ECSH51125 - Currency exchange office - what you would expect to see at a compliance intervention.
Source: gov.uk (2025-04-16)


Currency exchange offices operate in one of the following ways:

As a traditional Bureau de Change through which a customer exchanges currency by providing the following services:
- Exchange services which can be used to buy or sell foreign currencies, for example exchanging sterling GBP to Dominican pesos.
- Issuing travellers cheques, travel money cards and euro cheques.
- Exchanging travellers cheques for cash, euro cheques and money orders.
These are commonly associated with travel agents, airports, department stores, high street shops, hotels, supermarkets, train stations, cruise ships and ferries. Please note, however, there may be exceptions see ECSH43555 (https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh43555).
- A person or business which provides bulk cash/currencies to a customer (usually a business) on order which is then either picked up by the customer or delivered to them (potentially by a cash and valuable in transit (CVIT) company like G4S or Securicor).
- A person or business which carries out foreign exchange (foreign exchange, frequently abbreviated to “Forex” or “FX”), is the market in which currencies are traded), involving the digital trade of one currency to another different currency utilising the FOREX/FX Markets and the different currency subsequently being returned to its customer.
FOREX (FX)

A MSB providing FX service deals with high volume, bank-to-bank transactions, where there is minimal face-to-face contact with the customer. These transactions are a currency exchange trade and are made on a specific market similar to the stock market. ‘Retail FX’ is the provision of global payment services and Forex to individuals and corporate entities, as opposed to other financial institutions. For funds transferred abroad, FX businesses will also be responsible for converting the currency. This is completed at the end of the chain when the funds are transferred into the receiving bank account.

The majority of the customers of a currency exchange office are holidaymakers or those travelling on business. A proportion of their customers will be business travellers, and some will be private individuals wanting to buy assets (for example, property or vehicles) abroad from sellers who want cash.

Some Currency Exchange Offices also carry out money transmission and/or cheque cashing.

Information on Currency Exchange Office money laundering risks can be found at ECSH51100. (https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh51100)

Currency Exchange Offices can be a main or secondary business activity. When you arrive, you may find that it is:
- A stand-alone business totally dedicated to currency exchange operating in a high street, or at an airport or other transport hubs.
- Secondary to a main business activity for example a department store, hotel, travel agent etc.
How does a CEO operate?

Currency exchange offices generate income from:
- Commission (lower rates may apply for larger transactions).
- Exchange rate offered (likely to be less favourable if commission is not charged).
- Exchange rate differences between buying and selling.
They may buy foreign currency from banks, currency wholesalers and other exchange offices or recirculate currency that is already in circulation. Their operations vary according to the type of business and customers and can include:
- Travel agents who may offer exchange, on which they may not make a great profit, as part of the overall holiday booking service. A large proportion of the smaller travel agents will only exchange currency for customers who have booked a holiday. The average transaction value is around £500.
- Standalone offices only offering currency exchange facilities may be a branch of a larger organisation or simply a kiosk on the corner of a high street.
- Major department stores offer exchange facilities in many of their city outlets. The office will be a separate unit within the store. Transaction values can vary enormously. Many well-known department stores have their CEOs supervised by the FCA as they provide additional financial services in store.
- Cruise ships and ferries will provide on board currency exchange for passengers. The Operator must register if they operate within UK ports and if they operate within UK territorial waters. (Does not apply to ships simply passing through territorial waters). Transaction values will vary.
- Hotels usually only provide exchange facilities to residents. Hotel residents are offered exchange facilities for foreign currency to sterling and are mainly low value transactions.
- Currency wholesalers dealing with other Currency Exchange Offices.
Records will vary (depending on the type of business and size of transactions) from till rolls to individual customer accounts. It is usual to see the following documentation:
- Customer’s ID.
- Computerised customer account.
- Daily summary records.
- Banking records.
The business should be able to provide information on who supplies it with foreign currency and give details of the type of currency it trades in, for example euros, dollars, etc.