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Currency exchange: licences for bureaux de change and exchange houses

Exchanging one fiat currency for another, especially in cash, is regulated as a separate activity in most countries. Depending on the jurisdiction this means a licence from the central bank, entry on a regulator's list or register, or registration as a money services business. We help you choose the regime, prepare the application and set up the AML, cash-handling and IT processes that the regulator will check.

Fiat · cash and non-cashNot crypto, not FX trading
The regime

What currency exchange regulation covers

Currency exchange here means buying and selling fiat currencies for clients at an agreed rate with immediate settlement — through exchange offices, exchange houses, kiosks or online with delivery of funds. It is regulated because of the cash involved and the money laundering risk: regulators check owners and managers, the source of capital, client identification and transaction recording.

This is different from FX and CFD brokerage, where clients trade on price movements, often with leverage and without delivery of currency — that requires an investment firm or broker licence (see our Forex and CFD brokerage page). It is also different from exchanging crypto-assets for money: in Kazakhstan, for example, exchange operations with unbacked digital assets require a separate NBK licence, and in the EU crypto exchange falls under MiCA (see our crypto exchange page).

Regimes vary in form. Kazakhstan and the Czech Republic issue a licence; Lithuania keeps a list of currency exchange operators; Poland uses a register; the UAE licenses exchange houses that often combine exchange with remittance; Canada and the US treat currency exchange as a money services activity subject to registration.

Who needs this

  • Networks of exchange offices in cities, airports and border crossings
  • Exchange houses combining currency exchange and money transfers
  • Hotels, travel and retail groups launching an exchange service
  • Online services selling foreign currency with cash delivery or account transfer
  • Remittance businesses adding currency conversion as a separate service
  • Groups entering the UAE, Hong Kong or Singapore exchange market
Scope

Scope of the permission

What it typically permits

  • Buying and selling foreign currency for clients at published rates
  • Cash exchange through registered or notified exchange offices
  • Non-cash exchange where the regime and the business model allow it
  • Money transfers alongside exchange where the licence covers both, as with UAE exchange houses or a Hong Kong MSO
  • Operating several premises, subject to notification or approval of each

Restrictions

  • No leveraged FX trading, CFDs or derivatives — that is investment business
  • No exchange of crypto-assets — that requires a separate crypto regime
  • No deposit-taking or lending
  • In Kazakhstan, exchange operations by an authorised organisation are an exclusive activity under NBK rules
  • Each premises usually has to be notified, registered or approved before opening
  • A permission in one country does not allow exchange services in another
Jurisdictions

Regimes by jurisdiction

The table shows requirements confirmed against official sources as of 15 October 2026; where only secondary sources were available, the regime is described without figures, which are confirmed at the assessment stage.

