Regulatory Alerts2025-03-21 | Circular No.01Clarification on Reporting of Currency Transaction Reports (CTRs) under the Anti-Money Laundering Act, 2010 to the Financial Monitoring Unit (FMU)
This circular establishes that for all interoperable fund transfers, FinTech/PSP-mediated payments, and cross-bank shared counter services, the bank holding the customer's account bears the sole responsibility for filing Currency Transaction Reports (CTRs) with the FMU. Reporting entities must leverage KYC/CDD data and information exchanges with initiating banks to ensure accurate and timely compliance for transactions exceeding the PKR 2.0 million threshold. Banks are granted a transition period until September 30, 2025, to implement the necessary technical and monitoring infrastructure to meet these reporting obligations.
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