THE 2017-2018 Annual: Sustainable Transformation

THE
2017-2018
ANNUAL
REPORT
SUSTAINABLE
TRANSFORMATION
PHILIPPINES
Requests for permission to reproduce all or part of this
publication should be made to
The AMLC Secretariat

Telephone +63 2 306 3083
E-mail secretariat@amlc.gov.ph
Website amlc.gov.ph
© 2018 Anti-Money Laundering Council

THE
2017-2018
ANNUAL
REPORT
SUSTAINABLE
TRANSFORMATION
PHILIPPINES
To be a world-class financial intelligence unit that will
help establish and maintain an internationally compliant
and effective anti-money laundering regime, which will
provide the Filipino people with a sound, dynamic, and
strong financial system in an environment conducive to the
promotion of social justice, political stability, and sustainable
economic growth. Toward this goal, the AMLC shall, without
fear or favor, investigate and cause the prosecution of money
laundering and terrorism financing offenses.
To protect and preserve the integrity and confidentiality of

bank accounts
To ensure that the Philippines shall not be used as a money

laundering site for proceeds of any unlawful activity
To extend cooperation in transnational investigation and

prosecution of persons involved in money laundering
activities, wherever committed
IN MEMORIAM
The Anti-Money Laundering Council (AMLC) and its
Secretariat dedicate the 2017-2018 Annual Report
to former AMLC Chairman and Bangko Sentral ng
Pilipinas (BSP) Governor, Nestor A. Espenilla Jr.
A
ppointed head of the the 2018 Implementing Rules and
country’s central bank by Regulations (2018 IRR).
President Rodrigo Roa
Duterte on 3 July 2017, Other milestones under Chairman
Chairman Espenilla was the ex officio Espenilla’s guidance were the
Chairman of the AMLC, the Philippine approval of the Second National Risk
International Convention Center Assessment (NRA) Report, which
(PICC), and the Financial Stability evaluated the overall threat and
Coordination Council (FSCC). effectiveness of the country’s AML/CTF
regime, covering the years 2015 and
Under Chairman Espenilla’s 2016; and the approval of the National CHAIRMAN OF
leadership, the AMLC saw the Anti-Money Laundering and Countering THE ANTI-MONEY LAUNDERING COUNCIL
passage of Republic Act (RA) the Financing of Terrorism Strategy NESTOR A. ESPENILLA JR.
2018-2022 (NACS). Largely driven by 1958-2019
No.10927 or “An Act Designating
Casinos as Covered Persons under the Second NRA, the NACS lays out
RA No.9160, otherwise known as seven concrete objectives, ranging
the Anti-Money Laundering Act from the enhancement of Philippine
of 2001 (AMLA), as amended,” laws and regulations; strengthening
placing casinos as covered persons the AMLC’s investigations and
under the AMLA. Subsequently, the prosecutions; coordination among
AMLC, together with the Philippine government agencies; development
Amusement and Gaming Corporation of mechanisms to deter ML and TF;
(PAGCOR), the Aurora Pacific improved supervision of covered
Economic Zone and Freeport persons; international cooperation; and
(APECO), and the Cagayan information dissemination to combat
Economic Zone Authority (CEZA), ML and TF.
signed the Casino Implementing
Rules and Regulations (CIRR) of RA As a visionary manager and leader
No.10927, to prevent the Philippine with a fervent belief in leveraging
casino industry from becoming a technology, Chairman Espenilla also
venue for money laundering (ML) and spearheaded the AMLC Secretariat’s
terrorism financing (TF). administrative reorganization,
which more than doubled the staff
As an experienced and learned complement, and the acquisition and
policymaker, Chairman Espenilla operationalization of a data-mining
oversaw the adoption of significant system, which improved the quality of
regulations, such as the AMLC data-gathering, retrieval, and analysis.
Registration and Reporting These initiatives have enabled the
Guidelines (ARRG) and its AMLC to cope with the growing
amendments as well as the ARRG complexity and increasing number of
for Casinos (ARRGC) to ensure financial transactions and crimes.
proper and timely compliance with
reporting procedures; the Guidelines Chairman Espenilla passed away
on Digitization of Customer Records on 23 February 2019. He was 60
(DIGICUR Guidelines); the Anti- years old.
Money Laundering/Counter-Terrorism
Financing (AML/CTF) Guidelines Leading by example, Chairman
for Designated Non-Financial Espenilla serves as an inspiration
Businesses and Professions (DNFBP to all civil servants, and to him, the
Guidelines); the Guidelines on AMLC and its Secretariat will always IMAGE
Identifying Beneficial Ownership; and be grateful.  CORPORATE AFFAIRS OFFICE,
BANGKO SENTRAL NG PILIPINAS
ACKNOWLEDGMENTS
AMANDO M. TETANGCO JR. ATTY. TERESITA J. HERBOSA

Chairman Member
Anti-Money Laundering Council Anti-Money Laundering Council
July 2005 – July 2017 May 2011 – March 2018
Former Chairman Tetangco served as As the former Chairperson of the

the third Governor of the BSP and Securities and Exchange Commission
ex officio Chairman of the AMLC (SEC), Atty. Herbosa served as a
for two consecutive six-year terms Member of the AMLC. With over 30
from 2005 to 2017. Global Finance years of private law practice, she
magazine hailed him as one of the has implemented several significant
world’s top central bankers, having projects at the SEC, including the
earned the “A” rating eight times. Prior automation of public services and
to his appointment as Governor, he its internal operations, since her
was the Deputy Governor in charge appointment as Chairperson in 2011.
of the Banking Services Sector, Though her seven-year term ended
Economic Research, and Treasury. on 11 March 2018, she continued
to serve in a holdover capacity until
Before joining the then-Central Bank June 2018.
of the Philippines in 1974, he worked
at the accounting firm, SGV & Co. Atty. Herbosa finished her Bachelor
Chairman Tetangco finished AB of Arts and Bachelor of Laws degrees
Economics at the Ateneo de Manila from the University of the Philippines,
University, where he graduated cum graduating cum laude both times. She
laude. As a central bank scholar, obtained her Master of Comparative
he completed a Master of Arts Law degree from the University of
degree in Public Policy and Michigan Law School in Ann Arbor,
Administration at the University of Michigan, USA.
Wisconsin-Madison, USA.
CONTENTS
Benjamin E. Diokno, PhD Atty. Emilio B. Aquino About the

Chairman Member Anti-Money Laundering Council
Governor Chairman
Bangko Sentral ng Pilipinas Securities and Exchange Commission
Atty. Dennis B. Funa Atty. Mel Georgie B. Racela

Member Executive Director
Anti-Money Laundering Council AMLC Secretariat
Commissioner
Insurance Commission
12
2017-2018 by the Numbers
14
About the AMLC Secretariat
SUSTAINABLE TRANSFORMATION TOWARD…
18
A Fully Functional Financial
Intelligence Unit
30
A Reliable Partner in Law
Enforcement, Prosecution, and
40
An Efficient Supervisor
Asset Forfeiture
48
Second National Risk
52
National Anti-Money Laundering
54
Third Mutual Evaluation
Assessment on Money and Countering the Financing of of the Philippines
Laundering and Terrorism Strategy
Terrorist Financing
56
Acronyms
58
Glossary
THE COUNCIL
BENJAMIN E. DIOKNO, PhD ATTY. DENNIS B. FUNA

Chairman Member
Governor Commissioner
Bangko Sentral ng Pilipinas Insurance Commission
Prior to his appointment as BSP Governor, Chairman In December 2016, Atty. Funa was appointed Insurance
Diokno has had extensive experience in implementing Commissioner by President Duterte. Commissioner
reforms in the public sector. He pursued an Funa was formerly the managing partner of a local law
expansionary fiscal policy to finance investments in firm and a law professor at the De La Salle University
human capital development and public infrastructure College of Law and San Beda Alabang School of Law.
as the Secretary of the Department of Budget and
Management. His policy expertise and research At age 28, he was the youngest presidential
contribution extend to various areas of public economics, appointee of then President Fidel V. Ramos, upon
such as the structure and scope of government, tax being appointed Executive Director of the Videogram
policies and reforms, public expenditure management Regulatory Board. Commissioner Funa was
analysis, fiscal decentralization, national budget, and commended by Kongreso ng Mamamayang Pilipino in
public debt, among other topics. 2001 for his socio-political contribution to the country.
Some of the major policy reform contributions In 1997, Commissioner Funa was a scholar at the
of Chairman Diokno include providing technical London-based International Bar Association in its
assistance to the 1986 Tax Reform Program to simplify Biennial Conference in New Delhi, India; and in 1999,
the income tax system and introduce the value-added he was a scholar of the Association for Overseas
tax; helping design the 1991 Local Government Code Technical Scholarships in Tokyo, Japan.
of the Philippines; initiating a What-You-See-Is-What-
You-Get policy to streamline the release of funds; and He was a Commissioner in the Commission on Bar
sponsoring the Government Procurement Reform Act Discipline of the Integrated Bar of the Philippines (IBP),
to modernize, regulate, and standardize government serving from 2002 to 2011. IBP named him the “Most
procurement activities in the Philippines. Outstanding Commissioner.” He was the National
Director for Bar Discipline of the Integrated Bar of the
Chairman Diokno, Professor Emeritus of the University Philippines in 2012.
of the Philippines-Diliman, taught various courses in
economics for over 40 years. He also served as Fiscal Commissioner Funa is a member of the Philippine Bar
Adviser to the Philippine Senate; Chairman and CEO of Association and the International Law Society of the
the Philippine National Oil Company; and Chairman of Philippines, and he has authored 10 law books.
the Local Water Utilities Administration.
8 2017-2018 ANNUAL REPORT

THE SECRETARIAT
ATTY. EMILIO B. AQUINO, ATTY. MEL GEORGIE B. RACELA,

CPA, MPM, CSEE CPA, LLM
Member Executive Director
Anti-Money Laundering Council Anti-Money Laundering Council Secretariat
Chairperson
Securities and Exchange Commission
SEC Chairperson Aquino has a record of 14 years As head of the operational arm of the AMLC, Executive
in progressively responsible positions of trust. Director Racela executed the Chairman’s vision and
Concurrently, he is the Chairperson of the government- ensured that reforms are sustainable in the next
owned Credit Information Corporation and Chairperson generation of the Secretariat’s analysts, investigators,
of the Microfinance NGO Regulatory Council. prosecutors, supervisors, and strong support staff. To
institutionalize the reforms, he spearheaded the Quality
SEC Chairperson Aquino has a proven history of Management System (QMS) in 2017.
success and integrity in the administrative management
of two SEC Head Office Operating Departments, Executive Director Racela led legislative and regulatory
and two Regional Extension Offices (Davao and framework developments, which filled the critical gaps in
Zamboanga) and has been highly regarded for his fast the country’s AML/CTF defense, such as RA No.10927,
output on critical concerns of the Commission. otherwise known as “An Act Designating Casinos as
Covered Persons under RA No.9160, as amended;”
He served as the Supervising Commissioner on CIRR; Rules on the Imposition of Administrative
Enforcement, Human Resources, and Administration; Sanctions (RIAS) under RA No.9160, as amended;
and as the youngest director of the SEC’s former ARRG; ARRGC; DNFBP Guidelines; and DIGICUR
Prosecution and Enforcement and Non-Traditional Guidelines. Further, under his supervision were the
Securities and Instruments Departments. While approval of the Second NRA and the NACS.
practicing public accountancy and law, he also
taught commercial law at Ateneo de Zamboanga Prior to his appointment as Executive Director of
University and Western Mindanao State University the Secretariat, Atty. Racela honed his leadership,
for over a decade. management, and policy-making expertise as head
of the Anti-Money Laundering Specialist Group of the
In 1984, he graduated magna cum laude and Office of Supervisory Policy Development, Supervision
valedictorian at the University of Zamboanga with and Examination Sector of the BSP.
a Bachelor of Science degree in Commerce, major
in Accounting. He received a rating of 89.14% in He holds a Master of Laws degree in International
the Certified Public Accountant (CPA) Licensure Legal Studies from Georgetown University Law Center
Examination. He completed his law studies at San in Washington, DC, USA, where he graduated as a
Beda College and placed 16th in the 1992 bar exams. Dean’s Lister.
2017-2018 ANNUAL REPORT 9

