BSP Circular (Series of 2025) introduces restrictions on large value cash payouts and mandates enhanced due diligence (EDD) for large cash-related transactions. The policy targets money laundering, terrorism financing, and proliferation financing risks linked to cash-intensive activity.
Key Changes
- Cash payout restriction: payouts above PHP 500,000 (or FX equivalent) must be made via check, fund transfer, direct credit to deposit accounts, and/or BSFI digital payment platforms.
- Aggregation rule: the PHP 500,000 threshold applies to a single transaction or a series of transactions within one banking day.
- Lower limits allowed: BSFIs may set stricter cash limits based on their ML/TF/PF risk assessment or customer profile.
- EDD required for transactions exceeding the threshold under Section 921/921e of the MORB/MORNBFI.
- Cash payout after EDD may be allowed if the customer provides additional ID information and/or proof of legitimate business purpose.
- STR filing triggers: if EDD cannot be completed, or it would tip off the customer, the BSFI must file a suspicious transaction report (STR), monitor the account, and review the relationship.
Who Is Affected
- Banks and other BSP-supervised financial institutions (BSFIs).
- Customers requesting large cash withdrawals or cash-related payments.
- Compliance, branch operations, and AML/CFT teams implementing cash controls.
Effective Date & Transition
The circular takes effect 15 calendar days after publication in the Official Gazette or a newspaper of general circulation.
Compliance Actions Checklist
- Update AML/CFT policies to reflect the PHP 500,000 cash payout cap and non-cash payout channels.
- Implement transaction aggregation logic for same-day cash payouts.
- Adjust cash limits based on institutional ML/TF/PF risk assessments.
- Apply EDD procedures for threshold-exceeding transactions and document outcomes.
- Establish documentation requirements for additional ID and proof of legitimate business purpose.
- Define STR escalation paths when EDD cannot be completed or would tip off the customer.
- Train branch and operations staff on new payout restrictions and escalation rules.
FAQs
Can a customer still receive cash above PHP 500,000? Yes, but only after EDD is completed and additional ID or proof of legitimate purpose is provided.
Does the threshold apply to multiple smaller withdrawals? Yes. The PHP 500,000 limit applies to single or aggregated transactions within one banking day.
What if EDD cannot be completed? The BSFI must file an STR, monitor the account, and review the business relationship.
Related Links
- Regulator hub: /regulations/bsp
- Topic hub: /regulations/topics/aml-cft
- Ask CHD: /chat (Ask CHD about this regulation)