SBP raises cash transaction reporting threshold to PKR 3 million

The State Bank of Pakistan (SBP) informed banks on Thursday that the cash transaction reporting threshold had risen from PKR 2 million to PKR 3 million with immediate effect, following a federal government notification under the Anti-Money Laundering Act, 2010.

What is the new cash transaction reporting threshold?

Banks and other reporting entities must now submit Currency Transaction Reports (CTRs) to the Financial Monitoring Unit (FMU) for qualifying cash transactions of PKR 3 million or more. The previous threshold was PKR 2 million, meaning the government has increased the reporting limit by PKR 1 million, or 50%.

The central bank informed regulated financial institutions of the revised threshold in its November 12 circular.

The previous limit had been in place since January 2015.

The revision follows a Finance Ministry notification dated November 11, 2026, issued under the authority of the National Executive Committee on Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT).

Exercising its powers under Section 2(xi) of the Anti-Money Laundering Act, the committee specified PKR 3 million as the minimum amount for filing CTRs with the FMU.

The notification modifies Finance Division notification SRO 73(I)/2015, issued on January 21, 2015.

Does the new threshold change suspicious transaction reporting?

The revised threshold applies to cash-based Currency Transaction Reports and does not remove the requirement to report suspicious transactions involving smaller amounts.

Under Section 7 of the Anti-Money Laundering Act, financial institutions must submit both Suspicious Transaction Reports (STRs) and CTRs to the FMU.

An STR is filed when an institution identifies suspicious activity, while a CTR is triggered when a qualifying cash transaction meets or exceeds the prescribed amount.

Existing regulations require CTRs to be submitted immediately, but no later than seven working days after the transaction.

What compliance requirements remain for banks?

SBP has directed regulated financial institutions to comply with the revised threshold.

Banks must continue maintaining records of domestic and international transactions, including analyses used to establish the background and purpose of complex, unusual or large transactions.

Transaction records must be maintained for at least 10 years after completion, while records relating to STRs and CTRs must be retained for at least 10 years after reporting.