AML inspections by the FAU or the CNB

We have recently represented clients in AML inspections by the FAU or the CNB.

What are the most common deficiencies?

  1. The client purchased multipage general AML regulations but did not adapt them in any way to their business and their processes.
  2. AML systems are only on paper, practice does not match them.
  3. The AML systems are general, copying the law, but do not contain specific procedures.
  4. Employees are not sufficiently trained on how to apply AML correctly in practice.
  5. AML systems are outdated and do not respond to frequent legislative changes.

What to do about it?

  1. Thoroughly review existing AML systems and processes - not just the ones on paper, but how they actually work in practice.
  2. Tailor them to your business and your processes.
  3. Review and update AML systems regularly.
  4. Train your staff regularly.

If you set up and adjust your AML processes correctly following an inspection, this usually results in a significant reduction in fines for AML violations.

Should you have any questions regarding AML, contact us at or at +420 222 767 393 to arrange an initial consultation.

Arrange a consultation or find out more