11.03.2025 14:12
The range of entities that must notify the Financial Analytical Unit (“FAU”) of their contact person has been expanded. This obligation is newly placed on a number of professions and businesses. The deadline for the contact person to be notified to FAU is 3 March 2025.
This obligation follows from the amendment to Act No. 253/2008 Coll. (effective from 30 December 2024) on certain measures against the legalization of the proceeds of crime and terrorist financing, as amended (the “AML Act”), and provides, in particular, an extended list of entities obliged to report their contact person and other specific information to the Financial Analytical Unit (“FAU”).
Obliged Persons
For a complete list of currently obliged persons, please check the FAO’s website .
If the obliged person is a natural person, they will designate themselves as the contact person.
Examples of Entities under the Said Obligation
- a person authorised to grant leasing arrangements, guarantees, credits or loans, or to trade in them
- insurance intermediary
- a person who buys or trades in debts or receivables
- a person advising a business on capital structure, industrial strategy and related matters or providing advice and services relating to company conversions, transfers of business concerns or the acquisition of a shareholding in a business corporation
- a person providing money brokering services
- a person who buys or sells immovable property
- real estate agent
- auditor
- tax adviser
- a person authorised subject to another legal regulation to provide legal assistance or financial and economic advice in relation to taxes, duties and other similar monetary transactions, as well as in matters directly related thereto
- a person authorised to do business as an accounting consultant, bookkeeper and tax preparer under the Trade Licensing Act.
Role of the Contact Person:
- to liaise with the FAU regarding the reporting of suspicious transactions (Section 18 of the AML Act)
- to ensure ongoing compliance with the information obligation under Section 24 of the AML Act vis a vis the Unit and compliance with its guidelines.
Pursuant to the Amendment, Obliged Persons Must Provide the Following Information about their Contact Person to the FAU:
- identification data of the contact person (name, surname, date of birth),
- contact details (telephone number, e-mail),
- the timeframe when the contact person is available to the FAU,
- information on the relationship of the contact person to the obliged person (e.g. employee, agent),
- information on the kind and type of the obliged person according to Section 2(1) of the AML Act.
The time limit for notification of the contact person is reduced to 30 days.
The obliged person shall inform the FAU of its designated contact person via data mailbox within 30 days from the date on which it became an obliged person (instead of the previous 60 days); and within 15 days in case of a change in already notified data (instead of the previous 30 days).
Pursuant to Ministry of Finance Decree No. 420/2024 Coll. on the format and structure of the relevant submission under the AML Act, the obliged person shall provide information on its contact person in an .xml file generated in an interactive form.
The obligation to notify the FAU of the contact person under the new regime must be fulfilled within 30 days of the entry into force of the Decree, i.e. from 1 February 2025. This time limit will thus lapse on 3 March 2025.
Have you been an obliged person already before the amendment? There are new obligations for you as well.
As the range of reported data has been expanded, the deadline also applies to those entities that were already obliged persons before the amendment and had their contact person notified under the previous version of the law.
High Fines
Finally, be aware of the fact that failure to comply with the above-mentioned information obligation may result in a fine of up to CZK 10 million.
Please do not hesitate to contact us in this matter.
We are ready to assist you in identifying and reporting the contact person to the FAU.