Lately, Czech banks have been increasingly asking business owners questions like:
“Máte zavedené postupy AML?”
“Vztahuje se na vás povinnost dodržovat zákon o praní špinavých peněz?”
(“Do you have AML procedures in place?” / “Are you required to comply with anti-money laundering regulations?”)
If you’re wondering what’s behind these questions — or want to be ready when they come your way — this article will walk you through what AML is, who it applies to, what the law requires, and what steps to take if you’re subject to the new rules.
What Is AML and Why Everyone’s Talking About It
AML stands for Anti-Money Laundering. The term has been around for decades and has long been used by banks, large corporations, insurance companies — basically, anyone dealing with millions in transactions, licenses, or international clients. These entities are required to verify the source of their clients’ funds and report anything suspicious to the authorities.
But as online payments, cryptocurrencies, and cross-border transactions became more common, the old regulations proved too narrow — and too easy to bypass. This not only led to tax losses but also posed real risks to national security.
To address the issue, the European Union changed its approach to money laundering. It introduced new directives (including the 5th and 6th AML Directives — 5AMLD and 6AMLD), and in 2024, the Czech Republic implemented these rules by amending Act No. 253/2008 Sb. — the country’s key AML legislation.
With these updates now in force, AML compliance is no longer limited to big players. It now affects small and medium-sized businesses too. Entire sectors that previously had little to do with AML are being drawn in — accountants, real estate agents, lawyers, crypto companies, small online businesses, and many others.
The law now sets out clear obligations:
- know who you’re doing business with,
- check where the money comes from,
- identify who’s really behind the client,
- and be ready to explain it to the FAÚ — the Czech Financial Analytical Office.
Where a business owner could once say “I didn’t know,” that’s no longer an option.
Now, you’re expected to know.
What Act No. 253/2008 Sb Says — Clear and to the Point
What do entrepreneurs and business owners in the Czech Republic need to know?
The law doesn’t leave room for interpretation — it clearly defines who is subject to AML obligations. And it’s not just banks and insurance companies. The list also includes:
- accountants and tax advisors,
- real estate agents, lawyers, and notaries,
- cryptocurrency platforms, wallets, and exchanges,
- individuals handling cash or crypto transactions of €10,000 or more,
- businesses that manage third-party funds,
- intermediaries involved in the sale of high-value goods — such as gold, jewelry, or artwork,
- corporate service providers (e.g., company formation and administration),
- operators of online lotteries, bingo, and gambling services,
- bankruptcy and restructuring trustees.
In short, AML applies to any business that handles other people’s money, valuables, or high-risk transactions.
What matters now is not the size of the business — but the sector it operates in.
The legal definitions are fairly precise. If you offer accounting or legal services, deal in real estate, manage client assets, work with cryptocurrency, or register companies, you should definitely seek advice on whether AML obligations apply to you.
Here are the core AML duties for all obligated entities:
- verify the identity of each client (remote verification is allowed under the new rules),
- assess the risk level of transactions,
- document the process,
- and, if needed, report any suspicious activity to the Czech Financial Analytical Office (FAÚ).
Important: Responsibility doesn’t rest solely with the company — it extends to specific individuals.
If you’re a sole trader, you are personally liable.
In the case of an s.r.o., it’s the director or a designated AML officer who bears responsibility.
A Simple Checklist — Does AML Apply to You?
Answer these quick questions. If you say “yes” to even one, it’s worth consulting an AML specialist:
- Do you handle clients’ money or assets?
- Do you carry out transactions involving cash or cryptocurrency?
- Do you help set up companies or manage them on behalf of clients?
- Are you involved in real estate deals, or transactions with valuables, gold, jewelry, or artwork?
- Do you offer accounting, legal, or tax advisory services?
- Do you work as a bankruptcy or restructuring trustee (insolvenční správce)?
- Do you run online lotteries, bingo, or other forms of gambling?
- Are you involved in transactions where the client is not the ultimate beneficial owner?
- Do you work with clients from abroad or from high-risk countries?
If you recognized yourself in even one of these — there’s a good chance your business falls under AML regulations.
Better to find out now than deal with the consequences later.
What to Do If You Fall Under AML Regulations
This article isn’t meant to walk you through every detail of AML procedures and internal policies — that requires individual consultation tailored to your specific business.
But if AML regulations do apply to you, here’s what you’ll generally need to do:
- Appoint a responsible person — typically a company director or an external consultant.
- Create an internal AML policy — outlining how you’ll verify clients, assess risk, and handle suspicious transactions.
- Keep detailed records — including client data, transactions, and verification steps.
- Report to the FAÚ (Financial Analytical Office) if a transaction raises reasonable suspicion.
- Store documents for at least five years.
- Train yourself or your staff in AML basics — how to identify suspicious behavior, properly verify a client’s identity, and act within the law.
The good news? Many of these tasks can now be automated using AML software. These tools can screen clients against sanctions lists, assess risk levels, log activities, and generate reports.
What matters most is understanding this: AML compliance is no longer a formality — it’s a legal obligation.
What Happens If You Ignore AML Obligations
AML compliance isn’t a suggestion — it’s the law. And failing to comply can have serious consequences, even if you’re a sole trader.
Here’s what’s at stake:
- Fines — up to CZK 5 million, even for individuals.
- Frozen or denied bank accounts — banks may refuse to work with you.
- Audits by the FAÚ — especially if you lack documentation, procedures, or fail to act on suspicious activity.
- Personal liability — not just the company, but a specific individual is held responsible.
- Loss of business reputation — particularly damaging in finance, law, or related industries.
Often, it doesn’t start with an inspection. It starts with a simple question from your bank: “Who is this client?” or “Where did the funds come from?”
If you don’t have clear answers or even basic documentation, things can escalate quickly.
Final Thoughts
AML may not be the most exciting part of running a business — but ignoring it is no longer an option. The law has changed, the rules are stricter, and regulators are more active than ever. Even small businesses must now be able to demonstrate control over their processes.
If you’re subject to AML, you have two choices: handle it yourself, or hire professionals. Just make sure to ask one important question before you choose a provider:
How well are they handling AML?
Because it applies to them too.
