Card payments at exchange offices: the CNB clarifies the rules

In two analysed orders issued in 2025, the Czech National Bank imposed fines totalling CZK 250,000. Both cases involved the systematic operation of a currency exchange business without the required CNB authorisation. One case concerned three test transactions carried out at a retail shop. The other involved 36 transactions with an aggregate value of EUR 64,100. The year 2025 refers to the date of the CNB orders; the underlying conduct took place between 2018 and 2024.

Setting up a currency exchange office in the Czech Republic is not a standard trade licence exercise. It requires authorisation from the Czech National Bank, a properly prepared application, suitable management and ownership arrangements, notified business premises and functioning AML procedures. What mistakes most often cause delays or problems after the business opens?

A bank account is generally essential for the day-to-day operation of a currency exchange business. However, the bank onboarding process may be more detailed than for an ordinary trading company. Banks have their own AML/CFT obligations and must understand the customer’s business model, source of funds and expected account activity.

In four decisions issued or finally confirmed in 2024, the Czech National Bank imposed fines totalling CZK 815,000 on currency exchange operators. The highest penalties concerned a combination of customer-facing failures, inadequate transaction records and breaches of AML obligations. Operators were also fined for failing to submit the AMLIFE01 regulatory report.

A senior officer is one of the key persons assessed during an application for authorisation to operate a currency exchange business in the Czech Republic. The person does not necessarily have to own the company or work at the exchange counter. Czech law distinguishes between the general category of senior officers and those who effectively manage the currency exchange activity. Additional requirements apply to the latter group.

On July 1, 2021, an amendment to AML Decree No. 67/2018 Coll., on certain requirements for a system of internal policies, procedures, and control measures against money laundering and terrorist financing, will take effect.