An FAU inspection can come unannounced. And at that point, it's too late to catch up. We've prepared a practical AML questionnaire for you — 13 key questions that show whether you actually have your AML obligations fulfilled. If you answer 'no' or 'I don't know' to any of them, it's time to make a change.
Table of contents
Why do you need an AML questionnaire?
Most fines from the FAU are not related to money laundering. They're related to formal deficiencies — missing internal policies, unperformed client identification, inadequate archiving. These are exactly the problems that can be prevented with regular self-audits.
The AML questionnaire works as your internal control tool. Answer each question honestly, and for every 'no', note what needs to be fixed. The goal is to have 'yes' for all 13 questions.
What does the FAU inspect most frequently?
Based on publicly available FAU decisions, the most frequently inspected areas are:
- Existence and currency of internal policies (SVZ) — the most common reason for fines
- Client identification (KYC) — must be documentable
- Customer due diligence (CDD) — assessing the purpose and source of funds
- Screening against sanctions lists and PEP registers
- Record retention — archiving for the legally required 5–10 years
If you're falling short in any of these areas, it's a direct risk of a fine.
13 control questions of the AML questionnaire
Go through each question. If you answer 'yes', you're fine. If 'no' or 'I don't know' — that's an area for improvement.
📋 Documentation
- Do you have a current, up-to-date internal policies document (SVZ)?
- Does your SVZ include a risk assessment specific to your industry?
- Do you have a designated AML contact person (compliance officer)?
🔍 Client identification and due diligence
- Do you perform identification (KYC) for every client before starting a business relationship?
- Do you determine the ultimate beneficial owner (UBO) for legal entities?
- Do you assess the purpose of the transaction and the source of the client's funds (CDD)?
- Do you perform enhanced due diligence (EDD) for high-risk clients?
🛡️ Screening and monitoring
- Do you screen clients against sanctions lists (EU, UN, OFAC)?
- Do you check whether the client is a politically exposed person (PEP)?
- Do you continuously monitor business relationships and update risk assessments?
📁 Archiving and reporting
- Do you archive all AML documentation for 5–10 years?
- Do you know how and when to submit a suspicious transaction report (OPO) to the FAU?
- Do you train your employees in AML at least once a year?
Ready for inspection?
Find out if your business meets all AML obligations — before the FAU comes knocking.
How to evaluate the results?
Count how many questions you answered 'yes' to:
- 13/13 — Excellent. You're ready for an FAU inspection. Maintain this state.
- 10–12 — Good, but you have gaps. Focus on the missing areas as soon as possible.
- 7–9 — Risky. We recommend urgently filling in the missing measures.
- Less than 7 — Critical. You face a high risk of a fine. Act immediately.
Most common mistakes during FAU inspections
From practice, we know that businesses most often fail in these areas:
- Missing or outdated SVZ — the most common reason for fines, often hundreds of thousands of CZK
- Formal identification without real checks — a copy of an ID is not enough, you must assess the risk
- No sanctions list screening — often overlooked by smaller businesses
The FAU doesn't just check whether documents exist. It evaluates whether they're current, relevant, and whether you actually work with them.
How AML PROOF helps with inspection preparation?
AML PROOF covers all 13 areas from our questionnaire in one tool:
- Automatically generates SVZ and risk assessment tailored to your industry
- Performs client identification and determines the beneficial owner
- Connected to EU, UN sanctions lists and PEP registers — real-time screening
- Assigns a risk score to each client and transaction
- Archives all documentation in one place for the legally required period
The result? When the FAU inspection comes, everything is prepared and traceable.
Conclusion
An AML questionnaire is not a one-off task. We recommend going through it at least once every 6 months and always when changing your business model, adding a new type of client, or when legislation changes. Prevention is always cheaper than a fine.
Want to be sure you're ready? Start AML PROOF and keep all your obligations under control.