Czech AML Package: Who Is Obliged and Who Supervises From 2027

On 27 October 2026 the Czech Financial Analytical Office (Finanční analytický úřad, FAÚ) published the second article in its “AML balíček krok za krokem” (AML package step by step) series on the Czech AML package. The document, marked version 1 and titled “Povinné osoby z finančního a nefinančního sektoru a systém dohledu od 10. 7. 2027”, addresses two questions every Czech firm faces before Regulation (EU) 2024/1624 (the AMLR) applies on 10 July 2027: whether the firm is an obliged entity under the new rules, and which authority will supervise it.

The answer carries a registration consequence. Under the draft Act on the Economic Protection of the State (zákon o ekonomické ochraně státu, ZEOS), which the FAÚ describes as still at the bill stage, the FAÚ reads the draft as making entry in the new central register of obliged entities (CRPO) a condition for carrying on activities the Act designates as registrable, subject to its transitional provisions. On the FAÚ’s account, carrying on such an activity without the required entry would be unauthorised business and an offence under the draft. Whether a restriction or offence applies to a given obliged entity depends on its specific activity and the relevant provisions of the bill. The same FAÚ map moves several activities into and out of scope and ends the joint AML/CFT supervision of banks by the Czech National Bank (CNB) and the FAÚ.

The FAÚ map is its own legal reading of a bill. The EU texts it relies on are final: the AMLR, Directive (EU) 2024/1640 (AMLD6) and Regulation (EU) 2024/1620 establishing AMLA.

Related reading: The EU AML Package: The Countdown to 10 July 2027

The FAÚ’s Czech AML package series and the weight of its second article

The FAÚ opened the series in September 2026 with an article on the sources of AML/CFT law from 10 July 2027. The series page lists eleven topics, and only the first two carry a document so far. Two of the later topics are reporting topics: suspicious transaction and activity reporting together with threshold transaction reporting, and the reporting duty of supervisors with the related data collection from obliged entities. Neither has been published yet.

The FAÚ attaches caveats that matter to anyone quoting the series in a policy. The series page presents the articles as the FAÚ’s own legal position, which is non-binding and open to revision in light of material from AMLA, the European Commission, Czech courts and the Court of Justice of the EU, and notes that the Czech legislation still has to pass through the legislative process. The second article adds that most implementing acts are still being drafted or approved and assumes the Czech rules take effect with the package on 10 July 2027. A footnote records that ZEOS is still a proposal.

Every ZEOS reference in the article therefore points at draft text. Recording “FAÚ article 2, version 1, 27 October 2026” beside each ZEOS citation in a control document makes the later comparison with a new FAÚ version or the enacted Act a mechanical check.

Dates in the FAÚ article and the EU texts behind it

Obliged-entity status comes from two lists: AMLR Article 3 and draft ZEOS § 4

Two instruments will say who is an obliged entity in the Czech Republic: the AMLR and ZEOS. Section 4 of the draft ZEOS treats as an obliged entity a person with a link to the Czech Republic that is either an obliged entity under Article 3 of the AMLR (§ 4(a)) or a national obliged entity listed in § 4(b) to (i). Both lists are closed. Which AMLR requirements reach each national category depends on the national measure, because Article 3 of AMLD6 allows Member States to apply all or part of the AMLR to additional sectors. The applicable duties for a national category must therefore be checked category by category against the relevant ZEOS provisions.

Article 3 of the AMLR has three limbs: credit institutions, financial institutions, and natural or legal persons “acting in the exercise of their professional activities”, from auditors, external accountants and tax advisors in point (3)(a) to professional football clubs in point (3)(o). The FAÚ illustrates the professional-activity condition with an estate agent. It is obliged when it intermediates property sales in its licensed trade, and outside scope when it sells the car it used for client viewings, even a car held as a business asset, because that sale is the management of its own property.

A second boundary sits in a footnote. AMLR Article 80(1) sets a general ceiling of EUR 10,000, or its equivalent, for cash payments for goods or services, including linked transactions. Article 80(2) and (3) allow or preserve stricter national limits, while Article 80(4) excludes specified payments from the EU ceiling. Businesses should therefore check the applicable national limit and exclusions before setting cash-payment controls. The FAÚ points out that this limit binds persons trading in goods or providing services even when they are not obliged entities. The cash limit and obliged-entity status are two separate questions, and a firm can face the first without the second.