JurisdictionRegulatorRegimeKey points
KazakhstanNational Bank of Kazakhstan (NBK)Licence for exchange operations with foreign currency in cashIssued under NBK rules on exchange operations; minimum capital, daily cash coverage for each exchange office, opening hours and client identification thresholds are set by NBK regulations and confirmed at assessment
Czech RepublicCzech National Bank (CNB)Currency exchanger licence (Act No. 277/2013 Coll.)Application filed through the CNB REGIS system; each exchange office must be notified to the CNB at least 3 working days before opening; banks and credit unions may also exchange currency
LithuaniaBank of LithuaniaEntry on the List of Currency Exchange OperatorsFit-and-proper assessment of managers and qualifying holders; description of AML measures; decision within 30 days, extendable by a further 30 days
PolandPresident of Narodowy Bank Polski, according to available sourcesEntry in the register of currency exchange activityRegulated activity under Article 11 of the Foreign Exchange Law (Prawo dewizowe); detailed requirements confirmed with local counsel
UAE (mainland)CBUAEExchange house licence, Category A, B or CPaid-up capital AED 2m, 5m or 10m (AED 50m for an LLC); bank guarantee of at least the greater of 100% of minimum capital and 5% of average monthly transfers, capped at AED 75m
Hong KongCustoms and Excise DepartmentMoney Service Operator (MSO) licenceCovers money changing and remittance; fit-and-proper test including owners above 25%, competence assessment and interview; licence term 2 years; no minimum capital requirement
SingaporeMonetary Authority of Singapore (MAS)Money-changing licence (Payment Services Act)No minimum capital requirement; at least one year of relevant experience required; annual licence fee payable
CanadaFINTRAC; Revenu Québec in QuébecMSB registration (federal); MSB licence (Québec)Foreign exchange dealing is a money services activity; FINTRAC registration required before starting operations, renewed every 2 years; in Québec a provincial licence is also required
USAFinCEN; state regulatorsMSB registration (Form 107); state requirementsFinCEN registration within 180 days of establishment and renewal every 2 years; whether the model falls within MSB categories and which state rules apply is confirmed at assessment
AIFC (Astana)AFSAAuthorisation: Providing Money ServicesCovers currency exchange together with money transmission and payment services; separate from the Kazakhstan national regime; capital under AIFC prudential rules, confirmed with AFSA
KyrgyzstanNational Bank of the Kyrgyz Republic (NBKR)Licence for exchange operations with cash foreign currencyMinimum working capital (not charter capital) for bureaus opened from 1 June 2026: KGS 5 million in Bishkek and Osh, KGS 3 million in other regions, KGS 1 million for seasonal bureaus; for existing bureaus the requirement rises in stages to 2030. A change of founder needs NBKR consent, beneficial owners are disclosed down to individuals, a compliance officer trained in AML/CFT is required, and a licence may be revoked after 3 months of inactivity
GeorgiaNational Bank of Georgia (NBG)Registration with the NBGExchange bureaus register under NBG rules approved on 28 February 2018; the rules are published in Georgian only, so detailed requirements are confirmed with local counsel at assessment

How the regimes differ

  • Form of permission: a licence in Kazakhstan, the Czech Republic, the UAE, Hong Kong and Singapore; entry on a list or register in Lithuania and Poland; registration in Canada and at federal level in the US.
  • Capital: the UAE sets fixed paid-up capital by category plus a bank guarantee; Hong Kong and Singapore set no minimum capital but assess fitness, competence and experience; in Kazakhstan capital and daily cash coverage are set by NBK regulations.
  • Premises: the Czech Republic requires notification of each exchange office before opening; in Kazakhstan requirements apply to each exchange office.
  • Scope: in the UAE and Hong Kong one licence can cover exchange and remittance; in the EU currency exchange is regulated nationally, separately from payment services.
  • Kazakhstan: the NBK licence and the AIFC authorisation under AFSA are separate regimes; the NBK licence for cash currency exchange is also separate from the NBK licence for exchange operations with digital assets.
  • Kyrgyzstan and Georgia: the NBKR licenses exchange bureaus and sets minimum working capital by location rather than charter capital; in Georgia exchange bureaus register with the NBG.
Requirements

Core requirements

Company and owners

  • Company incorporated in the licensing jurisdiction
  • Transparent ownership and disclosure of qualifying holders and beneficial owners
  • Fit-and-proper checks of owners and managers
  • Documented source of capital

Capital and finances

  • Paid-up capital where the regime sets it, and bank guarantees where required
  • Sufficient cash and account balances to cover exchange operations
  • Business plan with premises, volumes and currencies
  • Cash logistics, insurance and bank relationships

Management, team and local presence

  • Managers with relevant experience (for example, at least one year in Singapore)
  • Compliance officer appointed by the company
  • Premises meeting security and equipment requirements
  • Trained cashiers and internal control over cash handling

Compliance and IT

  • AML/CFT programme with client identification above thresholds, sanctions and PEP screening
  • Recording of every transaction and retention of records
  • Detection and reporting of suspicious transactions, including structuring
  • Exchange software with rate management, receipts, cash reconciliation and regulatory reporting

Regulatory capital is separate from state and application fees, operating costs and our fees. Our fees are agreed after the project assessment.

