Compliance Corner – Cash Transaction Limit Under POCA

    JN Money

    Amendments to Jamaica’s Proceeds of Crime (POCA) legislation in 2013 introduced a cash limit on transactions within Jamaica. This amendment prohibits the exchange of cash when purchasing goods and services valued at one million Jamaica dollars ($1M) or more (or its equivalent in any other currency), within the Jamaican economy. Of note, this prohibition applies to a transaction or series of transactions which taken as a whole, amount to or exceeds J$1M. Therefore, while purchasing goods or services in Jamaica, no Jamaica citizen, resident or visitor, to include any business establishment should pay/accept cash valued at J$1M in exchange for goods and services.

    Are there any exceptions to the J$1M rule?

    Yes! Under POCA, provision is made for Exempt Person and Permitted Person.

    • Exempt Person – means a person or transaction exempt by the Minister subject to affirmative resolution.
    • Permitted Person – means a bank licensed under the Banking Act, a deposit taking institution regulated by the Bank of Jamaica, a person operating an exchange bureau as licensed by the Bank of Jamaica.

    How does this impact JN Money?

    As a money services business, JN Money does not qualify as an exempt or permitted person who would directly benefit from the exception provided where cash transactions valuing $1M or more is concerned. Therefore, Agents of JN Money would not be able to pay proceeds of a money transfer that amounts to $1M or more, in cash. There is however an exception where a Bank is an agent of JN Money. In this instance, JN Bank, a licensed deposit-taking institution, can pay the proceeds of a money transfer which amounts to $1M or more in cash. JN Money customers can collect remittance proceeds at select JN Money Shop locations.

    What, if any, impact does the POCA cash limit have for overseas senders?

    While the POCA cash limit doesn’t affect senders outside of Jamaica directly, it could influence their sending values if their recipients face disbursement challenges receiving cash payments at values J$1M or more. In these instances, customers can be encouraged to send directly to their bank accounts, or have their recipients apply for a JN Money Card (MT Card) to which proceeds from $1 to $1M and more can be disbursed. Recipients are then able to use their MT Card at Automated Banking Machines (ABMs) to make withdrawals, or at Point-of-Sale (POS) terminals to make purchases of goods and services. With the soon-to-come Visa enabled cards, recipients with these cards will also be able to do purchases online.

    Main Takeaways

    1. JN Bank Agents (via JN Money Shops) can disburse remittance proceeds $1M and over in cash.
    2. All other agents can disburse amounts below $1M in cash.
    3. Values above J$1M can be disbursed to a bank account or to the JN Money Card (MT Card).
    4. Senders can encourage their recipients to apply for the JN Money Card for ease of receiving their remittance proceeds.
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