THE ANTI-MONEY
LAUNDERING COUNCIL
I
n line with the policy of the State The AMLC is composed of the
to protect and preserve the Governor of the BSP as Chairman,
integrity and confidentiality of bank and the Commissioner of the
accounts, and to ensure that the Insurance Commission (IC) and the
Philippines shall not be used as an ML Chairperson of the SEC as Members.
site for the proceeds of any unlawful The Chairman and Members act
activity, the AMLC was created by unanimously in the discharge of
virtue of RA No.9160, otherwise known AMLC’s functions.
as the AMLA, as amended.
The AMLC is a hybrid-type of financial
The AMLC’s main task is to intelligence unit (FIU) because in
implement the AMLA, as amended addition to the core functions of
by RA Nos.9194, 10167, 10365, an FIU, such as receipt, analysis,
10927; and RA No.10168, otherwise and dissemination of suspicious
known as the Terrorism Financing transaction and other reports, it
Prevention and Suppression Act performs investigative, prosecutorial,
of 2012 (TFPSA). The AMLC is and supervisory functions.
mandated to assist in transnational
investigations and prosecutions The AMLC is assisted by a
of persons involved in ML and TF Secretariat, which is headed by an
activities wherever committed. Executive Director. 
CORE FUNCTIONS Examine any particular deposit or Apply before the Court of Appeals
investment with any banking or (CA), ex parte, for the freezing of any
Financial Intelligence Analysis non-bank financial institution, where monetary instrument or property
Require and receive covered (CTRs) or probable cause exists that the deposits alleged to be the proceeds of any
suspicious transaction reports (STRs) or investments are related to an unlawful activity as defined in the
from covered persons. unlawful activity AMLA, as amended
Probe into suspicious transactions or Identify properties, documents, and Apply for bank inquiry and/or examination
covered transactions deemed suspicious flow of financial transactions in relation
to ML and TF Supervision
Investigation Implement measures to counteract ML
Investigate ML and TF activities, Prosecution and TF
and other violations of the AMLA, Institute civil forfeiture proceedings
as amended and all other remedial proceedings Ensure compliance of covered persons
through the Office of the Solicitor with the AMLA, as amended
Enlist the assistance of any branch, General (OSG)
department, bureau, office, agency, Handle the disposition of
or instrumentality of the government, File complaints with the Department administrative cases
including government-owned and of Justice (DOJ) or the Office of the
-controlled corporations, in undertaking Ombudsman (OMB) for the prosecution Develop educational AML/CTF programs
AML/CTF operations of ML offenses

THE ANTI-MONEY LAUNDERING COUNCIL
AN
OVERVIEW
OF A
HYBRID
FIU
AS A RELIABLE
PARTNER IN LAW
AS A FULLY ENFORCEMENT,
FUNCTIONAL PROSECUTION,
FIU AND ASSET
Receipt, analysis, FORFEITURE
and dissemination Investigation
Prosecution
Forfeiture
AS AN EFFICIENT
SUPERVISOR
Policies
AML/CTF awareness

FINANCIAL INTELLIGENCE ANALYSIS
528 83 million
requests for information (RFIs) CTRs
569
reactive financial
from law enforcement agencies intelligence briefs
(LEAs) and other sources
173
Egmont Secure Web
779
STRs
thousand 51
proactive financial
(ESW) RFIs received intelligence reports
10
Mutual Legal Assistance
(MLA) RFIs
2017
TURNOVER OF FORFEITED ASSETS
TO THE BUREAU OF TREASURY (BTR)
2018 Php 48.856

BY THE
million
worth of cash and bank assets
NUMBERS +7 -hectare land

in Pangasinan
INVESTIGATION AND PROSECUTION
148 investigation reports Php 1,009,116,707

31 applications for bank inquiry worth of assets subject to civil forfeiture
+ 14 real properties
Php 1,718,386,789 5 watercrafts
worth of frozen assets 59 vehicles
+ 41 vehicles 8 motorcycles
17 firearms 25 firearms
insurance policies
insurance policies
2 ML cases filed with the Regional
Trial Court (RTC)
10 ML complaints filed with
DOJ and OMB

SUPERVISION
16
policies issued
CAPACITY-BUILDING
financial technical
intelligence assistance
registered designated analysis and grants for
non-financial investigation AMLC
businesses and trainings officers
professions (DNFBPs)
ARRG
31
reports of compliance
trainings
for covered
(ROCs) on banks for late persons
filing of CTRs
AML/CTF caravan
lectures for
covered persons regulatory workshops
AML/CTF manuals
BUDGET UTILIZATION
0.53%
ADVERTISING
3.18%
TRAINING
2.00%
SUBSCRIPTION
(PERIODICALS, INTERNET)
58.91%
INFORMATION AND
COMMUNICATIONS
TECHNOLOGY (ICT)
20.57%
OTHERS
(LEGAL SERVICES, OFFICE EQUIPMENT,
INSURANCE, UTILITIES, ETC.)
14.81%
UNUTILIZED

THE AMLC SECRETARIAT:
INTEGRATED AND UPGRADED
T
he AMLA, as amended, Also, they must have served for at least Commitments and Policy Group
authorized the AMLC to five years at the IC, SEC, or BSP. • Maintains and monitors
create a Secretariat to assist the country’s compliance
it in fulfilling its vision and To further strengthen a hybrid- with international
mission and in undertaking its AML/ type organizational structure AML/CTF standards
CTF operations. and to adequately manage and • Facilitates the execution and
monitor the level and direction of monitors the implementation of
The AMLC shall appoint an ML and TF risks in coordination memoranda of understanding
Executive Director to head the with various stakeholders, the (MOUs) with foreign FIUs
Secretariat for a term of five years. Secretariat underwent a two-phase • Manages the conduct of
The Executive Director must be a reorganization in 2017 and 2018, national risk assessments
member of the Philippine Bar, at constituting crucial units, such as and monitors the status of
least 35 years of age, and of good the Compliance and Supervision the resulting action plans
moral character, unquestionable Group, and employing more analysts, • Develops and adopts AML/
integrity, and known probity. investigators, and lawyers. The CTF policies, procedures,
Secretariat’s staff complement and guidance based on ML
All members of the Secretariat hold full- increased by 133%, that is, from 109 and TF trends and standards
time permanent positions at the BSP. to 254 plantilla positions. • Conducts and manages
AML/CTF public information
and awareness programs
Counseling, Adjudication, and

Mutual Legal Assistance Unit
• Renders legal opinion and
legal advisory services,
2017 relating to the interpretation
of the provisions of the
AMLA, TFPSA, and other
OFFICE relevant laws and rules
OF THE • Handles MLA requests to
EXECUTIVE and from foreign jurisdictions
DIRECTOR
• Adjudicates administrative/
compliance cases against
covered persons
DETECTION AND PREVENTION

TECHNICAL ADMINISTRATIVE
AND FINANCIAL DEPARTMENT
SERVICES • Collects, evaluates, and
STAFF SERVICES
DIVISION analyzes financial information
on potential ML and TF; and
disseminates the same to
authorized end-users
• Provides financial intelligence
INFORMATION to LEAs, foreign FIUs, and
LEGAL COMPLIANCE MANAGEMENT other AMLC Secretariat units to
SERVICES AND AND
INVESTIGATION support and assist investigations
STAFF ANALYSIS
GROUP GROUP • Ensures compliance of covered
persons with the AMLA, as
amended, by conducting
regular onsite examination of
covered persons not under
other supervising authorities;
targeted onsite examination of
covered persons with possible
compliance violations; and offsite
supervision of covered persons
• Supervises DNFBPs
THE AMLC SECRETARIAT
2018 ORGANIZATIONAL CHART

Office of the Executive Director AMLC
• Exercises general
supervision and control Enterprise Security Staff
of the operations AMLC • Formulates relevant
and functions of the
Secretariat SECRETARIAT Information Technology
(IT) security policies
• Enforces and and implements IT
implements decisions security systems
made by the AMLC and controls
OFFICE OF THE • Maintains the Security
EXECUTIVE Operations Center to
DIRECTOR monitor, identify, and
eradicate security risks
and vulnerabilities.
COMMITMENTS ENTERPRISE
AND SECURITY STAFF
POLICY GROUP
COUNSELING ADMINISTRATIVE,
AND LEGAL FINANCIAL, AND
ASSISTANCE UNIT IT SERVICES GROUP
DETECTION AND INVESTIGATION AND

PREVENTION ENFORCEMENT
DEPARTMENT DEPARTMENT
INVESTIGATION AND
ENFORCEMENT DEPARTMENT Administrative, Financial, and IT preventive maintenance, and
• Investigates suspicious Services Group utilization of the Secretariat’s
and covered transactions • Ensures compliance data center and network
deemed suspicious with relevant legislation, infrastructure
• Acts on requests for regulatory requirements, • Manages the development,
investigation and assistance and internal policies on implementation, and
• Gathers evidence personnel, facilities, property, maintenance of IT systems,
• Institutes the filing of freeze and supplies management modules, programs,
order; bank inquiry; civil • Records, monitors, and and projects
forfeiture; and ML and controls the utilization of the • Manages and monitors
TF cases approved annual AMLC budget centralized receiving and
• Prosecutes ML and TF • Manages the integrity, releasing of documents from
• Manages and monitors capacity, performance, and to various stakeholders
frozen and forfeited assets availability, administration, and the general public

GENDER AND
DEVELOPMENT (GAD)
Quality Management Through its GAD Focal Point The AMLC then formulates its annual
System (QMS) System (GFPS), the AMLC takes on GAD Plan and Budget (GPB) within
The QMS serves gender mainstreaming as a strategy the context of its mandates and allots
as a platform for the to promote gender equality and at least five percent of its national
implementation of the AMLC’s core sensitivity in its processes, systems, budget for the GPB implementation,
processes to deliver its mandate policies, operations, and procedures. pursuant to the MCW and the
pursuant to the AMLA, as amended. General Appropriations Act (GAA).
The Philippine Constitution
The AMLC QMS, as approved by recognizes the fundamental equality The GFPS prepares the GPB,
the Council per AMLC Resolution before the law of women and men, monitors its implementation, and
No.131 dated 20 December 2017, as enshrined in the Magna Carta of reports its results.
is a knowledge-based system that Women (MCW) or RA No.9710 and in
outlines the policies and procedures the provisions of the United Nations
necessary to improve and control
(UN) Convention on the Elimination
various processes of AMLC that will
of All Forms of Discrimination against
ultimately lead to better operational
Women (CEDAW), to which the
performance. The QMS ensures
consistency and improvement Philippines subscribed.
of working practices, which, in
turn, provides services that satisfy Executive Order (EO) No.273
customer requirements. (Approving and Adopting the Philippine
Plan for Gender-Responsive MALE FEMALE
The approved QMS is in accordance Development [PPGD 1995-2025])
with the requirements of the mandates agencies to incorporate and
international standard on QMS, ISO reflect GAD concerns in their agency
9001, approved policies, and other performance commitment contracts,
pertinent laws, rules, and regulations. annual budget proposals, and work
and financial plans.
NATIONAL GOVERNMENT BUDGET UTILIZATION
2017 2.12%
SUBSCRIPTION (periodicals, Internet)
PhP119,963,195.71
3.12%
TRAINING
0.37%
ADVERTISING
12.46%
UNUTILIZED
16.08%
OTHERS (legal services, office
equipment, insurance, utilities, etc.)
65.84%
ICT

38
TOTAL WORKFORCE: 123
29
19
14
8
3 5 3
1 2 1
CPA/ CPA/ CPA/

FORENSIC IT CPA/ DATA DATA LAWYER/
CPA LAWYER SCIENTIST IT EXPERT LAWYER IT EXPERT OTHERS LEA
ACCOUNTANT EXPERT SCIENTIST
1.82%
SUBSCRIPTION (periodicals, Internet)
2018
PhP75,057,000.00
3.28%
TRAINING
0.78%
ADVERTISING
18.56%
UNUTILIZED
27.74%
OTHERS (legal services, office
equipment, insurance, utilities, etc.)
47.82%
ICT

A FULLY
FUNCTIONAL FIU
A
s an FIU, the AMLC
requires and receives CTRs
and STRs from covered
persons. The AMLC collects,
evaluates, and analyzes financial
information, regarding potential ML
and TF; and disseminates financial
intelligence reports to LEAs, foreign
FIUs, and other Secretariat units to
support and assist investigations.
STR AND CTR COLLECTION

Covered persons submit CTRs
CTRs and STRs to the AMLC
electronically. Files are encrypted
and uploaded through a secure
portal. Then the files are
decrypted, checked, and validated
before being saved in the AMLC
database. The facility has
also been enhanced to require COVERED
timestamps on STRs and CTRs. PERSONS
STRs

A FULLY FUNCTIONAL FIU
24/7 Security System

The AMLC
leverages on ICT to
improve operational
efficiency, transparency, and security.
Confidentiality, integrity, and
availability of AMLC information are
checked, controlled, and maintained
through security controls and policies.
To ensure protection against security

DOCUMENT attacks that occur beyond office
MANAGEMENT hours, the AMLC security team
SYSTEM (DMS) operates 24 hours, seven days
The document management a week. This enables immediate
and tracking system with a case response to security threats and
management system is a computer guarantee continuous optimal
software. It stores and tracks performance of the security system.
electronic documents and images of
paper-based information captured The AMLC also monitors its compliance
through a scanner. Documents of with various government regulations
the AMLC are then organized into on ICT security and privacy, especially
electronic folders for intelligence, those issued by the Department of
investigation, and litigation cases. The Information and Communications
DMS also has a facility that enables Technology (DICT) and the National
collaboration among users. Privacy Commission (NPC).
ENCRYPTION AMLC PORTAL AMLC DATABASE

Financial Intelligence
Analysis Group
Standard Operating Procedure
Guidelines (FIAG SOP)
The FIAG SOP provides guidance
to analysts for the execution
of their duties in accordance
with AML/CTF laws. The
manual outlines the process
for operational and strategic
analysis, dealing with the receipt
of reports; case prioritization;
data collection and analysis; and
sharing of intelligence reports.
FINANCIAL INTELLIGENCE ANALYSIS

Requests for Information
Sources of Financial Transaction Information
Year LEAs and Other Triggers (confidential
Government informants, covered Year Total CTRs Total STRs
Agencies (GAs) persons, the public, etc.)
2017 39.9 million 287,265
2017 214 46 2018 43.1 million 491,717
2018 268
Know-Your-Customer
(KYC) Documents
Upload Facility
Covered persons upload KYC
documents electronically for use
by intelligence analysts as well as
handling lawyers and investigators
of the AMLC.

