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Situations where we need information and cooperation from the client
Pursuant to Sec. 9 of Act No. 253/2008 Coll., we particularly require the client to provide additional information and cooperation in the following cases:
- Before the establishment of the business relationship and during the existence of the business relationship.
- Before making a transaction outside a business relationship, if the conditions under Sec. 7, paragraph 1 are met, namely:
- as soon as it is clear that the transaction will reach a value of 15,000 EUR or more;
- the transaction is with a politically exposed person,
- the transaction is with a party whose country of origin is a high-risk country according to Commission Regulation (EU) 2016/1675 and the FATF list of high-risk countries,
- the transaction is with a person identified according to Sec. 11, paragraph 7 of the AML Act (includes remote identification with a checking payment by the client pursuant to the stipulated conditions),
- the funds transferred amount to 1,000 EUR or more.
- Before making a suspicious transaction.
How we define a suspicious transaction
Sec. 6 (1) For the purposes of this Act, a suspicious transaction means a transaction made under circumstances causing suspicion of attempted legalization of proceeds from crime or suspicion that the funds used in the transaction are intended to finance terrorism, or that the transaction is otherwise related to or connected with the financing of terrorism, and/or another fact that might indicate such suspicion.
Act No. 253/2008 Coll. stipulating, inter alia, the bank's obligation to carry out client due diligence and the client's obligation to cooperate with the bank in this respect. We treat all the submitted information in accordance with the principles of banking secrecy.
Due diligence is carried out on an ongoing basis throughout the term of the business relationship, e.g. by updating client data or the AML questionnaire. Due diligence also takes place on extraordinary occasions - screening of non-cash or cash transactions, screening of suspicious transactions, etc. The client may be asked by the bank at any time to provide information and to submit the relevant documentation.
If the client fails to cooperate in the identification or due diligence process, the bank has the right to refuse to execute a transaction or establish a business relationship under the aforementioned Act. Failing to provide the necessary cooperation may eventually lead to the termination of the business relationship with the client (pursuant to Sec. 15 of Act No. 253/2008 Coll.).
Examples of documents to be submitted
| Fact regarding the source | Additional information | Documents |
| Savings (from income) | Notification of income for previous periods Information about the employer, including the region of operations Over what period were the savings made |
Tax return Confirmation of income Statement of bank account to which the income was transferred |
| Loan (borrowing or credit) | Amount and purpose of the loan Creditor information Loan provision date Loan maturity and existence of collateral |
Collateral documents |
| Inheritance | Identity of the deceased Relationship to the deceased Date of acceptance of the succession share Total succession amount |
Confirmation of a credit institution regarding received succession payment to the client's account Document confirming heir’s acceptance of the succession |
| Donation | Total amount of the donation Information about the donor Relationship of the donee to the donor Purpose of the gift Source of donated funds |
Contract |
| Business income | Detailed information on the business and the entity Main or secondary business activity Sales (for cash deposits) Payment from the client's customer (for cash deposits) |
Tax return Annual report Confirmation of payment by a competent person Statement of sales from the client's cash register system (cash statements, cash book statements, etc.) For payments from a customer – in cash, the client can receive a maximum of 270 thousand CZK - sale/service contract or invoice to be submitted |
| Sale of assets | Identification of the property sold Selling price Method of sale (auction, through an intermediary, private sale, etc.) Term of ownership of the property in question Sale date |
Contract Extract from register, if the property is subject to registration |
| Dividend / profit share payment | Identification of the entity paying out the dividend or profit share | Audited annual report Regular or extraordinary financial statements Resolution to pay out dividends / distribute profits |
| Sale of securities | Type and form of securities, description Value of securities Method of sale Sale date Information on the investment term |
Contract Shareholder certificate |
| Sale of a company or its part | Identity of the company sold, including the area of business Share amount Total selling price Sale date |
Contract Confirmation from a credit institution of receipt of payment associated with the sale |
| Assignment (sale) of a receivable | Amount of consideration for the assignment of the receivable Nominal value of the receivable (principal and accessions) Identity of the assignee Client’s relationship to the assignee Assignment date |
Agreement to assign receivables Documents confirming the existence of the receivable |
| Other source of income | Identification of the source and nature of the income Date of receipt |
Relevant supporting documents |
Raiffeisenbank a.s. performs client due diligence to eliminate the risks of money laundering and terrorist financing to the greatest possible extent. Client due diligence is often known as "Know Your Customer". At the bank's request, every client is obliged to provide the information necessary for the due diligence and to submit the relevant documents. If the client fails to provide such cooperation or if the client due diligence cannot be carried out for any other reason, the bank must proceed in accordance with applicable laws.
The bank ascertains and evaluates information on the purpose and nature of the transaction or business relationship, the nature of business activities, information on the identification and verification of the client's beneficial ownership and identification of the client's management and ownership structure, and information on the origin of assets of a politically exposed person or on the application of international sanctions to the client. In accordance with Sec. 9a of Act No. 253/2008 Coll., the bank carries out enhanced identification and due diligence of clients with a high-risk third country as their country of origin, all at any time during the establishment or existence of the business relationship. The list of high-risk countries is determined on the basis of Commission Regulation (EU) 2016/1675 and the FATF list of high-risk countries. From the bank's perspective, AML (Anti Money Laundering) rules must be adhered to. These are anti-money laundering measures that are also intended to combat the financing of terrorism (CFT).
The bank treats all client data and submitted information in accordance with the principles of banking secrecy.