This article summarises only the two supplied decisions of the Czech National Bank. The total of CZK 250,000 should therefore not be treated as the total amount of all sanctions affecting the Czech currency exchange sector in 2025.
In particular, it does not include separate inspections, remedial measures or fines imposed by the Czech Financial Analytical Office (FAÚ) under the Czech AML Act. FAÚ also conducts AML/CFT supervision, brings administrative offence proceedings and publishes its final decisions.
In one of the analysed cases, the original information concerning possible unauthorised currency exchange activity was provided to the CNB by FAÚ itself.
1. CZK 50,000 for currency exchange transactions at a retail shop
In the first case, currency exchange activity was carried out at an ordinary retail establishment even though its operator had never obtained authorisation to operate a currency exchange business.
Over a period of 83 days, CNB inspectors completed three test transactions:
a sale of EUR 300 for CZK 7,500,
a purchase of EUR 365 for CZK 9,150,
a sale of EUR 200 for CZK 4,940.
During the transactions, the staff member quoted exchange rates, calculated the countervalue on a calculator and handed over the relevant cash. The CNB therefore concluded that this was not an isolated private favour but a systematic activity practically indistinguishable from an ordinary currency exchange office.
Following repeated requests from the CNB, the operator stated that the activity had ceased. A subsequent attempted test transaction was refused. However, the CNB treated as aggravating circumstances the use of an official retail establishment for the unauthorised activity and the operator’s initial failure to respond to the supervisory authority’s written requests.
A fine of CZK 50,000 was imposed, representing 1% of the applicable statutory maximum of CZK 5 million.
2. CZK 200,000 for 36 informally organised exchanges
The second case did not involve a traditional exchange counter. The transactions were organised through bank transfers followed by the delivery of cash.
Over a period of almost four years, the following transactions were completed with nine individuals:
36 currency exchange transactions,
involving
CZK 1,533,600,
exchanged for a total of
EUR 64,100
Customers transferred Czech koruna to a bank account and later received the corresponding euro banknotes, either directly or through intermediaries. The exchange was offered at a more favourable rate than that available from ordinary providers.
The CNB classified this arrangement as a systematic currency exchange activity conducted in the person’s own name, on their own responsibility and for profit. It considered the exploitation of customers’ interest in obtaining euros at favourable rates to be an aggravating circumstance. As a mitigating factor, the CNB noted that the person had not previously been penalised under the Czech Currency Exchange Act.
A fine of CZK 200,000 was imposed, representing 4% of the statutory maximum.
3. What do the decisions show?
Authorisation may be required even without a traditional exchange office
Whether an activity qualifies as regulated currency exchange does not depend on the name of the service, the existence of an exchange-rate list or the use of a physical exchange counter.
The CNB examines the actual substance of the activity, including its repetition, organisation, operation in the provider’s own name and on their own responsibility, and the intention to make a profit.
A model under which a customer transfers Czech koruna to a bank account and subsequently receives foreign currency in cash may therefore also constitute regulated currency exchange activity.
A relatively small number of transactions may still be systematic
In the first case, the CNB found the systematic element to be present even though only three test transactions were completed over 83 days. It also considered that, before receiving the CNB’s request to cease the activity, the staff member had completed an exchange whenever inspectors requested one.
The number of completed transactions is therefore not the only relevant factor. The intention to repeat the activity and readiness to provide exchanges to other customers may also be important.
Unauthorised activity bypasses customer-protection and AML controls
The authorisation process is intended to ensure that currency exchange activity is conducted only by vetted persons who meet the statutory requirements. An unauthorised provider also avoids the obligations, compliance costs and control mechanisms applicable to properly authorised operators.
In both decisions, the CNB referred to the risk that currency exchange transactions may be misused for money laundering and to the risk of counterfeit or altered banknotes entering circulation.
4. Practical recommendations
Before offering currency exchange on a repeated basis, the proposed model should be assessed to determine whether it constitutes regulated currency exchange activity.
Businesses should in particular:
prevent employees from conducting informal exchanges at another type of business establishment,
avoid organising repeated exchanges for acquaintances or customers without a legal assessment,
not assume that a combination of bank transfer and cash delivery falls outside regulation,
monitor the company’s data box and respond promptly to CNB requests,
obtain CNB authorisation and implement appropriate AML procedures before commencing the activity.
Conclusion
The 2025 decisions show that the CNB can identify unauthorised currency exchange activity not only through test transactions at business premises, but also through bank records, information from other public authorities and customer statements.
It is also important to remember that supervision does not end with the CNB. FAÚ is separately active in AML/CFT enforcement, and any sanctions imposed by FAÚ are not included in the figures presented in this article.
