Currency transaction report limit raised to Rs 3 million from Rs 2 million: what it means for cash deals

Banks in Pakistan will only have to file a currency transaction report (CTR) on cash deals of Rs 3 million or more, up from Rs 2 million, after the National Executive Committee on anti-money laundering and countering the financing of terrorism (AML-CFT) approved a 50% rise in the threshold. The committee is chaired by Finance Minister Muhammad Aurangzeb, Dawn reported on Tuesday.

What a CTR is, and what changes

A CTR is filed automatically whenever a cash transaction reaches the limit, whether or not anything looks wrong. It is different from a suspicious transaction report (STR), which a bank files when an account or deal looks like it could involve money laundering or terrorism financing, at any amount.

The committee sets these limits by notification in the official Gazette. Dawn did not say whether that notification has been issued, so the new limit applies from the date it is gazetted.

What it means for you

If you deposit or withdraw large sums in cash, for a car, a plot instalment or a wedding, a transaction between Rs 2 million and Rs 3 million will no longer be reported to the FMU automatically. It does not mean the cash is untaxed or unchecked: banks still have to report anything they find suspicious, and non-filers still pay withholding tax on cash withdrawals. Work out what a withdrawal costs you with our cash withdrawal tax calculator.

The higher limit is also an inflation adjustment of sorts: with consumer prices up sharply over the past few years (see our inflation rate page), Rs 2 million buys far less than it did when the earlier limit was set, so ordinary purchases were increasingly being reported.

Other decisions

• Maritime piracy becomes a predicate offence under the Anti-Money Laundering Act, so money made from it can be pursued as laundering. The definition comes from section 28 of the Pakistan Maritime Zones Act 2023.
• The Pakistan Virtual Assets Regulatory Authority (PVARA) joins the State Bank, the SECP and the FBR as an AML-CFT supervisor, giving it powers over crypto and other digital asset businesses.
• Aurangzeb asked for a roadmap "with defined timelines" to strengthen the FMU, which receives every CTR and STR, can demand records from any person or agency, and shares its analysis with investigators and foreign financial intelligence units.