Documents

Main application documents

  • Application form and corporate documents
  • Ownership structure and beneficial ownership disclosures
  • Fit-and-proper questionnaires and CVs of managers
  • Evidence of capital and its source
  • Business plan and financial projections
  • Description and documents for each exchange office
  • AML/CFT policy, risk assessment and identification procedures
  • Internal control and cash handling procedures
  • Description of exchange software, security and record-keeping
  • Bank guarantee or bank confirmations where required
Process

How the project runs

  1. 01

    Model analysis

    We define the services, cash and non-cash flows, currencies and locations, and distinguish exchange from FX trading, remittance and crypto.

  2. 02

    Choice of regime

    We compare jurisdictions by form of permission, capital, premises rules and banking access.

  3. 03

    Company and premises

    We register the company, structure ownership and help prepare premises and key persons.

  4. 04

    Application package

    We prepare the business plan, financial model, AML framework, internal control and IT description and file the application.

  5. 05

    Regulator dialogue

    We answer questions and revise documents until the licence, list entry or registration is granted.

  6. 06

    Launch and support

    We help with premises notifications, bank accounts and software set-up and support reporting and inspections.

Timing

Timing

Some regimes set review periods: in Lithuania the Bank of Lithuania decides on entry on the list within 30 days, extendable by 30 days; in the Czech Republic each new exchange office must be notified at least 3 working days before opening; a Hong Kong MSO licence is valid for 2 years. Actual timing depends on the completeness of the application, the premises and the regulator's questions.

  • Completeness of ownership and source-of-capital evidence
  • Readiness of premises, equipment and security
  • Readiness of the AML programme and the compliance officer
  • Bank account and cash logistics arrangements
  • Number of exchange offices and locations
  • Volume of regulator questions
Our work

What our team does

Lawyers

  • Analyse the model and distinguish currency exchange from FX trading, remittance and crypto
  • Recommend the jurisdiction and the type of permission
  • Register the company and prepare corporate documents
  • Prepare the application and lead the dialogue with the regulator
  • Draft client terms and premises-related agreements
  • Coordinate foreign-law opinions with local counsel where required

Finance specialists

  • Build the business plan and the financial model
  • Calculate capital, guarantees, cash coverage and operating funding needs
  • Design cash reconciliation and treasury processes
  • Prepare financial information for the regulator and banks

AML/compliance specialists

  • Prepare the risk assessment and the AML/CFT policy
  • Set identification thresholds, sanctions and PEP screening
  • Design suspicious transaction detection, including split transactions
  • Train cashiers and help prepare the person appointed by the company as compliance officer
  • Prepare the company for inspections

Engineers

  • Develop or adapt exchange software to regulatory requirements
  • Implement transaction records, receipts and reporting
  • Integrate screening services and bank accounts
  • Document IT and information security for the application
After authorisation

After the permission is granted

  • Notify or register each new exchange office before it opens
  • Maintain capital, cash coverage and guarantees at the required level
  • Record and retain every transaction and identify clients above thresholds
  • Report suspicious transactions and file regulatory reports
  • Renew the licence or registration on time, for example every 2 years for a Hong Kong MSO licence or FINTRAC registration
  • Notify the regulator of changes in owners, managers and premises
FAQ

Frequently asked questions

Describe your project in a few sentences. We will give you a substantive reply: which questions need answering and where to start.

Discuss your project
Is a currency exchange licence the same as an FX broker licence?

No. A currency exchange operator buys and sells currency for clients with immediate delivery. An FX or CFD broker offers trading on price movements, often with leverage, and needs an investment firm licence. See our Forex and CFD brokerage page.

Does a currency exchange licence allow exchanging crypto-assets?

No. Crypto-to-fiat exchange is regulated under separate regimes, such as the NBK licence for exchange operations with digital assets in Kazakhstan or MiCA in the EU. See our crypto exchange page.

Can one licence cover both exchange and money transfers?

In some countries, yes: UAE exchange houses and Hong Kong MSOs can provide both. In the EU, money remittance is a payment service with its own authorisation, while currency exchange is regulated nationally.

