The AML Act – what it requires of obliged entities
The AML Act on certain measures against legitimisation of proceeds from crime is the core legal framework for AML compliance in the Czech Republic. This page explains what the law requires and how to meet your obligations more easily.
What is the AML Act?
The AML Act — on certain measures against legitimisation of proceeds from crime and financing of terrorism — is the Czech transposition of the European AML directive. It sets out specific obligations for so-called obliged entities.
The AML Act has undergone a series of amendments and tightening in recent years. A key change comes with the European regulation AMLR (EU) 2024/1624, which will be fully applicable from 2027. The new European authority AMLA started operating in January 2026.
The Act is enforced by the FIU, which has significantly intensified inspections and penalties since 2023.
Key sections
- KYC / CDDClient identification and customer due diligence (KYC/CDD)
- EDDEnhanced identification and customer due diligence (EDD)
- Risk assessmentRisk assessment of the obliged entity
- Internal rulesInternal policies and procedures (SVZ)
- Contact personContact person for communication with the FIU
- Responsible personResponsible person — a member of the statutory body accountable for AML compliance
- STRSuspicious transaction reporting (STR) to the FIU
- MonitoringOngoing monitoring of the business relationship
- RetentionArchivace dokumentů — min. 10 let
Obligations under the AML Act
The AML Act imposes six core areas of obligation. Each must be actively fulfilled by the obliged entity.
Client identification and verification (KYC)
Before entering a business relationship, the obliged entity must identify the client — a natural or legal person — and verify their identity.
PEP screening and sanctions checks
Checking whether the client is a politically exposed person or appears on EU, UN sanctions lists.
Business relationship risk assessment
Every client must be assigned a risk category. High-risk clients are subject to enhanced due diligence.
Internal AML policy and responsible person
The obliged entity must have a written internal AML policy and designate a responsible person in writing — a member of the statutory body — and notify the FIU of a contact person. These are two distinct roles under two different provisions.
Suspicious transaction reporting (STR)
Suspicious transactions or business relationships must be reported to the FIU.
Archiving and audit trail
Veškerá AML dokumentace musí být uchována minimálně 10 let pro případ kontroly FAÚ.
Who does the AML Act apply to?
Obliged entities are precisely defined in the AML law. If you fall into one of the categories below, the full scope of AML obligations applies to you.
- Credit and financial institutions
- Real estate agents and brokers
- Accounting firms and tax advisors
- Attorneys and notaries
- Virtual asset service providers (cryptocurrencies)
- Leasing and factoring companies
- Casinos and betting shops
- Auctioneers and art dealers
- Insurance intermediaries
- Fund managers and investment advisors
Penalties for non-compliance
Frequently asked questions about the AML Act
Do I have to comply with the AML Act even if I am a small business?
Yes. The AML Act does not distinguish by company size — if you are a defined obliged entity under the law, you must fulfil all obligations without exception. The FIU inspects small businesses as well.
How does KYC differ from AML?
KYC (Know Your Customer) is one component of AML. AML is a broader system of measures covering KYC identification, PEP screening, risk assessment, internal policy, the responsible person and reporting.
When is EDD (enhanced due diligence) required?
EDD is mandatory for high-risk business relationships — the law defines mandatory triggers: the client is a PEP, the client's country of origin is a high-risk third country, or the transaction relates to a high-risk third country. EDD also applies where risk assessment indicates elevated risk.
How can I comply with the AML Act efficiently?
The most efficient approach is a dedicated cloud AML system that covers all legal requirements. AML PROOF automates KYC, PEP screening, risk assessment, internal documentation and FIU reporting in one place — no installation required.