When your company detects a transaction or client behavior that could relate to money laundering, terrorist financing, or another illegal activity, act quickly. In Czechia, businesses report such situations by submitting an Oznámení o podezřelém obchodu — a Suspicious Activity Report (SAR) — directly to the Financial Analytical Office (FAÚ).
Globally, many countries also use the term Suspicious Transaction Report (STR). In Czech law, SAR and STR fall under the same mandatory reporting obligation.
This article explains what an SAR is, who must file it, and how to complete and submit it correctly.
What is an SAR?
An SAR is a formal notice that an obliged entity — any business or professional covered by Czech AML obligations — files when it finds a transaction or activity that raises suspicion of money laundering, terrorist financing, or dealings with sanctioned assets. Under §18 of the Czech AML Act (Law No. 253/2008 Sb.), the reporting duty begins the moment your company identifies a transaction that looks suspicious.
In practice, this means your company must not only monitor and identify risks but must also report them to FAÚ without undue delay.
What does “without undue delay” mean?
When the law says you must report a suspicious transaction “without undue delay,” it means you must not wait until all details are clear or the transaction is completed. Therefore, as soon as there are reasonable indications of unusual or suspicious activity, the SAR must be filed promptly — ideally within several days. Delaying to collect more information or hoping the situation resolves itself may put your company at risk of regulatory penalties.
Which companies and professionals must file an SAR?
If your business qualifies as an “obliged entity” (povinná osoba) under § 2 of the Czech Anti-Money-Laundering Act (Act No. 253/2008 Sb.), you are required to report any suspicious transaction.
Among the obliged entities are:
- Banks, credit institutions, and payment service providers
- Virtual Asset Service Providers (VASPs) — crypto exchanges, OTC desks, custodians, and tokenization platforms (under MiCA, referred to as CASPs)
- Financial intermediaries, accountants, auditors, and tax advisors
- Lawyers and notaries (when acting on behalf of clients in financial or real estate transactions)
- Real estate agents and developers
- Providers of company formation, management, or nominee services
- Dealers in precious metals, art, or other high-value goods
Each of these entities must identify suspicious activity, document findings, and submit an Oznámení o podezřelém obchodu to the FAÚ without undue delay. Failure to do so can result in administrative or regulatory sanctions.
All obliged entities must also appoint a designated AML contact person (pověřená osoba), who acts as the main point of contact for the FAÚ.
How to submit an SAR in the Czech Republic
FAÚ provides an electronic form for submitting the report. Most reports are filed via your data box (“datová schránka”) and the MoneyWeb system.
Key steps:
- Detect the suspicious transaction as soon as possible
- Log into the electronic form system and fill in the mandatory sections
- Indicate whether it is an urgent notification (under § 20 AML Act) or a standard report (§ 15 or § 18)
- Upload relevant documentation (copies of identification, transaction details, account numbers)
- Review the report carefully before submission
The electronic system allows you to generate a confirmation of submission and review past reports.
How to fill out the SAR form: What you must include
Your report should include:
- Identifying details of the reporting entity (business name, registration number, type of mandatory person)
- Data on the person(s) involved in the transaction (clients, beneficial owners)
- Information about the transaction: type, amount, date, account numbers, reason for suspicion
- Whether the transaction was carried out, postponed or canceled
- Contact information for the person responsible for reporting within the company
The rules for the structure and required content of a SAR are described in the Methodical Guideline No. 4 issued by the Czech Financial Analytical Office (FAÚ).
Keep in mind that your company should include only the employee data required by law when preparing the report for FAÚ.
Why timely and high-quality SAR reporting matters
Failing to file, or filing late, means your business may be at risk of regulatory action. FAÚ monitors the quality of reports and gives feedback:
- After an investigation, you might receive a rating on your report (1 = no issues, 2 = identified shortcomings, 3 = serious shortcomings)
- Good reports improve your credibility with regulators and demonstrate your compliance culture
- High-quality data helps identify patterns of illicit activity and protect the financial system as a whole
Need Help Preparing or Filing Your SAR?
At AMS, we help crypto, fintech, and financial companies meet their Czech AML obligations:
- Determine whether you qualify as an obliged entity
- Design and implement AML/CFT procedures
- Train your team to detect and report suspicious activity
- Assist in preparing and submitting your SAR to FAÚ
Contact AMS to ensure your reporting process is accurate, compliant, and regulator-ready.
FAQ: SAR Reporting in the Czech Republic
How can I determine if a transaction warrants filing a Suspicious Activity Report (SAR)?
If you observe transaction behaviour that gives you reasonable cause to suspect money laundering, terrorist financing or sanctions violations — even if the transaction appears normal at first glance — you should file an SAR.
Examples include unusually large transfers, inconsistent client patterns, payments from unknown third parties, or links to high-risk territories including virtual asset flows.
Whenever your AML system raises an alert you cannot satisfactorily explain, it is safer to report than ignore.
Can I still file an SAR if the suspicious transaction has already gone through?
Yes, you can and should. Even if the transaction has already been completed, the duty to report applies as soon as suspicion arises. It doesn’t matter whether the transaction was done, delayed, or cancelled — what matters is that it looked suspicious. Always send your SAR to the Czech Financial Analytical Office (FAÚ) without undue delay once suspicion appears.
Do I need to ask my client before submitting a SAR?
No. You are not allowed to tell the client or anyone else that you are submitting an SAR. This is called tipping-off, and it is illegal under Czech AML rules. Your duty to report suspicious transactions overrides client confidentiality and any business agreements.
What happens after submitting a SAR?
Once FAÚ receives your SAR, they may request additional details, documentation, or clarification. The case might then be analysed internally or forwarded to law-enforcement authorities if a potential crime is identified.
You will not usually receive detailed feedback — only a confirmation of receipt or a general quality rating.
Can multiple related transactions be included in a single SAR submission?
Yes. If you identify several transactions that form a connected pattern—such as repetitive transfers to the same counterparty or structured payments—they may be consolidated into one SAR report. You should clearly explain the linkage between those transactions in the submission narrative.When your company notices a transaction or client behavior that might indicate money laundering, terrorist financing, or another unlawful activity, you should react immediately.
How long should I keep SAR documentation on file?
Businesses are expected to retain SAR-related documentation for at least ten years after filing. This includes internal analysis, decision-making notes, and the confirmation of submission from FAÚ.
Need Help With SAR Filing?
