Financial Crime World

Philippines Amends Financial Crime Reporting Procedures to Enhance Compliance and Prevention of Money Laundering and Terrorism Financing

The Anti-Money Laundering Council (AMLC) has issued a revised set of guidelines for financial institutions and other covered persons to report suspicious transactions, aimed at strengthening the country’s anti-money laundering and terrorism financing regime.

Key Changes

  • A more comprehensive definition of “covered persons” to include certain designated non-financial businesses and professions.
  • Real estate developers and brokers are now required to define “covered transactions” for their industry.
  • The Executive Director of AMLC is granted authority to require submission of all covered transactions, including low-risk ones, from individuals under investigation.
  • Financial institutions must include specific details of their reporting chain and process in their Money Laundering/Terrorism Financing Prevention Program.

Reporting Requirements

  • Clarification of rules regarding the timing of submission of suspicious transaction reports (STRs), including identification of applicable reporting and determination periods.
  • Non-working and non-reporting days are now taken into account when counting the prescribed reporting period, with automatic suspension if necessary.
  • Loan payment is no longer considered a low-risk transaction.

Low-Risk Transactions

  • A list of low-risk covered transactions involving Operators of Payment Systems has been provided.
  • Previously approved low-risk transactions involving money service businesses (MSBs) have been incorporated into the new guidelines.

Compliance and Administrative Sanctions

  • New provisions on compliance-checking and administrative sanctions have been introduced.
  • Updated online registration guidelines have been provided, along with a list of “red flags” and transaction codes for real estate transactions and virtual asset service providers.

Additional Changes

  • Changes to country and currency codes have been made.
  • Two new predicate crimes that must be reported have been added.
  • The reporting of loan availment and sale of real and other properties acquired has been updated, with specific guidelines provided for suspicious transaction reporting on a per account basis.

Resources

The AMLC Registration and Reporting Guidelines (ARRG) can be downloaded from the council’s website.