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Alena Mach
02.11.2022 | 6 min read
Updated: 15.10.2026
As part of their anti-money laundering obligations, companies are required to appoint a so-called contact person who will ensure the constant connection with the Financial Analytical Office (FAÚ), as well as to authorise a member of the statutory body responsible for compliance with obligations and record-keeping regarding anti-ML/TF measures in writing. This is provided for in articles 18, 22 and 22a of Act No. 253/2008 Coll., on Certain Measures against the Legalization of the Proceeds of Crime and the Financing of Terrorism (also known as the "Anti-Money Laundering Act" or the "AML/CFT Act").
The information in this article applies only to the activities of companies registered and operating in the Czech Republic.
General information about an authorised person
Companies that are legally required to comply with AML/CFT legislation must notify the Financial Analytical Office, through a data box, of the designated contact person within 30 days of becoming an obliged entity (§ 22(2) of the AML/CFT Act). Some obliged entities, such as attorneys and notaries covered by § 2(1)(g), are excepted from this notice. The 60-day period in the Act applies to the written authorisation of a member of the statutory body (§ 22a(2)).
If the contact person or any of the notified details change, the Office must be informed within 15 days. The notice states the contact person's name, position, telephone and electronic contact details, the hours when the person can be contacted, and the type of obliged entity.
It is worth noting that according to the AML/CFT Act, the contact person of a financial institution (e.g. a mini-fund under § 15 of the ISIF Act) cannot be a member of the statutory body (except for when it is justified by the nature and area of the obliged person`s activities).
In addition, employees responsible for the conclusion and legal regulation of transactions or employees engaged in internal audits (unless justified by the nature and area of the obliged person's activities) cannot be appointed to this position.
We recommend that you check whether a particular employee can be assigned as a contact person with the Financial Analytical Office (FAÚ) in each case.
Contact person and their obligations
One of the responsibilities of the contact person is to ensure an actual connection with the FAÚ. According to § 18 of the AML/CFT Act, such a link means notifying the supervisory authority when each suspicious transaction is detected.
Authorised person and their obligations
The authorised person responsible for ensuring compliance with anti-money laundering obligations under the AML/CFT Act can only be chosen and appointed from among the members of the statutory body. If there is only one member in the statutory body (for example, the managing director), then this person must be an authorised person by law. If there are several members in the statutory body, the authorised person may be selected from among them, and his powers must be delegated in writing.
The authorised person is responsible for complying with all AML obligations, including:
- Ensures the availability of internal regulatory documents system;
- Ensures the availability of a risk assessment system;
- Monitors the relevance of documentation;
- Identifies and monitors customers;
- Trains staff, etc.
What are the consequences of not having an authorised person and a contact person?
Breach of the duty to notify the FAÚ of the contact person under § 22(2) is an offence punishable by a fine of up to CZK 10 million (§ 45(3) and (5)). Failure to authorise a member of the statutory body under § 22a is punishable by a fine of up to CZK 1 million (§ 48(5) and (7)). Serious, repeated or persistent failures to authorise carry higher penalties (§ 48(10)).
Failure to comply with the abovementioned requirements may also result in additional secondary risks arising from improper compliance with AML/CFT obligations. It puts the company at risk not only of a reputational nature but also attracts unwanted attention from fraudsters, leading to increased regulatory oversight and additional fines.