Update: Through Circular No. 1230 (27 February 2026, effective 21 March 2026), the BSP raised the EDD threshold to PHP1,000,000. The per-customer approach in M-2026-005 continues to apply.
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 BSFIs shall conduct EDD for cash withdrawals exceeding PHP500,000.00 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. Streamlined EDD may be applied to bank-to-bank transactions (e.g., inter-branch or inter-bank cash requirements) and loan disbursements. For payouts during declared calamities or emergencies, a certification from the head of agency may be obtained. However, transactions that deviate from established customer profiles and those that present heightened money laundering, terrorism financing, or proliferation financing risks remain subject to stricter review.