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Discussion Points
•What is money laundering and how is it
committed?
•Why do criminals need to launder proceeds of
crime?
Fundamentals of Anti-Money •How may Covered Persons be abused for ML/TF?
•How can we detect and prevent money
Laundering/Counter-Terrorism launderers?
Financing (AML/CTF) •What are the preventive measures?
CAPACITY BUILDING TRAINING IN COMPLIANCE
WITH THE PROVISIONS OF THE AMLA

1 2

Money Laundering Defined

Money Unlawful Activity

Must be related to any of
Dirty Money
Laundering Transacts said monetary
instrument or property;
Converts, transfers,
disposes of, moves,
acquires,
possesses or uses said
monetary instrument or
property;
the 36 enumerated
predicate offenses under
Should always be the
related to the proceeds of
the AMLA, as amended an unlawful activity
–
is committed by any person Conceals or disguises the

who, knowing that any

monetary instrument or
true nature, source,
location, disposition,
movement or ownership of
or rights with respect to
said monetary instrument or
Attempts or conspires to
commit money laundering
offenses referred to
in paragraphs (a), (b) or (c);
Aids, abets, assists in or
counsels the commission of
the
Money Laundering
property;
property represents, involves,
or relates to the proceeds of Performs or fails to perform
Circumstances
any act as a result of which
Knowledge
any unlawful activity:
money laundering offenses
referred to in paragraphs (b) or (c) above; and
he facilitates the
offenses of money related to ML
(a), laundering referred to in If there is no knowledge,
paragraphs (a), (b) Usually related to the
(Sec. 4, AMLA, as amended) or (c) above. there is only civil liability
grounds for CTR/STR

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Stages of Money-Laundering Common Methods of Money

Laundering
The physical disposal of The separation of illicit Supplying apparent u Structuring and Smurfing
PLACEMENT

LAYERING

INTEGRATION
cash or other assets proceeds from their source legitimacy to illicit wealth
derived from criminal by layers of financial through the reentry of the
activity. During this phase, transactions intended to funds into the economy in u Bulk Cash Smuggling
the money launderer conceal the origin of the what appears to be normal
u Cash-intensive Business
introduces the illicit [Link] second business or personal
proceeds into the financial stage involves converting [Link] stage
system. the proceeds of the crime entails using laundered
Often, this is accomplished into another form and
creating complex layers of
proceeds in seemingly
normal transactions to u Shell or Shelf Corporations
by placing the funds into
circulation through formal financial transactions to create the perception of
financial institutions, obfuscate the source and
ownership of funds.
[Link] launderer,
for instance, might choose
u Credit Card Laundering
casinos and other to invest the funds in real
legitimate businesses, both
domestic and
estate, financial ventures u Gambling in Casinos
international. or luxury assets.

5 6

Terrorist Financing –
Differences and Similarities Between Terrorist Financing
TERRORISM FINANCING and Money Laundering
Is committed by any person:
Money Laundering Terrorism Financing
u who directly, or indirectly, willfully and without lawful excuse, possesses, provides, Definition The process of making large amounts of money generated by The financial support, in any
collects or uses property or funds or makes available property, funds or financial a criminal activity, such as drug trafficking or terrorist funding, form, of terrorism or of those
service or other related services, by any means appear to have come from a legitimate source who encourage, plan, or
ü Placement engage in terrorism
u with the unlawful and willful intention that they should be used or with the
ü Layering
knowledge that they are to be used, in full or in part:
ü Integration
(a) to carry out or facilitate the commission of any terrorist act; Objective To avoid detection To avoid detection
Motivation Lifestyle Politics, religion, ideology
(b) by a terrorist organization, association or group; or Amount of Usually large amounts Does not usually involve large
funds amounts
(c) by an individual terrorist
Sources of Criminal activities Criminal activities and
u who organizes or directs others to commit financing of terrorism under the funds legitimate sources
immediately preceding paragraph (of Section 4) Uses of funds To gain wealth and assets To execute terrorist activities

