When the obligation applies
- Notarial custody or custody of customer money, securities and other assets.
- Acting for or on behalf of a customer in buying or selling real estate, a business or part of it.
- Managing customer assets, including opening or managing bank or securities accounts.
- Forming, managing or operating corporations and similar entities, including gathering funds.
- Forming or managing trusts or similar foreign arrangements, including gathering funds.
- Collection, payments, transfers, deposits, withdrawals and other acts causing money movements.
Exceptions and important distinctions
- Not every legal service is covered; classify the particular act.
- Section 27 provides special information and reporting protections concerning legal status and representation; assess their conditions individually.
- Reporting and cooperation under section 27 use the relevant professional chamber.
- 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
- Record classification of the act and customer roles.
- Separate protected legal information from transaction evidence.
- For suspicion apply section 27 and the relevant chamber procedure.
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
- Service description and custody agreement
- AML records of parties and owners
- Reasons for professional exceptions and chamber submission
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. g) body 1–5; § 27Supervision and legal basis
FAÚ; Czech Bar Association or Czech Notarial Chamber under section 35(1)(d); special section 27 regime.
§ 2 odst. 1 písm. g) body 1–5; § 27 ↗
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