When the obligation applies
- Foreign entity within subsection 1 acting through a Czech branch or establishment, within that activity.
- Foreign person carrying out subsection 1 activities as a business in Czechia.
Exceptions and important distinctions
- A foreign registered office does not itself remove Czech duties.
- Also assess sector-specific rules and the actual operating model.
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
- Identify Czech activities and legal presence.
- Apply the relevant professional category and local procedures.
- Resolve file access and supervision for cross-border services.
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
- Activity and establishment map
- Authorisation
- Czech AML procedures and evidence
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. 2 písm. a)–b)Supervision and legal basis
Depends on activity: FAÚ, Czech National Bank or other section 35 body.
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