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Terrorist Financing- How do terrorists Financial Action Task Force (FATF)

raise, move and store funds?
The Financial Action Task Force (FATF) is an independent inter-
Legal Illegal
u
governmental body that develops and promotes policies to protect the
Sources Sources global financial system against money laundering, terrorist financing and
the financing of proliferation of weapons of massdestruction.
u The FATF Recommendations are recognized as the global anti- money
Purchasing/providing laundering (AML) and counter-terrorist financing (CFT) standard.
goods for services for
Fundraising or funds terrorism acts or u In its Forty (40) Recommendations, the Financial Action Task Force
through donors funding from other
terrorist groups
(FATF) requires countries to identify, assess, and understand ML/TF
risks, and to take action in mitigating those risks. FATF, an international
standard-setting body, develops and promotes policies to protect the
Procuring restricted global financial system against money laundering, terrorist financing, and
materials or goods;
Family Businesses committing criminal the financing of proliferation of weapons of mass destruction.
acts

9 10

Evolution of the Anti-Money Amendment under RA 11521

Laundering Act
SEC. 2. Declaration of Policy. – It is hereby declared the policy of the
State to protect and preserve the integrity and confidentiality of bank
RA 10927
RA 9194
RA 11521
July 29, 2017 RA 10365
accounts and to ensure that the Philippines shall not be used as a money
January 29, 2021,
RA 9160 March 23, RA 10167, March 7, 2013 laundering site for the proceeds of any unlawful activity. Consistent with
October 17, 2001, 2003,
July 6, 2012
Inclusion of
casinos its foreign policy, the State shall extend cooperation in transnational
Inclusion of Expanded
Only threshold
OGOs, Real (internet and
Covered investigations and prosecutions of persons involved in money laundering
Estate ship-based);
reporting, Freezing Persons (CPs), activities wherever committed, as well as in the implementation of
power given Ex-parte Developer and single casino
AMLC’s
petitions Brokers. Inclusion additional
executive freeze to courts, STR of tax crimes as
cash
transaction in predicate targeted financial sanctions related to the financing of the
now required a predicate crimes.
offense
excess of Php 5 proliferation of weapons of mass destruction terrorism, and financing
million
of terrorism, pursuant to the resolutions of the United Nations Council.

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Amendments under RA 11521 Amendments under RA 11521

(i) “Unlawful activity” refers to any act or omission or series or combination thereof
involving or having relation to the following:
u SEC. 3. Definitions. – For purposes of this Act, the following terms are
u hereby defined as follows: (34) Violation of Section 19 (a)(3) of Republic Act No. 10697, otherwise known as the
“Strategic Trade Management Act”, in relation to the proliferation of weapons of
mass destruction and its financing pursuant to United Nations Security Council
(a) “Covered Persons”, natural or juridical, refer to: Resolution Numbers 1718 of 2006 and 2231 of 2015;
(35) Violation of Section 254 of Chapter II, Title X of the National Internal Revenue
9) Real estate developers and brokers; and Code of 1997, as amended, where the deficiency basic tax due in the final assessment
is in excess of Twenty-five million pesos (P25,000,000.00) per taxable year, for each
tax type covered and there has been a finding of probable cause by the competent
10) Offshore gaming operators, as well as their service providers, authority: Provided, further That there must be a finding of fraud, willful
supervised, accredited or regulated by the Philippine misrepresentation or malicious intent on the part of the taxpayer: Provided,
Amusement and Gaming Corporation (PAGCOR) or any finally, That in no case shall the AMLC institute forfeiture proceedings to recover
government agency. monetary instruments, property or proceeds representing, involving, or relating to a
tax crime, if the same has already been recovered or collected by the Bureau of
Internal Revenue (BIR) in a separate proceeding;

13 14

Anti-Money Laundering Council COVERED PERSONS

Philippines’ central AML/CTF
authority and financial
intelligence unit, which is the
government instrumentality
mandated to implement the (a)Banks;
(b)Quasi-banks;
(a)Insurance companies;
(b)Pre-need companies;
(a)Securities dealers, brokers, salesmen,
investment houses, and other similar
AMLA and TFPSA. It also refers (c)Trust entities (c)Insurance agents; persons managing securities or rendering
to the official name of the (d)Pawnshops; (d)Insurance brokers; services, such as investment agents,
(e)Non-stock savings and loan (e)Professional reinsurers; advisors, or consultants;
Council, which is the governing associations; (f) Reinsurance brokers;
body of the said government (f) Other Non-bank financial institutions (g)Holding companies; (b)mutual funds or open-end investment
agency. For purposes of this which under special laws are subject to (h)Holding company systems; companies, close-end investment
BSP supervision and/or regulation; (i) Mutual benefit associations; and companies or issuers, and other similar
IRR, the government agency (g)Electronic money issuers; and (j) All other persons and their subsidiaries entities; and
shall be referred hereafter as (h)Foreign exchange dealers, and affiliates supervised or regulated by
the “AMLC”, while the money changers, and remittance the IC. (c)other entities, administering or
and transfer companies. otherwise dealing in commodities, or
governing body shall be financial derivatives based thereon,
referred hereafter as the valuable objects, cash substitutes, and
“Council”. other similar monetary instruments or
properties, supervised or regulated by
the SEC.

