Model AML documents – 2024

The Sample AML Documents product contains the following three sample documents:

• Own activity programme
• Questionnaire for the client – natural person
• Questionnaire for the client – legal entity

Documents are in word format. The Obliged Person’s Own Activity Programme (the Programme) is intended for service providers of (i) virtual currency wallets and (ii) virtual currency exchangers who are obliged persons within the meaning of Section 5(1)(a) of the Act on Virtual Currency Exchange.

1 lit. o) and p) of Act No. 297/2008 Coll. on protection against money laundering and on protection against financing of terrorism and on amendment and supplementation of certain acts(AML Act). Preparation of the Programme is one of the key obligations of the obliged person under Article 20 of the AML Act. The Programme is intended to serve and assist the obliged person in the prevention and detection of money laundering and terrorist financing. In particular, the Programme contains an overview of the specific forms of unusual business transactions, the manner of exercising due diligence in relation to the client, the manner of risk assessment and management, the procedure for assessing whether a trade being prepared or executed is unusual, the procedure from the detection of an unusual business transaction to its urgent reporting to the financial intelligence unit, including the procedure and responsibilities of the staff assessing the unusual trading operation, the procedure for delaying an unusual trading operation, the procedure for data retention, the content and timing of training for staff who may come into contact with an unusual trading operation in the course of their work, etc. When exercising due diligence in relation to a client pursuant to Sections 10 to 12 of the AML Act, virtual currency service providers are obliged, inter alia, to identify and verify the identification of their clients prior to entering into a business relationship. Questionnaires are used by virtual currency service providers to fulfil this obligation.