7 circumstances:

1. transactions that has no economic justification

2. the client is not properly identified

3. disproportionate to the financial capacity of the client

4. it deviates from customer profile

ex. Balut vendor deposits 499,000

5. structured in such a way to avoind being subject to reportorial requirements.

ex. you have 1.5M when you deposited it in only 1 day reportable kasi in excess
of 500,000 but if you deposited 300,000 for 5 days, hindi siya marereport under covered transactions
but will be reported under susppicious transactions kasi you are trying to avoid reportorial
requirements.

6. if it is in any manner related to money laundering or unlawful activities

7. any other acts which similar and analogous to the foregoing

c. Realty

- sa mga lupa

- amount should in excess of 500,000

Who report?

- Covered persons

Covered Persons

1. Finacial Institutions

- must be regulated or supervised by BSP, IC and SEC

 - ex. bank, pawnshop, foreign exchange remittance, insurance company, insurance
holding company, list of regulated or supervised by SEC like real state brokers and developers, dealers,
seller of securities, mutual funds, common trust funds

2. Designated non-financial businessess and profession

- entity not covered by BSP, IC and BSP but the AMLA still required to report

- ex. Jewelers, dealers or precious metals or stone, companies service providers [CSP],
other professionals [the one managing the asset of the client] and cassino and Philippine offshore
gaming Operators [POGO] and tax crimes.

3. Land Registgration Authority and Registry of deeds

Why do we need to know the covered persons

General Rule: in excess of 500,000 w/in 1 banking day are reportable by covered persons

Exceptions:

Jewelers, PRecious metals or stones = 1M

Cassino = 5M

Real estate brokers and developers = 7.5M

Tax crimes and violation of trade

management act on the financing

what if the person reported, proves there is no unlawful acts and therefore acquitted, can the person
demand the person who reported him?

- No, as long as the reporting are done in good faith and under the obl. of the law, the reporting
entity cannot be held liable for criminal and civil liability [safe harbour provision].