Internal suspicion escalation record

For: Authorised internal staff only

Confidential internal record. Not a suspicious transaction report or client form.

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. Internal reference, detection time and source

   Record when, where and by whom the finding was escalated; use an internal reference rather than a vague email subject.

2. Specific facts, uncertainties and available evidence

   Separate observed facts from assumptions. Reference available documents and describe the inconsistency.

3. Transaction status and need for immediate measures

   Is the transaction pending, ongoing or complete? Record timing and urgency; do not wait for a routine meeting.

4. Recipient role, time and receipt confirmation

   Escalate only to an authorised role and verify receipt; use the designated substitute if unavailable.

5. Assessment of reporting recipient, confidentiality and next steps

   Assess reporting, any professional-chamber channel and postponement. Do not send this internal record or protected reporting information to the client.

Illustrative use

MODEL ESC-01: discrepancy between payer and client detected before execution. Escalated to the designated internal role with receipt confirmed. Open: assess facts, applicable reporting process and further transaction handling.

When the case is uncertain

Accountable role not responding? Use urgent substitution; internal procedure must not postpone statutory reporting.

Legal basis: § 6, § 18–20, § 26–27, § 38

V12-2026-10-04 · Redakce eAML.cz

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