Thousands of Czech entrepreneurs face obligations that many are not even aware of. Act No. 253/2008 Coll. on certain measures against the legalisation of proceeds of crime — known as the AML Act — covers a surprisingly wide range of businesses. And the Financial Analytical Office has significantly tightened its inspections over the last two years. The good news: for the first time, there is a way to handle everything quickly, without a lawyer, and without paperwork.
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Who Does the AML Law Apply To?
Many entrepreneurs think the AML law only applies to banks. That is not true. An obliged entity under § 2 of Act 253/2008 Coll. includes, for example, a real estate agent, accountant, tax adviser, lawyer, currency exchange, gambling operator, or virtual asset service provider. An obliged entity can be an individual or a legal entity — what matters is the nature of the activity carried out, not the size of the company.
The most commonly affected sectors include:
- Real estate agents and property intermediaries
- Accountants and tax advisers
- Lawyers and notaries (for asset management, company formation, share transfers)
- Currency exchanges and payment service providers
- Gambling operators
- Virtual asset service providers (cryptocurrencies)
If you are unsure whether the law applies to you, you are not alone. This is one of the most common issues — and the FAU does not excuse ignorance.
What Exactly Does the Law Require?
The AML law imposes several key obligations on obliged entities. The primary obligation is client due diligence — verifying identity before starting a business relationship, identifying the beneficial owner including verification in the Beneficial Ownership Register, and assessing risks. This includes screening for politically exposed persons (PEPs) and checking international sanctions lists.
In addition, obliged entities must also:
- Report suspicious transactions to the Financial Analytical Office (FAU)
- Prepare a written internal policies system and risk assessment (§ 21 of the AML Act)
- Regularly train employees — at least once every 12 months
- Archive all AML documentation for 5–10 years
Internal Policies System — The Foundation of Everything
The internal policies system (§ 21 of the AML Act) is an internal document that precisely describes how your company fulfils its legal obligations. It must include a risk assessment (§ 21a), client verification procedures, rules for reporting suspicious transactions, and a regular employee training plan.
- Selected types of obliged entities — particularly financial institutions, currency exchanges, and gambling operators — are required to submit their internal policies to the FAU or CNB within 60 days of the obligation arising
- Other obliged entities do not need to submit the document, but must have it prepared and demonstrably used
- Employee training must take place at least once every 12 months
- A well-prepared internal policies system is crucial during an inspection — it demonstrates that the obliged entity not only knows its obligations but actively fulfils them
- The FAU always verifies during inspections whether the document reflects the actual operation of the company — generic templates are not sufficient
A well-prepared internal policies system is your strongest defence in the event of an FAU inspection.
What an FAU Inspection Looks Like in Practice
The Financial Analytical Office has significantly increased the number of inspections and fines issued in recent years. Inspectors focus on key areas:
- Existence and currency of the internal policies system — the most common reason for fines
- Correctness of client verification and beneficial owner identification
- Screening for PEPs and sanctions lists
- Reporting suspicious transactions to the FAU
- Maintaining and archiving documentation for the legally required period
Violations can result in fines of up to CZK 10,000,000 or 10% of annual turnover for legal entities, and up to CZK 1,000,000 for individuals. The most common mistake is not deliberate circumvention of the law — but simply being unprepared and lacking documentation.
Why It Was So Complicated Before
Fulfilling AML obligations traditionally meant hiring a lawyer or adviser, spending weeks creating internal documentation, and then repeating the entire process with every legislative change. For smaller businesses without their own legal department, this was a financially and time-consuming process — which many simply kept putting off.
The result: thousands of obliged entities enter FAU inspections unprepared. Yet every one of them could be ready — if they had the right tool available.
What Has Changed: AML Obligations Can Now Be Met Online
The Czech platform AML PROOF brings a different approach. It is an online tool that automates the entire process — from setting up your company profile, through client verification and screening, to risk assessment and generating reports ready for presentation to the FAU.
The platform is based on a methodology aligned with FATF recommendations, EU AMLR, EBA, and FAU methodological guidelines. The output of each case is a structured report with a complete audit trail — exactly what inspectors look for during a visit.
How It Works in Practice
You register, set up your company profile, and start your first case. The system performs client verification, automatically screens registers of politically exposed persons and international sanctions lists, evaluates risks, and generates a report. The entire process that used to take days or weeks can be handled with AML PROOF in hours.
The result is not just a fulfilled legal obligation — but the assurance that in the event of an FAU inspection, everything will be documentable, structured, and ready.