Table of contents
What is a PEP and why must you screen them
A politically exposed person (PEP) is a natural person who holds or has held a prominent public function. Act No. 253/2008 Coll. (Section 4(5)) defines a PEP as a person who is or within the past 12 months has been a head of state, a member of government, a member of parliament or senate, a judge of the Constitutional Court, a senior official of a state authority, an ambassador, a senior officer of the armed forces, a member of the governing body of a state enterprise or a political party — as well as their family members and persons known to have close business or personal ties with a PEP.
PEP status does not in itself mean that the client is committing a criminal offence. It means that the relationship requires enhanced attention, enhanced due diligence (EDD) and senior management approval before establishing a business relationship (Section 15(1) of the AML Act). If you do not know or cannot document the source of the PEP's funds, you must not carry out the transaction (Section 15(2) of the AML Act).
A detailed overview of the obligations of obliged entities can be found in our comprehensive AML Act guide 2026.
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Who must perform PEP checks
The obligation to screen clients for PEP status applies to all obliged entities under Section 2 of the AML Act. This is not limited to banks — the Act applies to a wide range of professions and businesses:
- Real estate agents and real estate agencies
- Accountants, auditors and tax advisers
- Lawyers and notaries for selected transactions
- Currency exchange offices and casino operators
- Insurance intermediaries
- Dealers in precious metals, stones and works of art
- Providers of trust and company services
If you are unsure whether your activity creates an obligation under the AML Act, enter your company registration number below — the system will verify it instantly.
What a PEP check must cover
It is not enough to ask the client whether they are a PEP and record their declaration. The law (Section 8(8) of the AML Act) requires that PEP status be determined and recorded — not only for the client, but also for the person acting on their behalf and for the beneficial owner. The client's declaration is a starting point, not proof.
A complete PEP screening under the AML Act and FAU methodological guidelines must include:
| Screening area | What is checked | Legal basis |
|---|---|---|
| Global PEP databases | Public functions in all jurisdictions, family members and close associates | Section 8(8), Section 15 of the AML Act |
| CZ sanctions list | Persons against whom the Czech Republic applies international sanctions under Act No. 69/2006 Coll. | Section 8(8) of the AML Act |
| EU sanctions list | EU consolidated list (Regulation No. 2580/2001 and others) | Directly applicable EU Regulations |
| UN sanctions list | List of the UN Security Council Committee | EU Regulations transposing UN Security Council Resolutions |
| Adverse media | Negative media coverage, links to financial crime, corruption or money laundering | FAU Methodological Guideline No. 9 on client due diligence |
Manual verification via public registers is possible, but time-consuming and difficult to document. For an FAU inspection you must demonstrate not only the result, but also the method and date of verification.
How to perform a free PEP check online: step by step
AML Basic enables you to carry out a complete PEP and sanctions screening in approximately 30 seconds — no registration required, with the first check free.
- Step 1 — Go to amlbasic.com. No registration or login required.
- Step 2 — Enter the client's name. Fill in the first and last name of the natural person or the trade name of the legal entity. The tool works with name variants, transliterations and fuzzy matching — it catches typos and foreign-language variants.
- Step 3 — Run the screening. The system checks the client against global PEP databases, CZ, EU and UN sanctions lists and adverse media sources. The result appears within 30 seconds.
- Step 4 — Download the PDF report. The result is generated as a PDF report with the date and time of the check, a list of sources checked and any matches found. The report serves as evidence for an FAU inspection.
The first check is free. Further screenings work on a pay-as-you-go basis — you pay only for checks actually carried out, with no monthly subscription or commitment.
What to do when the client is a PEP
A match in a PEP database does not automatically mean refusing the client. The law sets out a procedure you must follow and document:
- Enhanced due diligence (EDD): Verify the origin of the client's funds and overall assets (Section 9(2)(e) and (f) of the AML Act). The client's self-declaration of source is not enough — request supporting documents.
- Senior management approval: Before establishing or continuing a business relationship with a PEP, you must obtain the approval of the responsible person or company management (Section 15(1) of the AML Act).
- Ongoing monitoring: You monitor a business relationship with a PEP more intensively than with ordinary clients. Any change in their situation or a transaction that does not match their profile requires a risk reassessment.
- Match on a sanctions list: If the client appears on a sanctions list, the business relationship must not be established or continued. In such a case you are required to report the matter to the competent authority.
For a detailed account of how the FAU proceeds during inspections and what inspectors specifically look for, see our article FAU Inspection: What Inspectors Look For.
How often to repeat a PEP check
PEP status is not static. A client who was not a PEP when the business relationship began may become one — for example after being appointed to a public office. The law therefore requires ongoing monitoring throughout the duration of the business relationship (Section 9(2)(d) of the AML Act).
The law does not specify a frequency — this is determined by the client's risk profile under your internal AML policies (Section 21 of the AML Act). In practice, the following approach has proven effective:
- Standard clients: repeat PEP check at least once a year or for each new transaction above the statutory threshold
- Higher-risk clients: repeat screening quarterly or for each transaction
- When circumstances change: immediately upon learning of any change in the client's situation (new position, media appearance, change in ownership structure)
AML Basic enables repeat checks on a pay-as-you-go basis — you pay only for checks actually carried out. Each report is stamped with the date and time, so archiving is automatically auditable.
Perform your first PEP check for free
AML Basic screens a client against global PEP databases, CZ, EU and UN sanctions lists and adverse media in 30 seconds. You receive a PDF report ready for archiving. No registration, no subscription.
Start a free PEP checkFrequently asked questions
Is it enough to ask the client whether they are a PEP?
No. Act No. 253/2008 Coll. (Section 8(8)) requires PEP status to be determined and recorded. The client's declaration is a starting point, but the obliged entity must verify the result against available PEP databases and sanctions lists. Relying solely on the client's self-declaration is insufficient and will not be accepted as fulfilment of the obligation during an FAU inspection.
Must I perform PEP checks on existing clients too?
Yes. The law requires ongoing monitoring throughout the duration of the business relationship (Section 9(2)(d) of the AML Act). A client who was not a PEP at the start of the relationship may become one. The frequency of repeat checks is determined by your internal AML policies based on the client's risk profile.
What does a match on a sanctions list mean?
If the client appears on a sanctions list, the business relationship must not be established or continued. Unlike PEP status (where a business relationship is possible subject to conditions being met), a match on a sanctions list is an absolute bar. You are required to report the matter to the competent authority.
Is a PEP check the same as AML screening?
A PEP check is part of broader AML screening, not a synonym for it. Complete screening includes checking PEP status, sanctions lists (CZ, EU, UN) and adverse media. Checking only one source — for example only the EU sanctions list — does not satisfy the statutory requirement to determine PEP status.
How long must I retain the result of a PEP check?
10 years from the end of the business relationship or from the date of the transaction (Section 16(2) of the AML Act). The PDF report from AML Basic includes the date and time of the check and a list of sources reviewed — it is ready for archiving to meet this statutory retention period.