Memorandum of
Agreement (MOA)
As of December 2018,
the AMLC has 28 MOAs with
domestic LEAs and GAs. The
MOA outlines the conditions in
the sharing of intelligence.
Information used in Financial Intelligence No. of Financial Intelligence

Reactive Reports Produced
Year CTRs STRs Year Reactive
2017 2,170,635 21,203 2017 411
2018 984,032 6,275 2018 158
Information used in Financial Intelligence No. of Financial Intelligence

Proactive Reports Produced
Year CTRs STRs Year Proactive
2017 506 106 2017 8
2018 33,361 2,340 2018 43
Information-Sharing
Portal (ISP)
The AMLC has portals for
sharing documents with LEAs and
appropriate government agencies
(AGAs); and with covered persons
for intelligence purposes. The
portals have facilities to provide
feedback on shared information.
The portals are accessible to LEAs
with existing MOAs with the
AMLC; and to covered persons
with existing an ISP Agreement
with the AMLC.

MUTUAL LEGAL
ASSISTANCE (MLA)
The MLA refers to the formal
method of cooperation between
MLA Case Study on two jurisdictions for purposes of
the Freezing of Bank seeking assistance in the production
Accounts in Relation to of documents, asset freezing and
Money Laundering forfeiture, extradition, enforcement of
3 7
On 25 September 2017, the DOJ foreign judgment, and other kinds of
referred to the AMLC an MLA
MLA
legal assistance in criminal matters. Requests
request from the Netherlands to
freeze and eventually confiscate The AMLC enlists the assistance of
the funds of Mr. HOV and Ms. CDL, any branch, department, bureau,
Dutch and Taiwanese citizens, office, agency, or instrumentality
respectively. The Dutch authorities of the government, including
were conducting an investigation government-owned and -controlled
on Mr. HOV and Ms. CDL for ML, corporations, in undertaking any and
among other offenses. all AML/CTF operations. ESW RFIs
The AMLC then secured a freeze
order from the CA, amounting to
received
by AMLC 101 72
USD401,800 and PhP134,700. In EGMONT SECURE WEB
2018, the AMLC filed a petition (ESW) RFIS
for civil forfeiture against the
real properties and accounts of The ESW of the Egmont Group is a
Mr. HOV and Ms. CDL. The funds secure communication system that
are now subject of an asset ESW RFIs
allows encrypted sharing of, among referred
preservation order, while the
case is pending.
member FIUs, financial intelligence
and other information of interest
by AMLC
to other
5 30
to members. The ESW system FIUs
allows Egmont members to access
Memorandum of documents, contact information, and
Understanding (MOU) case typologies.
As of December 2018, the
AMLC has 43 MOUs with
foreign FIUs and counterparts.
RISK ASSESSMENTS
The MOU conforms with the Risk Assessment of the Non-Profit Task Force’s (FATF) “Best
model MOU of the Egmont Organization (NPO) Sector (2018) Practices: Combating the Abuse
Group and consistent with of Non-Profit Organizations
its Principles for Information What (Recommendation 8),” risk was
Exchange between FIUs. The study is a separate evaluation of determined as a function of criminal
ML and TF threats of the NPO sector threat and vulnerability. ML and
in the Philippines. TF threats were gauged based on
investigations and cases, involving
How NPOs; STR analysis; and inputs
Following the Financial Action from sector representatives.

Findings
ML threat Medium
(mostly involving graft and corruption NPOs exploited are those involving
and fraud) charitable, agricultural, educational,
and livelihood activities.
TF threat High-Low
(mostly based on allegations) NPOs at risk are those involving
charitable, social development,
humanitarian disaster relief, and
educational activities.
ML/TF vulnerability Medium
AML/CTF understanding Moderate

of NPOs
Controls in place Generally Effective

(regulatory framework, supervision,
preventive measures, self-regulation
mechanisms, and program delivery to
intended beneficiaries)
Regulated financial channels Generally Utilized
Overall NPO risk to ML Medium
Overall NPO risk to TF Low Medium
Recommendations* between the NPO sector

 Sustain outreach to the NPO and GAs/LEAs to support
sector and regulators legitimate investigations on
 Communicate results the abuse of the sector for
to stakeholders criminal purposes
• Create or amend risk-based
regulations and supervision A Risk Assessment on the Philippines’
for NPOs at risk for ML/TF Exposure to External Threats based
• Revise classification system on Submitted Suspicious Transaction
of SEC-registered NPOs to Reports (2018)
accurately capture the type
and purpose of the NPO What
 Encourage formalization of Relative to the NRA, the study
coordination mechanisms evaluates the exposure of the * = accomplished

Philippines to threats, originating STRATEGIC STUDIES

within and outside its jurisdiction;
and provides information on Suspicious Transaction Report
the generation, movement, and Quality Review: A 2017 Strategic
behavior of illicit funds related to Analysis Report that Assesses the
the top predicate crimes in Overall Quality and Effectiveness of
the country. the Suspicious Transaction Reports
Submitted by Covered Persons to
How the AMLC for the Year 2016 (2017)
The study analyzes STRs submitted
by BSP-supervised institutions, What
such as banks and money service The study distinguishes inadequate
businesses (MSBs), with a total of STRs from acceptable ones to
161,650 transactions executed from improve the quality of STRs of
1 January 2013 to 31 December covered persons.
2017 and with a combined value of
PhP17.895 trillion. How
The study applies descriptive and
Findings analytical techniques to determine
• Illicit funds from the quality level of 132,306 STRs
environmental crimes, submitted by 149 covered persons
illegal trafficking of persons, to the AMLC in 2016. Among the
kidnapping for ransom, information evaluated are the
and terrorism have entered accountholder details, subject of
the country. suspicion, transaction type, reason for
• Illicit funds from smuggling suspicion, predicate crime described in
have originated from the narrative, and place of transaction.
the country.
• 68% of the incoming Findings
proceeds were coursed • 53.09% of the 2016 STRs
through banks in the provide substantial information.
United Kingdom. • 46.91% of the 2016
• 29% of the illicit funds flowing STRs do not have
out of the country were sufficient information to
received by Hong Kong. warrant further analysis
and investigation.
Recommendations
 Promote immediate Recommendation
referral of various STRs • Reinforce the ARRG, specifically
to the appropriate LEAs, on how to properly narrate
supervisory authorities, details of circumstances, leading
AMLC Public-Private to the suspicion
Program partners, and
other jurisdictions through Strengthening Anti-Money Laundering
their respective FIUs Surveillance alongside Advancements
 Seek additional STR in Financial Technology: A Study of
information from the Transaction Profile of Accredited
appropriate agencies Virtual Currency Exchanges in the
and partners Philippines (2018)

What a more comprehensive

On the back of BSP Circular No. monitoring of the financial
944 (Guidelines for Virtual Currency behavior of individuals and
[VC] Exchanges) in 2017, the study entities possibly connected
assesses the transaction profiles of to illicit activities; and closer
accredited VC exchanges in relation coordination and information-
to suspicious transactions, clients sharing among covered
suspected of links to illicit activities, persons in the conduct of
and big-ticket transactions. AML surveillance.
How Recommendations
The study performs a descriptive  Reduce the prevalence
analysis on 1,086 CTRs and 21,280 of fraudulent activities,
STRs received from BSP-accredited using VC exchanges,
VC exchanges from 6 March 2017 to by imposing:
10 April 2018, involving transactions o Lower thresholds for
executed on their platforms from the amount, volume,
28 April 2014 to 6 April 2018 with a and/or frequency
combined value of PhP3.1 billion. of transactions in
an account
Findings o More stringent
• 41.9% of the total STRs were KYC procedures
tagged as deviations from o Stricter requirements for
the clients’ profile and/or increasing an account’s
transaction history, including transaction thresholds
transaction amounts not o Release of constant
commensurate with one’s advisories and
financial capacity. reminders to
• Other most frequently cited accountholders on
reasons for suspicion are prohibited activities
participation in investment and possible penalties
schemes, swindling, and o More rigid AML/due
fraudulent practices and other diligence standards
violations under the Securities for VC exchanges’
Regulations Code of 2000. payment partners,
• In terms of total volume, such as remittance
59.4% of the total STRs centers or mobile
are outward remittances to payment systems
domestic beneficiaries, while  Raise the level of the country’s
in terms of total value, cash financial literacy and educate
deposits form 58.5%. the public in performing
• In terms of total volume, their own due diligence,
55.4% of the total CTRs especially in assessing
are outward remittances to investment opportunities
domestic beneficiaries, while • Pass the National Identification
in terms of total value, cash System Bill and the SIM Card
deposits form 59.1%. Registration Bill that may
• The regulatory framework aid in curbing the anonymity
for VC exchanges enables exploited by criminals

1 2
Lookup
DATA Watchlists
MINING Foreign
Declarations
CTRs and
STRs
EXTRACT, TRANSFORM,
SOURCES AND LOAD
Towards Deepening Regulatory • Majority of the bases for

Compliance: An Assessment of suspicion emanated from the
the Development of Anti-Money institutions’ own monitoring
Laundering Reporting Compliance of their customers rather
of the Pawnshop and Money than reactive reporting to
Service Business Industry (2018) news articles or government
agencies’ RFIs.
What • Data analysis provided
In view of the development in substantial basis to
the regulatory and operational confirm broadening AML
environment of the pawnshop awareness, reporting,
and MSB industry, following the and compliance within
Bangladesh Bank Cyberheist in the industry.
2016, the study examines how the
industry’s compliance with AML Recommendations
reporting standards has evolved.
 Strengthen partnerships
through the Public-Private
How Partnership Program (PPPP)
The study performs a descriptive • Capitalize emerging regulatory
analysis on CTRs and STRs submitted technology solutions
from January 2013 to August 2018 • Establish industry associations
by BSP-accredited pawnshops and • Encourage sector
MSBs, operating in the parallel market, consolidation to lessen
that is, not affiliated with the formal industry fragmentation
banking sector. • Conduct further
capacity enhancements
Findings • Include the industry among
• CTR and STR submissions financial agents under
increased after the BSP’s supervisory authority,
Bangladesh Bank should the BSP Charter
Cyberheist and after the be amended, to safeguard
issuance of BSP Circular against unscrupulous
Nos.938 and 942. business practices that
• Timeliness of CTR may taint the integrity of the
submissions improved. financial system

3 4
System
IT Support
Administration
• Parsing and Standardization
for Matching Criteria
• Match and Cluster Data
• Single Entity View
• Network Build
• Alert Generation
• Report Generation
Management Investigation
SAS FINANCIAL
AMLC USERS
CRIMES SOLUTION
for FIU heads; facilitating proactive

PROACTIVE REPORTS information-sharing and alignment of
operational AML/CTF; and assisting
2017 Data Mining Reports
FIU critical incident responses for
on Patterns Related to Drug
timely information-sharing. The FICG
Trafficking and Investment Scam
has several working groups, namely, the
NPO Red Flags Assessment Project,
To ensure the quality of tactical and
the CTF Summit Secretariat, the
strategic studies of CTRs and STRs,
International Community of Experts, and
the AMLC invests in data-mining tools
the Southeast Asia Counter-Terrorism
and analysis systems.
Financing Working Group.
Data mining in pattern-based queries,
searches, or other analyses of the AMLC
CAPACITY BUILDING
database is used to detect predictive
Analyst Exchange Program (AEP)
patterns or anomalies that may indicate
19 to 30 June 2017
terrorist or money laundering activity.
Sydney, Australia
Since 2014, the AMLC has been
producing boiler room fraud/investment
10 to 21 July 2017
scam reports, the latest of which was
Manila, Philippines
in 2017 with potential leads to an
investment scam and illegal drugs.
Since 2009, the AMLC and the
Australian Transaction Reports and
COOPERATION AND Analysis Centre (AUSTRAC) have
COLLABORATION collaborated on a number of AML/
CTF capacity-building programs.
Financial Intelligence Consultative In 2017, the AMLC and AUSTRAC
Group (FICG) launched the AEP to pursue
intelligence-sharing in combating ML
The FICG aims to develop a and TF between the two countries.
mechanism for regional financial AMLC and AUSTRAC analysts
intelligence analyst exchanges gathered and developed intelligence
among the ASEAN and close partner on an agreed case and facilitated the
FIUs by providing regular and disclosure of this intelligence between
informal means of communication these agencies. The focus of the AEP

