What is the quantitative threshold for a covered transaction by real estate developers and brokers?

• A. A single transaction exceeding P7,500,000 in cash
• B. A single transaction exceeding P7,500,000 in cash or cash equivalents
• C. A single transaction exceeding P7,500,000 in cash or on account
• D. A single transaction exceeding P7,050,000 on account

Answer: (A)

A single cash payment exceeding 7,500,000 pesos is the trigger for a covered transaction by real estate developers and brokers. This threshold focuses on direct cash movements because large cash payments are the most significant red flags for illicit activity due to their traceability challenges. By defining the rule as a one-time cash amount, the framework creates a clear, enforceable line that signals the need for enhanced due diligence and reporting. It does not include cash equivalents or on-account payments in this threshold because those forms of payment can involve different pathways, timing, or levels of traceability and are typically addressed by other monitoring criteria.