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Jewelry Dealers
What are
DNFBPs? Dealers in Precious Metals and
WHAT ARE MONEY LAUNDERER’S LOOKING FOR?
Precious Stones Trust and Company
Designated Non-Financial
Businesses and Professions”
Service Providers
(DNFBP) refer to businesses and
professions, which are not under
the supervision or regulation of Lawyers, accountants, and other
the BSP, SEC and IC, and
designated as covered persons
professionals Casinos
under the AMLA.
Real Estate Brokers and Developers 3. Non-reporting
1. Anonymity 2. “Paperless
Transaction” requirement
Offshore Gaming Operators, as well
as their Service Providers

17 18

Preventive Measures Risk Management

(Philippines Setting)
u Risk Profiling / Scoring
u On-going Monitoring of customers
u Covered Transaction Reporting (CTR)
u Suspicious Transaction Reporting (STR)
u Training Programs
u Record Keeping
Customer Due Diligence Record-Keeping Transaction Reporting

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Customer Due Diligence Customer Due Diligence

“KNOW YOUR CUSTOMER” (KYC) “KNOW YOUR CUSTOMER” (KYC)
u CDD Measures [Section 2.1, Rule18, 2018IRR] u Existing Customers [Section 1.3, Rule 18, 2018 IRR]

(a) Customer Identification Process (CIP)

Apply CDD requirements to existing customers on the basis of materiality
(b) Customer Verification Process (CVP)
(c) Identification and Verification of Agents (IVA) and risk, taking into account whether and when CDD measures have previously
been undertaken and the adequacy of information and document obtained.
(d) Beneficial Ownership Verification (BOV)
(e) Determination of the Purpose of Relationship (DPR) u Customer Acceptance Policies [Section 2.4, Rule 18, 2018 IRR]
(f) Ongoing Monitoring Process (OMP) Have clear, written and graduated customer acceptance policies that
will seek to prevent suspicious individuals or entities from transacting
u Timing [Section 2.2, Rule18, 2018IRR]
with, or establishing or maintaining business relationship.
u May be conducted simultaneously, consecutively, or at such timing and
frequency as the covered person may determine to be appropriate, u Develop guidelines to assist their responsible officers in assessing
depending on the risks involved. whether a customer’s profile warrants acceptance or refusal of service
to protect the security and integrity of the business.

21 22

Customer Due Diligence Customer Due Diligence

“KNOW YOUR CUSTOMER” (KYC) “KNOW YOUR CUSTOMER” (KYC)
u Customer Identification Program (CIP)– To identify and u Required Identification Information (Natural Persons)
(Section 3.4, Rule 18, 2018 IRR)
record the true identityof their customers. [Section
3, Rule 18, 2018 IRR]
(1) Full name;
u FirstTimeTransactions: [Section 3.2, Rule 18, 2018 IRR] (2) Date of birth;
(3) Place of birth;
• First time customers shall be required to present the original and submit (4) Sex;
aclear copy of, at least, one (1) ID.
(5) Citizenship or nationality;
• If the ID presented does not bear any photo of the customer, or (6) Address;
the photo-bearing ID or a copy thereof does not clearly show the
face of the customer, a covered person may utilize ICT or any other (7) Contact number or information, if any; and
technology to take the photo of the customer. (8) Specimen signatures or biometric information.

