Banks stop reporting cash deals between Rs2 million and Rs3 million, but the line is worth half what it was

The State Bank of Pakistan has raised the cash amount at which banks must report a transaction to the country's financial intelligence unit from Rs2 million to Rs3 million. The change took effect immediately, through BPRD Circular Letter No. 24 of 2026, after the Finance Ministry notified it on 11 November. The nominal rise is 50 percent. Measured in prices or in dollars, the line has fallen by about half since it was last set, so the reporting net is wider than it looks and the rise only partly repairs that.

The old figure dates from January 2015, when the State Bank lowered the threshold to Rs2 million. It is the first change in almost 12 years. The circular says only that it follows a directive from the federal government. The decision itself was taken in October by the National Executive Committee on anti money laundering, chaired by Finance Minister Muhammad Aurangzeb, at the meeting that also moved to bring the crypto regulator PVARA under the law.

A currency transaction report, or CTR, is a routine filing, not an accusation. Banks and other reporting entities send it to the Financial Monitoring Unit, which sits inside the State Bank, for cash deposits and withdrawals above the notified amount. Since 1 January 2020 the filings go through the unit's goAML system. Account to account transfers are not CTRs, so the rule covers only physical cash. From now on a deposit of Rs2.5 million in notes generates no CTR, where before it did.

Two things do not change. Suspicious transaction reports, which a bank files when activity looks like laundering or terror financing, apply at any amount. And the threshold is not a ceiling: customers can still deposit or withdraw more than Rs3 million in cash. What shifts is how much routine cash information reaches the unit's database without anyone having judged it suspicious.

Inflation does most of the work

Profit by Pakistan Today estimates that consumer prices have roughly tripled since January 2015. On that estimate, Rs2 million in 2015 buys what about Rs6 million buys now, so a threshold of Rs3 million is worth half of the old one in real terms (1.5 times the nominal figure, divided by 3 for prices). The dollar comparison points the same way. At roughly Rs100 to the dollar in 2015, Rs2 million was about $20,000. At roughly Rs277 to the dollar now, Rs3 million is about $10,800.

That second figure is the useful benchmark. The United States has required banks to report cash transactions above $10,000 since the Bank Secrecy Act of 1970. In dollar terms Pakistan's new line sits just above the American one, where the 2015 line was double it. The practical effect is that Pakistan's threshold had been getting stricter every year as prices rose, because ordinary purchases such as a second hand car, a plot deposit or a wholesaler's weekly stock crossed Rs2 million more often than they once did.

What could go wrong

A higher line helps genuine traders, and it cuts the volume of reports the unit must store and screen. Fewer low value CTRs can let analysts spend time on patterns that matter. The risk is structuring, the habit of splitting cash into amounts just under the line. When the line was Rs2 million, deposits of Rs1.9 million were the tell. They can now run up to Rs2.9 million before triggering a report, and anyone planning to avoid notice has more room. Banks' own monitoring systems, which flag repeated near threshold deposits, matter more as a result, and their rules will need retuning.

There is also a gap in what is known. The government has given no reason beyond the directive, and no figure has been published on how many CTRs the unit received a year, or how many came from the band between Rs2 million and Rs3 million. Without those counts, nobody outside the State Bank can say how many filings the change removes, or whether any past investigation began with a report in that band.

Who gains is clear enough: cash heavy businesses, small banks with thin compliance teams, and the unit's own workload. The regulator carries the risk, because it now has less routine cash data at the same moment it is adding virtual assets to the law. The unit's annual report would show how many CTRs the old threshold produced, and so how many the change removes.