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Appeals of fines imposed by Czech regulators may result in worse penalties

Supreme Administrative Court cf no. 6 Afs 169/2016-42, dated 1 March 2017

Until recently, it was widely thought that if a defendant appealed against a fine imposed by a regulator in administrative proceedings, the fine could not be increased. However, the Czech Supreme Administrative Court has recently ruled that when a regulator's decision is fully vacated on appeal, and the regulator has to reconsider the case in full, the regulator may subsequently impose a higher fine than in the original decision.

Banks should now think twice before they appeal against a fine imposed by a regulator in Czech administrative proceedings.

Further information

This case summary is part of the Allen & Overy Legal & Regulatory Risk Note, a quarterly publication. For more information please contact Karen Birch –, or tel +44 20 3088 3710.

Legal and Regulatory Risk Note