2022arrgcourse 230117 101255

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AMLC

ONLINE
REGISTRATION
SYSTEM
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Who are required to register?
- Registration with AMLC is mandatory for
Covered Persons (CPs) under the Anti-Money

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encryption Laundering Act of 2001, as amended.
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Why CPs need to register?


- Registration with AMLC will enable CPs to
electronically submit their reportable
transactions (C/STRs) through the AMLC
Portal.
Required Attachments

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Compliance Officer’s /
Real Estate Broker’s
Key ID
Supporting Documents

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Bangko Sentral ng Securities and Insurance


Pilipinas Exchange Commission
Commission

Land Based Casinos


Supporting Documents
For CPs regulated by the BSP, SEC, IC and
for Land-Based Casinos
a. Notarized Secretary Certificate or Board /
Partnership Resolution showing the

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Compliance Officer’s designation.


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or
b. Certificate of Associated Persons for APs of
Brokerage Companies.
or
c. DTI Certificate for Pawnshops/Money Service
Businesses (PS/MSB) registered as Single
Proprietorship as well as a document, notarized
and signed by the owner designating the CO, if
the CO is not the owner of the PS/MSB.
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D N F B P

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Non
F inancial
Professions
D esignated

Businesses and

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DN F BP

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• Jewelry dealers, dealers in precious metals, and dealers
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in precious stones;
• Company service providers who provide services as
enumerated in the 2021 DNFBP Guidelines;
• Real Estate Brokers and Developers;
• Offshore Gaming Operators, as well as their service
providers, supervised, accredited or regulated by the
PAGCOR; and
DN F BP
• Persons, including lawyers and accountants, who

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provide any of the following services:
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1. Managing of client money, securities or other


assets;
2. Management of bank, savings, securities or
accounts;
3. Organization of contributions for the creation,
operation or management of companies; and
4. Creation, operation or management of juridical
persons or arrangements, and buying and selling
business entities.
Supporting Documents
DN F BP

attachments
a) Most recent Articles of Incorporation and
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General Information Sheet from the Securities


and Exchange Commission (SEC), Certificate
of Registration from the Department of Trade
and Industry (DTI); or proof of registration with
the Cooperative Development Authority (CDA);
Real Estate Brokers’ Certificate of Registration
or License from the Professional Regulation
Commission (PRC);
Supporting Documents
DN F BP

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b. Notarized Deeds of Undertaking of the entity,
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signed by the proprietor / partners / president /


directors (Annexes B and C, of the 2021
AML/CFT Guidelines for DNFBPs); and

c. Notarized Board resolution or Certificate of


designation as Compliance Officer.
Tip: All supporting documents must be scanned
together in one PDF or zipped file.
Required Attachments: Key ID
Compliance Officer’s / Real Estate
Broker’s Public Key

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• Compliance officer (CO) must create a Key ID under


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his/her name through the Kleopatra Software (for


Windows) or GPG Suite (for MacOS) to be exported
and likewise attached in the ORS.

• Alternate Officers registration and Key ID is optional.

Tip: If the you have been designated as the compliance


officer for several institutions, you may use the same
key ID that you have created for all the institutions.
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What is Encryption?

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Encryption

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Encryption

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Encryption

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Encryption

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Encryption

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Encryption

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Asymmetric Encryption

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STEP BY STEP PROCEDURE

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Installing the Creating Key Online


GPG software Pair Registration
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Installing the
GPG software

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STEP BY STEP PROCEDURE

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Installing the Creating Key Online


GPG software Pair Registration
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Creating Key Pair


STEP BY STEP PROCEDURE

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certificate Creating Key Pair for MacOS
STEP BY STEP PROCEDURE

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certificate Creating Key Pair for MacOS
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certificate Creating Key Pair for MacOS
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certificate Creating Key Pair for MacOS
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STEP BY STEP PROCEDURE

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STEP BY STEP PROCEDURE

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Installing the Creating Key Online


GPG software Pair Registration
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Online Registration
STEP BY STEP PROCEDURE

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Provisional Certificate of Registration

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Certificate of Registration
Provisional Certificate of Registration
• A Provisional Certificate of Registration
(PCOR) shall be issued to the DNFBP upon
its successful registration via the AMLC’s