Where Annex 2 fits

The draft ZEOS also has an Annex 2 that lists kinds of obliged entity in detail. The FAÚ is explicit that status arises only from the relevant AMLR provisions and § 4 of ZEOS, and that the annex supplies the detailed categorisation. A firm that finds its activity in Annex 2 has a label. The legal reason it is in scope still has to be traced to an AMLR point or a § 4 letter.

The national list in § 4(b) to (i)

Member States may add national obliged entities. Article 3 of AMLD6 allows Member States to extend all or specified AMLR requirements to additional sectors exposed to money laundering and terrorist financing risks. For new national measures, Article 3(2) requires notification to the Commission setting out the risk justification, the impact on the internal market, the AMLR requirements to be applied and the text of the draft national measures. Article 3(3) generally requires adoption to be postponed for six months after notification, unless the measure addresses a serious and present money laundering or terrorist financing threat. Article 3(7) provides a separate route for sectors already covered by national law transposing Directive (EU) 2015/849 on 9 July 2024; Member States must notify these sectors to the Commission by 10 January 2028. Article 3(8) requires the Commission to publish a consolidated list of national sectors by 10 July 2028 and annually thereafter.

The draft ZEOS uses that room in § 4(b) to (i). Some of these entities are already obliged under the current Act No. 253/2008 Coll. (the AML Act): the FAÚ’s example is insolvency and restructuring administrators, obliged today under § 2(1)(m) of the AML Act and carried into § 4(c) and (d) of ZEOS. One category is new: § 4(e) adds persons providing cash transport services as part of their business. The FAÚ’s supervision tables, which rest on the draft ZEOS, assign the national categories as follows; the proposed categories and allocations should be verified against the current official bill before they are relied upon.

The § 4(f) entry for virtual asset service providers sits in the non-financial national list, while crypto-asset service providers appear among the AMLR financial institutions. The FAÚ article does not explain where one category ends and the other begins. The precise boundary between the national category and crypto-asset service providers under Regulation (EU) 2023/1114, and the corresponding national obligations, must be checked against the current bill text, since earlier ministry drafts of ZEOS may already draw it.

Financial sector, non-financial sector and the four types in Annex 2

The financial and non-financial split comes from the FATF Recommendations, which separate financial institutions from designated non-financial businesses and professions. Article 2 of AMLD6 defines a “financial supervisor” as one in charge of credit and financial institutions, a “non-financial supervisor” as one in charge of the non-financial sector, and the “non-financial sector” as the obliged entities in Article 3(3) of the AMLR. The draft ZEOS repeats the split in § 7(d) and (e), but its non-financial sector means every obliged entity other than credit and financial institutions, which pulls the national obliged entities into it.

The result is a two-line test: credit institutions and AMLR financial institutions are financial-sector obliged entities, and every other obliged entity, including each national one in § 4(b) to (i), is non-financial. AMLA’s direct supervision and its indirect supervision of non-selected entities are both defined in terms of credit and financial institutions, so the test also decides whether AMLA can supervise the entity directly or indirectly. For the non-financial sector, the AMLA Regulation provides for oversight of the supervisors, such as the peer reviews in Article 35.

Annex 2 then adds a second axis, the type of obliged entity, which the FAÚ describes as the intensity of the entity’s economic engagement in the Czech Republic. There are four types:

• an obliged entity with its registered office in the Czech Republic;
• an obliged entity with its registered office abroad and an establishment (provozovna) in the Czech Republic, such as a German company trading in high-value goods that sets up a Czech establishment;
• an electronic money issuer, payment service provider or crypto-asset service provider operating in the Czech Republic under the free provision of services through agents, distributors or other infrastructure, including where the activity rests on a payment services authorisation obtained in another Member State;
• a gambling operator not established in the Czech Republic, with “establishment” defined in § 5(c) of the draft ZEOS; the FAÚ’s example is a Malta-based operator whose online games are also available in the Czech Republic.

Types three and four correspond, in my reading, to two host-country rules in AMLD6: Article 38 for e-money issuers, payment service providers and crypto-asset service providers operating through agents, distributors or other infrastructure, and the second subparagraph of Article 37(1), under which activities carried on under a specific national authorisation for the free provision of services are supervised nationally whether or not there is infrastructure in the territory. A foreign firm of type three or four can therefore be a Czech obliged entity without a Czech company or branch. For payment and e-money networks, the same agent footprint drives the question covered in our note on AMLA’s central contact point survey for PSPs and e-money issuers.

