If someone had asked you yesterday whether you may accommodate anyone who pays, you would probably have said yes. But there is a group of people to whom you may not provide accommodation — and from whom you may not even accept money. They are on sanctions lists, and the ban applies directly, regardless of whether you run ten apartments or let out a single flat inherited from your grandmother.

Beware of a shortcut that circulates on the internet: European rules do not impose a blanket ban on „providing services“. They ban something else, and something more important for a host — making funds and economic resources available to a sanctioned person (Article 2 (2) of Council Regulation (EU) No 269/2014). Economic resources mean „assets of every kind, whether tangible or intangible, movable or immovable, which are not funds but may be used to obtain funds, goods or services“ (Article 1 (d) of the same regulation). A flat handed over for use falls under that definition. The practical conclusion is therefore the same — do not accommodate them — but the reasoning matters, because the other, less known half of the duty follows from it: you may not deal with money you accept from such a guest. Not even return it.

What to do

What the ban actually says

The European Union freezes all funds and economic resources of the persons and entities on the list and at the same time prohibits anyone from making those funds and resources available to sanctioned persons directly or indirectly „or for their benefit“ (Article 2 (1) and (2) of Regulation 269/2014). Czech law adds to this: „dealing“ with property means, among other things, „handing it over for another's use“ (§ 3 (t) of Act no. 69/2006 Coll.). Accommodating a sanctioned person is therefore prohibited from two sides — as making a resource available to them and as dealing with their money, which you take from them.

The sectoral ban on services that guides sometimes invoke (Article 5n of Regulation No 833/2014) targets only the Russian government and legal entities established in Russia, and its paragraph 2 concerns tourism in Russia, not accommodation in Czechia. Your duty follows from the general ban on making resources available.

The implementation of sanctions in Czechia is governed by Act no. 69/2006 Coll. (as in force from 1 January 2026). Compliance is supervised by the Financial Analytical Office (§ 15 (1)), which also hears the offences (§ 20 (2)). Do not confuse this with money laundering: a host is not an obliged entity under the AML Act (§ 2 (1) of Act no. 253/2008 Coll.) — they become one only for a cash transaction worth EUR 10,000 or more (§ 2 (2) (c)). So you do not report suspicious transactions. The sanctions ban and the reporting of sanctioned property, however, apply to everyone.

Two lists, not one

The EU consolidated list is maintained by the European Commission (DG FISMA) and updated, at the declared frequency, daily. It is public and machine-readable — XML, CSV, PDF and an RSS feed of changes at webgate.ec.europa.eu/fsd/fsf. As of September 2026 it contains 4,401 natural persons, 1,725 organisations and 6,128 sanctioned targets in total; the persons in the data are linked to 114 countries. The EU Sanctions Map keeps 55 sanctions regimes. That the list is alive is shown by the packages against Russia and Belarus: the 19th of 8 May 2026, the 20th of 9 July 2026 and the 21st of 27 July 2026.

The second list is barely mentioned in guides, and yet the EU list does not replace it. The Czech national sanctions list under Act no. 1/2023 Coll. is kept by the Ministry of Foreign Affairs and published on its website (§ 3 (d), § 16 (1)) — as a PDF and as CSV open data; as of 23 July 2026 it contained 14 valid entries and was last updated on 24 July 2026. An entry on it is an „international sanction“ under § 2 (f) and such a person is a „person subject to international sanctions“ under § 3 (c) point 6 of Act no. 69/2006 Coll. — the same bans and the same fines apply to them. And since the point of the national list is to reach persons who are not on the EU list, screening against the EU list alone is incomplete by design.

Third-country lists (the American OFAC, the British one) are, according to the Financial Analytical Office, neither binding nor enforceable in Czechia, but they may indicate a higher risk.

For looking up a single name manually, sanctionsmap.eu and the EU Sanctions Tracker at data.europa.eu/apps/eusanctionstracker/ are the most convenient.

What a check looks like in practice

You do not have to be a detective. A sensible check at a host's looks like this:

1. 1On accepting the booking, compare the name of the person booking against both lists. A confirmed booking is a concluded accommodation contract and a deposit paid in advance is already holding someone else's money — the law expressly anticipates a suspicion arising „in the preparation or conclusion of a contract“ (§ 10 (2) of Act no. 69/2006 Coll.). For bookings that arrive in the app without a check-in, do the first round yourself — the name of the person booking against both lists is enough.

1. 1At check-in repeat the check against the documents, and for everyone accommodated, not just for whoever made the booking. You collect the necessary particulars by law anyway — name, date of birth, number and type of identity document (§ 3g (2) of Act no. 565/1990 Coll.), and for foreign nationals additionally the house book and the report to the police within 3 working days (§ 101 and § 102 of Act no. 326/1999 Coll.). → The guest register: what must not be missing (and what does not belong there)

1. 1A match of the name alone means nothing. For natural persons the list gives the date and place of birth, nationality, document numbers, aliases and transliterations of names — compare them. The Financial Analytical Office recommends verifying „as far as possible simultaneously“ the name, nationality, residence and date of birth. A mere match of the surname does not trigger the reporting duty: § 10 (1) requires that you learned of it „in a credible manner“.

1. 1Where you can neither confirm nor rule out the suspicion, report it. For a booking already concluded, the reporting duty arises immediately after the contract is concluded (§ 10 (2)). Under the Financial Analytical Office's methodological instruction the Office completes the identification, and from the moment of the report the state takes over responsibility for correct identification.

1. 1Write down the result. The law prescribes neither the form nor a deadline, but the Financial Analytical Office itself recommends documenting the verification. Record when, whom, against which version of which lists and with what result.

