The Czech National Bank issued a final fine of CZK 30 million to ČSOB — the highest AML penalty ever imposed on a financial institution in Czech history. The bank was not laundering money. It was fined for something else entirely. And that is exactly what should warn every real estate agent, accountant and tax advisor in the country.
Table of contents
1. What was ČSOB fined for?
In August 2026, the Czech National Bank published its final decision: ČSOB will pay CZK 30 million for deficiencies in its anti-money laundering control processes. This is the highest fine the CNB has ever definitively imposed on a financial institution.
What specifically went wrong?
Failed to review transactions of a high-risk client
From November 2022 to November 2023, ČSOB did not review the purpose and nature of transactions of a client it internally labelled as 'problematic', 'unacceptable' or 'high-risk'. Over three years, 58 cash withdrawals totalling CZK 136.4 million, USD 45,000 and EUR 3.7 million passed through this account.
Failed to establish complete ownership structure
From 2021 to 2024, ČSOB did not adequately verify the ownership and management structures of clients and their connections to international sanctions lists.
8,414 clients without sanctions verification
As of March 2025, the bank had not verified whether any person subject to international sanctions was present in the ownership structure of more than eight thousand clients with complex ownership structures.
Formal ongoing monitoring only
The law requires ongoing monitoring of business relationships — ČSOB did this only formally, on paper, not in practice.
The bank's response was predictable: no money laundering was proven, it concerns an older period, everything has been remedied. That may be true. But that is precisely the core of the problem.
2. The key misconception: fines are not for money laundering
Most obliged entities believe that AML fines are imposed on companies that actually launder money. That is not how it works.
FAU and CNB do not, in the vast majority of cases, fine for proven money laundering. They fine for failures in fulfilling AML obligations — for a flawed or missing process, for the absence of an audit trail, for formal controls without real substance.
The distinction is critical. ČSOB most likely did not help anyone legalise the proceeds of crime. It was fined because it could not prove that it had carried out the controls correctly. And that was enough for a CZK 30 million fine.
Exactly the same principle applies to FAU inspections of non-financial obliged entities — real estate agents, accountants, tax advisors and lawyers. The inspector does not need to prove you were laundering money. It is enough that you lack documentation, an audit trail or a functioning process.
3. What does this mean for non-financial obliged entities?
ČSOB has a compliance department, in-house lawyers, sophisticated systems and CNB oversight. And yet it received the highest AML fine in history.
Try to imagine how the same inspection would go for a three-person estate agency managing AML with a paper questionnaire signed by the client. Or for an accountant who checks clients by manually searching the EU sanctions list and notes the result in Excel.
Act No. 253/2008 Coll. imposes the same obligations on these firms as on banks — proportionate to their size and risk profile. But that does not mean the inspection will be less rigorous. It means FAU will assess whether the firm has a functioning, documented and auditable process appropriate to its situation.
Without systemic support, this is practically impossible to fulfil. Paper records without a timestamp, without identification of the database checked and without the name of the person who carried out the check are, from FAU's perspective, almost worthless — just as they were for ČSOB.
4. AMLR 2027: the situation is about to get significantly stricter
Next July, the unified European AML Regulation will enter into force — and the rules of the game will change dramatically. No national exemptions, no lenient interpretations.
„It cannot be excluded that in the future CNB will impose even higher fines, which is driven by obligations arising from EU law."
What AMLR specifically brings:
AMLA — a new European supervisory authority
Based in Frankfurt, it coordinates AML enforcement across the entire EU. National regulators such as FAU will be bound by harmonised standards — the scope for a more lenient interpretation narrows considerably.
Lowering the client verification threshold to EUR 10,000
Today the AML process must be initiated for a one-off transaction above EUR 15,000. From July 2027 this threshold is being reduced.
Stricter standards for everyone
The same rules for a large bank and for a one-person estate agency.
Higher fines
For serious or repeated failings, fines may reach significantly higher amounts than today. The CZK 30 million for ČSOB will one day sound like small change.
Focus on medium and small firms
Large financial institutions are already under close regulatory scrutiny. After 2027, estate agencies, accounting firms, tax advisors and lawyers will come under systematic review.
5. How to prepare?
The ČSOB fine is a concrete illustration of what the regulator considers inadequate: missing documentation, formal ongoing controls and the absence of an audit trail.
For non-financial obliged entities this means three things:
A documented process
Every client identification, every sanctions list check, every risk assessment must be recorded with a timestamp, the name of the person who carried it out and the result.
Functioning ongoing monitoring
The law requires ongoing monitoring of business relationships. A paper questionnaire from 2022 for a client you are still working with is not sufficient.
An up-to-date internal policies system
The document must reflect the firm's actual processes, not generic formulations.
Time to prepare: less than one year.