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
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 — this is where the biggest surprise lies
The non-financial sector is precisely the area where many entrepreneurs are unaware they fall under AML. The law lists eleven categories:
- Real estate agents and intermediaries — for purchase, sale, or rental of properties
- Lawyers and notaries — for asset management, company formation, or share transfers
- Accountants and tax advisers — for bookkeeping and financial advisory
- 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 (cryptocurrencies)
- 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.
Does AML apply to you?
Find out immediately whether your business is subject to AML and which measures apply to you.
Other entities — cash payments over EUR 10,000
The AML law also applies to entities that are not typical obliged entities:
- Any entrepreneur who accepts a cash payment exceeding EUR 10,000 (approx. CZK 250,000) — regardless of industry
- Non-commercial legal entities carrying out activities falling within regulated categories
This means that even a car repair shop that accepts a cash payment of CZK 260,000 for repairing a luxury vehicle becomes an obliged entity at that moment and must fulfil AML obligations on a one-off basis.
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:
- Take our free obliged entity test — find out in 2 minutes if AML applies to you
- 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.
Conclusion
AML applies to a much wider circle of entities than most entrepreneurs think. It's not just about banks and insurance companies — AML obligations apply to real estate agents, accountants, lawyers, art dealers, crypto intermediaries, and even ordinary entrepreneurs accepting larger cash amounts.
Not sure if AML applies to you? Take our quick test and find out in 2 minutes.