Who becomes an obliged entity on 10 July 2027

The FAÚ lists new obliged entities from 10 July 2027 under the word “for example”, so the list illustrates and is not exhaustive:

• undertakings whose main activity is acquiring holdings, including financial holding companies, mixed financial holding companies and financial mixed activity holding companies;
• traders in high-value goods;
• persons storing cultural goods and high-value goods in free zones and customs warehouses, where the transaction or linked transactions reach EUR 10,000 or more;
• investment migration operators;
• non-financial mixed activity holding companies;
• cash transport service providers, as national obliged entities under § 4(e) of the draft ZEOS.

The high-value goods category is narrower than the phrase suggests. Article 3(3)(f) of the AMLR covers persons trading in high-value goods “as a regular or principal professional activity”, and Article 2(1), point (54), defines high-value goods by reference to Annex IV, which sets a value line for each: jewellery and gold- or silversmith articles above EUR 10,000, clocks and watches above EUR 10,000, motor vehicles priced above EUR 250,000, and aircraft and watercraft priced above EUR 7,500,000. On my reading, a car dealer that never sells a vehicle priced above EUR 250,000 does not trade in high-value goods within the AMLR definition, whatever its turnover.

Football agents and clubs: a 2029 date and an exemption procedure

The FAÚ’s first article flagged a staggered start, and the second names the entities behind it. Article 90 of the AMLR applies from 10 July 2027, except to football agents and professional football clubs in Article 3(3)(n) and (o), for which it applies from 10 July 2029. Clubs are in scope only for transactions with an investor, with a sponsor, with football agents or other intermediaries, and for a player’s transfer.

Article 5(1) of the AMLR lets Member States exempt, in full or in part and on the basis of proven low risk, clubs in the highest national division with total annual turnover below EUR 5,000,000 in each of the previous two calendar years. The FAÚ describes how § 6 of the draft ZEOS handles the point. From 10 July 2029, professional football clubs fall within AMLR Article 3(3)(o) for the transactions specified there, unless a valid exemption applies. Article 5 permits Member States to exempt qualifying top-division clubs and, on the basis of proven low risk, clubs in lower divisions, subject to the procedure in Article 7. On the FAÚ’s account, the draft ZEOS separately defines selected professional football clubs using top-division participation and turnover evidence; that national definition does not itself replace the EU obliged-entity scope or the exemption procedure. The FAÚ shows itself as the supervisor for these clubs.

Under AMLR Articles 5 and 7, an exemption for professional football clubs depends on a Member State risk assessment and the EU procedure for notifying and confirming the exemption. Meeting the EUR 5,000,000 turnover threshold does not itself confer an exemption. The proposed Czech evidential procedure and treatment of lower-division clubs require confirmation against the current ZEOS text.

Who drops out on 10 July 2027, and the routes back in

The FAÚ’s fifth table lists, as examples, activities that create obliged-entity status under the current AML Act and will stop doing so from 10 July 2027.

Each exit carries a qualification. The account information exit lines up with the AMLR’s financial-institution definition, which, in the FAÚ’s rendering of Article 2(1), point (6)(a), excludes the activities in point 8 of Annex I to Directive (EU) 2015/2366, the account information service. The payroll exit is conditional: under § 6 of the draft ZEOS, as the FAÚ describes it, an external accountant doing only payroll work falls outside the definition only if it has notified that fact to the CRPO. Without the notification, on the FAÚ’s reading, the accountant stays inside the definition and inside Article 3(3)(a) of the AMLR.

The cash-trade exit is the one most easily misread. A business that loses obliged-entity status for its large cash trades still faces the Article 80 cash limit described above, which sets a general EU ceiling of EUR 10,000 on those trades, or a stricter national limit where one applies.

Some firms will lose one basis and gain another. The FAÚ considers it possible, and in some cases likely, that an entity’s status will not change because another category picks it up. Its example is a used-goods business selling jewellery worth more than EUR 10,000, which from 10 July 2027 would be trading in high-value goods under Article 3(3)(f) and Annex IV point 1, where that trading is a regular or principal professional activity.

Supervision from 10 July 2027: one supervisor per activity

The FAÚ summarises four structural changes. The first is exclusivity: each activity that makes a person an obliged entity will have one supervisor. Credit institutions, supervised for AML/CFT today by both the CNB and the FAÚ, will from 10 July 2027, assuming ZEOS is in force, answer to the CNB alone.

