Czech Republic

Global sanctions guide

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  1. Does the Czech Republic have a sanctions regime in place?

Yes.

  1. Does the Czech Republic implement UN sanctions?

Yes. The Czech Republic is a member of the European Union, which implements UN sanctions in all member states by way of directly effective regulations.

  1. Does the Czech Republic implement an autonomous sanctions regime?

Yes. International sanctions which do not have direct effect are incorporated into Czech law by means of Government Decree adopted by the Czech Government on the basis of Act No. 69/2006 Coll. Certain restrictive measures, specifically embargoes relating to military goods, may be implemented via individual administrative acts adopted by Czech authorities within the limits of their discretion.

  1. What is the nature of the sanctions regime in the Czech Republic?

The Czech Republic follows the restrictive measures laid down by the UN, the EU and other international organisations which are binding on the Czech Republic, as well as measures introduced autonomously. Autonomous sanctions are introduced by government decree.

The Financial Analytical Unit of the Ministry of Finance is responsible for coordinating all restrictive measures. Depending on the measure, other ministries and government agencies may be involved. The Ministry of Finance is also responsible for granting exemptions from bans and restrictions, where permitted by Act No. 69/2006 Coll.

The EU “Third Money Laundering Directive” was implemented into Czech law by Act no. 253/2008 Coll. (“AML Act”).  The AML Act sets out obligations relating to the prevention and detection of the use of the financial system for money laundering and terrorist financing.

  1. Does the Czech Republic maintain a list of sanctioned individuals and entities?

No. The Czech Republic relies on UN and EU sanctions lists.

  1. Are there any other lists related to sanctions?

No.

  1. Does the Czech Republic have a licensing or authorisation system in place?

Yes. The Ministry of Industry and Trade grants licences for all imports and exports of military material. The decision to issue such licences is based on binding statements made by the ministries of Foreign Affairs, Interior and Defence.

  1. What are the consequences for a breach of sanctions in the Czech Republic?

The consequences for breach of sanctions are fines up to 4,000,000CZK.  Where the breach has been committed by an individual, legal entity, or entrepreneur:

  • property can be forfeited
  • they can be fined up to 50,000,000CZK where the benefit gained or damage caused exceeded 5,000,000CZK

In some cases a breach of sanctions is a criminal offence. If the Ministry of Finance has a reasonable suspicion that a criminal offence has been committed, it should provide the Police with the necessary evidence.

  1. Who are the relevant regulators in the Czech Republic and what are their contact details?

The Financial Analytical Unit of the Ministry of Finance is responsible for international sanctions and AML reporting.

Financial Analytical Unit
Ministry of Finance
PO. BOX 675
Jindrišská, 1411121
Prague
Czech Republic

T: (+420) 257 044 501
F: (+420) 257 044 502
E: fau@mfcr.cz
www.mfcr.cz/en/

The Czech National Bank is also responsible for AML reporting.

Czech National Bank
Na Příkopě, 28 115 03
Prague
Czech Republic

T: (+420) 224 411 111
F: (+420) 224 411 111
www.cnb.cz/en/index.html

Contributor law firm

Henrieta Hovanová, DELTA legal, advokátní kancelář s.r.o, Krakovská 1392/7, 110 00, Prague 1, Czech Republic