Table of contents
- What is an AML questionnaire and why the law does not use that term
- What the questionnaire must contain for an individual
- What must additionally be included for a legal entity
- Source of funds: what to ask and how to document it
- Most common mistakes in AML questionnaires
- Specifics for real estate agencies and accountants
- Frequently asked questions
What is an AML questionnaire and why the law does not use that term
Act No. 253/2008 Coll., on certain measures against money laundering and terrorist financing (the AML Act), does not use the term "questionnaire". It imposes two key obligations on obliged entities: client identification (Sections 7 and 8) and client due diligence (Section 9). An AML questionnaire is a practical tool through which an obliged entity fulfils these obligations and — equally importantly — documents them demonstrably.
The first essential point follows: the Czech Financial Analytical Office (FAU) has not issued any official AML questionnaire template. There is no form you can simply download, complete and consider done. The questionnaire content must match the scope of obligations imposed on your specific activity — and the risk level of the particular client and transaction (Section 9(3) of the AML Act).
When do you need a questionnaire? You must identify the client at the latest when it becomes clear that the transaction value will exceed EUR 1,000, and always when a business relationship is established or in the case of a suspicious transaction (Section 7(1) and (2) of the AML Act). Client due diligence must be performed, among other cases, always before a single transaction worth EUR 15,000 or more and when a business relationship is established (Section 9(1) of the AML Act).
Everything you learn through the questionnaire must be retained for 10 years from the end of the business relationship or from the date of the transaction (Section 16(2) of the AML Act). For a detailed overview of all obligations, see our comprehensive AML Act guide 2026.
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Try AML PROOF for freeWhat the questionnaire must contain for an individual
The foundation consists of identification data under Section 5(1)(a) of the AML Act:
- all given names and surnames
- personal identification number (or date of birth and gender if not assigned)
- place of birth
- permanent or other residence
- nationality
- identity document number and type, issuing state or authority, and validity period
For a self-employed individual, also the business name, distinguishing addendum, registered office and company ID.
You record the data and verify them from the identity document — including verifying that the client's appearance matches the photograph in the document (Section 8(2)(a) of the AML Act). The questionnaire should therefore also include confirmation that the document is valid and that verification took place.
Declaration whether the client acts on their own behalf
If another person acts for the client, they must provide proof of authority to act and the obliged entity must verify its scope (Section 8(6) of the AML Act). If you suspect the client is concealing acting for a third party, you must request supporting documentation (Section 8(10) of the AML Act).
Politically exposed person declaration
As part of identification, the obliged entity must determine and record whether the client, the person acting for them or their beneficial owner is a politically exposed person (PEP) or a person subject to international sanctions applied by the Czech Republic (Section 8(8) of the AML Act). A client declaration is a standard way to obtain this information — but it does not relieve you of the obligation to verify it against available lists.
Purpose and intended nature of the transaction
The purpose and intended nature of the transaction or business relationship (Section 9(2)(a) of the AML Act). The question "why is the client requesting this service" is not a formality — without it you cannot later assess whether a specific transaction matches what you know about the client.
What must additionally be included for a legal entity
For a legal entity, the questionnaire covers everything above (the individual acting for the client is identified) plus:
Basic identification data of the legal entity
Business name or designation, registered office, company ID, and data for identifying and verifying members of the statutory body (Section 5(1)(b) of the AML Act). You verify the existence of the legal entity from a document from a trustworthy source, typically an extract from the commercial register (Section 8(2)(b) of the AML Act).
Beneficial owner
You determine their identity and take measures to verify it from trustworthy sources. If the client is subject to registration in the beneficial ownership register under Act No. 37/2021 Coll., you must always verify the beneficial owner from that register and at least one additional source (Section 9(2)(b) of the AML Act). You also determine whether the beneficial owner is a PEP or a sanctioned person.
Ownership and control structure
For a legal entity or trust, you determine the entire structure and whether it involves a person subject to international sanctions applied by the Czech Republic (Section 9(2)(c) of the AML Act).
Nature of the client's business
According to FAU Methodological Guideline No. 9 on client due diligence, in higher-risk cases you must not settle for a generic description such as "wholesale". You should understand what type of activity it is, at what volume it operates and who the client's typical customers are — and from that infer what transactions can be expected. Missing or formal collection of business nature information is among the most common findings during inspections.
Source of funds: what to ask and how to document it
Client due diligence includes review of the sources of funds or other assets involved in the transaction or business relationship (Section 9(2)(e) of the AML Act). This obligation applies to every client due diligence review — not only in high-risk cases.