COMPLEX NETWORK The MAEP

produced a link chart analysis of
associations and transaction flows
related to the Marawi incident in 2017.
used, and previously unknown

financiers and facilitators, who helped
finance high-profile terrorist groups in
Southern Philippines.
Analysis has pinpointed, for example,

certain financial transactions of an
individual that funded the travel of
suspected foreign terrorist fighters.
The exchange of information
coursed through formal and informal
mechanisms between AMLC and its
partner agencies validated information
that foreign terrorist fighters traveled
from Indonesia to join the siege
included financial transactions related in Marawi. This has established a
to child pornography/child exploitation relationship and trust system, thereby
material and ML between Australia improving the validation process and
and Philippines. timeliness component in the conduct
of TF investigations.
Multilateral Analyst Exchange
Program (MAEP) The MAEP findings have been shared
among participating FIUs and their
MAEP, one of the activities included respective law enforcement and
in the AMLC-AUSTRAC Partnership domestic partner agencies; and have
Program (AAPP), is a multilateral been presented by the AMLC at the
project, involving financial intelligence Counter-ISIS Finance Group meeting
analysts from AUSTRAC, Indonesian in Warsaw, Poland.
Financial Transaction Reports and
Analysis Centre (PPATK), Bank Negara Regional Financial Intelligence
Malaysia, and AMLC. The program Analysis Course (FIAC)
aims to identify and understand the flow
of funds and material support to the Developed by AUSTRAC in 2017 and
Maute Group; and associated groups in first held at the 2018 Counter-Terrorism
the Philippines prior to and during the Summit in Brunei, the Regional FIAC
Marawi Siege in 2017. is a shared approach among ASEAN
FIUs, including the AMLC, to build
The 2018 MAEP resulted to financial intelligence skills, capability,
actionable financial intelligence for and tradecraft to understand, detect,
national LEAs in Indonesia, Malaysia, prevent, and disrupt financial crime.
Philippines, and other relevant
partners. It helped the participants The course also offers perspectives and
identify money-moving networks, insights from the global academe and
probable fund sources, networks LEAs on ML, serious and organized

crime, and TF threats and risks. It PCOO eFOI Training

promotes cross-jurisdiction collaboration 25 August 2017
and relationship-building among Manila, Philippines
representatives of the ASEAN FIUs.
FATF Standard Training Course
UNODC Advanced CFT Training 23 to 29 July 2017
16 to 19 July 2018 South Korea
Makati City, Philippines
DOJ-OOC and UNODC Training
UNODC CFT and Proliferation on Cryptocurrencies Investigation
Financing Training 13 July 2017
20 to 22 June 2018 Makati City, Philippines
Australia-Asia Program to Combat Intelligence Analysis

Trafficking in Persons Seminar-Workshop
11 June 2018 15 to 19 May 2017
Cagayan de Oro City, Misamis
AUSTRAC Financial Oriental, Philippines
Intelligence Course
16 to 23 May 2018 APG Assessor Training
Manila, Philippines 1 to 5 May 2017
Australia
UNODC Basic CFT Training
10 to 13 April 2018 FBI ASEAN CTF Training
Makati City, Philippines 24 to 28 April 2017
Thailand
APG Regional Workshop:
The Exploitation of NPOs for ASEAN Regional Risk Assessment
Terrorist Financing Workshop, and AML/CFT Training
23 to 26 November 2017 Program, FATF Training and
Malaysia Research Institute
27 to 30 March 2017
2017 APG Typologies Workshop South Korea
13 to 16 November 2017
South Korea Intelligence Analysis Workshop
6 to 10 February 2017
IMF-STI Workshop on Risk-Based Clark, Pampanga, Philippines
Approaches to AML/CFT Supervision
23 to 27 October 2017 Strategic Intelligence
Singapore Orientation Workshop
Quezon City, Philippines
APG Assessor Training
26 August to 3 September 2017 Regional Workshop in preparation
Australia for the 3rd CTF Summit 

A RELIABLE PARTNER IN LAW
ENFORCEMENT, PROSECUTION,
AND ASSET FORFEITURE
T
he AMLC investigates administrative and compliance
suspicious transactions, cases against covered persons.
covered transactions
deemed suspicious, ML In 2018, the AMLC adopted an
and TF activities, and violations asset preservation system on the
of the AMLA, as amended and the management and preservation
TFPSA. It acts on requests for of assets and properties that are
investigation from domestic law subject of asset preservation order
enforcement and other agencies of and judgment of forfeiture. This
the government, and requests for allows the AMLC to ensure that
assistance from other jurisdictions during the pendency of cases and
and international organizations. after their forfeiture, the assets
do not diminish in value, including
The AMLC also gathers perishable assets converted into
evidence to establish probable cash before remittance to the
cause required in the filing of National Treasury or, in appropriate
applications for bank inquiry, cases, to the requesting State.
petitions for freeze orders, civil
forfeiture cases, and criminal Through timely use of provisional
complaints for ML. The AMLC has and confiscation measures, criminals
held 10 case conferences with are deprived of the proceeds and
relevant GAs to synthesize efforts instrumentalities of their illegal
in the investigations of ML, its activities. Ultimately, this makes
related predicate offenses, and lawlessness unprofitable and reduces
TF. The AMLC also adjudicates both predicate crimes and ML.
FINANCIAL INVESTIGATION
No. of Financial Intelligence No. of Investigation Reports
Reports Used Developed
Reactive Reactive
2017 198 2017 117
2018 101 2018 28
No. of Financial Intelligence No. of Investigation Reports

Reports Used Developed
Financial
Intelligence Proactive Proactive
Reports 2017 6 2017 2
2018 30 2018 1

A RELIABLE PARTNER IN LAW ENFORCEMENT,
PROSECUTION, AND ASSET FORFEITURE
Financial Crimes
Investigation Manual
Financial investigation
is an inquiry into a subject’s
financial matters, money, property,
expenditure, business, and finance
of any kind. Because it is important
to have a tool in detecting ML,
TF, and other related serious
offenses, the AMLC standardized its
operations in financial investigation.
It revolves around the collection,
collation, and analysis of a variety of
eReturns financial documents, which include,
Upload Facility but not limited to, bank and other
Registered covered financial account information and
persons upload returns (in records, investments, commercial
compliance with the freeze documents, real estate, and motor
order) electronically for the vehicle records. The collected data
use of intelligence analysts as are used to identify associations and
well as handling lawyers and links to subjects as well as evidence
investigators of the AMLC. and leads to the discovery of assets
for forfeiture.
Civil Forfeiture
No. of Civil Estimated Value of
Forfeiture Forfeited
Investigation and Disruption Tools
Cases Assets (PhP)
No. of Freeze Order 2017 9 922,643,319
Applications Estimated Value 2018 7 86,473,388
for Bank No. of Petitions for
of Frozen Assets
Inquiry Freeze Order
(PhP) Prosecution
2017 16 8 733,867,575 ML/TF
ML Cases
2018 15 11 984,519,214 Complaints
2017 1 2
2018 9 -

NALECC Sub-Committee on AML/

DOMESTIC CFT (NALECC SCAML/CFT)
MEMBERSHIPS
Created by virtue of NALECC
National Law Enforcement Resolution No.10-2003 on 15
Coordinating Committee (NALECC) August 2003, NALECC SCAML/CFT
serves as an effective coordinating
Created on 11 September 1982 by mechanism for LEAs and GAs,
virtue of EO No.829 and reorganized performing vital roles in combating
by EO Nos.41 and 41-A, the NALECC ML and TF.
serves as a forum for dialogue and
coordination among GAs/entities The Executive Director of the AMLC
engaged in the enforcement of general Secretariat serves as the Chairperson
and special laws. of the NALECC SCAML/CFT. To date,
the sub-committee consists of 35
Functions member-agencies, including the three
• Coordinate policies/ financial supervisors, various LEAs,
procedures to facilitate intelligence agencies, prosecutors,
cooperation and integration and other GAs.
of efforts among member-
agencies and ensure a During the meetings, results of AMLC
unified direction in the strategic and intelligence studies are
suppression of activities shared with relevant participating
• Identify priority areas LEAs, and AML/CTF matters, including
for coordinated/joint law latest developments, typologies, and
enforcement activities actions, are discussed.
• Prepare and submit to
the committee chairman Joint Terrorism Financial
for consideration/ Investigation Group (JTFIG)
implementation of basic
strategies/plans, which JTFIG is an inter-agency coordination
outline the law enforcement composed of law enforcement units
facet of the peace and that work on providing intelligence
order campaign; and and information to probe and uncover
delineate policies and terrorist financial networks. The
NALECC thrusts in the effective AMLC is a member along with the
implementation of law Anti-Terrorism Council-Program
SCAML/CFT
enforcement functions Management Center (ATC-PMC),
MEETINGS Armed Forces of the Philippines
NALECC has 59 members and 16 (AFP), Bureau of Immigration (BI),
sub-committees, and the AMLC is a National Bureau of Investigation
regular member. (NBI), Philippine Center on
Transnational Crime (PCTC),
The AMLC participates in the Philippine National Police (PNP)
following NALECC sub-committees: Anti-Cybercrime Group, PNP Anti-
• Dangerous Drugs and Kidnapping Group, PNP Aviation
Controlled Chemicals Security Group, PNP Directorate
• Intelligence Coordination for Intelligence, PNP Special Action
• International Law Force, PNP Intelligence Group,
Enforcement Cooperation and the US Federal Bureau of
• Organized Crime Investigation (FBI).

Inter-Agency Committee against Presidential Legislative Liaison

Drugs (ICAD) Office (PLLO)
ICAD ensures that each member PLLO is tasked to orchestrate

agency shall implement and the formulation of the Executive-
comply with all policies, laws, Legislative Agenda and all
and issuances pertaining to the other concerns of the Executive
government’s anti-illegal drug Department having to do with
campaign in an integrated and legislation and see these concerns
synchronized manner. through the various processes.
It is mandated to promote the
Inter-Agency Council against presidential legislative initiatives
Trafficking (IACAT) and other administration-sponsored
priority policy reforms and
Section 140 of the Revised Rules development programs through a
and Regulations Implementing strategic information dissemination
RA No.9208, as amended by RA campaign and sustained day-to-
No.10364 imposes obligations on day collaboration with the two
relevant government agencies to Chambers of Congress (at both
integrate human trafficking issues personal and institutional levels),
in their strategy and program as well as with other interest
formulation. The AMLC, as groups and generate maximum
participating agency, is required to: support for the President.
• Assist IACAT and LEAs in The AMLC participates in the

the financial investigation of following PLLO clusters:
trafficking-in-persons cases • Security, Justice, and Peace
as an ML predicate offense • Economic Development
• Act on requests of IACAT • Good Governance Cluster
and LEAs for issuance
of freeze orders and In the past, the AMLC has
institution of civil forfeiture utilized the PLLO in pushing the
proceedings against the prioritization of bills, including
assets of the traffickers casinos as covered persons under
the AMLA, as amended.
Anti-Terrorism Council (ATC)
Philippine Anti-Drugs Strategy (PADS)
Section 53 of the RA No.9372
created the ATC, responsible for the On 29 October 2018, EO No.66
proper and effective implementation institutionalized the implementation
of the anti-terrorism policy of the of PADS by all government
country. The National Intelligence agencies. The strategy envisions
Coordinating Agency (NICA) that by 2022, Filipino communities
serves as the ATC Secretariat, will be drug-free “through supply
while the AMLC, NBI, BI, Office reduction efforts, involving strong
of Civil Defense, the Intelligence law enforcement with consistent
Service of the Armed Forces of the and adherence to and observance
Philippines (ISAFP), PCTC, and of human rights, coupled with
PNP intelligence and investigative comprehensive demand reduction
groups serve as support agencies initiatives and supported by strong
for the ATC. international ties.”

AMLC action plans Manila Regional Trial Court (RTC)

• Strengthen the implementation in an AMLC case and in favor of the
of drug-free policies and government, giving custody of the
programs in the workplace transfer certificate of title to the AMLC
(Work Place Preventive Drug Secretariat.
Education Program)
• Provide access for A turnover, however, is not a mere
employees to various drug mechanical and bureaucratic
prevention services and procedure, but one laden with
programs in the workplace meaning. It represents the
(Work Place Preventive Drug culmination of the AMLC’s efforts to
Education Program) run after proceeds of crimes and ML,
• Heighten community which must be confiscated in favor of
awareness on the the government. Crime does not pay,
government’s drug supply and turnovers are intended to convey
and reduction programs and a strong message to would-be
policies through: money launderers.
o Expansion of
outreach activities to As of 2018, the AMLC has forfeited
different sectors and remitted almost PhP49 million to
o Development of the Philippine government.
AML/CTF training
modules, which
will include the
CASE STUDY
government’s NXTZ Company Case
drug supply and
reduction programs Investigation triggers
and policies On 13 September 2017, the
United Nations • Amend legislation, policies, Philippine Drug Enforcement Agency
Convention Against and programs on drug supply (PDEA) requested the AMLC to
Corruption (UNCAC) and demand reduction conduct a financial investigation on
The UNCAC, of which the AMLC • Strengthen intelligence and Mr. YCT, who was arrested during a
is one of its respondents, is the investigation in ML activities buy-bust operation of PDEA on 28
only legally binding universal predicated on drug trafficking February 2017.
anti-corruption instrument, which
covers five main areas: preventive ASSET An estimated amount of one kilo of
measures, criminalization and
law enforcement, international
PRESERVATION methamphetamine hydrochloride
(shabu) worth PhP2,000,000 was
cooperation, asset recovery, SYSTEM seized from Mr. YCT. In addition,
and technical assistance and The AMLC manages and preserves financial documents, including
information exchange. The assets and properties that are handwritten notes, checkbooks,
UNCAC includes a chapter on subjects of asset preservation orders and deposit slips to nine
asset recovery aimed at returning and judgements of forfeiture. individuals, including NXTZ
assets to their rightful owners, Company, were recovered during
including countries from which In 2018, the AMLC turned over the the buy-bust operation.
assets have been taken illicitly. title of a seven-hectare property in
Anda, Pangasinan to the BTr, the Mr. YCT was subsequently charged
Republic’s custodian of acquired with the violation of RA No.9165 or
assets. It was a forfeited land based the Comprehensive Dangerous Drugs
on a decision promulgated by the Act of 2002, as amended.

