Internal policies outline

For: Entities subject to the relevant internal-policy obligation

Before use, verify applicability, written-form requirements and any supervisory submission.

Before use

Check current sector rules in the related articles. Add accountable roles, specific sources and steps actually performed. Do not enter unnecessary personal data.

How to complete the template

1. Scope, responsibilities and substitutes

   Define activities, roles and substitutes; check section 21 and exceptions. Every rule needs an assigned performer.

2. Identification, due diligence, PEPs, sanctions and updates

   Describe permitted identification methods step by step, client and owner checks, PEPs, sanctions, updates and retained evidence.

3. Enhanced measures, refusal and escalation

   Define recognisable triggers for enhanced measures and inability to complete checks. Approval must not override a statutory prohibition.

4. Suspicious reports, postponement, confidentiality and access

   Define urgent escalation, the applicable reporting channel, section 20 handling and restricted access. Internal approval must not cause a statutory deadline to be missed.

5. Records, training, internal checks and change management

   Assign retention, training and effectiveness checks. A change log records version, effective date, approval and staff communication.

Illustrative use

MODEL POL-01: role A receives suspicion, role B substitutes. Sender verifies receipt through a protected channel. Open action: test substitution before putting the version into operation.

When the case is uncertain

Written policies not required? Document the exception; do not automatically extend it to other AML duties.

Legal basis: § 21, § 21a, § 18–20, § 38

V10-2026-10-04 · Redakce eAML.cz

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