Regulatory Alerts2026-02-06
Clarification on the Implementation of BSP Circular 1218 Series of 2025 on Large Value Cash Transactions
Bangko Sentral ng Pilipinas issued Memorandum No. M-2026-005 to clarify that enhanced due diligence for cash withdrawals exceeding P500,000 must be conducted on a per-customer basis rather than per transaction. The directive permits streamlined due diligence for low-risk scenarios such as bank-to-bank transfers and calamity-related payouts, while mandating rigorous checks for transactions deviating from expected customer behavior. Financial institutions are required to implement these procedures efficiently without unduly delaying legitimate transactions through targeted staff training and process optimization.
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