I Already Run an Exchange Office

You have the licence. What now?

Obtaining the bureau-de-change licence is not the end of your duties – it is where they begin. The Czech National Bank carries out on-site inspections and test purchases, in which a CNB officer acts as an ordinary customer, and imposes fines for any breaches, publishing final decisions on its website.

The most frequently sanctioned failings are nothing exotic: a defective exchange rate list, missing pre-contractual information, a missing notice of the right of withdrawal, a refused reversal, formal AML documentation that does not match actual operations, or missing training records.

When is it time to have your exchange office reviewed?

• the CNB has announced an inspection or is inspecting exchange offices in your area;
• you have not updated your documentation since setting up – both the law and the CNB's interpretation have moved on;
• you have changed staff at the premises and the new team has not been trained;
• you are opening additional premises or changing your opening hours, registered office or manager;
• you are buying an existing exchange office and need to know what you are taking on;
• you inherited the office from a previous adviser and do not know what state the documentation is in;
• your bank has flagged a relationship review (de-risking) and wants evidence of your compliance framework.

What we can do for you

Legal audit of the exchange office

A comprehensive compliance review – corporate basics and registrations, premises and rate list, transaction documentation, AML compliance, reporting, consumer duties and GDPR. The output is a written report with findings ranked by severity, specific recommendations and a remediation timeline. On request we fix the deficiencies for you straight away.

Review and update of AML/CFT documentation

We go through your internal AML policy and risk assessment and bring them in line with the current AML Act and with how your office actually operates. During inspections the CNB routinely sanctions not only missing documentation but also copied templates that do not match real operations. We add customer identification and due diligence forms, the suspicious transaction reporting procedure and archiving rules.

CNB inspection readiness

We review your premises through an inspector's eyes against a check-list and run a simulated test purchase: rate list → pre-contractual information → identification above the threshold → transaction → receipt → withdrawal notice. You get a written report with findings and corrective measures before the CNB does the same thing.

PEP and sanctions screening

We set up customer screening against politically exposed person lists and sanctions lists, including an automated tool and records of the checks performed. A transaction must not be executed if doing so would breach a binding restrictive measure – and a missing screening process is a typical inspection finding.

CNB reporting

We take over your reporting: the DEV (ČNB) 26-04 report "Purchase and Sale of Foreign Currency", quarterly or annually depending on your transaction volume, including deadline management and any corrections.

Staff training

We train your counter staff in AML/CFT duties – thresholds, customer identification and due diligence, PEPs and sanctions, indicators of suspicious transactions, reporting procedure. We issue a confirmation of attendance for each employee and set up the training records the law requires at least once every 12 months.

Whistleblowing policy

A bureau-de-change operator is an obliged entity under the AML Act and therefore needs an internal reporting system regardless of headcount. Failure to establish one is punishable by a fine of up to CZK 1,000,000.

Representation before the CNB and the FAÚ

If an inspection has already taken place or administrative proceedings have begun, we take over communication with the authority, prepare submissions and work to minimise the sanction.

Why deal with it before the inspection arrives

Remedying something you found yourself costs a fraction of a fine plus the clean-up carried out under the regulator's supervision. The CNB's final decisions are also public – the impact on your standing with banks and business partners is often more painful than the fine itself and, in extreme cases, ends in the termination of your bank account.

How it works

1. Non-binding consultation – we go through what you have and what worries you.
2. Collecting documents – we ask for your documentation and details of your operations; e-mail is usually enough.
3. The review – we assess the documentation and, depending on scope, visit your premises.
4. Report and remediation – you get prioritised findings and either handle them yourself or we fix them for you.

Get in touch

Write to us using the form below, or book a free introductory consultation. Just tell us how many premises you have and when you last updated your AML documentation.

Where to next?

• Legal audit of an exchange office
• Preparing for a CNB inspection
• AML obligations of an exchange office
• PEP and sanctions screening
• CNB reporting for exchange offices
• Duties of a bureau-de-change operator