Estimated Value Estimated Other Assets

No. of Petitions of Cash and Other Value of Real Subject of
Valuated Assets (PhP) Property (PhP) Freeze Order
2017 6 713,173,902.75 1 vehicle

1 motorcycle
Freeze Orders on
Cases Predicated
on Drug Trafficking
2018 8 839,637,358.12 24,477,781.06

41 vehicles
17 firearms
insurance policies
TOTAL 14 1,552,811,260.87 24,477,781.06
Estimated Value
Estimated Estimated Other Assets
of Cash and
No. of Cases Value of Real Value of Subject of
Other Valuated
Property (PhP) Vehicles (PhP) Freeze Order
Assets (PhP)
13 real properties
22 vehicles
5 motorcycles
2017 6 819,198,158.22 5 watercrafts
1 condo unit
8 units of firearms
Assets Subject of
Civil Forfeiture
Related to Drug
Trafficking
37 vehicles
2018 36,310,777.97 26,789,145.81 855,000.00 1 motocycle
17 units of firearms
insurance policies
TOTAL 9 855,508,936.20 26,789,145.81 855,000.00

The AMLC received similar requests Consequently, several STRs

for information and financial were filed with the AMLC,
investigation from other LEAs, such pertaining to the transactions
as Bureau of Jail Management of the subject persons and
and Penology (BJMP), ISAFP, entities. Investigations conducted
and the PNP Criminal Investigation by the banks revealed that
and Detection Group, pertaining said transactions were not
to the individuals subject of commensurate to the respective
the investigation. financial capacities of the subjects.
Coordination There were identified transfers

Domestic coordination due to of funds with no established
RFIs from: relationship between the parties to
• BJMP the transfers. Transfers of funds
• Intelligence Service AFP were also noted with persons and
• PNP Criminal Investigation entities who are respondents to
and Detection Group civil forfeiture cases, relating to
• Land Registration Authority the violation of RA No.9165, as
(LRA) amended, filed by the AMLC with
• Land Transportation Office various courts. Thus, this further
(LTO) taints the accounts with proceeds of
• NBI illegal drug activities.
• Department of Trade and
Industry (DTI) Proceeds
• SEC On 9 May 2018, the AMLC issued
Resolution No.64-A, authorizing
International coordination due to its Secretariat to inquire into the
RFIs to: bank accounts of the subjects.
• Macau Subsequently, the CA, in its
• China resolution dated 4 July 2018,
• Hong Kong issued a freeze order against those
bank accounts.
Findings
Based on the AMLC’s initial As of 23 October 2018, there are
financial investigation, there were 643 frozen bank accounts in 15
numerous large denominated financial institutions, involving
transactions of the subjects with PhP670,011,425.44 of funds in
no underlying legal or trade the accounts.
obligation, purpose, or economic
justification because subject The AMLC is in the process of its
persons failed to substantiate the bank inquiry into the subject bank
veracity of their transactions with accounts for the filing of petition
financial documents. for civil forfeiture on the funds, if
warranted, and the filing of an ML
There were abrupt increases in case against the subjects.
the number of transactions made
to the different bank accounts Initial investigation disclosed that the
of subject persons and entities, proceeds of funds were channeled
beginning 2016. Moreover, the to a sole proprietorship engaged
nature of the businesses owned by in the online selling of luxury bags.
the subjects could not justify the Observed were numerous large
sudden increase in the amounts denominated cash/check deposits
transacted and the volume of and local fund transfers among the
transactions to the accounts of subjects, who mostly originated from
subject persons. Fujian, China.

CASE
UPDATES
Financing of terrorism through Laundering the proceeds of cyberheists

kidnapping for ransom and through banks, remittance agents, and
use of ATMs (AMLC Annual casinos (AMLC Annual Report 2016)
Report 2016)
In 2016, over USD80 million was
On 26 March 2016, the Abu Sayyaf stolen from the account of Y Bank
Group (ASG) abducted 10 ship at its depository bank in Country U.
crew members of Country I off the The money was then electronically
waters of Southern Philippines. transferred to accounts registered
The ASG demanded a ransom under fictitious names at a branch of
of PhP50,000,000 with an initial NH Bank in the Philippines. The said
payment of PhP1,000,000, funds were withdrawn by suspects who
deposited into a bank account used them to play in casinos. Around
owned by spouses, JJ and AJ, from USD15 million of the stolen funds have
Jolo, Sulu. so far been returned to Country Y.
Upon the release of the 10 crew Investigations and further probing on

members and after several assets and financial documents as well as
withdrawals of the ransom money, domestic and international coordination
the AMLC and Philippine intelligence led to the filing of petitions for civil forfeiture
and law enforcement agencies on assets of QRS and TUV, who are
agreed to freeze the ATM account to officers of AJ Leisure Corporation, a
prevent further dissipation of funds, casino involved in the case, in February
while continuing the surveillance on 2017. An asset preservation order (APO)
JJ and other suspected members of was eventually issued in March 2017.
the ASG.
In April 2018, an APO was issued against
A total of PhP498,653.68 the assets of XB and ZB, owners of BC
(approximately USD9,970) from Corporation, a remittance company.
the said account is now subject
of indefinite freeze by virtue of AMLC filed criminal complaints for ML
the AMLC TF resolution. In 2018, on VY and other officers of the NH
the AMLC filed a petition for civil Bank before the DOJ.
forfeiture on the assets of JJ •
The DOJ, in its resolution in 2017,
and AJ. found probable cause for the
filing of ML charges against VY
A TF case was also filed against and other officers of NH Bank.
JJ and AJ in October 2018 for •
In 2018, DOJ also filed
the violation of Section 8 of RA information against the five
No.10168 for receiving funds executives of NH Bank for
intended for a UN-designated ML under Section 4(f) of the
terrorist organization. AMLA, as amended.

In 2018, the AMLC, NBI, and

OMB acted on the MLAT request
from the US for the production of
documents in relation to the seizure
and eventual forfeiture of the
properties of Ms. N and members
of her immediate family in the said
jurisdiction, which were acquired
Large-scale corruption through during the pork barrel scam.
the use of non-government
organizations (NGOs), dummy Civil Forfeiture and ML cases
corporations, and foreign exchange resulting from the MLAT
dealers (AMLC Annual Report 2014) Close coordination with US authorities
have resulted to the filing of a civil
In an alleged misuse of the Priority forfeiture case against the assets of
Development Assistance Fund Ms. N found in the US, amounting to
(PDAF) or pork barrel by several around USD12.5 million.
members of Congress, the scam
involved the funding of agricultural On 1 August 2018, a US federal
“ghost projects,” using the PDAF grand jury indicted Ms. N and her
of participating lawmakers. Funds cohorts, for conspiring to funnel in
would be processed through fake and out of the US some USD20
foundations and NGOs established million of Philippine public funds
under the holding company of Ms. obtained through a multi-year bribery
N. Each foundation or NGO served and fraud scheme.
as an official recipient of a particular
legislator’s PDAF funds for the CAPACITY BUILDING
supposed implementation of these
projects. The funds, however, would Law enforcement agencies and
be withdrawn and split among Ms. AMLC Secretariat personnel
N, the lawmaker, the facilitator of the American Bar Association AML/
fund transfers, and the local mayor CFT trainings for Investigators
or governor. and Prosecutors
10 to 14 September 2018
Some of Ms. N’s employees
eventually became whistleblowers, AML/CTF Trainings for Investigators
agreeing to expose the scam and and Prosecutors with PDEA
testify against her. 30 July to 3 August 2018
Davao City, Philippines
International Cooperation
Investigations revealed that Ms. Financial Investigation Training
N and members of her family with NICA
transferred money to the USA. 7 to 8 June 2018
Through the ESW, the AMLC
sought the assistance of the Financial Investigation Training
Financial Crimes Enforcement with ISAFP
Network (FinCen), the FIU of 27 April 2018
the US, yielding positive results.
Material information showed how Financial Investigation Training
the money was transferred and with NBI
established how money changers 13 March 2018
acted as conduits. Baguio City, Philippines

Financial Investigation Training AMLA, as amended, 2016 RIRR,

with PDEA Financial Investigation, Legal
12 March 2018 Remedies for CIDG
Cavite, Philippines 10 to 11 August 2017
Manila, Philippines
26 April 2018
Countering Transnational
Financial Investigation Training Organized Crime
with PNP 5 to 27 August 2017
15 February 2018 Germany
Quezon City, Philippines
AMLC-OMB Workshop
AMLC-NBI Workshop 27 to 28 July 2017
Clark, Pampanga, Philippines Financial Investigation for Public
Corruption Course
AMLC-PDEA Workshop 9 to 15 July 2017
21 to 22 November 2017 Thailand
Puerto Princesa City, Palawan, Philippines
Operational Workshop on Cross-
4th Asset Recovery Interagency Border Financial Investigation Training
Network-Asia Pacific (ARIN-AP) 19 to 23 June 2017
Asset Recovery Training Pasay City, Philippines
South Korea Financial Investigation Workshop
19 to 22 June 2017
Cross-Regional Workshop on the
Investigation, Prosecution, and Export Control (Weapons-
Adjudication of Foreign Terrorist Smuggling) Workshop
Fighter Cases 22 to 24 March 2017
7 to 9 November 2017 Manila, Philippines
Countering the Financing CTF Investigators Workshop

of Terrorism and Proliferation 6 to 9 March 2017
of Weapons of Mass Indonesia
Destruction through Effective
Asset-Freezing 42nd Asia Region Law Enforcement
18 to 19 October 2017 Management Program (ARLEMP)
Makati City, Philippines 14 February to 3 March 2017
Vietnam
Financial Investigative Techniques
25 to 29 September 2017 Export Control and Related
Thailand Border Security Training Counter
Proliferation Investigations Course
Workshop on the Amendment of 6 to 9 February 2017
HSA at the ATC Manila, Philippines
17 to 18 August 2017
Manila, Philippines 6 to 10 March 2017
Cebu City, Philippines
Workshop on HSA
16 August 2017 22 to 25 August 2017
Manila, Philippines Manila, Philippines 

AN EFFICIENT SUPERVISOR
RA No.10927,
otherwise known
as “An Act Designating
Casinos as Covered Persons under
the RA No. 9160, otherwise known
as the Anti-Money Laundering Act
T
of 2001 (AMLA), as amended”
he AMLC undertakes studies on ML and TF trends and standards for
Effective 29 July 2017 the adoption of necessary policies, procedures, and guidance. Then
the AMLC ensures compliance of covered persons with the AMLA, as
On 21 June 2013, the FATF removed amended, and its other rules and regulations by conducting regular
the Philippines from the list of and targeted onsite examination; and offsite supervision of covered persons.
vulnerable jurisdictions (“grey
list”) but enjoined the Philippines
to “work with the [Asia Pacific
KEY AML/CTF POLICY they have established
Group on Money Laundering] ISSUANCES AML/CTF standards in
their respective Money
APG as it continues to address Casino Implementing Rules and Laundering/Terrorism
the full range of AML/CFT issues Regulations (CIRR) of RA No.10927, Financing Prevention
identified in its Mutual Evaluation An Act Designating Casinos Program (MLTFPPs) with
(ME) Report, in particular, as Covered Persons Under RA adequate board and senior
regulating the casino sector in the No.9160, Otherwise Known as the management oversight and
Philippines for AML/CFT purposes Anti-Money Laundering Act of 2001, internal controls.
and making it subject to AML/CFT as amended” • Second, AGAs, namely
requirements.” PAGCOR, CEZA, and
Council approval 11 October 2017 APECO, with respect to
On 14 July 2017, President Rodrigo Effective 4 November 2017 their casino operations and
Roa Duterte signed RA No.10927, licensees, supervise these
which places casinos as covered Similar to banks and other financial casinos’ compliance with
persons under the AMLA, as institutions, casinos undertake high- their MLTFPPs.
amended. Casinos are thus volume and high-speed financial • Third, the AMLC ensures
required to perform the following activities but in the gaming context. that the AGAs, as the
obligations: Casinos are generally large cash- supervising authorities,
based businesses, competitive as well as covered
• Conduct KYC procedures in its growth and susceptible to persons comply with their
and perform the criminal activity. Internet-based duties over casinos on
necessary customer due casinos, casino junket operations, AML/CTF matters.
diligence and reduced transparency of high-
• Report suspicious rollers, which usually make up a As the first institutional layer, casinos
transactions majority of casino turnover yet should ensure that the three lines of
• Report covered cash only a minority of casino patrons, defense are in place:
transactions exceeding raise substantial challenges.
PhP5,000,000 Vulnerabilities are noted with • Operations business units
• Keep records of identifying sources and movements that deal and transact directly
transactions of funds. with customers
• Casino compliance functions
With the passage of RA No.10927, The CIRR provides for three for officers that ensure the
the Philippines was removed from institutional layers of prevention to day-to-day compliance with
the APG membership action. minimize the exposure of casinos to AML/CTF obligations
ML and TF: • An audit function that conducts
post-assessment reviews of
• First, casinos, as primary casinos’ compliance with AML/
layer, should ensure that CTF obligations

