Non-business legal entities providing listed services

When the obligation applies

Non-business legal entity authorised to provide a subsection 1 activity as a service.
Separate alternative: cash transaction of at least EUR 10,000.

Exceptions and important distinctions

Non-profit status alone is not an exemption.
Receiving ordinary non-cash donations alone does not meet the specified activity conditions.
Section 28 does not automatically apply to every service; the limited regime requires obliged status arising only for a transaction of at least EUR 10,000.

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

Distinguish a service, internal operations and a cash transaction.
For listed services determine the relevant sector duties; assess section 28 where status arises only from a cash transaction of at least EUR 10,000.
Record reasons why the Act applies or does not apply.

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

Constitution and authorisation
Contracts and service nature
Duty classification

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. d); odst. 3 písm. a)

Prepare client information in the AML form →

Supervision and legal basis

Depends on activity and section 35.

§ 2 odst. 2 písm. d); odst. 3 písm. a) ↗