The cash-payment limit and the AML trigger are independent. Identification cannot make a prohibited cash payment lawful. A bank transfer does not automatically remove a service provider’s AML duties.
Payments exceeding CZK 270,000
Section 4 of Act No. 254/2004 Coll. requires payments exceeding CZK 270,000 to be cashless and prohibits the recipient from accepting them in cash. Exactly CZK 270,000 does not itself exceed the limit. Aggregate all payments by the same payer to the same recipient during one calendar day, in Czech and foreign currencies.
Section 3 territorial rules and exemptions also matter. Under Section 2(2), cash deposits to and withdrawals from an account are not payments for this statute. This is not an exemption from a bank’s AML checks.
Obliged status for cash transactions
A business outside the ordinary Section 2(1) list becomes obliged under Section 2(2)(c) for a cash transaction worth EUR 10,000 or more. Examine paragraph (d) for non-business legal entities too. Section 28 defines this regime’s scope, covering customer measures, records, suspicious transactions, cooperation and confidentiality.
This does not mean every firm must permanently operate the same AML system as a bank. Registered-office providers and external accountants, however, have their own professional categories applying to bank transfers as well.
Different aggregation and conversion
AML Section 54(4) aggregates related acts of a divided transaction without a one-day restriction. The cash-payments statute uses the daily total between the same payer and recipient. Calculate the tests separately.
Convert the AML euro threshold using Section 54(3), with the CNB rate on the duty-performance day and the previous-day fallback if unavailable. The cash-payments statute converts foreign currency under Section 4(3) using the CNB rate valid on the payment day.
Cash may have a broader AML meaning
AML Section 54(5) also covers payment in specified precious metals or stones, other high-value commodities or virtual assets. Anything other than banknotes is therefore not automatically outside AML cash rules. Do not mechanically transfer this broader definition to the other statute.
The new EU AMLR has a separate application date from July 2027. Its future rules do not replace today’s Czech limits.
Practical steps
- Establish the service and payment regimes.
- Calculate the daily koruna test and related AML transaction separately.
- Check territorial scope, definitions and the specific exemption.
- Use a lawful payment method for prohibited cash payments and separately complete AML measures.
Illustrative scenario
A firm is due CZK 180,000 and CZK 120,000 from one payer in one day. Two receipts cannot circumvent the CZK 300,000 daily total.
When the situation differs
A trader splits one agreement into cash instalments on different days and assesses each separately for AML. Related acts aggregate for AML.
What to document
- Separate calculations with exchange-rate sources.
- Agreement, instalment schedule and payment records.
- Reasoned application of a specific statutory exemption.
Common pitfalls
- Claiming AML starts only above CZK 270,000.
- Applying one-day cash aggregation to every AML case.
Frequently asked questions
Does the cash restriction apply only to businesses?
No. Act No. 254/2004 Coll. also applies to individuals outside business where its conditions are met.
Does identifying the customer solve the cash prohibition?
No. AML compliance and payment legality are separate questions.
Put this guidance into practice
Choose a record for the step you are working on. Adapt it to your profession and actual case.
- Practice obligations map · PDF / Word
- Ordinary businesses and large cash transactions →
- Non-business legal entities providing listed services →
Complete client information online
Where to go next
- AML monetary thresholds: value, currency and related transactions — Separate identification, due diligence and obliged-entity thresholds, including currency conversion and aggregation.
- Art, precious metals and other selected transactions — Different categories for art, cultural objects, precious materials, used goods and cash transactions.
Sources and legal references
- Zákon č. 253/2008 Sb. — aktuální znění e-Sbírky ↗
§ 2 odst. 2 písm. c)–d), § 28, § 54 odst. 3–5 · accessed 2026-10-04 - Zákon č. 254/2004 Sb. — aktuální znění ↗
§ 2–4 · accessed 2026-10-04 - Nařízení (EU) 2024/1624 ↗
čl. 90 · accessed 2026-10-04
Editorial work and source checks are not independent legal approval of your particular process. Compare the conditions and exceptions with your own circumstances.