Cash Limits and AML Compliance in Classic Car Sales in the Czech Republic
Selling historic cars for cash involves legal risks related to the cash payment limit and AML rules. Exceeding the limits or failing to properly identify the client may result in multi-million fines or criminal prosecution. In this article, we explain which rules you must follow to ensure your classic car transactions are carried out safely and in compliance with the law.

Article contents
- Cash limit: CZK 270,000 per day
- AML Act: Customer identification and due diligence
- Suspicious customer behaviour
- Registration of vintage vehicles and the link to payments
- Relevant authorities and inspections
- What you are exposed to and how to defend yourself
- Specifics of the special VAT scheme
- Amendment to the AML Act and the contact person
Quick summary
- The limit for cash payments is CZK 270,000 (approx. EUR 10,500) per day between the same parties.
- The AML Act requires customer identification and due diligence if, as a trader, you accept cash in the amount of EUR 10,000 or more, or in any suspicious transaction.
- Suspicious customer behaviour must be reported without undue delay.
- The attorneys at ARROWS advokátní kancelář have long-standing experience with this area and can help ensure your transactions proceed safely.
When and how cash becomes problematic in vehicle sales
Let’s start by clarifying a fundamental point: cash is not prohibited. Czech law allows it, and individuals have the right to choose this method of payment. The problem is not cash itself, but the limits and rules that accompany its use. For a used-vehicle dealer—especially one dealing in vintage vehicles—a strict regime applies.
The legal uncertainty in practice lies in the fact that the statutory framework is strict and the supervisory authorities uncompromising. While the Czech National Bank (ČNB) supervises the circulation of currency, the Ministry of Finance and the Financial Analytical Office (FAÚ) monitor money flows. The attorneys at ARROWS advokátní kancelář have been dealing with this issue for a long time and can advise you on how to operate safely in this environment.
Cash limit: CZK 270,000 per day
The simplest and most important rule is: Czech law prohibits providing or accepting a cash payment exceeding CZK 270,000 between the same parties within one calendar day. Full stop. No exceptions, no concessions. Even if the money is completely clean and the customer is your long-standing partner, exceeding this limit is a breach of the law.
If a customer wants to pay you in cash for a vintage vehicle worth CZK 300,000, you must not accept such a payment, regardless of the circumstances.
This rule follows from Act No. 254/2004 Coll., on Restrictions on Cash Payments. A breach may be committed by both the payer and the recipient—i.e., both parties to the transaction. Sanctions can reach up to CZK 5 million for a legal entity or a self-employed individual.
The limit is calculated not per single transaction, but as the sum of all payments between the same parties during one calendar day. You cannot circumvent it by splitting one transaction into several smaller payments on the same day. The tax authorities and the Customs Administration focus on this behaviour.
A practical problem is that a trader is sometimes unaware that accepting cash above the limit breaches the law, even if the money is legal.
Related questions on restrictions on cash payments
1. Does the limit apply even if two friends buy a car together and pay in cash?
Yes. The limit applies to payment for a single obligation. If the subject of the purchase is one car, the CZK 270,000 limit applies to the total payment of the purchase price, even if several people contribute to it.
2. Can I agree with the customer that they will pay CZK 250,000 in cash today and the remaining amount tomorrow?
Technically, the law refers to a one-day limit. However, if it is clear that this is a purposeful splitting of a single transaction (so-called structuring) in order to avoid statutory obligations, it may be assessed as circumvention of the law.
3. What happens if I accidentally accept a payment slightly exceeding the limit, e.g. CZK 275,000?
Even exceeding it by CZK 5,000 is a breach of the law. A fine may be imposed on both parties. If you realise the mistake, you should consult a lawyer immediately— in some cases, the situation can be addressed.
AML Act: Customer identification and due diligence
We now come to the second important point of the legal framework – Act No. 253/2008 Coll., on Certain Measures against the Legalisation of Proceeds of Crime (the AML Act). As a used-vehicle dealer, you become an obliged entity at the moment you accept a cash payment of EUR 10,000 or more. This is where the key connection arises. If you accept cash up to approximately CZK 250,000, you are not automatically an obliged entity. If you accept cash from CZK 250,000 to CZK 270,000, you are an obliged entity and must carry out customer identification and due diligence. Cash above CZK 270,000 must not be accepted at all.
Customer identification means establishing and verifying the customer’s identity— for individuals, typically copying details from an ID card or passport; for companies, verifying the beneficial owner. You must record these details and retain them for 10 years.