Exclusivity attaches to the activity. A company with several obliged activities can still answer to several supervisors, each limited to the obligations linked to the authorisation or activity within its remit. The FAÚ’s example is a firm offering safe custody of valuables that also trades in precious metals and stones as a regular or principal activity: the FAÚ supervises the safe custody as financial supervisor, and the Czech Trade Inspection Authority (Česká obchodní inspekce, ČOI) supervises the precious-metals trading as non-financial supervisor. For some financial institutions, supervision follows a defined set of activities, financial leasing being the FAÚ’s example (§ 48(2) of the draft ZEOS).

The second change applies the financial and non-financial split to supervisors. The third divides financial-sector supervision between AMLA, for selected obliged entities, and national supervisors for the rest, with AMLA overseeing the national authorities. The fourth adds a public authority over the professional chambers that supervise their members.

The draft supervisor map

Under the ZEOS bill, four public institutions and five professional chambers would act as national supervisors, and two public authorities would oversee the chambers. The table condenses the FAÚ’s supervision tables. The detailed assignments are the FAÚ’s account of the draft and should be checked against the current official ZEOS bill before reliance.

The proposed CNB allocation requires confirmation against the current official ZEOS bill. The § 47(1) test described here is the FAÚ’s account of the bill version it used and has not been independently authenticated against the bill, and section numbering may change between draft versions. The FAÚ stresses that an AMLR financial-institution category is insufficient on its own to make the CNB the supervisor. On the FAÚ’s account of the draft, supervision of financial-institution activities depends on sectoral authorisation and existing CNB supervisory competence: the CNB would supervise financial institutions that carry on the activity under a CNB authorisation, licence or registration (or a comparable foreign authorisation for operating in the Czech Republic) and that are also subject to CNB supervision under another sectoral law, with the FAÚ taking those outside these conditions. The annotations show the effect: lending, financial leasing and guarantees are marked “consumers only” in the CNB list and “entrepreneurs only” in the FAÚ list.

Two rows split a single AMLR point. Under Article 3(3)(j), on cultural and high-value goods in free zones and customs warehouses, the FAÚ’s tables give storing to the Customs Administration and trading and intermediation to ČOI. Credit intermediaries under Article 3(3)(k) appear in both the CNB and the FAÚ tables, with a note that intermediaries of non-housing consumer credit that are not AMLR financial institutions go to the FAÚ. Firms in either category should confirm their supervisor against the final ZEOS text.

AMLA’s layer over Czech financial institutions

The AMLA Regulation defines a “selected obliged entity” as a credit institution, financial institution or group of them, at the highest level of consolidation in the Union, that AMLA supervises directly under Article 13; every other such institution or group is “non-selected”. The FAÚ’s summary of selection follows the recitals: high-risk entities or groups operating in at least six Member States, assessed at group level, as a rule 40 of them, each supervised for at least three years.

The Regulation adds the timing. Article 13(4) requires AMLA to start the first selection by 1 July 2027 and conclude it within six months, publish the list without undue delay, and begin direct supervision six months after publication. Article 106(2) limits AMLA’s first selection to 40 obliged entities or groups if more than 40 otherwise qualify, with ranking criteria for deciding which are selected. In subsequent rounds, Article 13(2) permits AMLA, following consultation with supervisory authorities, to agree a higher number where more than 40 qualify. A selected entity stays under direct supervision until AMLA starts supervising on a later list that no longer includes it (Article 13(6)). The groundwork data exercise behind that selection is covered in our guide to AMLA’s risk assessment data collection for the 2027 selection.

Article 13(3) of the AMLA Regulation establishes an additional selection mechanism for Member States that have no qualifying high-risk institution or group under the main selection criteria. However, Article 106(3) expressly disapplies that mechanism during AMLA’s first selection process, which must commence by 1 July 2027. The first round is governed by the cross-border assessment criterion in Article 12(1), the high residual-risk criterion in Article 13(1) and the selection limit and ranking rules in Article 106(2). The additional Member-State selection mechanism becomes relevant in subsequent selection rounds.

