External accountants

When the obligation applies

Providing accounting advice, bookkeeping or tax records as an authorised business activity.

Exceptions and important distinctions

An employee keeping the employer’s accounts is not a separate obliged entity on this basis.
Intragroup shared accounting requires assessment of the actual model; it is not automatically an external service.
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.

01 · Before the first engagement

Define the service and check timing

Distinguish monthly bookkeeping, recurring returns and a genuinely occasional service. For an ongoing relationship, do not delay identification because of a low fee. For occasional work assess the value of the subject of the service.

Evidence: Order, service description and reasons for relationship or transaction classification.

§ 2 odst. 1 písm. e), § 4, § 7, § 9

Business relationships and occasional transactions →AML monetary thresholds: value, currency and related transactions →Open working template

02 · Before the first engagement

Verify the client, representative and owners

Receiving accounting papers does not verify identity. Choose a permitted method, check representative authority and entity ownership. A bank account or data box alone does not perform your checks.

Evidence: Method record, authority evidence and ownership sources.

§ 5, § 8–11

New customers: from initial information to documented due diligence →Remote identification: lawful options and their conditions →Beneficial owners: establish first, then verify →Open working template

03 · Before service starts

Understand activity and complete the assessment

Record normal income, countries, services and expected payments. Address PEPs, sanctions facts and open questions. If checks cannot be completed assess section 15; suspicion has its own reporting process.

Evidence: Reasoned conclusion, evidence and measures, not just a score.

§ 9–9a, § 15, § 18

Purpose and intended nature of the relationship: what to establish →Source of funds and source of wealth: two different questions →Simplified and enhanced due diligence: evidence determines risk →Open working template

04 · During the relationship

Respond to changes in accounting records

A new owner, unusual third-party payer or activity outside the profile triggers review. Accountants need not know every client transaction but must assess relevant information obtained through their service.

Evidence: Event, request, response and updated conclusion.

§ 8 odst. 9, § 9, § 18

Client updates and refusal: changes and missing cooperation →Suspicious transactions: internal escalation and cooperation →Open working template

05 · At closure

Close the relationship and archive the complete record

Separate handover of accounting to a new supplier from your AML archive. Retention and confidentiality do not end with termination. Record the retention-trigger event and authorised access.

Evidence: Relationship end, document inventory, applicable retention rule and tested backup.

§ 16, § 38

How to retain and securely transfer AML evidence →AML service providers, DPA, incidents and exit →Open working template

Prepare client information in the AML form →