The AML Act also requires customer due diligence and the reporting of suspicious transactions regardless of the limit, if you suspect money laundering. If something appears suspicious at first glance (e.g., the customer is nervous, wants to split payments), you have a duty to carry out due diligence and, if appropriate, report the transaction to the Financial Analytical Office (FAÚ). The attorneys at ARROWS advokátní kancelář point out that it is not your duty to decide whether the money is legal, but to report suspicious situations.
Suspicious customer behaviour
How can you tell that a transaction is suspicious? The AML Act lists typical indicators. Let’s break them down using examples from the practice of vintage-vehicle dealers.
- The customer is nervous and avoids questions. They come to you with cash and, when asked about the origin of the funds, give vague answers. In the context of their age, employment, or visible lifestyle, the transaction seems unrealistic.
- The transaction lacks economic rationale. The customer is not interested in the car, does not address its technical condition, but wants to quickly “park” money in a valuable vehicle with the aim of reselling it soon (often below market price).
- Splitting the payment below the limit (structuring). The customer wants to buy a car for CZK 350,000, but instead of paying by bank transfer, proposes paying CZK 150,000 today, CZK 150,000 tomorrow, and the remainder the day after. This is a textbook example of a suspicious transaction aimed at avoiding limits.
- A request for an “off-the-record” transaction. The customer suggests that a lower amount be stated in the contract and the rest paid “on the side”. You must not agree to such an arrangement and you should consider filing a report.
When you notice these signals, you have a duty to file a suspicious transaction report (STR) with the FAÚ. The report must be submitted without undue delay via the FAÚ electronic portal (DataMart).
Related questions on identification and AML obligations
1. Do I have to identify all buyers, or only some?
You must carry out identification whenever you act as an obliged person (cash receipt above EUR 10,000/CZK 250,000) or whenever the transaction is suspicious. In a standard cash sale of a cheaper car that is not suspicious, no statutory identification obligation arises under the AML Act.
2. How long do I have to keep identification data?
Data and copies of documents obtained as part of AML obligations must be retained for 10 years from the completion of the transaction.
3. What happens if I file a suspicious transaction report and it later turns out the money was legitimate?
Nothing will happen to you. If you acted in good faith and fulfilled your reporting obligation, you are protected. The FAÚ (Financial Analytical Office) will review the report and, if it finds no issue, will close the matter.
Registration of vintage vehicles and the link to payments
When selling a vintage vehicle, proper administration is also important. Historic vehicles are registered in the Register of Historic and Sports Vehicles. Even though this agenda is formally separate from payments, in the event of a dispute, perfect documentation is your lifeline.
If the buyer or authorities later challenge ownership or the origin of the funds, a properly drafted sale and purchase agreement with identification of the parties and a clear payment trail is essential. In the case of cash payments, always issue a receipt that is linked to the sale and purchase agreement.
Relevant authorities and inspections
The Financial Analytical Office (FAÚ) supervises compliance with the AML Act in the Czech Republic. It checks whether you have an internal policies system in place, whether you perform identification, and whether you report suspicious transactions. Fines can reach up to CZK 10 million. The Financial Administration and the Customs Administration inspect compliance with the Act on Restricting Cash Payments and the proper payment of taxes.
The Czech Trade Inspection Authority supervises compliance with consumer rights. Inspections may be planned or random and often focus on formal deficiencies in the sales process. The attorneys at ARROWS advokátní kancelář have experience representing traders in these inspections and can minimise the impact of any findings.
How to act correctly
Let’s outline the procedure for how you should respond when a customer pulls out a bundle of banknotes. The first step is always to verify the amount. If the price is above CZK 270,000, strictly refuse cash.
Explain to the client that the law prohibits it and imposes high penalties on both parties. If the amount is in the range of approximately CZK 250,000–270,000, you become an obliged person. You must carry out full identification and customer due diligence under the AML Act. Then assess the risk and the client’s behaviour.
If you suspect that the money comes from criminal activity, you must report the transaction. Document everything thoroughly by preparing a sale and purchase agreement that contains all relevant details. If you accept cash, issue a receipt. Archive identification data securely in accordance with GDPR and the AML Act.
