When the obligation applies
- Other activities of an enforcement officer under the Enforcement Code.
- Custody of money, securities or other assets.
Exceptions and important distinctions
- Compulsory enforcement itself must not automatically be treated as the other activities or custody covered by this point.
- 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
- Classify the particular act.
- For custody identify parties and the assets origin.
- For reporting use section 26(3) and the Czech Chamber of Enforcement Officers channel; preserve the relevant confidentiality.
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
- Description of act and legal regime
- Custody documents
- Identification and due diligence
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. f); § 26Supervision and legal basis
FAÚ and the Czech Chamber of Enforcement Officers within section 35.
Am I an obliged entity? Activities matter, not just a business ID
Map actual services to the Czech AML Act and identify conditions, authorisations and exemptions.
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Distinguish the funds used in a particular transaction from the creation of the client’s wider wealth, and assess supporting documents.
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Recipient, timing and content of reports, including professional-chamber routes.
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