CZECH REPUBLIC Trends and Developments Contributed by: Jan Kohout and Illia Antonov, PRK Partners
matic tool for a mid-sized member state that wishes to act swiftly while the slower machinery of EU consen - sus-building runs its course. Whether the new govern - ment will continue to deploy this instrument with the same vigour as its predecessor remains to be seen. The institutional framework and the capacity gap At the heart of Czech sanctions implementation stands the Financial Analytical Office ( Finanční ana - lytický úřad , or FAU). The FAU is, simultaneously, the central administrative authority and national co-ordi - nator for implementing international sanctions, as well as the national Financial Intelligence Unit (FIU), the principal supervisor and methodological authority in the field of anti-money laundering and countering the financing of terrorism (AML/CFT). This consolidation of mandates in a single body gives the FAU a uniquely broad remit, but it has also created chronic strain on finite resources. Since the initial moderate staff increases and redeploy - ments that followed the first sanctions packages, the personnel capacity of Czech sanctions-implementing institutions has not grown in proportion to the expand - ing sanctions universe. The FAU has faced persistent staffing constraints, a challenge acknowledged by policy analysts and practitioners alike. This capacity gap has had tangible consequences for enforcement practice and has underscored a broader tension: the disconnect between the availability of high-quality intelligence on sanctioned persons and assets, on the one hand, and the institutional (in)ability to translate that intelligence into timely administrative and preven - tive action, on the other. The enforcement paradigm: criminal law predominance The enforcement of international sanctions in the Czech Republic operates through a dual-track system. Administrative enforcement is led by the FAU, which is empowered to impose fines and coercive measures, while criminal enforcement is triggered when a viola - tion reaches the threshold of a criminal offence. In the latter case, the Police, specifically the National Centre for Combating Organised Crime (NCOZ), investigate, the Public Prosecutor’s Office prosecutes, and the criminal courts determine guilt and sentence.
Despite this dual structure, Czech enforcement prac - tice to date has been predominantly weighted towards the criminal track. Only a handful of court decisions relating to sanctions violations have been handed down. A significant proportion of cases remain at the investigation or pre-trial stage and are unlikely to reach the courts for several years, principally because of the need for international judicial co-operation, which pro - longs criminal proceedings. Meanwhile, administrative enforcement has been far less visible. The predominance of criminal enforce - ment, with its inherently higher burden of proof, over administrative and preventive action is a defining fea - ture of the Czech sanctions landscape and reflects, at least in part, the capacity constraints discussed above. A notable legislative development may partially rebal - ance this picture. With effect from 1 January 2026, the Czech Criminal Code was amended to introduce a new criminal offence of breaching international sanc - tions through gross negligence. Previously, only inten - tional conduct was criminalised. The amendment spe - cifically targets violations related to military material or dual-use goods and is designed to capture exporters who, through gross negligence, allow their products to reach Russia or Belarus, whether directly or via third- country intermediaries. From assets to operations: the shifting enforcement focus In the immediate aftermath of the Russian invasion of Ukraine in February 2022, the attention of Czech competent bodies was almost entirely absorbed in the task of mapping and freezing the assets of sanctioned persons and entities. By 2025, over one hundred prop - erties and assets with a total value exceeding CZK10 billion had been frozen. The exercise revealed highly complex international corporate ownership structures. Russian persons, many of whom had been active in the Czech economy since the 1990s, frequently held assets through layered offshore entities, necessitating painstaking analysis of ultimate beneficial ownership. Only recently has the focus of enforcement started to shift meaningfully towards trade and services bans, ie, dynamic, ongoing operations rather than static asset
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