KINGSTON, Jamaica — It is your money. You earned it, saved it, and perhaps spent years putting it aside to buy land, repair a house or purchase a vehicle. Yet when you want to hand over a substantial amount in cash, the law may stand in your way.
Under Jamaica’s Proceeds of Crime Act (POCA), payments at or above the J$1 million cash threshold are generally prohibited for covered transactions, subject to statutory exemptions.
The restriction was introduced to combat money laundering, not to enrich banks. But when the alternative is a chargeable bank transfer, a difficult question emerges: should Jamaicans have to pay a financial institution simply to use their own legitimate money?
The Million-Dollar Rule
POCA dates back to 2007, but the cash restriction was introduced by amendments in 2013. Section 101A restricts large cash payments for goods, services and settlement of obligations. The Financial Investigations Division explains that deliberately splitting transactions to evade the threshold is also prohibited.
Banks and other permitted institutions have statutory exceptions. Possessing J$1 million is not automatically an offence, and legitimate large deposits are not automatically prohibited. Banks must, however, apply anti-money-laundering checks.
The aim is understandable. Untraceable cash can facilitate corruption, fraud and organised crime. But crime prevention and protection from excessive charges are not mutually exclusive.
Parliament Saw This Coming
When Parliament debated the amendments in October 2013, the proposed threshold was initially J$500,000. Concerns about business activity and access to payment services helped prompt a revision to J$1 million.
Reporting by the Jamaica Information Service recorded lawmakers raising questions about banking charges and whether the country’s electronic payment systems were ready. Thirteen years later, that debate remains relevant.
The question is no longer whether financial safeguards are needed. It is whether people have affordable ways to comply.
The Banks Still Get Paid
Published personal banking fee schedules in 2026 illustrate the issue. At selected Jamaican commercial banks, online ACH transfers cost approximately J$19.55 to J$19.73, while online RTGS transfers cost approximately J$200 to J$236.90. One institution introduced an online ACH fee in June 2026 for a service previously provided without a charge.
Assisted transactions can cost considerably more, with published charges reaching J$650 for ACH transfers and J$1,200 for RTGS transfers. These examples are from publicly available personal banking schedules and include applicable GCT. Fees and exemptions differ by institution, account and transaction type.
Not every transfer costs money. Some same-bank transfers and eligible digital transactions remain free. Nevertheless, fee-bearing electronic transactions create revenue for banks. That does not prove that POCA caused those charges or that banks earn excessive profit. Payment technology, security and regulation all cost money.
But the public deserves to know what compliance costs, and who ultimately bears it.
Count the Cost
Imagine one million chargeable electronic transfers each month at an average J$20 fee. That generates J$20 million in monthly gross charges, or J$240 million annually. At J$50 per transaction, the illustrative annual figure rises to J$600 million.
These are scenarios, not estimates of real Jamaican banking revenue or profit. They exclude expenses, tax, exemptions and free transfers. Adjust the interactive calculator below to explore different assumptions.
What could bank transfer fees generate?
Change the assumptions to estimate hypothetical gross fees, not actual bank revenue.
J$20,000,000
J$240,000,000
Illustrative only. Assumes every modelled transaction attracts the fee. Excludes costs, taxes and exemptions.
Even Depositing Cash Can Cost Money
One commercial bank’s October 2026 personal banking schedule lists a cash-deposit fee of J$3.90 per J$1,000 for deposits exceeding J$1 million. The precise calculation and applicable exemptions should be confirmed directly with the institution.
Depending on the account and service, people handling legitimate money may pay to deposit it, move it or receive it. For a contractor, small business or family managing property payments, these costs matter.
A Million Is Not What It Used To Be
The published J$1 million POCA threshold has not increased since 2013, although inflation has changed its purchasing power. Materials, equipment, labour and renovation costs have all risen. A payment once considered exceptional may now be an ordinary business transaction.
There is also a separate J$1 million threshold within the ACH payment system; that banking-system rule should not be confused with POCA’s physical-cash restriction. Higher-value digital payments may involve different transfer methods and fees.
Reviewing the statutory threshold periodically would not mean abandoning money-laundering oversight. It would mean assessing whether the restriction remains proportionate.
What About Jamaicans Without Banks?
The Bank of Jamaica’s 2023 National Financial Inclusion Study reported a 77.2 per cent financial inclusion rate, leaving 22.8 per cent of adults without an account at a formal financial institution. These are 2023 survey findings, not a 2026 estimate.
Barriers to affordable, accessible digital payments can fall hardest on lower-income and rural communities. Cash remains important in informal commerce, agricultural trading and household services. Financial policy must account for those realities.
Who Really Benefits?
Government and investigators gain more traceable transactions. Businesses may benefit from lower cash-handling risks and more reliable records. Banks receive payment activity and some associated fees, but also bear operating costs. Consumers benefit from security while sometimes facing charges and access barriers.
Those gains and burdens are not necessarily shared equally.
The Question Jamaica Must Answer
Could Jamaica guarantee affordable basic digital payments? Should the cash threshold be reviewed against inflation? Should financial institutions report domestic transfer fees more transparently?
Protecting Jamaica from dirty money should never mean making ordinary people feel their clean money comes with a compulsory handling charge.
POCA serves a legitimate public purpose. But thirteen years after the cash restriction was introduced, its effect on ordinary Jamaicans deserves scrutiny.
Because the money belongs to the customer. The law belongs to the public. And the cost of obeying it deserves attention too.
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