Here you will find answers to key questions related to AML and the cooperation process.
What is AML and why is it important?
AML (Anti‑Money Laundering) refers to a set of legal and internal measures designed to prevent the laundering of proceeds of crime and the financing of terrorism. It is important because it protects the financial system, reduces the risk of businesses being misused for criminal purposes, and helps companies meet their statutory obligations. Well‑designed AML processes also minimise regulatory risks and potential sanctions.
Who is an obliged entity under the AML Act?
An obliged entity is any subject covered by Act No. 253/2008 Coll., on certain measures against the legalisation of proceeds of crime and the financing of terrorism. This includes, for example, banks, payment institutions, currency exchange providers, real estate agencies, accountants and tax advisors, auditors, virtual asset service providers, gambling operators, and dealers in art or precious metals. Every obliged entity must establish and maintain an appropriate AML framework.
What obligations does an obliged entity have in the area of AML?
Obliged entities are primarily required to:
- carry out customer identification and due diligence,
- conduct risk assessments and apply a risk‑based approach,
- monitor and evaluate business relationships and transactions,
- report suspicious transactions to the Financial Analytical Office,
- retain documentation and records,
- ensure internal policies, staff training, and ongoing updates of the AML system.
These obligations are designed to ensure that the company can identify and address risk‑related situations in a timely manner.
What are CDD and EDD?
CDD (Customer Due Diligence) is the basic level of customer verification, including identification, verification of identity, understanding the purpose of the business relationship, and ongoing monitoring. EDD (Enhanced Due Diligence) is an extended level of verification applied in higher‑risk situations or with higher‑risk clients. It may include deeper verification of the source of funds, more detailed checks, or more frequent monitoring.
How does customer identification and due diligence work?
Customer identification and due diligence (CDD) are performed when establishing a business relationship or executing certain transactions. The process includes:
- identifying and verifying the customer using reliable documents,
- identifying the beneficial owner,
- understanding the purpose and nature of the business relationship,
- assessing the customer’s risk profile,
- ongoing monitoring of activities and updating customer information.
The aim is to verify that the customer is who they claim to be and that their activities do not indicate unusual or high‑risk behaviour.
What is a suspicious transaction and when must it be reported?
A suspicious transaction is any transaction or customer behaviour that may indicate money laundering or terrorist financing. The company does not need to prove criminal activity — it is sufficient to have a reasonable suspicion that the transaction lacks economic rationale, is unusual, disproportionate to the customer’s profile, or shows other risk indicators. Obliged entities must report a suspicious transaction without delay to the Financial Analytical Office (FAÚ), preferably before the transaction is executed. If delaying the transaction could enable criminal activity, the report may be submitted afterwards.
Obliged entities must report a suspicious transaction without delay to the Financial Analytical Office (FAÚ), preferably before the transaction is executed. If delaying the transaction could enable criminal activity, the report may be submitted afterwards.
How often must AML documentation be updated?
AML documentation must be updated regularly to reflect current legislation, the company’s risk profile, and changes in its operations. It is generally recommended to:
- conduct a full review at least once a year,
- perform ad-hoc updates, whenever:
- legislation or FAÚ guidance changes,
- the business model or services change,
- new risks are identified,
- internal or external audits reveal deficiencies.
Regular updates demonstrate that the company applies a risk‑based approach and maintains an effective AML framework.
What sanctions may be imposed for breaches of AML obligations?
For breaches of AML obligations, the Financial Analytical Office may impose significant sanctions, depending on the severity of the violation. These may include:
- fines reaching millions of CZK,
- remedial measures or restrictions on activities,
- prohibition of activity for individuals,
- publication of the decision, which may cause reputational damage,
- in severe cases, criminal liability.
Sanctions typically depend on the extent of the breach, the level of risk involved, and whether the company demonstrably neglected its obligations.
Who are AMLConsult´ services suitable for?
AMLConsult’ services are designed primarily for small and medium‑sized businesses and for entities classified as DNFBPs (Designated Non‑Financial Businesses and Professions) that need to meet their AML obligations and often do not have an internal AML team.
At the same time, I am able to provide specialised support to larger organisations, including banks, credit institutions and other regulated entities, whether in the form of external consultancy, capacity support or targeted project work. My services are suitable for organisations seeking practical, clear and effective assistance with setting up an AML framework, updating documentation, training staff or addressing specific AML‑related situations in practice.
How does AMLConsult provide its services – online or in person?
I provide my services primarily online, which allows me to remain flexible and respond efficiently to clients’ needs. In‑person meetings are possible, but generally only in exceptional cases and by prior arrangement.
Can I book a one‑off consultation?
Yes, a one‑off consultation is available. This option is suitable for clients who need targeted guidance on a specific AML‑related question or issue. The minimum billable time for a one‑off consultation is one hour.
Do you provide customised AML training?
Yes, I provide customised AML training. The content and scope of the training are tailored to the client’s specific needs, business model and the knowledge level of participants. The training can focus on regulatory requirements, practical procedures, internal processes or real‑life AML scenarios relevant to your organisation.
Can you help me prepare for an inspection by the FAU?
Yes, I can assist you in preparing for an inspection by the Financial Analytical Office (FAU). This includes reviewing your existing AML documentation, identifying potential gaps, and recommending specific corrective measures.