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Online Registration System.
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• The PCOR is valid for six (6) months, unless


the AMLCS Executive Director or Officer-in-
Charge grants a one-time extension for up to
six (6) months, upon written request with
justification.
Certificate of Registration for DNFBPs
The AMLC shall issue a Certificate of
Registration (COR) upon determination of
complete submission of the following
documentary requirements in addition to those

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attached in the provisional registration:
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a. Copy of business registration or permit from


the city or municipality currently having
jurisdiction over the place of establishment
and operation of the office;

b. List of operating office locations;


Certificate of Registration for DNFBPs
c. Proof of attendance of the proprietor,
partners, directors and principal officers in
an AML seminar; and

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d. Most recent Clearance from the National


Bureau of Investigation (NBI) or its
equivalent in a foreign jurisdiction, of all
directors and principal officers.

Tip: Please may email the additional


documents to any of the registration staff of
the AMLC.
Common Mistakes
➢ Attaching the AMLC.asc file instead of the key ID of
the Compliance Officer;

➢ Incomplete documentary requirements;

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➢ Board Resolution or Secretary’s Certificate is not
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notarized;

➢ Unverified email address of the Compliance/Alternate


Officer;

➢ Incorrect/incomplete name of Compliance Officer; and

➢ Putting your employer’s name under the institution


name field (for real estate brokers).
AMLC Secretariat - Registration Staff

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(02) 5302-3848; 8708-7067

contact
Atty. Rafael Echaluse Conrad Bulanadi
rechaluse@amlc.gov.ph cbulanadi@amlc.gov.ph
0927-169 7198 0915-778 0720

Catherine Masaoay Christian Ray Canalita


cmasaoay@amlc.gov.ph ccanalita@amlc.gov.ph
0960-690 8794 0968-772 7045
AMLC Transaction Reporting
AMLC REGULATORY ISSUANCE NO. 4
Series of 2021
 The 2021 AMLC Registration and Reporting Guidelines (ARRG) is
the AMLC’s comprehensive effort to provide the legal and policy
framework for registration by covered persons into the AMLC’s online
system, and to ensure proper and timely compliance with reporting
procedures.

 The ARRG consists of the following:


 Part 1 – General Provisions
 Part 2 – Online Registration System
 Part 3 – Transaction Security Protocol
 Part 4 – Reporting Procedures including Annexes
SALIENT FEATURES ON AMLC REPORTING

 Timing and Manner of Submission of Covered Transaction


Reports (CTRs)

 Submission of CTRs beyond 12:01 am of the day following


the 5th working day from occurrence of the transaction shall
be considered as non-compliance with the requirement to file
CTRs in accordance with the standard set by the AMLA
SALIENT FEATURES ON AMLC REPORTING

 Timing and Manner of Submission of Suspicious


Transaction Reports (STRs)

 Covered Persons shall report to the AMLC all suspicious


transactions within the next working day from the occurrence
thereof.

 “Occurrence” shall refer to the date of establishment of suspicion


or determination of the suspicious nature of the transaction.
SALIENT FEATURES ON AMLC REPORTING

 Low-risk Covered Transactions

 Updated list of reason for suspicion including the two (2)


new predicate crimes:

 PC34 – Violation of Section 19(A)(3) of RA 10697, otherwise


known as the Strategic Trade Management Act

 PC35 - Violations of Section 254 of Chapter II, Title X of the


National Internal Revenue Code of 1997, as amended
SALIENT FEATURES ON AMLC REPORTING

 Uploading of KYC Documents, limited to the following


predicate crimes:
 Kidnapping for Ransom
 Drug Trafficking
 Hijacking destructive arson and murder, including those
perpetrated by terrorists against non-combatant persons and
similar targets and
 Acts of terrorism
 Financing of Terrorism
 Violation of Section 19(A)(3) of RA 10697, otherwise known
as the Strategic Trade Management Act
SALIENT FEATURES ON AMLC REPORTING

 Suspicious Transaction Reporting on a per account basis

 Uploading of eReturns via the AMLC Portal

 Non-working and Non-reporting Days

 New Transaction Codes


SALIENT FEATURES ON AMLC REPORTING

EFFECTIVE: JANUARY 9, 2022

 Lifting of Loan Payment as a deferred for reporting as a


CTR;