Amendments to the AMLC • Pending completion by

Registration and Reporting registering DNFBPs of
Guidelines (ARRG) all the requirements, the
AMLC Regulatory Issuance (A) No.1, AMLC will issue PCORs to
Series of 2018 registering DNFBPs.
• AMLC then requires
Council approval 21 February 2018 compliance with and
Effective 11 May 2018 completion of all other
requirements within six
The four-part ARRG is the months from the approval
AMLC’s comprehensive effort of the PCOR, otherwise the
to provide the legal and policy PCOR will be cancelled.
framework for registration by
covered persons into the AMLC’s ARRG for Casinos (ARRGC) The data collection
online system, and to ensure AMLC Regulatory Issuance (C) system of the AMLC was
proper and timely compliance No.1, Series of 2018 modified to enable the
with reporting procedures. casino industry to register and
Council approval 20 February 2018 submit reports in accordance
Salient changes include: Effective 19 May 2018 with the ARRGC.
• Revisions in the definition of The ARRGC requires casinos to

terms and data elements register with the AMLC’s electronic
• Modified procedures in reporting system to be able to file
transferring files CTRs and STRs.
• Additional guidelines for
CT/ST reporting The ARRGC includes, among others:
• Revision of data elements
• Inclusion of transaction codes • Alerts and red flags for
and their mandatory fields suspicious transactions
• Requirement of a
Amendments to the Online reporting chain
Registration System of the ARRG • Time and manner of
AMLC Regulatory Issuance report submissions
(A and B) No.3 • Quality of reports
• Guide to registering in the
Council approval 23 November 2018 AMLC system and reporting
Effective 9 January 2019 CTRs and STRs
Salient changes are: The ARRGC requires AGAs to ensure

• Pending BSP issuance that casinos, casino operators and
of institution codes for licensees, and integrated resorts
MSBs, the AMLC will issue under their respective regulation install
a provisional certificate an AML/CTF reportorial system within
of registration (PCOR) a reasonable time, not to exceed 90
to registering MSBs days from publication of the ARRGC,
and pawnshops. upon consultation with the AMLC.

Guidelines on Digitization of Anti-Money Laundering/Counter-

Customer Records Terrorism Financing Guidelines
(DIGICUR Guidelines) for Designated Non-Financial
AMLC Regulatory Issuance (A, B, Businesses and Professions
and C) No.2, Series of 2018 (DNFBP Guidelines)
AMLC Regulatory Issuance (B)
Council approval 11 September 2018 No.1, Series of 2018
Effective 13 October 2018
Council approval 9 May 2018
The guidelines require covered Effective 29 June 2018
persons, including banks, to store
digitized records of their customers The guidelines are based on RA
in their own central database. No.10365, which includes as covered
Compliance officers or other duly persons, jewelry dealers in precious
authorized officers may then retrieve stones and metals; company service
customer records quickly, and, providers who provide fund/securities
upon request or order, upload these management services for other
records to the AMLC’s portal without persons; and persons and entities
having to request said records from who, as a business, provide services
branches on a per need basis. to organize, create, and manage
companies and arrangements.
Salient features include:
Under the guidelines, the AMLC
• Reiteration of the policy that oversees compliance by DNFBPs
revealing ongoing AMLC with the provisions of the AMLA, as
investigations is inimical to amended. The guidelines require
the public interest DNFBPs to register with the AMLC,
• Imposition upon the board and, attendant to registration, submit
of directors, partners, or deeds of undertaking to comply with
proprietors the obligation the provisions of the AMLA, and to
to ensure awareness attend regular AML/CTF trainings.
among personnel of
their responsibilities in Guidelines on Identifying
maintaining confidentiality Beneficial Ownership
of financial investigations AMLC Regulatory Issuance (A, B,
• Digitization of customer and C) No.3, Series of 2018
records and creation of a
central and secure database Council approval 22 November 2018
of customer records Effective 27 November 2018
• Updating of
AML/CTF manuals The guidelines require covered persons
• Compliance-checking to identify beneficial owners and to
by the AMLC, along validate information if customers and
with supervising and beneficial owners pose a high risk for
regulating authorities ML or TF. “Beneficial owners” refer to
• A reasonable period those individuals or natural persons,
for compliance who ultimately own or control the

customer, or those for whom another ownership; customer due diligence;

person conducts a transaction. AMLC supervision and compliance-
checking; and national risk
Covered persons must conduct management and assessment.
assessments on the risks posed by
customers and beneficial owners. Rules on the Imposition of
The guidelines therefore promote Administrative Sanctions (RIAS)
transparency and dissuade criminal under RA No.9160, as amended
elements, and would-be money
launderers and terrorists from Council approval 24 May 2017
hiding their identities. Effective 9 August 2017
2018 Implementing Rules and To ensure that covered persons

Regulations (2018 IRR) of RA comply with the AMLA, as amended, its
No.9160, otherwise known as the implementing rules and regulations, and
Anti-Money Laundering Act of all issuances of the AMLC and to deter
2001, as amended commission of ML and other violations
of the law, the AMLC issued the RIAS.
Council approval 22 November 2018
Effective 27 November 2018 Administrative sanctions range
from a simple reprimand to a
An update of the 2016 Revised IRR PhP500,000-fine per violation.
(RIRR), the 2018 IRR incorporates The imposition of appropriate
the amendments under RA No.10927, administrative sanctions depends on
which includes casinos as covered the following:
persons. The CIRR, however,
continues to govern the AMLA • Asset size of the
implementation of the casinos. covered person
• Gravity of violation
The 2018 IRR features new rules • Nature of violation
on the AMLC’s cooperation and • Existence of mitigating or
coordination with LEAs; beneficial aggravating circumstances
2016 Revised Implementing Rules and Regulations of RA No.9160,

as amended
Council approval 21 September 2016

Effective 9 August 2017
Salient features include

• Use of biometrics as additional customer due diligence (CDD) requirement for
individual and corporate signatories
• Passport or alien certificate of registration as default identification
document for foreign nationals
• Deferred face-to-face for low-risk customers
• Filing of STRs if the covered person reasonably believes that the conduct
of enhanced due diligence will tip-off the customer

AMLC-REGISTERED COVERED PERSONS

Compliance
and Supervision
Manual (CSM)
The CSM is a systematic
approach in conducting a risk-
based assessment of covered SEC-supervised
persons. Its procedures are 12.45%
based on acceptable standards PAGCOR-supervised
and international best practices 0.31% IC-supervised
that are consistent with relevant 6.53%
domestic laws and regulations. BSP-supervised
AMLC-supervised 80.32%
0.38%
The CSM is divided into five
sections that evaluate the overall
compliance of covered persons
with their respective AML/CFT
frameworks: 17
• Registration and DNFBP institutions
14
reporting
• Onsite Assessment
• Offsite Assessment PAGCOR-supervised casinos
• Special Assessments
• DNFBPs Risk Rating System
Adjudication Manual
The manual
serves to assist hearing
ARRG Briefings
officers in adjudicating
for DNFBPs
administrative cases and in
the day-to-day performance of
their duties. It was drafted to
implement the provisions of the
RIAS. The manual further aims
to show how the adjudication
process can be conducted in a
fair and professional manner in Company service Accountants/ Lawyers/
accordance with administrative providers accounting law firms
due process. It also sets working firms
processes that will strengthen
the integrity of the hearing
officer’s function. The manual
is a developing document, and
it is designed to be revised and
updated as the need arises.
Jewelers Casinos Real estate

brokers

Late Reports
Generation System
The AMLC uses a system
to generate late CTR submissions,
taking into account holidays and
non-reporting days.
ENFORCEMENT OF COOPERATION AND

AML/CTF RULES AND COLLABORATION
REGULATIONS
Supervising agencies
Reports of compliance (ROCs) Asian Development Bank
In 2018, the AMLC’s Compliance (ADB) Customer Due
and Supervision Group (CSG) filed Diligence Workshop
with its Legal and Evaluation Group 19 to 20 March 2018
(LEG) ROCs against 31 banks for late Tagaytay City, Philippines
submissions of CTRs. The LEG then
assessed the ROCs to determine if With support from ADB, the AMLC
formal administrative charges against facilitated the harmonization
covered persons must be filed. workshop of the AML guidelines
for the BSP, SEC, and IC,
Compliance-checking resulting to enhancements of and
The AMLC and PAGCOR conducted commitments to the guidelines.
a joint onsite examination of one
of the major casinos in the country. Covered persons
Compliance with AML/CTF policies was Quarterly meetings with the
checked, focusing on the assessment Association of Bank Compliance
of the adequacy and effectiveness of: Officers, Inc. (ABCOMP) and
• Board of directors and senior representatives of MSBs
management oversight
• MLTFPP Through regular meetings, the
• Internal control and audit AMLC gleans insights from the
• Customer identification and ABCOMP and representatives
due diligence processes of MSBs that could help enhance
4
• Oversight of casino policies, rules, and regulations,
marketing arrangement which would further prevent
(junket operation) the country from becoming a
• Risk assessment/profiling, covert for laundering proceeds
ongoing monitoring of from unlawful activities and for meetings
customers’ accounts and terrorist financing. with ABCOMP
4
casino transactions
• Monitoring and reporting In turn, policy compliance and
of covered and awareness are encouraged as
suspicious transactions issuances by the AMLC and
• Recordkeeping management other supervising agencies are meetings
• Compliance with the continuing discussed and clarified during with MSBs
education and training program these meetings.

CAPACITY BUILDING
Supervising agencies
Regulatory Exchange Program (REP) Study Tour at the Casino
19 to 23 February 2018 Regulatory Authority of Singapore
Sydney, Australia 19 January 2017
Singapore
19 to 23 March 2018
Manila, Philippines In drafting the Philippines’
AML/CTF policies for casinos, the
An initiative under the AAPP, the AMLC Secretariat looked into
REP focuses on bilateral knowledge- Singapore’s supervision of
sharing and in in-depth consideration casinos and implementation of
on casino regulatory issues of mutual relevant regulations.
priority, including:
Covered persons
• Risk-based supervision AML/CTF Lecture Caravan
models, including
development of sectoral/ The AMLC conducted nationwide AML/
thematic risk assessments CTF trainings for banks and MSBs.
• Regulation of the gaming sector
in each respective jurisdiction ADB AML/CTF trainings for MSBs
• Consideration of relevant and
appropriate legislation and With technical assistance from
regulation of relevant services ADB Office of Anti-Corruption and
Integrity, AMLC conducted training
Training on the AMLA, as amended; on the AMLA and BSP regulations
2016 RIRR; Financial Investigation; for MSBs.
and Legal Remedies for SEC
conducted by the AMLC Secretariat AMLC Secretariat personnel
13 to 15 September 2017 OCC AMLC School for
Manila, Philippines Foreign Bank Supervision
(AML/CTF Course)
Training on the AMLA, as 6 to 19 July 2017
amended; and the Casino IRR Washington DC, USA
for PAGCOR, CEZA, and APECO
conducted by the AMLC Secretariat Training CIRR-Casino AML/CTF
23 to 25 October 2017 23 to 25 October 2017
Manila, Philippines Manila, Philippines 

7-8 Aug 2017

AML/CTF Lecture Caravan
13-14 Oct 2017
2017
2018
LAOAG ADB AML/CTF Trainings for MSBs

2018
12-13 Jan 2017 14-15 Dec 2017

PAMPANGA 18-19 Jan 2018
17-18 May 2018
6-7 Dec 2018 BSP MANILA
TAGAYTAY
26-27 Jul 2018
NAGA
16-17 Aug 2018
ROXAS
16-17 Mar 2017
CEBU
27-28 Oct 2017
15-16 Mar 2018

