Ordinary businesses and large cash transactions

When the obligation applies

Business outside subsection 1 carrying out a cash transaction of at least EUR 10,000.
Non-business legal entity carrying out a cash transaction of at least EUR 10,000.
Apply section 54 to connected payments; the cash-payment definition also includes the listed high-value commodities and virtual assets.

Exceptions and important distinctions

A business ID, foreign partner or bank request does not alone make a business an obliged entity.
Assessing the AML threshold does not replace the separate cash payment limitation law.

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

Assess all activities before using the residual category.
Aggregate connected cash payments and identify both payment roles.
Apply the transaction-specific duties under section 28.
Separately check sanctions and legality of cash settlement.

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 classification and transaction value
Contract and payment records
Transaction-specific customer file

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. c)–d); § 28; § 54

Prepare client information in the AML form →

Supervision and legal basis

FAÚ.

§ 2 odst. 2 písm. c)–d); § 28; § 54 ↗