 STR trigger in the reporting of STRs

 Updated of Country and Currency codes


SALIENT FEATURES ON AMLC REPORTING

EFFECTIVE: JANUARY 9, 2022

 Guidelines for Format 1


 Letter U - Loan Availment Transactions, wherein amount to
be indicated in the Transaction Amount (D-7) is the amount
released to the borrower and approved loan amount at D-15
Field

 Letter V - Sale of ROPA, wherein amount to be indicated in


the Transaction Amount (D-7) is the amount received from the
buyer and amount of ROPA at D-15 Field
Hardware/Software Requirements Report Creation Submission

!
AMLC Transaction Reporting requires a certain degree of
computer skills.
Hardware/Software Requirements Report Creation Submission

HARDWARE
REQUIREMENTS
Hardware/Software Requirements Report Creation Submission

Computer System

Internet Connection
Wired network/WiFi/portable broadband/DSL
Hardware/Software Requirements Report Creation Submission

SOFTWARE
REQUIREMENTS
Hardware/Software Requirements Report Creation Submission

Spreadsheet Program
Microsoft Excel, iWork Numbers,
OpenOffice Calc

GNU Privacy Guard Software - Kleopatra


(Downloadable from the AMLC Website)

Internet Browser
Internet Explorer, Firefox, Chrome
Safari, Opera, Netscape
Hardware/Software Requirements Report Creation Submission

Covered Persons (CPs) must complete


the AMLC Online Registration to access
the AMLC Reporting Portal
Hardware/Software Requirements Report Creation Submission

Report Creation
Hardware/Software Requirements Report Creation Submission

Report Creation Methods

Database Extraction
(will require programming)

Manual Encoding
using a Spreadsheet program
Hardware/Software Online Registration & Transaction Security
Hardware/Software Requirements Report Creation Report Creation Submission
Submission
Requirements Protocol

Parts of an AMLC Report


Header Record
H - basic information of the reporting institution
and report file

D Detail Record
- transaction data and subject data

Trailer Record
T - report summary

Each record contains multiple fields,


! enumerated in the
Electronic Record Format table (Format 1)
Hardware/Software Online Registration & Transaction Security
Hardware/Software Requirements Report Creation Report Creation Submission
Submission
Requirements Protocol

4 Types of C/STRs

A Add

E Edit

D Delete

T Test
Hardware/Software Online Registration & Transaction Security
Hardware/Software Requirements Report Creation Report Creation Submission
Submission
Requirements Protocol

AMLC SYSTEM CODES


(Annex B of the ARRG)

AMLC Transaction Codes (page 172 to 207 in the ARRG)


C - Current Acct/Savings Acct; D - Time Deposit; F - Foreign Exchange; I - Trade; K - Credit Cards; L - Loans;
N - Insurance; R - Remittance; S - Securities; T - Treasury; U - Trust/Investment Mgmt. Acct/Custodianship;
O - Others (Dealer Precious Stones and Metals / DNFBs etc.) ); V - Virtual Asset/Currencies

Currency Codes (page 208 to 211 in the ARRG)

Country Codes (page 212 to 217 in the ARRG)


Hardware/Software Online Registration & Transaction Security
Hardware/Software Requirements Report Creation Report Creation Submission
Submission
Requirements Protocol

SYSTEM CODES
AMLC Transaction Codes B
Outward remittance (domestic) where the instruction
Outward Remittance/TT
is to credit the beneficiary's account kept in another
R RORDE (Domestic) - Credit to
bank (the beneficiary bank is different from the
Beneficiary’s Account
accountholder's bank).
RORDE
Requirements

TRANSACTION TITLE
IC (page 242-246 in the ARRG)

BSP/SEC/DNFBPs
Hardware/Software Requirements

Electronic Banking
(Domestic) Credit to
Outward Remittance

Beneficiary Account via


(D-5) ACCOUNT NO./PN NO./CLIENT

X
STOCK OR REF. NO./CREDIT CARD
ACCOUNT NUMBER
Protocol

(D-6) OLD ACCOUNT NO./PN


NO./CLIENT STOCK OR REF. NO.
BSP/SEC/DNFBPs (page 218-242 in the ARRG)

X
(D-7) PESO AMOUNT

(D-8) FX AMOUNT

(D-9) FX CODE
Report Creation

(D-10) NATURE/PURPOSE OF
Hardware/Software Online Registration & Transaction Security

TRANSACTION
D-12) MATURITY DATE / EXPIRY
DATE
(Annex C of the ARRG)