The questionnaire should include a question on the source of funds. FAU Methodological Guideline No. 9 offers practical guidance on what documents to request based on the declared source:
| Declared source | Additional information | Possible documents |
|---|---|---|
| Savings from income | income level in past periods, employer, saving period | tax return, income certificate, bank statement |
| Business income | business details, main/secondary activity | tax return, annual report |
| Profit distribution | distribution decision | financial statements, profit distribution resolution |
| Receivable sale | consideration amount, assignee identity, assignment date | assignment agreement, receivable existence documents |
| Other source | income identification and nature, receipt date | relevant supporting documentation |
The depth of documentation depends on the client's risk profile (Section 9(3) of the AML Act) — for a standard client a declaration suffices; for a higher-risk client you request documents.
A special regime applies to politically exposed persons: in addition to the source of funds used in the transaction, you must take appropriate measures within the business relationship to determine the origin of the PEP's total wealth (Section 9(2)(f) of the AML Act). If you do not know the source of funds for a PEP, you must not proceed with the transaction (Section 15(2) of the AML Act).
Most common mistakes in AML questionnaires
In practice — including analysis of forms actually in use — the same deficiencies keep recurring:
- Missing declaration on acting on own behalf. The questionnaire identifies the client but does not determine whether they are acting for a third party.
- PEP declaration only for the representative, not the client. Typically for self-employed individuals: the form asks about the agent's political exposure but the principal person does not sign a declaration. The check applies to the client, the acting person and the beneficial owner (Section 8(8) of the AML Act).
- Document validity is not verified. The form copies the ID card number but does not record the validity period or confirmation that verification from the document took place (Section 5(1)(a) and Section 8(2) of the AML Act).
- Generic business description. "Business activity" or "wholesale" without further detail is insufficient under FAU Methodological Guideline No. 9 in higher-risk cases.
- Missing question on source of funds. Review of sources is a mandatory part of every client due diligence review (Section 9(2)(e) of the AML Act), not an add-on for risky clients only.
- Method of identification is not recorded. During an FAU inspection you must demonstrate not only what you found out but also how — whether identification took place in physical presence (Section 8(1)) or through one of the forms of remote identification.
Each of these mistakes means the obligation was not demonstrably fulfilled — and that is exactly what the supervisory authority evaluates during an inspection. For more on what inspectors look for, see our article FAU Inspection: What Inspectors Look For.
Specifics for real estate agencies and accountants
AML questionnaire for real estate agencies
A real estate intermediary is an obliged entity under Section 2 of the AML Act and performs identification and due diligence for transactions related to property brokerage. In addition to standard elements, the questionnaire should specifically determine the purpose of purchase or sale, the source of funds for the purchase price (own savings vs. loan vs. other source) and, for corporate buyers, the beneficial owner. Financing in cash or from abroad is a typical moment when it is appropriate to request documents according to the table above.
AML questionnaire for accountants
Accountants and tax advisers establish long-term business relationships with clients — client due diligence is therefore not a one-off event but an ongoing process (Section 9(2)(d) of the AML Act). A questionnaire completed when taking on a client is the starting point; data must be kept up to date and their validity checked in subsequent transactions (Section 8(9) of the AML Act). In practice, updating the questionnaire at regular intervals derived from the client's risk profile works well.
Questionnaire, screening and archiving in one step
AML PROOF guides you and your client through the entire process: digital questionnaire for individuals and legal entities, automatic verification against sanctions and PEP lists, risk scoring and archiving for the statutory 10 years. Everything ready to present during an FAU inspection.
Start for freeFrequently asked questions
Is there an official AML questionnaire template?
No. The FAU has not issued any binding questionnaire template and Act No. 253/2008 Coll. does not use the term "questionnaire". Each obliged entity sets the content according to the scope of its obligations and the risk profile of clients (Section 9(3) of the AML Act).
Must every client complete a questionnaire?
Identification is performed at the latest for transactions above EUR 1,000 and always when a business relationship is established or in the case of a suspicious transaction (Section 7(1) and (2) of the AML Act). Client due diligence must be performed, among other cases, always before a transaction worth EUR 15,000 or more and when a business relationship is established (Section 9(1) of the AML Act). The scope of information collected varies by risk level.
How long must I retain a completed questionnaire?
10 years from the end of the business relationship or from the date of the transaction (Section 16(2) of the AML Act).
Is a client signature enough or must I verify the data?
A client declaration is not sufficient. You verify identification data from the identity document including appearance match (Section 8(2) of the AML Act), the beneficial owner from the beneficial ownership register and an additional source (Section 9(2)(b) of the AML Act), and PEP status against available lists.