Fees reach further than selection. Article 77(1) of the AMLA Regulation requires an annual supervisory fee from selected obliged entities and from non-selected obliged entities meeting the Article 12(1) cross-border assessment criterion. For a non-selected institution or group, fee liability therefore does not depend on receiving a high residual-risk classification or qualifying for direct supervision under Article 13(1). Article 77 of the AMLA Regulation bases the annual fee on the cost of direct and indirect supervision of the selected and non-selected obliged entities subject to fees, and Article 77(6)(e) caps a non-selected entity’s fee, in proportion to its income or turnover, at 20% of the fee for a selected entity with the same income or turnover. Article 77(6) sets 1 January 2027 as the Commission’s deadline for the delegated act on the methodology, and Article 77(5) preserves national financial supervisors’ own fees for tasks not conferred on AMLA.

Professional chambers and the authorities that will oversee them

AMLD6 Article 37(3) lets Member States leave supervision of the obliged entities in Article 3(3)(a) and (b) of the AMLR, the tax, audit, accounting and legal professions, with self-regulatory bodies that have the necessary powers and resources. The FAÚ says the Czech Republic has chosen that route for members of the relevant chambers. Article 52 then requires a public authority to oversee each self-regulatory body: it verifies that the body meets the Article 37 requirements, issues guidance, ensures the body supervises adequately and effectively, reviews the exemptions it grants from individual documented risk assessments, and can compel information, other than information gathered while ascertaining a client’s legal position or in connection with judicial proceedings, and issue instructions.

Under the draft ZEOS, the Ministry of Justice would oversee the Czech Bar Association, the Notarial Chamber and the Chamber of Executors, and the FAÚ would oversee the Chamber of Tax Advisers and the Chamber of Auditors. The FAÚ describes this authority as answerable to AMLA for the chambers’ supervision and as the intermediary between them. Where supervision sits with a self-regulatory body, AMLD6 Article 37(4) makes the Article 52 authority the participant in the national coordination mechanism among supervisors.

One Article 52 duty feeds AML reporting statistics. The overseeing authority’s annual report must state, for each self-regulatory body, the number of suspicious transaction reports made by the obliged entities it supervises, whether filed directly with the FIU under Article 69(1) of the AMLR or forwarded by the body under Article 70(1) (AMLD6 Article 52(7)(b)). Czech chamber members’ reporting volumes will therefore be published chamber by chamber.

The CRPO: registration that conditions the activity

Part five, head III of the draft ZEOS creates the central register of obliged entities (centrální rejstřík povinných osob, CRPO), administered by the FAÚ. It gathers basic data on every obliged entity in the Czech Republic and, for the obliged entities the Act specifies, makes entry a condition of lawfully carrying on the activity. Data on five subjects will be transferred or entered:

• the obliged entity;
• its beneficial owner;
• a member of its senior management;
• its compliance officer;
• its contact person for the Financial Intelligence Unit, which the FAÚ says is recorded only where the obliged entity has designated one. The FAÚ lists this contact person separately from the compliance officer; whether the compliance officer is the default FIU contact under the bill is a point to confirm in the bill text.

Data held in the base registers will transfer automatically to the extent they are kept there, and data from other public administration systems only where those systems are connected to the CRPO. Access is limited to authorities named in the Act, most of them to data within their remit, and the FIU contact person is visible only to the FIU and the obliged entity concerned. The FIU function itself is performed by an internal FAÚ unit that is functionally independent and organisationally separate from the FAÚ’s management and executive structures.

The CRPO start date needs separate attention from anyone planning around 10 July 2027. According to the FAÚ, a transitional provision ties the CRPO launch to an FAÚ notice on its official notice board stating when entries begin. The FAÚ’s account is that CRPO registration is a condition for carrying on the specified registrable activities under the draft (it cites § 29 and § 29(1)(c) for the bill version it used). The corresponding registration condition, offence provision and transitional interval after the notice must be checked in the current official bill before an operating prohibition or offence is treated as established; paragraph numbers may change between draft versions.

The EU basis sits in AMLD6 Article 4, which requires obliged entities outside the licensed or regulated groups (currency exchange and cheque cashing offices, trust or company service providers, gambling providers) to be subject to minimum registration requirements that let supervisors identify them, unless other licensing or registration rules already do so. In my reading, the CRPO is how the draft meets that requirement, and the draft goes further by tying entry in the register to the right to operate.

