BSP Clarifies Enhanced Due Diligence Rules for Large-Value Cash Transactions

The Bangko Sentral ng Pilipinas (“BSP”) through Circular No. 1218, Series of 2025 introduced the Enhanced Due Diligence (“EDD”) requirement for large-value cash transactions. The BSP through Memorandum No. M-2026-005 clarifies that BSP-Supervised Financial Institutions (BSFIs) shall conduct EDD on a per customer basis, instead of a per transaction basis. Furthermore, BSFIs must complete EDD procedures before releasing funds and obtain documentation supporting the legitimate purpose of the withdrawal.

The BSP clarifies that BSFIsshallconduct EDD for cash withdrawals exceedingPHP500,000.00 whether conducted as a single transaction or aggregated within one banking day and EDD procedures may be streamlined depending on the client’s risk profile and transaction history. Simplified procedures are also allowed for inter-bank activities and emergency withdrawals supported by government certification. However, transactions that deviate from established customer profiles and those that present heightened money laundering, terrorism financing, or proliferation of financing risks remain subject to stricter review.