When the obligation applies
- Formation of legal entities or trusts.
- Temporary acting for a legal entity or trust connected with formation and administration.
- Providing a registered office or address for another legal entity, including related services.
- Acting as a nominee shareholder for another person.
- Acting for a customer in all activities under section 2(1)(g)(1)–(5).
- Shelf companies: assess formation, transfer and representation by the actual service; the commercial label is not an exemption.
Exceptions and important distinctions
- A lawyer/notary classified under point g uses the special professional regime.
- Nominee shareholder exception: customer with securities traded on a European regulated market and equivalent disclosure requirements.
- Distinguish ordinary letting of real premises from a formal registered office service by substance; point h has no general turnover or fee threshold.
- 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
- Break down the service package: address, mail, formation, temporary director and share transfer.
- Identify the service customer, buyer, representatives and ultimate natural-person owners; record the state before and after transfer.
- Identify and check the customer before providing an ongoing service.
- Review corporate purpose, actual activity, financing and unusual requests.
- Link handover evidence to changes in ownership; a registry entry is not a complete AML file.
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
- Registered office contract and related service description
- Formation and transfer documents
- Representative authority and identification of actual individuals
- Ownership structure before/after sale
- Purpose, financing, risks and subsequent updates
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. h) body 1–5; odst. 3 písm. c)Supervision and legal basis
FAÚ.
§ 2 odst. 1 písm. h) body 1–5; odst. 3 písm. c) ↗
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