FAU Methodological Guideline No. 6 for the Gambling Sector: What It Means for AML Obligations of Gambling Operators

Who does Methodological Guideline No. 6 apply to?

FAU Methodological Guideline No. 6 (ref.: FAU-18007/2026/03, legal status as of 1 February 2026) is addressed exclusively to obliged entities in the gambling sector under § 2(1)(c) of Act No. 253/2008 Coll. — i.e. gambling operators under Act No. 186/2016 Coll. on gambling. The exception covers lottery and bingo operators not operated via remote internet access, and tombola operators — they are not bound by the guideline.

The guideline was developed following an FAU questionnaire survey in the gambling sector and answers specific questions operators face in practice. It covers four areas of obligations: client identification and due diligence, suspicious transaction reporting, record retention and employee training, and finally preventive measures including the internal control system (SVZ).

The AML Act takes precedence over the Gambling Act

This is the baseline rule that the FAU explicitly confirms in MP No. 6 and which has significant practical impact.

The AML Act (Act No. 253/2008 Coll.) is a special legal regulation — lex specialis — in relation to the Gambling Act. Where the two laws conflict and it is impossible to comply with both, the AML Act takes precedence.

A concrete example: under § 17i(1) of the Gambling Act, the operator must pay out funds from a user account immediately upon the player's request. However, if the conditions for refusing a transaction under § 15 of the AML Act (e.g. suspected identity misuse) or for deferring execution of the client's instruction under § 20 of the AML Act and reporting a suspicious transaction are met, the operator must follow the AML Act — and defer or refuse the payout, even though the Gambling Act would require immediate payment.

Client identification: when and how in gambling

For gambling operators, the general identification threshold under § 7(1) of Act No. 253/2008 Coll. applies: client identification must take place at the latest when it is apparent that the transaction value will exceed EUR 1,000. The law requires related payments — e.g. bets on the same race or within a short time period — to be aggregated and treated as a single transaction (§ 54(4) of the AML Act).

MP No. 6 clarifies how to assess a business relationship versus an occasional transaction:

A business relationship arises where the Gambling Act requires client registration — i.e. for online gambling where the player has a user account. Identification must take place before that relationship is established.

An occasional transaction occurs in gambling where registration is not required — for example course betting on animal races without a user account, or totalisator betting on animal races. Identification is then performed before a transaction exceeding EUR 1,000 is executed.

Land-based casinos and gaming halls are a special case. The Gambling Act does not require registration, but § 71 of the Gambling Act requires operators to identify visitors whenever they enter a gaming hall or casino. This obligation overlaps with AML identification rules.

The guideline also clarifies that the statutory EUR 1,000 threshold is a minimum requirement — based on its own risk assessment (§ 7(4) and § 21a of the AML Act), an operator may set a lower threshold or identify clients for all transactions regardless of value. As for acceptable identity documents: any document issued by a public authority containing at least the identified person's name, surname and date of birth, from which their appearance is apparent, qualifies. In the Czech Republic this includes a national ID card, passport, driving licence and digital copy of a national ID card.

Client due diligence: specifics for the gambling sector

Client due diligence in the gambling sector follows § 9 of the AML Act with one important deviation from other non-financial obliged entities: the threshold for due diligence on a one-off transaction for gambling operators is EUR 2,000 (§ 9(1)(a)(5) of the AML Act), whereas other obliged entities generally apply a EUR 15,000 threshold.

Client due diligence includes in particular:

MP No. 6 clarifies suspicious behaviour indicators specific to gambling. These include using multiple user accounts with foreign identities, a so-called dormant account (deposit without gaming activity followed by withdrawal), rapid account activation and deactivation, frequent changes of payment cards for deposits, or depositing at one location and withdrawing at another.

The FAU also clarifies in the guideline that payout review should always occur when risk factors materialise — and that paying out winnings is likewise a transaction under the AML Act and subject to the same rules as a deposit.

Politically exposed persons (PEPs) in gambling

For clients with politically exposed person (PEP) status, enhanced identification and due diligence under § 9a of the AML Act applies without exception in the gambling sector. Simplified due diligence (§ 13 of the AML Act) cannot be used for PEPs.

Key rules for PEPs in gambling:

For determining PEP status, the FAU refers to Methodological Guideline No. 7 — Measures regarding politically exposed persons. If the operator uses a commercial screening tool, it should generate both a record of the verification result and information on the sources used (whether international and national sanctions lists are included).

Record retention and employee training

Record retention in the gambling sector follows § 16 of the AML Act. The retention period is 10 years from execution of a transaction outside a business relationship or from termination of a business relationship. Records may be kept electronically — MP No. 6 explicitly confirms this and treats scanned documents as electronic storage. The key requirement is reconstructability: records must demonstrate who, where, when and how obtained the relevant information and how it was assessed.

Employee training follows § 23 of the AML Act. For gambling operators, the same rules apply as for other obliged entities: employees who may encounter a suspicious transaction in the course of their work must be trained at least once every 12 months. New employees must be trained before being assigned to such a position.

MP No. 6 adds two important clarifications specific to the gambling sector:

First — if an employee does not reliably speak Czech and specialises in dealing with foreign clients, training must be delivered in the language the employee uses when dealing with those clients. A language barrier is not an excuse for failing to train.

Second — the FAU recommends training outside the regular cycle when new products, services or technologies are introduced, and also when there is a significant change to AML regulations or new FAU methodological guidelines are issued.

Internal control system and risk assessment: what the FAU clarifies

A gambling operator must have an internal control system (SVZ) and risk assessment (§ 21 and § 21a of the AML Act). MP No. 6 clarifies what the risk assessment in gambling must contain.

The primary risk factor for games is the distinction between online and land-based operations. Additional factors include game speed, number of players, ability to use cash or anonymous payment methods, transaction volume and availability of limit-setting tools.

VIP clients represent a special category — a possible enhanced risk factor comparable to private banking (Annex 2 to the AML Act). The operator must have rules in the SVZ for identifying and managing this risk.

The guideline also confirms that the SVZ must include procedures for making retained records available to relevant authorities and that gaming terms should oblige clients to inform the operator of changes to identification data.

Frequently asked questions about FAU MP No. 6