Turning the FAÚ article into a status-and-supervisor map

The FAÚ’s conclusion names what an obliged entity needs: a correct reading of the provision that gives it status, knowledge of which body supervises it, and an overview of its duties, with CRPO registration singled out. It also repeats that the duties apply only while the entity carries on an AML/CFT-relevant activity. As a working sequence:

1. List every activity the firm carries on in or into the Czech Republic that could be AML/CFT-relevant, including activities run through agents, distributors or online channels.
2. For each activity, record the status source: the AMLR Article 3 point (with the Article 2(1) definition behind it) or the draft ZEOS § 4 letter. Note Annex 2 categories as labels only.
3. Record the sector (financial or non-financial) and the Annex 2 type, one to four.
4. Assign the supervisor from the FAÚ tables, testing the two § 47(1) conditions for every financial-institution activity and flagging the split rows under Article 3(3)(j) and (k).
5. Mark changes against the current AML Act: activities that gain status, activities that lose it, and losses offset by a new category, as in the jewellery example.
6. Prepare the proposed CRPO data set: obliged entity, beneficial owner, senior management member, compliance officer and any separately designated FIU contact person, plus any payroll-only notification; check the data fields and the FIU-contact rules against the current ZEOS text.
7. For credit and financial institutions in a cross-border group, add AMLA status: candidate for selection, non-selected entity subject to fees, or neither.
8. Tag each ZEOS reference with the FAÚ version relied on.

The output is one row per activity, so a mixed group may hold several rows with different supervisors.

Frequently Asked Questions

Our Prague holding company only holds the shares of a Czech bank. Is it an obliged entity, and who would supervise it?

Undertakings whose main activity is acquiring holdings are new financial-institution obliged entities from 10 July 2027 in the FAÚ’s list. Its CNB table places financial holding companies, mixed financial holding companies and financial mixed activity holding companies in the financial-institution row, while its FAÚ table covers holding companies “other than” those three forms. A company holding bank shares should therefore first establish whether it is one of the three named forms: if it is, it sits in the CNB row, where the § 47(1) conditions decide whether the CNB is the supervisor; a holding vehicle outside the three forms lands with the FAÚ in the draft map.

A payment institution authorised in another Member State serves Czech customers through Czech agents. Which supervisor applies?

It is a type three obliged entity in the Annex 2 scheme. AMLD6 Article 38(1) makes host-country supervisors responsible for activities carried on through agents, distributors or other infrastructure. Article 38(2) moves that supervision to the home supervisor only where the criteria in the Article 41(2) technical standards are not met and the host supervisor notifies the home supervisor that local infrastructure is limited; the home supervisor then informs the entity within two weeks (Article 38(4)). On the FAÚ’s account, the § 47(1) CNB conditions count a comparable foreign authorisation for operating in the Czech Republic.

An agency lets flats for us at EUR 3,000 a month. Does that make the agency an obliged entity for the lettings?

Article 3(3)(d) of the AMLR covers estate agents and other real estate professionals to the extent they act as intermediaries in real estate transactions, including letting where the monthly rent amounts to at least EUR 10,000 or the equivalent, irrespective of the means of payment. A letting at EUR 3,000 a month is below that line. The agency’s sales intermediation is a separate question, and estate agents sit with the FAÚ in the draft map. Businesses buying and selling real estate on their own account fall under the national category in § 4(b) of ZEOS.

A lawyer at our firm provides tax advice as a principal activity. Is the Czech Bar Association the supervisor for that?

The FAÚ’s tables suggest it may not be. The chambers table assigns Article 3(3)(a) only to auditors and tax advisers, and the Article 3(3)(b) activities of advocates to the Czech Bar Association. The FAÚ table lists “any other natural or legal persons (other than tax advisers), including independent legal professionals such as lawyers” giving tax advice as a principal business or professional activity. AMLR Article 3(3)(a) can bring tax-advice activities undertaken by legal professionals into scope, but it does not allocate Czech supervisory responsibility. Whether the FAÚ or the Czech Bar Association supervises that activity must be confirmed against the current ZEOS supervisory provisions.

Can the CNB hand a struggling non-selected Czech institution to AMLA?

Article 14 of the AMLA Regulation lets a financial supervisor ask AMLA, in exceptional circumstances and with reasons, to take over direct supervision of a particular non-selected entity. AMLA can agree only if national measures have proved ineffective against serious, repeated or systematic breaches, if the risk or breaches affect several group entities and the supervisors agree Union-level action would work better, or if the national supervisor has a temporary, objective and demonstrable lack of capacity. The entity is told of the request and its proposed timeline.

A licensed online gambling operator has no Czech premises. Could a Czech exemption take it out of scope?