DUMAGUETE
19-20 Apr 2018

CAGAYAN DE ORO
18-19 Oct 2018 17-18 Nov 2017

DAVAO
ZAMBOANGA

SECOND NATIONAL
RISK ASSESSMENT
(NRA) ON MONEY
First NRA LAUNDERING AND
Memorandum Circular
No. 64 dated 20 June 2014
issued by the Office of the
TERRORIST FINANCING
President enjoined 39 government
agencies to participate in the
conduct of the First NRA with actions
coordinated through the AMLC.
In 2016, the Philippines concluded

its First NRA, covering 2011 to
2014. The identified ML threats are
predominantly from the proceeds- Recommendation 1
generating predicate offenses, of the FATF 40 Forty
T
such as drug trafficking, investment he Philippine NRA is a Recommendations
scams, and corruption. Criminals government-wide evaluation Assessing risks and applying a
mainly use banks, securities, of the overall exposure of the risk-based approach, where countries
remittance agencies, and foreign country to ML and its related should identify, assess, and understand
exchange dealers to channel the predicate offenses, terrorism, and TF. their ML/TF risks; designate an
illegal proceeds. Thus, these sectors authority or mechanism to coordinate
have imposed stricter measures and As lead agency, the AMLC steered actions to assess risks, and apply
enhanced coordination with covered various government offices, LEAs, resources to mitigate these risks; apply
persons under the supervision of the and private organizations through a risk-based approach to ensure that
BSP and the SEC. the Second NRA, identifying ML/ measures to prevent or mitigate ML
TF risks within the realm of the and TF are commensurate with the
LEAs, supervised sectors, financial risks identified; and require financial
institutions, and covered persons institutions and DNFBPs to identify,
and entities under the AMLA, as assess, and take effective action to
amended. Approved in November mitigate their ML/TF risks
2017, the Second NRA covers the
period 2015 to 2016. 
COMPONENTS OF THE ASSESSMENT

Sectors
Assessed
Banks
NATIONAL ML/TF NATIONAL ML/TF LEVEL OF
THREAT VULNERABILITY ML/TF RISK
Gauge the
ML/TF risk
Analyze Consider sectoral of financial
Securities Insurance
generation, flows, vulnerability and inclusion
and patterns of national AML and (effective access
proceeds of crimes CTF defense and wide range
from different mechanisms in place of financial
sector perspectives services)
in the country
Other financial Designated non-
financial businesses 2ND NRA
institutions RESULTS HIGH MEDIUM MEDIUM HIGH
(OFIs) and professions
(DNFBPs)

SECOND NRA
NATIONAL ML THREAT
Modified World Bank Tools
• Assess the overall threat HIGH HIGH MEDIUM
and effectiveness of the AML
mechanisms in place
• Identify the gaps within the
Threats
existing AML systems of
the sectors arising
• Assess the impact of a from Dangerous Plunder and Anti-Graft Web-related
certain sector to the overall predicate Drugs Law and Corrupt Practices Crimes
sectoral ML vulnerability crimes Violations Act Violations
• Assess the ability of the sectors
to address cross-border threats
• Require OFIs and DNFBPs
to use the World Bank tools
to assess specific AML Investment Fraud Tax Crimes Trafficking
controls similar to that of and Estafa in Persons
the banking, securities, and
insurance sectors
• Assess the overall threat and
vulnerability of jurisdiction to
terrorism and TF Smuggling Copyright Infringement/
Intellectual Property Kidnapping
Law Violations for Ransom
Quantitative Research
• Statistics from periodical
reports and submissions
of LEAs, GAs, private
entities, association, and Illegal Manufacture Environmental
covered persons and Possession of Crimes
• AMLC and other Firearms, Ammunition,
government databases and Explosives
Qualitative Research
• Purposive sampling, where
respondents are selected
on the basis of knowledge, Sectoral
connection, and judgment in
relation to ML/TF assessment
threats Banks MSBs Securities
• Survey across
financial institutions
• Interviews with different sectors
DNFBPs NPO Insurance

Action Plans
• Obtain commitment of same account and in various withdraw huge amounts of
relevant GAs to collect related accounts; and financial funds in cash
data on proceeds of crimes capacity and relations of parties • Provide a venue for covered
involved in their respective to transactions, involving huge persons and supervising
agencies amounts of funds authorities to share ML
• Conduct frequent bilateral • Require covered persons trends and typologies
coordination workshop to monitor and conduct • Facilitate sharing of client
between AMLC and other enhanced due diligence information among covered
relevant LEAs on account holders who persons across different
• Require covered persons to use their bank accounts as sectors, subject to prevailing
conduct enhanced profiling of a temporary repository of rules on confidentiality
clients focused on beneficial huge amounts of funds or • Conduct an in-depth study on
ownership and legal existence; as pass-thru accounts; and the ML/TF vulnerability of the
transaction patterns in the who deposit and immediately NPO sector

SECOND NRA
SECTORAL VULNERABILITY
MEDIUM HIGH
NATIONAL ML
1ST NRA 2ND NRA
VULNERABILITY
SECTORS
BANKING
2011-2014
MEDIUM
2015-2016
MEDIUM
MEDIUM
SECURITIES MEDIUM MEDIUM Priority National Vulnerability
INSURANCE MEDIUM MEDIUM AML controls
OTHER FINANCIAL INSTITUTIONS  National AML policy
MSBs MEDIUM HIGH and strategy
 CDD framework
Pawnshops MEDIUM MEDIUM HIGH
 Capacity and resources
NSSLAs (assessed based MEDIUM for financial investigators
Lending and Finance on products) MEDIUM and prosecutors
E-money Issuers MEDIUM  Capacity and resources
DNFBPs for judicial processes
 Quality of customs and
Casino VERY HIGH HIGH border controls
Real Estate MEDIUM HIGH MEDIUM
Dealers in Precious Metals MEDIUM HIGH MEDIUM Action Plans
Lawyers, Notaries MEDIUM MEDIUM  Develop NACS
 Conduct trainings on
Accountants MEDIUM MEDIUM
financial investigation
Trusts MEDIUM LOW assessed under banking techniques, ML trends
Company Service Providers MEDIUM MEDIUM and typologies, and asset
Car Dealers MEDIUM HIGH MEDIUM forfeiture
 Strengthen effective and
timely coordination with
FINANCIAL INCLUSION PRODUCTS LEAs, GAs, and covered
PRODUCT ML RISK TF RISK persons
 Strengthen border controls
Microfinance Loans Low Low
 Conduct trainings on AML/
Microdeposits Low Low CTF and ML/TF cross-
Microinsurance Low Low border typologies
Electronic Money Low Low  Revisit customs laws and
Pawning Low Low regulations
 Set financial inclusion as a
Remittance thru pawnshops Low to Medium Low to Medium strategic objective
 Propose the inclusion of tax
evasion and other tax-related
crimes as predicate offenses
to ML under the AMLA, as
Priority amended, pursuant to the
Sectors recommendation of the FATF
Casinos MSBs
Pawnshops Banks E-Money

Issuers

SECOND NRA
OVERALL TERRORISM AND

TERRORIST FINANCING THREAT
HIGH
Sources of funds Use of funds
1,039
Predominantly from incidents were
illegal means, such as Operational purposes, such as
kidnap for ransom. purchase of arms and vehicles
committed
by terrorists/
threat groups
from
Legitimate means
through the use of 2014 to 2016
NPOs, family funding, Support for the communities,
and legitimate where they operate, as the
business fronts groups provide the basic needs,
livelihood support, and even
educational opportunities for
these communities, and, in turn,
the communities shield them
Funding from external from government forces even
terrorist groups if they know the nature and
source of funds
Channels/ Identified
modes of hotspots are
transactions
mostly in
Bulk cash transactions Remittance agencies
Southern
Philippines.
Vulnerabilities
Geographic Adequacy
Low STRs
factors of resources

NATIONAL AML/CFT
STRATEGY (NACS)
O
n 12 Nov 2018, the Office of FATF 40 Recommendations, particularly
the President issued EO No. Recommendation 2, and Immediate
68, approving the NACS, a Outcome 1 of the FATF Methodology.
result of collaborative efforts
of key AML/CTF agencies, including Different GAs identified action
those who participated in the first and plans, which include the
second NRA. The NACS is a coordinated amendment and passage of laws,
approach for the government and the enhancement of supervisory
private sector in combating ML and TF frameworks, strengthening ML/
in the country. It has seven strategic TF investigation and prosecution,
objectives to address the risks identified and campaigns to increase public
under the NRA. awareness. The NACS also
provides action items to address
The adoption of the NACS is also part proliferation financing as set out
of the country’s compliance with the under the FATF Standards.
National AML/CFT Coordinating

Committee (NACC)
EO No. 68 provides for the the strategic objectives and
creation of the NACC, a action plans of the NACS.
body tasked to oversee the
implementation of the NACS NACC Subcommittees
and its action plans. The AMLC is • Financial Intelligence, Law
designated as the committee’s Enforcement, and Prosecution
Secretariat, responsible for • Supervision of
monitoring the duties and Financial Institutions
responsibilities of the NACC and • Supervision of DNFBPs
the sub-committees, which will • TF and Proliferation Financing
be the primary implementers of • AML/CTF Awareness
Recommendation 2 of the FATF Immediate Outcome

40 Recommendations 1 of the FATF Methodology
National Cooperation and ML/TF Risk and
Coordination, where countries Understanding, where countries
should have national AML/CTF should have understood their ML/
policies, designate an authority, TF risks and have domestically
and have coordination coordinated actions to combat ML, TF,
mechanisms for effective and proliferation financing
coordination and cooperation
among policymakers, FIUs,
LEAs, supervisors, and other
competent authorities

NACS
STRATEGIC
OBJECTIVES
Enhance the Philippine
AML/CTF legal
framework to address
the country’s ML/TF
risks and the deficiencies
in the country’s
compliance with
international standards

Strengthen the AMLC
and its capacity for
ML/TF intelligence-
gathering, investigations,
and prosecutions

Improve capacity and 2018 TO 2022 AML/CFT
collaboration among CAPACITY BUILDING
the FIU, LEAs, and
prosecutors for the
ROADMAP (ACBR)
effective investigation
Council approval 15 August 2018
and prosecution of, as
well as the confiscation of
In line with strategic objectives 2,
proceeds relating to ML,
3, 6, and 7 of the NACS, the ACBR
its predicate offenses,
aims to develop AML/CTF regulators
terrorism, and TF
and practitioners and to strengthen

covered persons and institutions
Enhance AML/
tasked to ensure that the country
CTF regulation and
is not used as an ML, TF, and
supervision framework to
proliferation financing site. 
ensure an effective and
robust AML/CTF system
in supervised institutions TRAINING NEEDS ANALYSIS
To identify potential training interventions
Develop and strengthen for the AMLC’s investigators, intelligence
mechanisms to prevent, officers, and compliance personnel to
disrupt, and combat address gaps noted in the NRA, which
terrorism, TF, and require immediate attention
proliferation financing

Strengthen domestic and
international cooperation MULTI-PRONGED APPROACH
mechanisms for the
effective exchange of
information; facilitate
actions against criminals
and their assets; and
assist in the capacity
building of relevant GAs
IMPROVED
MANPOWER SKILLS TOOLS
Promote AML/CTF COMPLEMENT ENHANCEMENT REINFORCEMENT AML/CFT
awareness of GAs, CAPACITY
covered persons and
the general public

THIRD MUTUAL
EVALUATION (ME)
T
he Philippines is undergoing
the third round of ME to
gauge the country’s levels
of technical compliance with
international AML/CTF standards; and
effectiveness of the country’s existing
AML/CTF system. The country, along
with 12 other jurisdictions, is a founding
member of the APG, created in 1997
in Bangkok, Thailand. To date, the
APG, an autonomous and collaborative
international organization, has 41
members, who all commit to a mutual
peer review system.
In a Memorandum dated 22 February

2018, the Executive Secretary, Office
of the President of the Philippines,
designated the AMLC, as the lead
2009 ME agency for the 2018 ME and enjoined
The Philippines has all departments, bureaus, offices, and
come a long way from agencies of the Executive Branch,
the second ME in 2009. In including government financial
2013, the country was removed institutions and government-owned
from the gray list of the FATF’s or -controlled corporations, to be
International Co-operation identified by the AMLC to actively
Review Group (ICRG), which participate and extend the necessary
analyzes high-risk jurisdictions assistance in the conduct of the ME.
and recommends specific
actions to deal with the ML/TF Pursuant to the authority from
risks, as most of the deficiencies the Office of the President, the
identified in the second ME AMLC issued the ME Operational
have been addressed, such as Guidelines, creating working and
the passage of RA No.10168 or sub-working groups; identifying the
TFPSA. In addition, the passage functions and obligations of member-
of RA No.10365, which further agencies with respect to the ME ME Portal
amended AMLA, strengthened process; outlining the ME process; The AMLC
the powers of the AMLC and providing timelines; enumerating the created a secure online
expanded the list of predicate effects of a “non-compliant” or “poor” portal to share with the ME team
offenses in accordance with ME; and laying down the framework documents, containing AMLC’s
FATF-designated categories toward the adoption of the NACS. responses, comments, and their
of offenses. corresponding attachments.
The results of the third ME will be
deliberated upon and published
in 2019. 