What capital is required?

It depends on the country. UAE exchange houses need AED 2m to 10m depending on category, or AED 50m for an LLC, plus a bank guarantee; Hong Kong and Singapore set no minimum capital. In Kazakhstan the amounts are set by NBK regulations and confirmed at assessment.

Can you guarantee the licence and a bank account?

No. The decision belongs to the regulator, and the decision to open an account belongs to the bank. We prepare the project so that it meets the requirements and can withstand the review.

Sources checked on 15 October 2026
  • Czech National Bank — currency exchanger licence under Act No. 277/2013 Sb. — https://www.cnb.cz/cs/dohled-financni-trh/vykon-dohledu/povolovaci-a-schvalovaci-rizeni/povoleni-k-cinnosti-smenarnika/povoleni-k-cinnosti-smenarnika-a-oznameni-smenarenskych-provozoven-podle-zakona-c.-277-2013-sb.-o-smenarenske-cinnosti/index.html (checked 15 Oct 2026)
  • Bank of Lithuania — currency exchange operators — https://www.lb.lt/en/currency-exchange-operators (checked 15 Oct 2026)
  • Polish Foreign Exchange Law (Prawo dewizowe), Art. 11 — https://prawnik.cc/laws/prawo-dewizowe/rozdzial-4-dzialalnosc-kantorowa-art-11-dzialalnosc-kantorowa (secondary text; register-keeping authority requires confirmation; checked 15 Oct 2026)
  • CBUAE — Exchange Business Standards (official rulebook copy) — https://cbuae.thomsonreuters.com/en/entiresection/3531 (checked 15 Oct 2026)
  • ADGM FSRA — Providing Money Services framework — https://adgm.com/media/announcements/fsra-introduces-enhancements-to-the-regulatory-framework-for-providing-money-services (checked 15 Oct 2026)
  • Hong Kong Customs and Excise — MSO Licensing Guide (May 2026) — https://eServices.customs.gov.hk/MSOS/download/guideline/Licensing_Guide_en.pdf (checked 15 Oct 2026)
  • MAS — Money-changing licence — https://www.mas.gov.sg/regulation/payments/money-changing-licence (checked 15 Oct 2026)
  • FINTRAC — MSB registration — https://fintrac-canafe.canada.ca/msb-esm/intro-eng11 and https://fintrac-canafe.canada.ca/msb-esm/reg-eng (checked 15 Oct 2026)
  • Revenu Québec — money-services business licence application — https://www.revenuquebec.ca/en/businesses/sector-specific-measures/money-services-businesses-msbs/money-services-business-licence-application/ (checked 15 Oct 2026)
  • FinCEN — MSB registration — https://www.fincen.gov/index.php/money-services-business-msb-registration (checked 15 Oct 2026)
  • AFSA — regulated activities (Providing Money Services) — https://afsa.aifc.kz (checked 15 Oct 2026)
  • NBKR Board resolution No. 2026-П-17/29-3-(НПА) of 13 May 2026 (minimum working capital of exchange bureaus) — https://www.nbkr.kg/contout.jsp?item=2145&lang=RUS&material=131932 (checked 15 Oct 2026)
  • NBKR Board resolution No. 2026-П-17/29-4-(НПА) of 13 May 2026 (amendments to the licensing regulation for exchange bureaus) — https://www.nbkr.kg/contout.jsp?item=2145&lang=RUS&material=131942 (checked 15 Oct 2026)
  • NBG news: new rule on registration of currency exchange bureaus (28 Feb 2018) — https://nbg.gov.ge/en/media/news/the-national-bank-of-georgia-ratified-new-rule-for-currency-exchange-bureaus-registration (checked 15 Oct 2026)

Discuss your exchange business

Tell us about your locations, currencies and planned volumes. We will outline the permission required, the main risks and the next steps; our fees are agreed after this assessment.

Discuss your project
Contact

Tell us about your project

We will review the description and give you a substantive reply: which regime may apply and where to start.

Prefer e-mail? Write to us directly.info@paralex.kz

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