Pakistan has raised the mandatory reporting threshold for cash transactions handled by banks from Rs2 million to Rs3 million as part of changes to the country’s anti-money laundering and counter-terrorism financing framework. The National Executive Committee on Anti-Money Laundering and Countering the Financing of Terrorism (AML-CFT) approved the revision at its 19th meeting on October 27, 2026, chaired by Finance Minister Muhammad Aurangzeb. The revised limit determines when banks and other reporting entities must submit Currency Transaction Reports (CTRs) to the Financial Monitoring Unit (FMU). Under the previous threshold, cash transactions of Rs2 million or above were reportable; the new threshold increases that amount by 50 percent. The decision forms part of a broader review of Pakistan’s financial monitoring arrangements, including institutional capacity, coordination among government agencies and the use of emerging technologies in financial intelligence. The changes are intended to update the framework used to identify and assess financial activity that may require further scrutiny.
Currency Transaction Reports and Suspicious Transaction Reports serve different purposes under the anti-money laundering system. A CTR is triggered when a cash transaction reaches or exceeds the prescribed reporting threshold, while a Suspicious Transaction Report (STR) is filed when a transaction or activity raises concerns about possible money laundering or terrorist financing. The higher CTR threshold does not mean that suspicious transactions below Rs3 million are exempt from scrutiny or that banks can disregard unusual account activity. The FMU receives and analyses both types of reports and can request transaction records and related information from relevant agencies or individuals under the applicable law. It may share its findings confidentially with investigating and prosecuting authorities or with foreign financial intelligence units under reciprocal arrangements. For banks and other reporting institutions, the distinction remains important because compliance obligations extend beyond the amount involved in a cash transaction. The practical application of the revised threshold will depend on the relevant official notification and implementation arrangements.
The committee also approved the inclusion of Section 28 of the Pakistan Maritime Zones Act, 2023, in Schedule I of the Anti-Money Laundering Act. This provision concerns piracy, bringing the specified offence within the framework of predicate offences associated with money laundering. In a separate decision, the committee approved adding the Pakistan Virtual Assets Regulatory Authority (PVARA) to Schedule IV of the AMLA. The inclusion is intended to bring virtual asset oversight more directly into the country’s anti-money laundering and counter-terrorism financing arrangements. It is particularly relevant as Pakistan develops regulatory requirements for virtual asset service providers and digital asset activities. However, the committee’s approval should be distinguished from a complete description of all licensing, reporting or operational requirements that may apply to individual businesses. Those details depend on the applicable legislation, notifications and regulatory guidance. The decisions together show that the government is addressing financial risks across conventional banking transactions, specified criminal offences and emerging virtual asset activities within a coordinated legal framework.
The meeting also reviewed progress on earlier AML-CFT decisions, the performance of the FMU and institutional capacity-building initiatives, including the use of artificial intelligence and machine learning in financial monitoring. Aurangzeb called for timely follow-up, better coordination among relevant institutions and a clear roadmap with defined timelines to improve the FMU’s analytical and operational capacity. The official announcement said the committee sought to keep the national framework responsive to evolving financial risks and emerging technologies. For banks, fintech companies and virtual asset businesses, the developments highlight the importance of following formal regulatory notices and maintaining appropriate transaction-monitoring and reporting processes. The revised cash reporting threshold changes one specific trigger for CTR filing, but it does not remove the separate requirement to report suspicious activity where applicable. Further implementation details will clarify how the revised limit and other approved changes are incorporated into the operating procedures of reporting entities and the wider financial intelligence system.
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