Threshold Transaction Reporting in Nepal — Sector Limits and Linked Transactions

This is a reading aid, not the complete threshold table. Exemptions and transaction definitions must be checked in the full guideline. A value below one sector's limit cannot be assumed below another sector's requirement.

Assume a sector rule aggregates the relevant customer's cash deposits in one day at NPR 1 million or more. Deposits NPR 600,000 and NPR 450,000 total NPR 1,050,000 and satisfy that assumed trigger. The monitoring system should identify the customer across accounts or channels as the applicable rule requires. It should not treat each deposit independently to avoid reporting.

A TTR is triggered by the specified objective criteria; an STR/SAR follows suspicion and has no minimum monetary threshold in the guidance. The same facts may require both. A TTR does not state that the customer committed a crime, while filing one does not remove the need to assess suspicious patterns.

Maintain sector-specific rules, customer identifiers, aggregation logic, exemptions, review evidence and submission acknowledgements. Test the boundary, linked transactions and changes to customer data. Preserve the basis for an exemption rather than applying it from an informal customer description. Rejected goAML reports require correction and evidence of accepted submission.

Review thresholds and exemptions when FIU or the sector regulator changes its guidance. Check the current sector rules and reporting instructions before configuring a reporting process.

For A, B and C class BFIs, the July 2025 guideline's table identifies specified cash deposits or withdrawals of NPR 1 million or more in a single account in one day, including a series of transactions. The same table gives different rules for other sectors. Securities purchase or sale reaches its stated NPR 1 million trigger over a single day; real-estate transactions reach the stated NPR 10 million trigger by a customer over a day.

Insurance treatment includes the specified annual premium measures and submission on the first and sixteenth days of Nepali months. PSP/PSO reporting uses a monthly customer aggregation rule across the stated accounts or wallets. The period, person, account and transaction type should therefore be configured together, rather than entering only an amount in monitoring software.

The guideline provides sector exemptions separately from the threshold table. Preserve the actual basis for an exemption and assess any suspicious features independently. FIU's STR/SAR guidance covers attempted or completed activity below an objective reporting threshold where the examination establishes the required reasonable grounds.

Meeting a threshold does not itself establish wrongdoing. Assess any unusual pattern or explanation independently, including attempted activity below the TTR trigger. The threshold report and suspicious-report decision therefore need separate conclusions and evidence.

The July 2025 TTR table notes that certain directives for accountants, auditors and company or trust service providers did not mention TTR provisions. It should not be turned into a bank-style threshold obligation for every professional service. ICAN's current guidance separately addresses auditors' STR responsibilities.

Keep the relevant rule version, aggregation logic, exemption decision, review and accepted submission evidence. When a rule changes, update monitoring and reporting procedures together and document the date the revised rule took effect.