Home / Guide

AML for real estate agents in Czechia: FAÚ contact person, client identification and what to watch

A real estate agent in Czechia is an obliged entity under the AML Act. When and how to notify FAÚ of your contact person (form guide), how to identify and check clients, when to refuse a deal and how long to keep records.

Do you act as an agent in property sales? Then under Act No. 253/2008 Coll. (the AML Act) you are an obliged entity: you notify the Financial Analytical Office (FAÚ) of a contact person, identify and check clients, keep records and report suspicious transactions. This overview follows the Act as in force from 11 January 2026 and includes a step-by-step guide to the FAÚ form.

AML for real estate agents in Czechia: FAÚ contact person, client identification and what to watch

1. When an agent is an obliged entity

A real estate agent is an obliged entity under Act No. 253/2008 Coll. (Section 2(1), letter d, point 2). For lease, sublease or usufructuary lease (pacht) deals, this applies only when the monthly payment (or their total) reaches at least EUR 10,000. It covers both self-employed agents with a trade licence and agencies.

2. Contact person: notify FAÚ within 30 days

You appoint a specific employee or member of the statutory body (for example, a managing director) to report suspicious transactions and deal with FAÚ. A self-employed agent appoints themselves where this matches the scope of their business (Act No. 253/2008 Coll., Section 22(1)).

You notify FAÚ through your data box (datová schránka) within 30 days of becoming an obliged entity, and of any change in the details within 15 days (Act No. 253/2008 Coll., Section 22(2)). You state the contact person’s name, position, phone and e-mail, the hours when they can be reached, and the type of obliged entity. The filing must be in XML format (Decree No. 420/2024 Coll., Section 1).

3. The FAÚ form step by step

Open formulare.fau.gov.cz and choose “Formulář oznámení o určení kontaktní osoby”.
Úvod (introduction): in the “Typ povinné osoby” field, select “[028] … realitní zprostředkovatel”. If your business also falls under another type of obliged entity, add it to the same form. Leave the “Číslo jednací FAÚ” field empty.
Informace k povinné osobě: company ID (IČO), name and registered address.
Kontaktní osoba: surname, first name, role (the obliged entity itself, member of the statutory body or employee), contact hours for each day, phone, mobile and e-mail.
Odeslání (sending): the “ODESLAT DATOVOU ZPRÁVOU” button takes you to your data box and sends the form in XML format. Alternatively, use “VYGENEROVAT DOKUMENT PRO MANUÁLNÍ ODESLÁNÍ” and send the downloaded XML file from your data box to the FAÚ data box with ID dk79ijv.
You will then find the message among sent messages in your data box.

According to FAÚ guidance (the “Kontaktní osoby – Formulář” page on fau.gov.cz, updated 12 November 2025), a PDF or DOCX file is not a valid filing. The “ULOŽIT” (save) button only creates a draft you can return to. When you correct or add details, send a new form listing all current contact persons, because it fully replaces the previous one.

4. Client identification

You identify the client whenever a business relationship begins and whenever a transaction is suspicious, and otherwise no later than when it becomes clear that the transaction will exceed EUR 1,000 (Act No. 253/2008 Coll., Section 7(1) and Section 7(2)). A business relationship is one that is clearly meant to last from the outset, typically a brokerage agreement. The procedure is set by Act No. 253/2008 Coll., Section 8:

The first identification takes place in the client’s physical presence, or for a company in the presence of the person acting for it.
You record the details, verify them against an identity document and compare the client’s appearance with the photo.
For a legal entity, you verify its details from a document proving its existence obtained from a reliable source (for example, a Commercial Register extract) and also identify the individual acting for it.
If a representative acts for the client, they must prove their authority unless it can be found in a public register.
You establish and record whether the client, the person acting for them and the beneficial owner are politically exposed persons (PEPs) or persons subject to international sanctions applied by the Czech Republic.

5. Customer due diligence and enhanced due diligence

When a business relationship begins, you also carry out customer due diligence, no later than before the transaction takes place (Act No. 253/2008 Coll., Section 9(1), letter b). You set its scope according to the risk and must be able to justify to FAÚ inspectors why it was adequate (Act No. 253/2008 Coll., Section 9(3)). Due diligence covers:

the purpose and intended nature of the transaction;
the beneficial owner, for a company listed in the register of beneficial owners always from that register and one other source;
the ownership and control structure if the client is a legal entity;
ongoing monitoring of the business relationship;
the source of the money or other assets involved;
for a politically exposed person, also the origin of their wealth.

Enhanced due diligence is always required for a politically exposed person and for a client whose country of origin is a high-risk third country (Act No. 253/2008 Coll., Section 9a(2)). A natural person’s country of origin is the state of their citizenship, the state where they are registered for residence and the state where they have lived for more than 1 year (Act No. 253/2008 Coll., Section 4(15)). Since 29 January 2026, Russia has also been on the EU list of high-risk third countries (Commission Delegated Regulation (EU) 2026/46).

6. When to refuse a deal

You do not carry out the transaction and do not start (or you end) the business relationship if the client refuses identification, does not prove a representative’s authority, does not cooperate with due diligence, or if you doubt the truth of their information or the authenticity of their documents (Act No. 253/2008 Coll., Section 15(1)). With a politically exposed person, you do not carry out a transaction if the origin of the money or assets used is unknown to you (Act No. 253/2008 Coll., Section 15(2)).

7. Suspicious transaction: report to FAÚ and keep it confidential

You report a suspicious transaction to FAÚ without undue delay, and immediately after discovering it if delay would be dangerous (Act No. 253/2008 Coll., Section 18(1)). The “Oznámení o podezřelém obchodu” form is on the same website, formulare.fau.gov.cz. The report and investigation are confidential, so you tell the client nothing about it (Act No. 253/2008 Coll., Section 38(1)).

8. Internal rules, risk assessment and training

Every agent must apply risk management procedures and assess the risks of their business (Act No. 253/2008 Coll., Section 21(1) and Section 21a(1)). Only an agent who employs nobody in AML-related work and has nobody else working for them, not even as a contractor, may skip putting them in writing (Act No. 253/2008 Coll., Section 21(3)).

Everyone else, meaning agencies with employees or cooperating agents, must prepare a written system of internal rules and a written risk assessment within 60 days of becoming an obliged entity. Both are approved by the statutory body and kept up to date (Act No. 253/2008 Coll., Section 21(2) and Section 21a(2)).

Employees and cooperating persons who may come across a suspicious transaction must be trained at least once every 12 calendar months, and new ones before they start such work. You keep records of attendance and training content for at least 5 years (Act No. 253/2008 Coll., Section 23(1), Section 23(2) and Section 23(4)).

9. Records and personal data

You keep identification data, copies of documents (if you make them), due diligence records and records of how you assessed the client’s risk profile for 10 years after the business relationship ends. The period starts on the first day of the month following the month of the last known step in the transaction (Act No. 253/2008 Coll., Section 16(1) and Section 16(5)).

Before the business relationship starts, you give the client information on personal data processing under the GDPR, including a general notice that you also process personal data to prevent money laundering and terrorist financing (Act No. 253/2008 Coll., Section 24(2)).