Pakistan raises cash reporting threshold to Rs3m, brings piracy and crypto under anti-money-laundering law

Banks will now report cash transactions to the Financial Monitoring Unit from Rs3 million, up from Rs2 million, under changes approved by a committee chaired by Muhammad Aurangzeb.

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Men count dollars and rupees at an exchange counter in Islamabad
People count US dollars and rupees at a currency exchange counter in Islamabad. File photo. — AFP

— Pakistan has raised the cash threshold at which banks must file currency transaction reports to the State Bank’s Financial Monitoring Unit by 50 per cent, from Rs2 million to Rs3 million, and brought maritime piracy and the new crypto regulator inside its anti-money-laundering law.

The changes were approved by the National Executive Committee on Anti-Money Laundering and Countering the Financing of Terrorism, chaired by Finance Minister Muhammad Aurangzeb, Dawn reported. The committee sets the limits at which banks, financial institutions and other agencies must report transactions, and announces them through notifications in the official Gazette.

What the new limit means

Under the Anti-Money Laundering Act, a currency transaction report is required whenever a cash transaction equals or exceeds the threshold, which now stands at Rs3 million. That is separate from a suspicious transaction report, which banks must file whenever a transaction or activity points to money laundering or terrorism financing, whatever its size.

The Financial Monitoring Unit receives and analyses both kinds of report. It can demand the full record of any transaction from any agency or individual in Pakistan, all of whom are legally bound to comply promptly, and can share its findings confidentially with investigators, prosecutors and foreign financial intelligence units.

Piracy and crypto brought in

The committee added Section 28 of the Pakistan Maritime Zones Act 2023 to Schedule I of the anti-money-laundering law, making maritime piracy a predicate offence, meaning the proceeds of piracy can now be pursued as money laundering. The Act defines piracy as any illegal act of violence, detention or depredation committed for private ends by the crew or passengers of a private ship or aircraft against another vessel or the people and property on board.

It also added the Pakistan Virtual Assets Regulatory Authority to Schedule IV, giving the crypto regulator anti-money-laundering supervisory powers over virtual and digital assets alongside the State Bank, the Securities and Exchange Commission of Pakistan and the Federal Board of Revenue.

Pressure on the monitoring unit

An official statement said the meeting reviewed progress on Pakistan’s anti-money-laundering regime, including the Financial Monitoring Unit’s performance and its use of artificial intelligence and machine learning. Aurangzeb called for regular follow-up, closer coordination between institutions and a clear roadmap with deadlines to strengthen the unit’s analytical and operational capacity, while the committee stressed keeping the framework responsive to new financial risks and technologies.

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