What you are exposed to and how to defend yourself
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Risks and penalties |
How ARROWS helps (office@arws.cz) |
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Exceeding the cash limit (CZK 270,000): A fine of up to CZK 5 million for a legal entity/entrepreneur. |
Legal audit and process setup: We will assess your business procedures and set limits so that you do not end up in breach of the law. |
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Failure to report a suspicious transaction (STR): A fine of up to CZK 5 (or 10) million imposed by the FAÚ for failing to report a suspicious transaction. |
AML compliance and training: We will prepare an internal policies system for you and train you and your employees on how to recognise a suspicious transaction and how to file an STR correctly. |
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Failure to identify and conduct customer due diligence: A fine of up to CZK 10 million for not carrying out identification/due diligence. |
Documentation management: ARROWS advokátní kancelář will ensure you have the correct identification forms available and know when to use them. |
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Incorrect VAT treatment (special scheme): Additional tax assessment by the tax authority + penalties and default interest. |
Tax advisory: We will help you correctly apply the special scheme for dealers in second-hand goods (Section 90 of the VAT Act) so you do not pay tax unnecessarily, while still remaining compliant. |
Specifics of the VAT special scheme
When selling used vehicles, you will often use the so-called special scheme under Section 90 of the VAT Act. Under this scheme, you account for VAT only on your dealer’s margin (the difference between the purchase and sale price), not on the full price of the vehicle. The condition is that the vehicle was purchased from a non-VAT payer or from another dealer who also used the special scheme. Be careful in situations where you purchase from a VAT payer who claimed input VAT deduction. In that case, you must not use the special scheme.
Amendment to the AML Act and a contact person
In connection with amendments to the AML Act, obliged persons are required to designate and notify the FAÚ of a so-called contact person. This person communicates with the authority and is responsible for fulfilling AML obligations.
This must be a member of the statutory body or an employee. If you have not yet complied with this obligation, it must be remedied immediately. The fine for failing to comply with this obligation may reach up to CZK 1 million.
Foundation: A secure legal framework for your business
To keep your vintage-vehicle business safe, we recommend having the following areas in order:
- Internal policies system (AML programme): If you become an obliged person, you must have a written risk assessment system.
- High-quality sale and purchase agreement: The agreement must protect your interests and clearly define the condition of the historic vehicle.
- Employee awareness: Train staff so they know they must not accept cash above the limit.
- Records: Keep records of identification and transactions for 10 years.
The attorneys at ARROWS advokátní kancelář can help you set up all of these processes on a turnkey basis.
Conclusion of the article
Selling vintage vehicles is both a passion and a business. Don’t let it be spoiled by an unnecessary fine for accepting cash. The risks associated with the CZK 270,000 limit and the AML Act are real, and inspections do take place. Compliance is not just bureaucracy—it is your insurance against ruinous penalties. We will provide you with expert legal support so you can focus on what matters most: the beauty of historic vehicles.
FAQ – Most common legal questions
1. Can I refuse a cash payment and require bank transfer only?
Yes. In particular, if accepting cash would mean exceeding the statutory limit of CZK 270,000, you must refuse cash. For lower amounts, it is advisable to state this condition in your terms and conditions.
2. If I do not report a suspicious transaction, what will happen to me?
You face an administrative fine of up to CZK 5,000,000 and, in serious cases, criminal prosecution for negligent money laundering.
3. What is a beneficial owner and why do I have to verify them?
A beneficial owner is a natural person who effectively controls a legal entity or benefits from its activities. The AML Act requires you, in the case of corporate clients, to identify who is truly behind the company.
4. Can I buy a classic car as a private individual and immediately resell it without AML obligations?
If you do this as a one-off transaction as a private individual, the AML Act generally does not apply to you (however, the CZK 270,000 threshold always applies). If, however, you carry out this activity on an ongoing basis for profit, you become an entrepreneur and an obliged person.
5. How long do I have to retain identification documents?
The statutory period is 10 years from the completion of the transaction or from the termination of the business relationship.
Notice: The information contained in this article is of a general informational nature only and is intended for basic guidance on the topic under the legal framework as of 2026. Although we take the utmost care to ensure accuracy, legal regulations and their interpretation evolve over time. We are ARROWS, a Prague-based law firm registered with the Czech Bar Association (our supervisory authority), and for maximum client protection we maintain professional liability insurance with a limit of CZK 400,000,000. To verify the current wording of regulations and their application to your specific situation, it is necessary to contact ARROWS directly (office@arws.cz). We accept no liability for any damage arising from the independent use of the information in this article without prior individual legal consultation.
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