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Customer Due Diligence Customer Due Diligence

“KNOW YOUR CUSTOMER” (KYC) “KNOW YOUR CUSTOMER” (KYC)
u “Identification Document” [Section 1(qq), Rule 2, 2018 IRR] u Required Identification
u Required Identification Documents(Juridical Persons)
For Filipino citizens: (a) PhilID; (b) other IDs issued by the government; and (c) Information (Juridical Persons) (Section 3.4, Rule 18, 2018 IRR)
other IDs that can be verified using reliable, independent source documents, (Section 3.4, Rule 18, 2018 IRR)
(1) DTI/BSP/AMLC
data or information. Certificates of Registration,
(1) Full name; or Certificate of
Incorporation or Partnership.
(2) Nameof authorized
For foreign nationals: (a) PhilID, for resident aliens; (b) Passport; (c) Alien representative, transactor or (2) Articles of
signer; Incorporation/Partners
Certificate of Registration; and (d) other IDs issued by the government. hip;
(3) Current office address;
For Filipino students: (a) PhilID; (b) School ID signed by the school principal or head (3) Registration DataSheet/Latest
(4) Contact number or information, General Information Sheet;
of the educational institution; and (c) Birth Certificate issued by the Philippine if any;
Statistics Authority; and (4) Secretary’s Certificate (Re:Signing
(5) Nature of business;and Authority); and
(6) Specimensignatures or biometric (5) Forentities registered outside of
For low risk customers: Any document or information reduced in writing which information of the authorized the Philippines, similar documents
representative/transactor/signer. and/or information
the covered person deems sufficient to establish the client’s identity.

25 26

Risk Based Approach to Customer Politically Exposed Persons (PEP)*

Due Diligence
u Politically-Exposed Persons (PEPs)
u RISK-BASEDAPPROACH(RBA)TOCDD. [Section 9.1, Rule 18, 2018 IRR] • An individual who is or has been
entrusted with prominent public position
in (a) the Philippines with substantial
• In conducting CDD, a risk-based approach shall beundertaken. authority over policy, operations or the
use or allocation of government-owned
• To assess customers to determine who are likely to poselow, normal, or resources;
high risk u (b) aforeign State; or (c) an international
organization. [Section 1(xxx), Rule 2, 2018 IRR]
• To set the standards in applying Reduced Due Diligence (RDD), • Covered persons shall establish and record
Average Due Diligence (ADD), and Enhanced Due Diligence (EDD) the true and full identity of PEPs, as well as
including a set of conditions for continuance or discontinuance of their immediate family members and “Not all PEPs are high risk”
business relationship. close relationships /associates. [Section 1,
Rule 19, 2018 IRR]

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Designated Covered Transaction Report (CTR)

Persons or Entity
Timing of Reporting:
A designated person is an individual, A transaction (in cash Within five (5) working
entity, or organization that has been or equivalent Covered Transaction days from the date of
officially identified by the United Nations, monetary instrument) Report occurrence(unless the
a recognized jurisdiction, or by a where the amount is AMLC prescribes a
in excess of the (CTR) different period
national authority for being a terrorist, a
financer of terrorism, a terrorist group, or threshold. not exceeding 15
an individual whose funds are subject to working days)
seizure due to involvement in terrorism-
related activities. These designations GENERAL RULE SPECIFIC RULE
trigger targeted financial
Transaction in cash or other equivalent Acasino cash transaction exceeding
sanctions, such as asset freezes, under
monetary instrument Php5,000,000.00 or its equivalent in
the anti-money laundering and counter-
terrorist financing framework. exceeding Php500,000.00 other currency.

29 30

Suspicious Transaction Report Covered Transaction also a Suspicious

Transaction
[Section 1.2, Rule 22, 2018 IRR]
- No underlying legal
or trade obligation,
purpose or economic - Structuring
In cases where the transaction breached the Php 500,000.00
justification - Deviates from threshold and there are suspicious circumstances, report first as a
- Amount not
commensurate with
client’s profile and/or
the past transactions Timing of Reporting: CTR, subject to updating if it is finally confirmed to be reportable
client’s business or
financial capacity
as STR.
Within the next working
STR day from date of
Form and Quality of Report [Section 3, Rule 22, 2018
IRR]
Related to an unlawful occurrence (discovery) • Complete
- Client not properly
identified
activity, or any money
laundering activity or
• Accurate
- Similar or analogous offense is about to be, • Timely
circumstances is being or has been
committed

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Safe Harbor Provision

uNo administrative, criminal or civil proceedings shall lie against
any person for having made a CTR or an STR in the regular
performance of his duties and in good faith, whether or not
such reporting results in any criminal prosecution under the AMLA
MALICOUS REPORTING IS A or any other Philippine law.
uDO NOT BE AFRAID TO FILE CTR AND STR!

