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(Revised December 2009)
INTRODUCTION ………………………………………………………….… 3 OBJECTIVES ………………………………………………………………... 3 PART A. R.A. 9194 THE ANTI-MONEY LAUNDERING LAW OF 2003
I. MONEY LAUNDERING PROCESS ………………………………………4 II. THE CRIME OF MONEY LAUNDERING ………………………………..5 III. BASIC PRINCIPLES TO COMBAT MONEY LAUNDERING ………….6 IV. COVERED INSTITUTIONS ………………………………………………8 V. DUTIES AND OBLIGATIONS OF COVERED INSTITUTIONS ..….. ...8 VI. PENALTIES …………………………………………………………………9 VII. AUTHORITY TO INQUIRE INTO BANK DEPOSITS …………………..9 VIII. FREEZE ORDERS……………………………………………….………11 IX. RECORD KEEPING…… ………………………………………….……..11 X. CROSS-BORDER ISSUES……………………………………………..12 BANK POLICIES AND PROCEDURES
XI. PART B.
A. Customer Identification…………………………..………………12 B. Account Opening of Individual Accounts………………………17 C. Account Opening of Corporate Accounts………………………19 D. Correspondent Banking…………………………………….……21 E. Remittance Tie-Ups………………………………………………23 F. Loan Application Processing………………….…..…….………25 G. AMLA Day-to-Day Policies and Controls 1. Acceptance of Foreign Currency Checks…………...…26 2. Sale and issuance of Dollar Demand Draft……………27 3. Issuance of Cashier’s Checks/Managers Checks ……27
Property of PSBank Data Classification: Confidential Revised December 2009
4. Acceptance of Second-endorsed Checks……………..28 5. Spurious Checks…………………………………….……28 6. Guidelines for Fund Transfers…………………….…….29 7. Dormant Accounts…………………………………….….32 8. Closed Accounts………………………………………….33 9. Uploading to ICDB - