The Central Bank of the Philippines published frequently asked questions to support implementation of BSP Circular No. 1218 (Series of 2025) on large value cash transactions, clarifying how BSP-supervised financial institutions should apply stricter controls and enhanced due diligence (EDD) to mitigate money laundering, terrorism financing and proliferation financing risks linked to high-value cash activity. The FAQs confirm that the PHP 500,000 threshold applies to a single cash payout transaction or the aggregate of a customer’s cash payout transactions within one banking day, and it is computed across Philippine pesos and foreign currencies. Withdrawals above the threshold remain permitted, but cash-only payouts exceeding PHP 500,000 require appropriate EDD and supporting documents, with BSFIs expected to set their own escalation and approval processes including senior management approval as part of EDD. The scope includes over-the-counter and ATM withdrawals, foreign currency transactions, check encashments, cash loan drawdowns or disbursements, and cash advances, while a payout that combines cash and non-cash modes is not covered by the Circular 1218 EDD requirement for large value cash payouts. The FAQs also address operational expectations around consolidated monitoring and aggregation of customer activity across accounts and branches, treatment of transactors or authorised representatives, payee checks for check encashment, and EDD application to “For the Account of” and “In Trust For” accounts. For money service businesses, the BSP clarified that Circular 1218 does not supersede Section 103-M of the Manual of Regulations for Non-Bank Financial Institutions, which requires payouts above PHP 500,000 (or foreign currency equivalent) in a single transaction to be made via check or direct credit to deposit accounts. BSFIs are expected to use the FAQs to enhance their policies and procedures for consistent implementation of the circular, which took effect on 07 October 2025.
Central Bank of the Philippines 2025-10-30
Central Bank of the Philippines issues FAQs clarifying enhanced due diligence for cash payouts above PHP 500,000
The Central Bank of the Philippines issued FAQs to aid in implementing BSP Circular No. 1218 on large value cash transactions, emphasizing enhanced due diligence (EDD) for transactions exceeding PHP 500,000. EDD applies to cash-only payouts above this threshold, requiring supporting documents and senior management approval. The FAQs address operational expectations for monitoring and aggregation of customer activity, confirming that the circular does not override existing regulations for non-bank financial institutions.