CRIMINAL OFFENSE! uFiling CTRs and STRs is an exception to the Data Privacy Act
uCTR and STRs are not necessarily proof that the customer is
involved in unlawful activity. It only serves as triggers for possible
[6 months – 4 years imprisonment, investigation.

P100,000 – P500,000 NON-REPORTING OF CTRAND STR IS A

No probation] CRIMINAL OFFENSE!
[6 month – 4 years imprisonment,
P100,000 – P500,000 fine, or
both]

33 34

Confidentiality of Reports Registration for Purposes of

u Covered persons, and their officers and employees, are
prohibited from communicating, directly or indirectly, in
Reporting
any manner or by any means, to any person or entity, or the
media, the fact that a CTR or STR has been or is about to be u Section 52. Period of Registration with the AMLC. – For new
filed, the contents of the report, or any other covered persons and existing DNFBPs, as defined herein, who
information in relation thereto. Any information about have not yet registered, they shall register with the AMLC within a
such reporting shall not be published or aired, in any period of 6 months within the effectivity of these guidelines. In
manner or form, by the mass media, or through electronic case of newly established DNFBPs, registration must be done
mail, or other similar devices. prior to commencement of its operations as a DNFBP.

BREACH OF CONFIDENTIALITY IS A CRIMINAL OFFENSE!

[3 – 8 year imprisonment,
P500,000 – P1,000,000]

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MTPP: Continuing Education and Record Keeping

Training Program • To maintain and safely store for five (5) years from the dates of
transactions all customer records and transaction documents. [Section 1, Rule
20, 2018 IRR]
• Develop, or create opportunities for,
• To keep all records obtained through CDD, account files and business
continuing education and training programs to correspondence, and the results of any analysis undertaken, for, at least,
five (5) years following the closure of account, termination of the business
promote AML/CTF awareness and strong or professional relationship or after the date of the occasional transaction.
compliance culture. [Rule 16, Section 4.1, 2018 IRR] [Section 2, Rule 20, 2018 IRR]

• Refresher programs, at least, every three (3) years. • If a case has been filed in court involving the account, to retain and safely
keep beyond the five (5)-year period, until it is officially confirmed by the
[Rule 16, Section 4.4, 2018 IRR] AMLC that the case has been resolved, decided or terminated with finality.
[Section 3, Rule 20, 2018 IRR]
• MTPP Updating must be done at least, once every
FAILURE TO KEEP RECORDS IS A CRIMINAL OFFENSE
two years. (6 months – 1 year imprisonment,
P100,000 – 500,000 fine, or both)

37 38

Guidelines on the Digitization of Guidelines on the Digitization of

Customer Records (DIGICUR) Customer Records (DIGICUR)
u Digitize all customer records – including “look back” to records prior to u Quality – complete, accurate, timely, and secured so as to be of use in
implementation period – exclude closed accounts beyond the 5-year
retention period; does not apply to Money Service Business (MSB) AMLC investigations.
operations, except when the business model allows electronic wallet. u Final Deadline – 30 September 2022 covers all prior and subsequent requests
for extensions.
u Maintain a central database – maintained in head offices; compliance officer
given direct and immediate access u Quarterly DIGICUR Status Report of Compliance (QUADSREC) – to be
u Submissions to AMLC – via AMLC’s File Transfer and Reporting Facility submitted within 15 calendar days after each quarter, except the first report shall be
submitted on or before 31October 2021.
u (FTRF), or in such other forms asrequired (i.e. certified true copy)
Ø Failure to submit QUADSREC - Serious Violation under the Rules of
u Quality – complete, accurate, timely, and secured so as to be of use in AMLC Procedure in Administrative Cases (RPAC) with penalties from Php15,000
investigations.
to Php150,000 per customer.
u Implementation – start within 6 months from effectivity (13 October 2018); u Non-Compliance with DIGICUR – Grave Violation under the RPAC with penalties
within 2 years after the end of the 6-month period to implement, all customer from Php37,500 to Php375,000 per customer.
records should be completely digitized.