(D-13) AMOUNT OF CLAIM /


DIVIDEND
(D-14) NO. OF SHARES/UNITS

(D-15) NET ASSET VALUE


(D-16) NAME OF
X

CORRESPONDENT BANK
(D-17) ADDRESS OF
X

CORRESPONDENT BANK
X

(D-18) COUNTRY CODE


MANDATORY FIELDS and PARTIEES

(D-D-1) REASON
X

(D-D-2) NARRATIVE
Report Creation Submission

MANDATORY PARTY
A,B
Submission
Hardware/Software Online Registration & Transaction Security
Report Creation Submission
Requirements Protocol

Party Flags (BSP/SEC/DNFBPs)


Account Holder/
A I Issuer
Customer
B Beneficiary T Transactor
C Counterparty Subject of
S
Suspicion
P Other Participant

 The Party Flag S is mandatory for STRs to identify the “Subject of


Suspicion”
 Not all Parties are required across all transaction codes
Hardware/Software Online Registration & Transaction Security
Hardware/Software Requirements Report Creation Report Creation Submission
Submission
Requirements Protocol

Name Flags
N Name of Person

Y Name of Corporation

U V W X Y Z

2 A N LAST NAME FIRST NAME MIDDLE NAME


3 A Y CORP. NAME
4
Hardware/Software Online Registration & Transaction Security
Hardware/Software Requirements Report Creation Report Creation Submission
Submission
Requirements Protocol

Format of Address Fields

U V W X Y Z AA AB AC

2 A N DELA CRUZ JUAN C BLDG/ HOUSE # DISTRICT/ PROVINCE/


STREET/ BRGY TOWN/ CITY COUNTRY/
ZIP CODE

3 A Y ABC BLDG/ HOUSE # DISTRICT/ PROVINCE/ 19800101 MANILA,


CORPORATION STREET/ BRGY TOWN/ CITY COUNTRY/ PHILIPPINES
ZIP CODE

Address Flags (Y or N) are no longer needed in Format 1.0; all addresses should
be divided into three (3) fields
Hardware/Software Online Registration & Transaction Security
Hardware/Software Requirements Report Creation Report Creation Submission
Submission
Requirements Protocol

Guidelines
Transaction
Date
Transaction FX Code
Code if w/ FX
Amount

Reference Mandatory For


Account Address
Nos.
Fields Holder

Flags If STR Nationality

Header
Record
Hardware/Software Online Registration & Transaction Security
Hardware/Software Requirements Report Creation Report Creation Submission
Submission
Requirements Protocol

Encoding of Records and Fields

A B C D E F G

1 H 1 12345600000 20211201 CTR 1 A


2

4
Hardware/Software Online Registration & Transaction Security
Hardware/Software Requirements Report Creation Report Creation Submission
Submission
Requirements Protocol
Hardware/Software Online Registration & Transaction Security
Hardware/Software Requirements Report Creation Report Creation Submission
Submission
Requirements Protocol
Hardware/Software Online Registration & Transaction Security
Hardware/Software Requirements Report Creation Report Creation Submission
Submission
Requirements Protocol
Hardware/Software Online Registration & Transaction Security
Hardware/Software Requirements Report Creation Report Creation Submission
Submission
Requirements Protocol
Hardware/Software Online Registration & Transaction Security
Hardware/Software Requirements Report Creation Report Creation Submission
Submission
Requirements Protocol
Hardware/Software Online Registration & Transaction Security
Hardware/Software Requirements Report Creation Report Creation Submission
Submission
Requirements Protocol
Hardware/Software Online Registration & Transaction Security
Hardware/Software Requirements Report Creation Report Creation Submission
Submission
Requirements Protocol

File Saving
Hardware/Software Online Registration & Transaction Security
Hardware/Software Requirements Report Creation Report Creation Submission
Submission
Requirements Protocol

AML Report File Format


CSV
Comma Delimited File
Hardware/Software Online Registration & Transaction Security
Hardware/Software Requirements Report Creation Report Creation Submission
Submission
Requirements Protocol

File Saving
1

1. File, Save As
2. Directory 5
3. Filename
4. Save as CSV
5. Save
Hardware/Software Online Registration & Transaction Security
Hardware/Software Requirements Report Creation Report Creation Submission
Submission
Requirements Protocol

Filename Convention
CPs with 11-digit Institution Code

1st 6 digits of the


Institution Code Sequence No.

