AML doesn't just apply to banks. You hear this more and more — but who exactly does AML apply to? The answer is broader than most entrepreneurs think. In this article, we show you the complete list of entities covered by the AML law and explain how to find out if it applies to you.
Table of contents
- Who does AML apply to? The basic principle
- Financial sector
- Non-financial sector — where AML obligations are hidden
- Other entities — cash payments at least EUR 10,000
- How to find out if AML applies to you?
- What obligations does this create?
- Frequently asked questions about AML obligations
- Conclusion: Determine your obligation today
Who does AML apply to? The basic principle
The AML Act (No. 253/2008 Coll.) applies to so-called obliged entities. These are subjects that are legally required to implement measures against money laundering and terrorist financing.
What matters is not the size of the company, the number of employees, or the turnover. What matters is the activity you carry out. If your business falls within the legally defined list, you are an obliged entity — regardless of whether you have one or a thousand employees.
Financial sector
Financial institutions form the core of AML regulation. These include:
- Banks and credit unions — including foreign branches operating in the Czech Republic
- Insurance and reinsurance companies — especially life insurance
- Investment firms and securities dealers
- Payment institutions and currency exchange operators
- Pension companies
For credit institutions, the AML Act applies to all their business activities. For other financial institutions, it applies to the part of the activity that falls under the regulated sector.
Non-financial sector — where AML obligations are hidden
The non-financial sector is precisely the area where many entrepreneurs are unaware they fall under AML (Anti-Money Laundering — anti-money laundering and counter-terrorism measures). The law lists these main categories:
- Real estate agents and intermediaries — for purchase, sale, or rental of properties (as of May 1, 2024, also for rental at EUR 10,000 per month)
- Lawyers and notaries — for asset management, company formation, or share transfers; exception: provision of legal advice without handling client funds
- Accountants and tax advisers — for bookkeeping and financial advisory; exception: provision of tax advice without handling funds
- Auditors and court executors
- Dealers in precious metals, stones, and jewellery
- Dealers in works of art and antiques
- Dealers in cultural goods
- Trust and company service providers (company formation, registered offices, nominee services)
- Virtual asset service providers (CASP — for example, cryptocurrency exchanges)
- Gambling operators
- Pawnshops and second-hand dealers (for higher cash transactions)
An important rule applies to the non-financial sector: the AML Act only applies to the part of business that falls within the defined categories. For example, if an accountant also runs an e-shop, AML obligations only apply to the accounting activity.
Podléháte AML?
Zadejte IČO vaší firmy a okamžitě zjistěte, zda podléháte AML předpisům
Other entities — cash payments at least EUR 10,000
The AML law also applies to entities that are not typical obliged entities when performing specific transactions:
- Any entrepreneur or natural person who accepts a cash payment of at least EUR 10,000 (approx. CZK 250,000) — regardless of industry or whether this is their usual activity
- Similarly, an entrepreneur accepting EUR or equivalent payments if a single payment reaches at least EUR 10,000
Practical example: A car repair shop that normally accepts payments via bank transfer becomes a one-off obliged entity at the moment a customer pays CZK 260,000 (approx. EUR 10,700) in cash for repairing a luxury vehicle. The shop must then identify the customer, assess the transaction risk, and possibly report it to the FAU as suspicious — even if this is its only such large cash transaction in the year.
How to find out if AML applies to you?
The surest way is to review § 2 of the AML Act and compare your business activities with the legal list. But you can do it even more simply:
- Enter your company's IČO in the banner above — instantly find out if you are an obliged entity. If yes, set up your profile and start meeting AML obligations
- Check your trade licence or business activity in the commercial register
- Consider whether you accept or intermediate larger cash amounts
If you're not sure, we recommend taking the test. It's better to find out now than during an FAU inspection.
What obligations does this create?
Once you discover you are an obliged entity, you acquire specific legal obligations. Here is an overview of the most important ones:
- Client identification and due diligence (KYC — Know Your Customer) — verify the identity of clients and understand the purpose of their business
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- Ongoing client monitoring — monitor their transactions and detect suspicious activity even after the relationship begins
- Reporting suspicious transactions (STR) — if you suspect money laundering or terrorist financing, report it to the FAU within 5 business days
Frequently asked questions about AML obligations
Does AML apply to small businesses or sole traders?
Yes, AML applies to all obliged entities regardless of size. What matters is the nature of the activity you carry out, not the number of employees or turnover. A small real estate agent working alone or with one employee has the same AML obligations as a large real estate agency.
Must I meet AML obligations all year round, or only for specific transactions?
It depends on the type of obliged entity. Real estate agents, accountants, lawyers, and other standard obliged entities have continuous obligations — they must have a prepared SVZ, perform client identification, conduct ongoing monitoring, and train employees. In contrast, an entrepreneur who encounters a cash payment above EUR 10,000 has obligations only in connection with that specific transaction.
What happens if I don't comply with AML obligations?
The Financial Analytical Office (FAU) can impose fines of up to CZK 10,000,000 (approx. EUR 400,000) under Section 44 of Act No. 253/2008 Coll. — not just for criminal conduct, but also for failure to fulfil formal obligations (missing SVZ, non-performed identification, lack of training). Additionally, penalties are publicly disclosed, which harms your company's reputation and may prevent access to banking services.
How quickly must I start meeting my AML obligations?
The law does not provide for a transition period. Your obligations arise at the moment your activity becomes regulated — whether it is registration as a real estate agent, your first crypto transaction, or receipt of a cash payment above the minimum limit. From day one, you must therefore operate in compliance with the AML Act. If you are already an obliged entity without a prepared SVZ, we recommend creating one as soon as possible.
Conclusion: Determine your obligation today
AML applies to a much wider circle of entities than most entrepreneurs realise. It's not just about banks and insurance companies — AML obligations apply to real estate agents, accountants, tax advisers, lawyers, insolvency practitioners, art dealers, providers of virtual asset services, and even ordinary entrepreneurs accepting larger cash payments.
That's why it's so important to ask the fundamental question: Do I fall under the AML Act? Find out now — enter your company's IČO in the banner above and instantly know if you are an obliged entity.
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