For: External bookkeeping practices
Ticking a box does not perform the measure.
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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
- Activity, relationship or occasional transaction, trigger date
Is the engagement occasional or expected to recur? Record its subject and start date; the fee alone is not a reliable transaction-value test.
- Client, representative and authority; identification actually performed
Who contracts and gives binding instructions? Verify identity and authority. For remote identification, retain all steps of the chosen statutory method.
- Purpose, beneficial owner, PEP, sanctions and risk factors
How does the client earn money, who owns it and what does it expect? Compare explanations with evidence; resolve inconsistent activities and payments.
- Uncertainties, measures, accountable role and approval
Can the client be accepted, is more evidence needed, or does section 15 apply? Assess reporting under section 18 separately; refusal does not replace reporting.
- Sources, versions, date and update triggers; own archive
What triggers review: a new owner, payer, service or country? Assign responsibility and evidence location, not just a checklist completion date.
Illustrative use
MODEL ACC-01: monthly bookkeeping for a Czech company; business relationship, identify director before acceptance. Action: evidence direct ownership and activity. Status: open, service not yet started.
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When the case is uncertain
Missing identification or an explanation of funds? Keep the item open, specify evidence needed and assess section 15 and possible suspicion.
Legal basis: § 2, § 7–9a, § 15–16, § 18
V01-2026-10-04 · Redakce eAML.cz
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