When the obligation applies
- Customer providing statutory cooperation with identification and due diligence by an obliged entity.
Exceptions and important distinctions
- This is a situational guide, not an additional category of obliged entity under section 2.
- The customer’s own AML status is assessed separately by 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
- Verify the recipient and secure channel.
- Provide necessary information, documents and explanations.
- Correct changes and discrepancies over time.
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
- List of documents supplied
- Data controller information
- Secure delivery confirmation
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.
§ 8 odst. 11; § 9 odst. 7Supervision and legal basis
Supervision of the obliged entity by sector; the Czech data protection authority for personal data.
Identification and customer due diligence are different
Identity, purpose, beneficial ownership and funds: assign the correct customer measures.
Read article →AML and GDPR: purposes, roles and proportionate data scope
AML records’ legal basis, transparency and provider roles without blanket consent.
Read article →For customers: why AML information is requested
Understand document requests, secure delivery and how to resolve an unclear requirement.
Read article →