The term AML (Anti-Money Laundering) often terrifies accountants and tax advisors unnecessarily. Many mistakenly believe it only applies when a client transfers hundreds of millions. The reality is quite different. As an independent accountant or tax advisor, you very often meet the definition of an obliged entity.
Table of contents
- 1. AML for Accountants: When do you become an obliged entity?
- 2. Overview of AML obligations for accountants — what you must fulfill
- 3. AML Questionnaire Template for Accountants
- 4. Three levels of client control — how to distinguish them
- 5. AML Training for Accountants — how to ensure it
- 6. Notification of the FAU Contact Person
- 7. Penalties for non-compliance — what accountants face
- 8. Practical steps — where to start
1. AML for Accountants: When do you become an obliged entity?
Act No. 253/2008 Coll., Section 2(1)(e) explicitly states that an obliged entity includes an accountant, auditor, and tax advisor — meaning anyone who, as a business, maintains accounting records or provides accounting or tax advisory services.
It doesn't matter whether you are a large advisory firm or a freelance accountant. If you do business in these fields, the law applies to you.
Situations where an accountant/tax advisor is an obliged entity:
- Maintaining accounting records for clients as a business
- Tax advisory as a business
- Setting up commercial companies for clients
- Management of trust funds
- Providing registered offices for companies
2. Overview of AML obligations for accountants — what you must fulfill
As an obliged entity, you have these basic obligations:
System of Internal Principles (SVZ) — § 21
A written document describing how your office carries out AML duties. The FAU requires it first during an inspection.
Risk Assessment — § 21a
A written assessment of the risks of money laundering specifically for your activity — type of clients, products, distribution.
Client Identification — § 7–8
Before starting cooperation with a new client, you must ascertain their identity.
Client Control — § 9
Ascertaining the ultimate beneficial owner for corporate clients, checking against sanctions lists and PEP registers.
Ongoing Monitoring — § 9(1)
You monitor clients throughout the entire duration of the cooperation, not just at onboarding.
Archiving for 10 years — § 16
All documentation regarding client identification must be kept for 10 years.
Reporting Suspicious Transactions to FAU — § 18
If you detect a suspicious transaction, you are obliged to report it to the FAU. Tax advisors file reports through the Chamber of Tax Advisors of the CR.
Training pursuant to § 23
All employees and persons in a comparable position must be trained before assignment to their respective position and at least once every 12 months thereafter.
FAU Contact Person — § 22
Within 30 days of becoming an obliged entity, you must notify the FAU of a contact person for ongoing communication. Failure to do so risks a fine of up to CZK 10,000,000 (approx. EUR 400K).
Designated Person — § 22a
A member of the statutory body responsible for fulfilling AML obligations.
Stress-free AML agenda for accountants
Overwhelmed? Doing AML questionnaires in Word? Try our digital tool to save dozens of hours of work.
3. AML Questionnaire Template for Accountants
“Where can I find an AML questionnaire template for accountants?” This is the most common question we receive. Unfortunately, there is no universal state-mandated template – each advisory profession has its specifics, and the questionnaire must cover your concrete risks.
The law does not define a fixed AML questionnaire template — the content must match your specific business and risk assessment. A correct AML form for accountants must contain:
For natural persons:
- First name, last name, date of birth, address
- ID document number and type
- Nationality
- Purpose and nature of the business relationship
- Source of funds (for higher value transactions)
- Declaration on political exposure
For legal entities additionally:
- Company ID (IČO), registered office, legal form
- Identification of the ultimate beneficial owner (§ 9(2)(b))
- Ownership and management structure
- Source of funds and wealth
AML PROOF digitizes this entire process — the client fills out the questionnaire online, and you receive the result instantly, including checks against sanctions lists and PEP databases.
4. Three levels of client control — how to distinguish them
The law distinguishes three levels of client control — and it is important for accountants to know when to use which:
Simplified Client Control (§ 14)
Can only be applied in exceptions expressly specified by the law — for example, clients who are obliged entities themselves. This is not the default state.
Standard Client Control (§ 9)
The basic obligation for all clients. Identification, determination of the ultimate beneficial owner, purpose of transaction, sanctions list screening.
Enhanced Identification and Control (§ 9a, § 13)
Mandatory for higher risks — politically exposed persons, clients from risky countries, unusual ownership structures, high-value transactions. Requires deeper scrutiny of the source of funds and management approval.
5. AML Training for Accountants — how to ensure it
The law (§ 23) requires:
- Training of every employee and person in a comparable position before assignment to the relevant position
- Repetition at least once every 12 months
- Training upon any change to the SVZ or risk assessment
The training content must cover:
- Indicators of a suspicious transaction (§ 6)
- Procedures for client identification and control
- Procedure upon discovering a suspicious transaction
- Current sanction obligations
You must maintain training records for at least 5 years (§ 23(2)). Failure to ensure training carries a fine of up to CZK 5,000,000 (approx. EUR 200K) (§ 48(5)).
For solo accountants without employees and persons in a comparable position: § 21(3) allows you not to prepare a written SVZ if you have no employees — but the obligation to train yourself remains.
6. Notification of the FAU Contact Person
From February 2025, a new duty applies — every obliged entity (including accountants and tax advisors) must notify the FAU of a contact person for ongoing communication.
What this means in practice:
- Within 30 days of becoming an obliged entity, you must report the name, contact, and job title of the contact person to the FAU.
- Changes to the contact person must be reported within 15 days.
- The notification is submitted via data box using the prescribed FAU form.
- Failure to comply risks a fine of up to CZK 10,000,000 (approx. EUR 400K).
Pozor:Note: This is not an "obliged entity registration" with the FAU — it is the notification of a contact person under § 22 of Act No. 253/2008 Coll. The obliged entity itself is not registered with the FAU.
7. Penalties for non-compliance — what accountants face
The FAU also penalizes small advisory firms and freelance accountants. Most common fines:
- •Absence of SVZ or risk assessment: up to CZK 1,000,000 (approx. EUR 40K)
- •Inadequate client identification: up to CZK 10,000,000 (approx. EUR 400K)
- •Failure to provide training for employees and persons in a comparable position: up to CZK 5,000,000 (approx. EUR 200K)
- •Failure to notify the FAU contact person: up to CZK 10,000,000 (approx. EUR 400K)
- •Failure to report a suspicious transaction: up to CZK 5,000,000 (approx. EUR 200K)
Důležité:Important: Liability is strict — to issue a fine, it is enough to prove the obligation was not fulfilled. The FAU does not have to prove intent or actual money laundering.
8. Practical steps — where to start
If you don't have your AML agenda sorted out yet, follow these steps:
Check if you are an obliged entity → test at /obligatorytest
Develop a risk assessment (§ 21a)
Develop an SVZ (§ 21)
Notify the FAU contact person (§ 22)
Set up the client identification process (§ 7–9) — digital AML questionnaire
Train yourself and your employees and persons in a comparable position (§ 23(1) and (2))
Archive all documentation for 10 years (§ 16)
AML PROOF guides you through all steps automatically — from the SVZ through client identification to training.