and FAÚ supervisory remit for the particular authorisation.

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

Authorisation and product map
Customer and transaction records
Risk assessment, internal procedures and review 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. a) body 1–2

Prepare client information in the AML form →

Supervision and legal basis

FAÚ; the Czech National Bank for entities within its supervisory remit under section 35(1)(a).

§ 2 odst. 1 písm. a) body 1–2 ↗