Financial services and virtual assets

When the obligation applies

Banks and credit cooperatives: P15.
Investment services, markets and records: P16.
Funds and pension companies: P17.
Payments, electronic money and postal money services: P18.
Loans, leasing, guarantees and receivables: P19.
Life insurance: P20.
Currency exchange, corporate finance and valuables custody: P21.
Virtual asset services: P22.

Exceptions and important distinctions

This is not an additional statutory category or a substitute for a sector profile.
Section 2(4) tied-agent exemption applies only to b)(3), (7) and (8); the information duty remains.

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

Select the particular P15–P22 financial profile.
Verify authorisation, product and any Czech cross-border regime.
Apply sector rules and the particular supervision.

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
Statutory category classification
Customer and transaction 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) a b), odst. 2 a 4

Prepare client information in the AML form →