THIRD ME
PHASES OF THE ME
Technical
Effectiveness
compliance
assessment
assessment
Involves a report of Involves a report on

technical compliance, the adequacy of the
submitted on 4 May 2018, implementation of the FATF
which checks whether Standards and effectiveness
existing laws, regulations, of the country’s existing
legal issuances, and AML/CTF system,
enforceable means submitted on 30 July 2018,
comply with the FATF which was validated during
Standards and its criteria the onsite visit from 14 to
28 November 2018 by the
Four possible levels of APG ME team, consisting of
compliance legal, financial, regulatory,
o Compliant FIU, and law enforcement
o Largely compliant experts through a series
o Partially compliant of interviews with local
o Non-compliant supervisors, government
and law enforcement
agencies, and private
stakeholders concerned
ME Support
To equip the country for the third ME, AUSTRAC, Australia’s financial
intelligence agency, held workshops, allowing participants from government
offices, LEAs, and private stakeholders to work together to prepare, address gaps,
and collect information.
ACTIVITY DATES
Mutual Evaluation Workshop 24 to 26 April 2017
Pre-ME Workshop (joint with APG) 7 to 9 March 2018
Mock Onsite Interviews 28 to 31 August 2018
17 to 21 September 2018
23 to 25 October 2018

ACRONYMS
AAPP AMLC-AUSTRAC Partnership Program
ABCOMP Association of Bank Compliance Officers, Inc.
ACBR AMLC Capacity Building Roadmap
ADB Asian Development Bank
AEP Analyst Exchange Program
AFP Armed Forces of the Philippines
AGA Appropriate Government Agency
AML Anti-Money Laundering
AMLA Anti-Money Laundering Act
AMLC Anti-Money Laundering Council
APECO Aurora Pacific Economic Zone and Freeport Authority
APG Asia/Pacific Group on Money Laundering
APO Asset Preservation Order
ARRG AMLC Registration and Reporting Guidelines
ARRGC ARRG for Casinos
ASEAN Association of Southeast Asian Nations
ASG Abu Sayyaf Group
ATC Anti-Terrorism Council
ATC-PMC ATC-Program Management Center
ATM Automated Teller Machine
AUSTRAC Australian Transaction Reports and Analysis Centre
BI Bureau of Immigration
BJMP Bureau of Jail Management and Penology
BSP Bangko Sentral ng Pilipinas
BTr Bureau of Treasury
CA Court of Appeals
CDD Customer Due Diligence
CEDAW UN Convention on the Elimination of All Forms of Discrimination against Women
CEZA Cagayan Economic Zone Authority
CFT Combatting/Countering the Financing of Terrorism
CIRR Casino Implementing Rules and Regulations
CPA Certified Public Accountant
CSG Compliance and Supervision Group
CSM Compliance and Supervision Manual
CTF Counter-Terrorism Financing
CTR Covered Transaction Report
DICT Department of Information and Communications Technology

DIGICUR Digitization of Customer Records
DMS Document Management System
DNFBP Designated Non-Financial Business and Profession
DOJ Department of Justice
DOJ-OOC DOJ Office of Cybercrime
DTI Department of Trade and Industry
EO Executive Order
ESW Egmont Secure Web

FATF Financial Action Task Force
FBI Federal Bureau of Investigation
FIAC Financial Intelligence Analysis Course
FIAG SOP Financial Intelligence Analysis Group Standard Operating Procedure
FICG Financial Intelligence Consultative Group
FINCEN Financial Crimes Enforcement Network
FIU Financial Intelligence Unit
FSCC Financial Stability Coordination Council
GA Government Agency
GAA General Appropriations Act
GAD Gender and Development
GFPS GAD Focal Point System
GPB GAD Plan and Budget
IACAT Inter-Agency Council Against Trafficking

IBP Integrated Bar of the Philippines
IC Insurance Commission
ICAD Inter-Agency Committee against Drugs
ICRG International Co-operation Review Group
ICT Information and Communications Technology
IMF-STI International Monetary Fund-Singapore Regional Training Institute
IRR Implementing Rules and Regulations
ISAFP Intelligence Service of the AFP
ACRONYMS
ACRONYMS
ISP Information-Sharing Protocol
IT Information Technology
JTFIG Joint Terrorism Financing Investigation Group
KYC Know Your Customer
LEA Law Enforcement Agency

LEG Legal and Evaluation Group
LRA Land Registration Authority
LTO Land Transportation Office
MAEP Multilateral Analyst Exchange Program

MCW Magna Carta of Women
ME Mutual Evaluation
ML Money Laundering
MLA Mutual Legal Assistance
MLAT Mutual Legal Assistance Treaty
MLTFPP Money Laundering/Terrorism Financing Prevention Program
MOA Memorandum of Agreement
MOU Memorandum of Understanding
MSB Money Service Business
NACS National AML/CFT Strategy

NACC National AML/CFT Coordinating Committee
NALECC National Law Enforcement Coordinating Committee
NALECC SCAML/CFT NALECC Sub-Committee on AML/CFT
NBI National Bureau of Investigation
NGO Non-Government Organization
NICA National Intelligence Coordinating Agency
NPC National Privacy Commission
NPO Non-Profit Organization
NRA National Risk Assessment
NSSLA Non-stock Savings and Loan Association
OFI Other Financial Institutions

OMB Office of the Ombudsman
OSG Office of the Solicitor General
PADS Philippine Anti-Drugs Strategy

PAGCOR Philippine Amusement and Gaming Corporation
PCOR Provisional Certificate of Registration
PCTC Philippine Center on Transnational Crime
PDAF Priority Development Assistance Fund
PDEA Philippine Drug Enforcement Agency
PHP Philippine Peso
PICC Philippine International Convention Center
PLLO Presidential Legislative Liaison Office
PNP Philippine National Police
PPATK Pusat Pelaporandan Analisis Transaksi Keuangan/Financial Transaction Reports and Analysis Centre
PPGD Philippine Plan for Gender-Responsive Development
PPPP Public-Private Partnership Program
QMS Quality Management System
RA Republic Act
REP Regulatory Exchange Program
RFI Request for Information
RIAS Rules on the Imposition of Administrative Sanctions
RIRR Revised Implementing Rules and Regulations
ROC Report of Compliance
RTC Regional Trial Court
SEC Securities and Exchange Commission

STR Suspicious Transaction Report
TF Terrorism Financing
TFPSA Terrorism Financing Prevention and Suppression Act of 2012
UN United Nations
UNCAC United Nations Convention against Corruption
UNODC United Nations Office on Drugs and Crime
US/USA United States of America
USD United States Dollar
VC Virtual Currency
GLOSSARY
Covered Persons (1) Banks, non-banks, quasi-banks, trust entities, Notwithstanding the foregoing, the term ‘covered
foreign exchange dealers, pawnshops, money persons’ shall exclude lawyers and accountants
changers, remittance and transfer companies acting as independent legal professionals in
and other similar entities, and all other persons relation to information concerning their clients
and their subsidiaries and affiliates supervised or or where disclosure of information would
regulated by the BSP; compromise client confidences or the attorney-
client relationship: Provided, that these lawyers
(2) Insurance companies, pre-need companies, and accountants are authorized to practice in the
and all other persons supervised or regulated by Philippines and shall continue to be subject to the
the IC; provisions of their respective codes of conduct
and/or professional responsibility or any of its
(3) (i) Securities dealers, brokers, salesmen, amendments.
investment houses, and other similar persons
managing securities or rendering services as (8) Casinos, including internet- and ship-based
investment agent, advisor, or consultant, (ii) casinos with respect to their casino cash
mutual funds, close-end investment companies, transaction related to their gaming operations
common trust funds, and other similar persons,
and (iii) other entities administering or otherwise
dealing in currency, commodities, or financial
derivatives based thereon, valuable objects, Covered Transaction (1) A transaction in cash or other equivalent
cash substitutes, and other similar monetary monetary instrument exceeding PhP500,000;
instruments or property supervised or regulated
by the SEC; (2) A transaction with or involving jewelry dealers,
dealers in precious metals, and dealers in precious
(4) Jewelry dealers in precious metals, who, as a stones in cash or other equivalent monetary
business, trade in precious metals for transactions instrument, exceeding PhP1,000,000; and
in excess of PHP1,000,000;
(3) A casino cash transaction, exceeding PhP5,000,000.
(5) Jewelry dealers in precious stones, who, as a or its equivalent in other currency.
business, trade in precious stones for transactions
in excess of PhP1,000,000;
Suspicious Transaction A transaction, regardless of amount, where any of
the following suspicious circumstances, is
(6) Company service providers which, as a
determined, based on suspicion or, if available,
business, provide any of the following services
reasonable grounds, to be existing:
to third parties: (i) acting as a formation agent
of juridical persons; (ii) acting as (or arranging
• There is no underlying legal or trade
for another person to act as) a director or
obligation, purpose, or economic justification.
corporate secretary of a company, a partner of
• Client is not properly identified.
a partnership, or a similar position in relation to
• Amount involved is not commensurate
other juridical persons; (iii) providing a registered
with the business or financial capacity of
office, business address or accommodation,
the client.
correspondence or administrative address for a
• It may be perceived that the client’s
company, a partnership, or any other legal person
transaction is structured to avoid being the
or arrangement; and (iv) acting as (or arranging for
subject of reporting requirements under
another person to act as) a nominee shareholder
the AMLA.
for another person; and
• Any circumstance relating to the transaction
deviates from the profile of the client and/
(7) Persons who provide any of the following or the client’s past transactions with the
services: covered institution.
• The transaction is in any way related to
(i) Managing of client money, securities, or an unlawful activity or offense under the
other assets; AMLA that is about to be, is being, or has
been committed.
(ii) Management of bank, savings, or securities • The transaction is similar or analogous to
accounts; any of the foregoing.
(iii) Organization of contributions for the creation, Threats Scale and characteristics of the proceeds of
operation, or management of companies; and criminal activities or terrorism financing in the
jurisdiction.
(iv) Creation, operation, or management of juridical
persons or arrangements, and buying and selling Vulnerabilities Weaknesses or gaps in a jurisdiction’s defenses
business entities. against ML and TF
EDITORIAL BOARD
Mel Georgie B. Racela

Chairperson
Ma. Rhea M. Santos-Mendoza

Vice Chairperson
Matthew M. David
Jerry L. Leal
Alvin L. Bermido
Members
EDITORIAL STAFF
Ma. Rhea M. Santos-Mendoza

Editor in Chief
Sarabeth R. D. Aunario
Managing Editor
Ann Grace L. Pacis

Copy Head
Mary-Joy J. Gache-Marasigan
Copy Editor
Kristine B. Patilleros-Bitancur
Ma. Cielito Carmela Gabrielle G. Mateo
Raymond R. Cruz
Ronaldo C. Velasco
Mary Kryslette C. Bunyi
Roxanne Therese C. Layno
Contributors
Janice H. Garcia
Layout Artist
Virginia A. Tamondong
Editorial Assistant
amlc.gov.ph

THE 2017-2018 Annual: Sustainable Transformation

Uploaded by

Document Information

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

THE 2017-2018 Annual: Sustainable Transformation

Uploaded by

Copyright:

Available Formats

THE

The AMLC Secretariat

© 2018 Anti-Money Laundering Council

To protect and preserve the integrity and confidentiality of

To ensure that the Philippines shall not be used as a money

To extend cooperation in transnational investigation and

AMANDO M. TETANGCO JR. ATTY. TERESITA J. HERBOSA

Former Chairman Tetangco served as As the former Chairperson of the

Benjamin E. Diokno, PhD Atty. Emilio B. Aquino About the

Atty. Dennis B. Funa Atty. Mel Georgie B. Racela

SUSTAINABLE TRANSFORMATION TOWARD…

BENJAMIN E. DIOKNO, PhD ATTY. DENNIS B. FUNA

8 2017-2018 ANNUAL REPORT

ATTY. EMILIO B. AQUINO, ATTY. MEL GEORGIE B. RACELA,

2017-2018 ANNUAL REPORT 9

10 2017-2018 ANNUAL REPORT

2017-2018 ANNUAL REPORT 11

FINANCIAL INTELLIGENCE ANALYSIS

2018 Php 48.856

NUMBERS +7 -hectare land

INVESTIGATION AND PROSECUTION

148 investigation reports Php 1,009,116,707

12 2017-2018 ANNUAL REPORT

2017-2018 ANNUAL REPORT 13

Counseling, Adjudication, and

DETECTION AND PREVENTION

2018 ORGANIZATIONAL CHART

DETECTION AND INVESTIGATION AND

2017-2018 ANNUAL REPORT 15

NATIONAL GOVERNMENT BUDGET UTILIZATION

16 2017-2018 ANNUAL REPORT

CPA/ CPA/ CPA/

2017-2018 ANNUAL REPORT 17

STR AND CTR COLLECTION

18 2017-2018 ANNUAL REPORT

24/7 Security System

To ensure protection against security

ENCRYPTION AMLC PORTAL AMLC DATABASE

2017-2018 ANNUAL REPORT 19

FINANCIAL INTELLIGENCE ANALYSIS

20 2017-2018 ANNUAL REPORT

Information used in Financial Intelligence No. of Financial Intelligence

Information used in Financial Intelligence No. of Financial Intelligence

2017-2018 ANNUAL REPORT 21

22 2017-2018 ANNUAL REPORT

ML/TF vulnerability Medium

AML/CTF understanding Moderate

Controls in place Generally Effective

Regulated financial channels Generally Utilized

Overall NPO risk to ML Medium

Overall NPO risk to TF Low Medium

Recommendations* between the NPO sector

2017-2018 ANNUAL REPORT 23

Philippines to threats, originating STRATEGIC STUDIES

24 2017-2018 ANNUAL REPORT

What a more comprehensive

2017-2018 ANNUAL REPORT 25

Towards Deepening Regulatory • Majority of the bases for

26 2017-2018 ANNUAL REPORT

for FIU heads; facilitating proactive

2017-2018 ANNUAL REPORT 27

COMPLEX NETWORK The MAEP

used, and previously unknown