SBP Raises Cash Reporting Threshold to Rs3 Million — What Changes for Banks and Customers

November 14, 2026

The State Bank of Pakistan (SBP) has raised the threshold at which banks must automatically report large cash transactions, lifting it from Rs2 million to Rs3 million with immediate effect. From now on, banks and other institutions regulated by the central bank will file a Currency Transaction Report (CTR) with the Financial Monitoring Unit (FMU) only when a cash deposit or withdrawal reaches Rs3 million or more.

The change was communicated to banks in a circular letter on Thursday 12 November 2026. It follows a notification issued by the Finance Ministry on 11 November 2026, after the National Executive Committee on anti-money laundering approved the change in October 2026. The committee is chaired by Finance Minister Muhammad Aurangzeb.

What is a Currency Transaction Report?

A CTR is a routine, automatic report that a bank sends to the Financial Monitoring Unit whenever a customer deposits or withdraws cash at or above a set threshold. The FMU is the national unit that receives and analyses reports about financial transactions, as part of Pakistan’s system for detecting money laundering and the financing of terrorism.

It is important to understand what a CTR is not. It is not a tax, not a fine, and not a limit on how much cash a person may use. A customer can still deposit or withdraw any amount; the threshold only decides whether the transaction is automatically reported. Nor is a CTR an accusation. A report on its own means nothing about the customer — it simply becomes part of the data the FMU can analyse if it is looking into a wider pattern.

CTRs sit under the Anti-Money Laundering Act 2010, and records of CTRs — along with Suspicious Transaction Reports (STRs) — must be kept for at least ten years. An STR is different: a bank files one when a transaction looks suspicious, whatever the amount. The CTR threshold, by contrast, is purely mechanical — cross it in cash, and a report is filed; stay below it, and none is generated.

Why thresholds exist at all

Large movements of physical cash are harder to trace than electronic payments, and they can be used to move the proceeds of crime, evade tax, or finance terrorism. Reporting creates a paper trail that investigators can follow. But reporting every cash transaction would bury the FMU in data and impose heavy costs on banks, so the system draws a line: only the larger transactions are reported automatically, while smaller ones are left alone unless something about them looks suspicious. That line is what has now moved.

What actually changes

In practical terms, the change is narrow. A cash deposit or withdrawal of, for example, Rs2.5 million would previously have triggered an automatic CTR; from now on it will not, while a transaction of Rs3 million or more in cash will still be reported exactly as before.

Nothing else changes. Banks must still verify customers’ identities, monitor accounts, and file STRs whenever a transaction appears suspicious, at any amount, and the ten-year record-keeping requirement is unchanged. The threshold applies to cash transactions — deposits and withdrawals of physical currency — not to cheques, bank transfers, or digital payments.

For ordinary customers, the change will be invisible. It does not restrict access to their money, does not change the documents a bank asks for, and does not make a Rs2.5 million transaction any more or less legitimate than it was last week. Only the volume of automatic reporting changes, and how much data flows to the FMU.

The threshold had not moved since 2015

The most striking feature of this change is how long the old threshold had stood. The Rs2 million figure was set in January 2015 and had not been revised for more than eleven years, while the economy and the scale of cash in circulation both grew. Cash in circulation reached a record Rs11.9 trillion at the end of March 2026, according to SBP data — a reminder of how central physical cash remains in Pakistan’s economy.

That long freeze is also why the headline number can be misleading. A rise from Rs2 million to Rs3 million is a 50 percent increase in rupee terms, which sounds large — but the threshold was fixed in 2015, and over more than a decade the purchasing power of the rupee has fallen as prices have risen. Rs3 million today buys considerably less than Rs2 million bought in 2015, so while the nominal figure has gone up by half, the real value of the threshold is lower now than when it was set. In effect, the bar for automatic reporting has been reset to a level that is, in real terms, lower than the 2015 bar, even though the number printed on it is higher.

No official reason for the change has been given. It came through the established process — approval by the National Executive Committee on anti-money laundering, followed by the Finance Ministry notification and the SBP circular — but neither has publicly explained the thinking behind it.

What this means

For customers, nothing changes in how they use cash: no new restriction, no new form, no new cost. For banks, the volume of automatic CTR filings will fall, since fewer transactions will cross the higher line — but their duties to watch for suspicious activity and keep records for ten years are exactly as before. For the system as a whole, the threshold has been brought somewhat closer to the scale of today’s economy, after more than a decade in which it stood still while prices and cash in circulation moved on. Whether the new Rs3 million figure holds for another decade, or is reviewed more often from here, is a question the SBP and the Finance Ministry have not yet answered.

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