Article 4 of the AMLR lets Member States exempt certain gambling providers, in full or in part, on the basis of proven low risk, but never casinos, and never providers whose principal activity is online gambling or sports betting unless the online service is operated by the State or its organisation, operation and administration are regulated by the State. An operator in that non-exemptable group stays an obliged entity whatever the national choice, and the FAÚ article does not say whether the Czech Republic will use Article 4 at all. In the FAÚ map such an operator is a type four entity, supervised by the Customs Administration.

Related Articles

• The EU AML Package: The Countdown to 10 July 2027: how the AMLR, AMLD6 and the AMLA Regulation fit together.
• AMLA Risk Assessment Data Collection: The 2027 Selection Exercise: the data AMLA gathers to decide which institutions it will supervise directly.
• AMLA Central Contact Point Survey: The 15 September Deadline for PSPs: what AMLA asked of payment and e-money networks using agents.
• AMLA Central Database RTS: Who Reports What, and From When: the supervisory reporting flows into AMLA’s central AML/CFT database.
• FATF Gaming and Gambling Risks: The New AML Red-Flag Indicators: FATF red flags for gambling operators.

Key Takeaways

• Firms leaving obliged-entity status for large cash trades should keep a control on the Article 80 cash cap, checking the applicable national limit and exclusions, before retiring their cash-transaction procedures.
• Payroll-only accountancy firms should monitor the FAÚ notice announcing the start of CRPO entries, but should verify the notification procedure, any transitional period and the resulting change in obliged-entity status against the current ZEOS text before using that notice as an operational trigger.
• A lender serving both consumers and businesses in the Czech Republic should assess its activities separately under the proposed national supervisor-allocation rules. A split between CNB and FAÚ supervision is a scenario to verify against the current ZEOS draft and the FAÚ’s accompanying table, rather than an established requirement.
• Top-league football clubs below EUR 5,000,000 turnover should keep two calendar years of turnover figures available, but under AMLR Articles 5 and 7 an exemption depends on a Member State risk assessment and Commission confirmation, and the Czech procedure is to be confirmed against the current ZEOS text.
• For AMLA’s first selection round beginning in 2027, a Czech credit or financial institution should assess its exposure against the Article 12(1) requirement to operate in at least six Member States and the Article 13(1) high residual-risk criterion. The Article 13(3) additional Member-State selection mechanism is excluded from that first round by Article 106(3), although it may become relevant in later rounds.
• Non-selected credit institutions, financial institutions and relevant groups meeting Article 12(1)’s six-Member-State criterion should assess their liability for AMLA’s annual supervisory fee, even where they do not qualify for direct supervision because their residual risk is not classified as high. Article 77(6)(e) requires the fee for non-selected entities, in proportion to income or turnover, not to exceed 20% of the fee for selected entities with the same income or turnover.

Sources and References

• FAÚ, “AML balíček krok za krokem: 2. článek” (news item, 27 October 2026): fau.gov.cz
• FAÚ, “Povinné osoby z finančního a nefinančního sektoru a systém dohledu od 10. 7. 2027” (article version 1, 27 October 2026, PDF): fau.gov.cz
• FAÚ, “AML balíček krok za krokem” series page: fau.gov.cz
• Regulation (EU) 2024/1624 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing (AMLR): EUR-Lex
• Directive (EU) 2024/1640 on the mechanisms to be put in place by the Member States for the prevention of the use of the financial system for the purposes of money laundering or terrorist financing (AMLD6): EUR-Lex
• Regulation (EU) 2024/1620 establishing the Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA Regulation): EUR-Lex
• Regulation (EU) 2023/1114 on markets in crypto-assets: EUR-Lex
• Directive (EU) 2015/2366 on payment services in the internal market (PSD2), Article 4(19) and Annex I: EUR-Lex
• Act No. 253/2008 Coll., on certain measures against the legalisation of proceeds of crime and the financing of terrorism (the current AML Act): e-Sbírka

The FAÚ notice and the dates that follow it

The Czech side of this map still has two open dates: the enactment of ZEOS, which the FAÚ expects to take effect with the AMLR, and the FAÚ notice on its official notice board that opens CRPO entries. The EU side is fixed. The Commission’s deadline for the AMLA fee methodology is 1 January 2027, AMLA’s first selection must start by 1 July 2027, and the AMLR applies from 10 July 2027. The artifact to have ready before the CRPO notice is the one-row-per-activity status-and-supervisor map, tagged to FAÚ version 1 and re-checked against each later version of the FAÚ article and against the enacted ZEOS text.

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