1234562018041901.csv

Report Date
Hardware/Software Online Registration & Transaction Security
Hardware/Software Requirements Report Creation Report Creation Submission
Submission
Requirements Protocol

Filename Convention
CPs with 18-digit Institution Code

1st 9 digits of the


Institution Code Sequence No.

1234567892018041901.csv

Report Date
Hardware/Software Online Registration & Transaction Security
Hardware/Software Requirements Report Creation Report Creation Submission
Submission
Requirements Protocol

Encryption
Hardware/Software Online Registration & Transaction Security
Hardware/Software Requirements Report Creation Report Creation Submission
Submission
Requirements Protocol

Report Encryption

1. Kleopatra
2. File
3. Sign/Encrypt
4. Locate & select file
5. Open
Hardware/Software Online Registration & Transaction Security
Hardware/Software Requirements Report Creation Report Creation Submission
Submission
Requirements Protocol

Report Encryption

6. Sign and Encrypt


7. Next
8. Anti-Money Laun...
9. Add
10. Next
Hardware/Software Online Registration & Transaction Security
Hardware/Software Requirements Report Creation Report Creation Submission
Submission
Requirements Protocol

Report Encryption

11. Select Signatory, Uncheck “Remember…”


12. Sign & Encrypt
13. Passphrase
14. OK
Hardware/Software Online Registration & Transaction Security
Hardware/Software Requirements Report Creation Report Creation Submission
Submission
Requirements Protocol

Report Encryption

15. Finish

The encrypted CSV file will be saved in the same


directory where the CSV file is located.
Online Registration & Transaction
Hardware/Software Requirements Submission
Security Protocol

Report Submission

Report Submission
Hardware/Software Online Registration
Online&Registration
Transaction&Security
Transaction
Hardware/Software Requirements Report Creation Submission
Submission
Requirements Protocol
Security Protocol

Report Submission

Log-on to https://portal.amlc.gov.ph
using the username and password issued by the AMLC.
Hardware/Software Online Registration
Online&Registration
Transaction&Security
Transaction
Hardware/Software Requirements Report Creation Submission
Submission
Requirements Protocol
Security Protocol

Report Submission

1. CTR/STR File Upload


Hardware/Software Online Registration
Online&Registration
Transaction&Security
Transaction
Hardware/Software Requirements Report Creation Submission
Submission
Requirements Protocol
Security Protocol

Report Submission

2. Browse signed/encrypted file


3. Upload
Hardware/Software Online Registration
Online&Registration
Transaction&Security
Transaction
Hardware/Software Requirements Report Creation Submission
Submission
Requirements Protocol
Security Protocol

Report Submission

4. Go to File Upload History


Hardware/Software Online Registration
Online&Registration
Transaction&Security
Transaction
Hardware/Software Requirements Report Creation Submission
Submission
Requirements Protocol
Security Protocol

Report Submission

5. Check uploaded file


6. Request for Email Validation
Hardware/Software Online Registration
Online&Registration
Transaction&Security
Transaction
Hardware/Software Requirements Report Creation Submission
Submission
Requirements Protocol
Security Protocol

Report Submission

7. Refresh
Hardware/Software Online Registration
Online&Registration
Transaction&Security
Transaction
Hardware/Software Requirements Report Creation Submission
Submission
Requirements Protocol
Security Protocol

Report Submission

8. CLICK TO DOWNLOAD
Hardware/Software Online Registration
Online&Registration
Transaction&Security
Transaction
Hardware/Software Requirements Report Creation Submission
Submission
Requirements Protocol
Security Protocol

Report Submission

9. Open
Hardware/Software Online Registration
Online&Registration
Transaction&Security
Transaction
Hardware/Software Requirements Report Creation Submission
Submission
Requirements Protocol
Security Protocol

Report Submission

10. File/Save or Print


After 90 days from receipt of request for validation message, the Portal system will clear the
status shown under the Validation Message column.
Hardware/Software Online Registration
Online&Registration
Transaction&Security
Transaction
Hardware/Software Requirements Report Creation Submission
Submission
Requirements Protocol
Security Protocol

Report Submission

Only encrypted files with correct filename structure


! are accepted in the AMLC portal.
Detect. Deter. Report.
Thank you

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