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Risk Management in Philippines INSTITUTIONAL RISK

Setting MANAGEMENT
u The board of directors of the covered person shall exercise active control
u Covered persons shall, comply with all the and supervision in the formulation and implementation of
institutional risk management. They shall be ultimately responsible for the
requirements under the AMLA and TFPSA, their covered person’s compliance with the AMLA and TFPSA, their respective
respective IRR, and other AMLC issuances. They shall IRR, and other AMLCissuances. [Rule 15, Section 2.1, 2018 IRR]
u Covered persons shall develop sound risk management policies, controls
have the duty to cooperate with the AMLC in the,
and procedures which are approved by the board of directors to enable
discharge of the latter’s mandate, and execution them to manage and mitigate the risks that have been identified in the NRA, or
of its lawful orders and issuances, to protect their by the AMLC, SAs or the covered person itself. [Rule 15, Section 2.2(a), 2018 IRR]

businesses or professions from being used in ML/TF

activities. (Rule 4, Section 2.1, 2018 IRR)

41 42

Money Laundering/Terrorism Financing Legal Remedies under the RA 9160

Prevention Program (MTPP) as amended
u The MTPP shall be in writing and shall include, at the minimum, internal policies,
controls and procedures on the following: u Prosecution of Money Laundering (ML) and Predicate
(a) Risk management; Offenses
(b) Compliance management setup; 1. Any person may be charged with and convicted of both the
(c) Screening procedures to ensure high standards when hiring employees; offense of money laundering (subject offense) and
(d) Continuing education and training program; the unlawful activity (predicate offense)
(e) Independent audit function; 2. Any proceeding relating to the unlawful activity shall
(f) Details of implementation of preventive measures; be given precedence over the prosecution of any offense or
(g) Compliance with freeze, bank inquiry and asset preservation orders, and all violation under R.A. No. 9160 without prejudice to the freezing
directives of the AMLC; and other legal remedies.
(h) Adequate safeguards on the confidentiality and use of information exchange;
(i) Cooperation with the AMLC and SAs. [Rule 16, Section 1, 2018 IRR]

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u Bank Inquiry Authority

• With Court Order (Court of Appeals): u Freeze Orders
AMLC may apply ex parte for bank inquiry into
o
• Ex parte petition with the Court of Appeals (CA):
deposits related to unlawful activities (other than o CA may issue a Freeze Order valid for 20 days.
terrorism, drugs, KFR). o Within 20 days, CA holds a summary hearing to decide
CA must act within 24 hours.
o whether to lift or extend the order (up to 6 months).
• Without Court Order: • Covers related accounts: Accounts determined to be
AMLC may conduct inquiries directly if related to:
o
linked or materially connected to those subject to the
Kidnapping for Ransom (KFR)
§
freeze.
Temporary Restraining Orders (TROs): Not allowed, except
Dangerous Drugs Act violations
•

by the Supreme Court (or CA in Terrorism Financing cases).

§

Terrorism financing
§

45 46

u Civil Forfeiture (Non-Conviction Based Asset

Recovery) u Sanctions Freeze Orders (ATC Designations
Filed with the Regional Trial Court (RTC).
under Anti-Terrorism Act)
•

• Standard of proof = preponderance of evidence (not proof beyond

reasonable doubt). • Triggered by Anti-Terrorism Council (ATC) designation.
• Forfeited assets may be: • AMLC issues immediate freeze orders on assets of
o turned over to the National Government, or designated individuals/entities.
o returned to victims, depending on the circumstances. • Freeze without delay — to prevent dissipation of assets.
u Sub-measures:
• Obligations of Covered Persons:
• Provisional Asset Preservation Order (PAPO):
o Prevents disposal or transfer of property during proceedings. o Immediately freeze assets of designated or potential
o RTC holds summary hearing within 20 days. matches.
• Asset Preservation Order (APO): o Report to AMLC within 24 hours.
o Effective until final judgment. o File related Suspicious Transaction Reports (STRs).
o Maintains status quo of the property.

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What is money laundering and how is it committed?

Why do criminals need to launder proceeds of crime?
How may Covered Persons be abused for ML/TF? THANK YOU!
How can we detect and prevent money launderers?
What are the preventive measures?

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