AML compliance & AML service in the Czech Republic

Can I act as a contact person for the FAU if I am the company director?

 

Yes, a company director may act as the contact person, provided they have sufficient language proficiency (Czech or Slovak) and are an official employee or a member of the obliged entity’s statutory body. However, if the obliged entity is a credit or financial institution, members of the statutory body cannot serve as contact persons by default, nor can employees responsible for executing or settling transactions, or those involved in internal audit. Exceptions may apply if justified by the nature and scale of the obliged entity’s business. It is important to note that this role cannot be outsourced to third parties such as external legal advisors. If you intend to delegate this role internally, it must be assigned to an employee or qualified internal expert.

​

What communication channels does the regulator use to contact companies?

 

The primary communication channel used by the regulator is the Datová schránka (Data Mailbox), which receives official notifications from public authorities, including the FAU. It is essential to check this mailbox regularly and respond promptly to any incoming messages. In some cases, regulators may also send duplicate notifications by email to ensure receipt. Additionally, official correspondence may be sent to the company’s registered legal address. Therefore, all channels should be monitored closely to ensure compliance with regulatory requirements.

 

What should I do if I don't have access to the Datová schránka?

 

If you do not have access, first verify whether your Datová schránka has been activated. This can be done through the official Datová schránka portal or at any Czech POINT office (post offices, municipal authorities, or notaries). If you’ve forgotten your password or lost access, it can be restored via Czech public services – in the Czech Republic through Czech POINT, or abroad via a Czech consulate. In urgent cases, temporary access can be granted to an authorized person through the Data Mailbox system.

​

How soon must I submit a suspicious activity report (SAR)?

 

Under Czech AML legislation, a company must submit a Suspicious Activity Report (SAR) to the FAU without delay and as soon as a suspicious transaction is identified. Delayed submission may be considered a compliance breach.
 

If I have a registered company in the Czech Republic, can I operate in other EU Countries?

 

Yes, a CASP company registered in the Czech Republic can operate in other EU countries under the passporting rights provided by the MiCA regulation. This allows service provision in other member states without obtaining an additional license, either through remote services or by establishing a branch. To qualify, the company must have a physical office and effective management in the Czech Republic and must notify the Czech National Bank (ČNB) before entering new markets.
 

My company is newly established and has no operations yet. When do I need to submit the AML report?

 

According to AML requirements, your company must submit a risk assessment report (hodnotící zpráva) detailing anti-money laundering and counter-terrorism financing measures no later than the end of the fourth calendar month after the reporting period ends. Even if your company has no operations, this obligation still applies. The focus of the report is on assessing the adequacy of internal procedures and control systems. For inactive companies, the report may contain only minimal information, but it still must be prepared and submitted in accordance with legal requirements.

 

I can’t open a business bank account. do you assist with KYC compliance for banks?

 

Yes, we provide full support for companies undergoing KYC compliance with banks. This includes preparing accurate AML documentation (AML policies, risk assessments, risk profiles, UBO documents, and client onboarding documentation by risk level – low, medium, high), setting up internal AML procedures in line with bank and legal requirements, and communicating with the bank throughout the compliance process. We also assist in providing additional documents upon request. If you need professional assistance, our specialists can guide you through every step.

​

Will the Czech regulator (ČNB) accept an AML specialist with foreign qualifications?

​

Yes, ČNB may recognize foreign qualifications, but the following conditions must be met: Relevance of the education to AML/compliance must be demonstrated, sufficient professional AML experience must be proven through documentation (references, contracts, course certificates), completion of certified Czech AML courses approved by regulatory authorities, fulfillment of the "Fit & Proper" criteria, including a clean criminal record and absence of financial crime-related convictions.

​

Which countries are considered high-risk for AML purposes?

​

In the Czech Republic, the list of high-risk jurisdictions aligns with FATF and EU lists. Engaging with clients from these countries requires Enhanced Due Diligence (EDD) procedures.

​​

How often must a company update its internal AML procedures?

​

AML procedures must be reviewed and updated regularly – at least once a year – and additionally whenever there are legal changes, newly identified risks, or the introduction of new technologies.