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.
BANGKO SENTRAL NG PILIPINAS To All BSP-Supervised Financial InstitutionslBSFls} Clarification on the Implementation of BSP Circular 12/8, Series of 2025 megulation on Large Value Cash Transactions)' In implementing the enhanced due diligence (EDD) requirements under BSP Circular No. 12/8. ' BSFls shall conduct EDD for cash withdrawals exceed in P500.000, on a per customer basis, instead of per transaction basis. This shall cover the customers usual business transactions. Subject MEMORANDUM No. M-2026-005 OFFICE OFTHE GOVERNOR BSFls may also adopt streamlined EDD considering the customer's risk rofile. nature of business or operations, and transaction patterns. Streamlined EDD may be applied to bank-to-bank transactions. such as inter-branch or inter-bank cash requirements. or loan disbursements, For cash payouts or withdrawals during declared calamities/emergencies, certification from the head of agency may be obtained. Meanwhile. more rigorous EDD shall be applied when transactions deviate from a customer's expected behavior or present heightened risks, BSFls must ensure that EDD procedures do riot unduly delay legitimate transactions by streamlining processes and providing branch personnel with targeted training to promote consistent, efficient. and effective implementation, For guidance and strict implementation. February 2026 I^,.^ Including BSP Memorandum No. M-2025 036 dated 30 October 2025 containing the Fre uentl Asked Q t' on the Regulation on Large Value Cash Transactions ELI M. REMOLONA. R. Governor