Central Bank of the Philippines recalibrates enhanced due diligence threshold for large value cash payouts to PHP 1 million

The Central Bank of the Philippines issued a circular amending its anti-money laundering, counter-terrorism financing and countering proliferation financing requirements to recalibrate when Bangko Sentral-supervised financial institutions must apply enhanced due diligence (EDD) to large value cash payouts. The updated trigger requires risk-based EDD for cash payouts exceeding PHP 1,000,000 or the equivalent in foreign currency. The PHP 1,000,000 threshold applies to a single transaction or a series of transactions within one banking day, with EDD performed at the customer level and not separately for each transaction where appropriate EDD has already been applied. Institutions may apply proportionate or risk-based EDD measures based on the customer’s assessed risk profile, nature of business and transaction patterns, and may also set lower cash transaction limits based on their institutional money laundering, terrorism financing and proliferation financing risk assessment and or the customer’s financial profile. Where EDD cannot be satisfactorily completed, or where completing EDD could tip off the customer, the institution must file a suspicious transaction report, closely monitor the account and review the business relationship, taking into account relevant alerts, red flags, suspicious indicators and typologies. The amendments take effect 15 calendar days after publication in the Official Gazette or in a newspaper of general circulation in the Philippines.