• With a doubtful match the European Commission's EU Sanctions Helpdesk will help free of charge (eu-sanctions-compliance-helpdesk.europa.eu) — a counterparty check for businesses with up to 250 employees; acknowledgement of receipt within 2 working days, processing 5 to 10 working days.

A confirmed match step by step

1. 1Do not accommodate them. The flat is an economic resource; handing it over for use is prohibited making available.

1. 1Do not deal with anything of the guest's that you hold. From the moment you learn of it, you may deal with the property only to protect it from loss, deterioration, destruction or other damage (§ 11 (1)). A deposit received is frozen property — and returning it would be making funds available, i.e. a breach of the ban. Do not return it.

1. 1Notify the Financial Analytical Office without undue delay, in writing or orally on the record (§ 10 (1) and (3)). The safest route is data box egi8zyh; then e-mail fau@fau.gov.cz, telephone +420 257 044 501 (working days 8:00–16:00), outside those hours +420 603 587 663, by post to Finanční analytický úřad, P. O. BOX 675, Jindřišská 14, 111 21 Praha 1.

1. 1Under § 1 of Decree no. 281/2006 Coll. the notification must contain: a brief description of the property, its value (if known) and its location at the time of the notification; who owns it; whether there is an imminent danger of damage, deterioration or use contrary to the law; other significant information; and a telephone or electronic contact for you.

1. 1From the delivery of the notification you have a claim against the state for reimbursement of the strictly necessary costs of administering and protecting the property (§ 11 (2)). The Office may also call on you to hand it over (§ 11 (3)).

1. 1If you want to do anything else with the money or the belongings, you need an exemption. It is granted by the Financial Analytical Office under § 9 of Act no. 69/2006 Coll., or by the competent authority under Articles 4 to 6e of Regulation 269/2014.

The money arrives before the guest

With direct bookings paid in advance, the risk arrives before the check-in. A sanctioned person's money in your account is frozen property that you hold — and that is exactly the situation the reporting duty targets („property is located with them“, § 10 (1)). That is why the first round of the check belongs to the booking, not to the doorstep.

The law ties the notification to property actually being located with you. The conservative approach is to report whenever the match is confirmed and to describe in the notification what you hold — or that you hold nothing. The risk is asymmetric: there is no penalty for an unnecessary report, but up to CZK 50,000,000 for failing to report.

The real risk: small, but expensive

The probability that a sanctioned person will stay with you is small. The price of a mistake, however, is not:

• The lists have grown substantially since 2022 — today the consolidated list holds 4,401 natural persons and 1,725 organisations across roughly 45 sanctions programmes and 114 countries (the EU Sanctions Map records 55 regimes); the list is updated daily and in 2026 alone three packages of sanctions against Russia and Belarus were added (8 May, 9 July and 27 July 2026).
• For breaching the sanctions ban and for failing to meet the reporting duty alike, a fine may be imposed up to the highest of the following: CZK 50,000,000, 10 % of annual turnover according to the latest ordinary financial statements, 10 % of annual turnover according to the latest consolidated statements, twice the benefit obtained or twice the damage caused (§ 19 (3) (a) of Act no. 69/2006 Coll.). For dealing with frozen property contrary to § 11 (1), a fine of up to CZK 1,000,000. An attempt is punishable too (§ 19 (2)).
• For a breach of the sanctions ban the Office may publish the operative part of the decision for 5 years (§ 21 (1)); for failure to report under letter (f) that does not apply.
• The criminal dimension exists, but it only comes in from a „larger scale“: anyone who breaches an international sanction on a larger scale may face up to 3 years or a ban on activity (§ 410 (1) of the Criminal Code). From 1 January 2026 amendment no. 270/2025 Coll. added § 410a and § 410b — under § 410b (1) (c) the larger scale is assessed by the value of the service or transaction too, and the guide under § 138 of the Criminal Code is a value of at least CZK 100,000. With a single ordinary booking the real risk is therefore an offence before the Office, not criminal prosecution.

The cost/risk ratio is thus clear: the check costs nothing and once in a lifetime it may save your whole business.

The most common mistakes and myths

• „This concerns banks.“ — Banks and other obliged entities additionally have the AML regime. But the ban on making funds and economic resources available and the reporting duty under § 10 of Act no. 69/2006 Coll. apply to everyone, hosts included.
• „The EU list is enough.“ — The Czech national list exists precisely to reach persons who are not on the EU list. Legally it is equally binding (§ 3 (c) point 6 of Act no. 69/2006 Coll.).
• „The platforms check it for me.“ — Airbnb's terms expressly require the host to comply with the sanctions rules applicable to them, and it does not screen users across the board; what Booking does is not described in its publicly available terms. Legally it makes no difference: Act no. 69/2006 Coll. knows no transfer of the duty to a platform. What is more, some guests — direct bookings, companions, walk-ins — never pass through a platform at all.
• „My booking was blocked, so that person is on the list.“ — Platforms also apply the American or British lists, which are not binding in Czechia. A block therefore does not in itself mean a sanction under EU law — and conversely, a person on the EU or Czech list may pass through a platform unnoticed.
• „It is enough to check Russians.“ — The consolidated list merges around 45 sanctions programmes, from Iran, North Korea and Syria to thematic regimes (terrorism, human rights, cyberattacks). The persons in the data are linked to 114 countries.
• „If they pay by card, they have been screened.“ — Sanctions screening is done by the card issuer against its own client, not by you against the guest; a card issued outside the EU is moreover not bound by EU sanctions. Accepting a payment from frozen funds is itself dealing with sanctioned property.
• „I didn't know who it was.“ — The good-faith defence works only for someone who had no reasonable cause to suspect that they were breaching sanctions. Without any check at all, an entrepreneur will not make that case.

Frequently asked questions

Updated: 5 September 2026, verified against the sources listed above. This is informational text, not legal or tax advice — consult a professional about your specific situation.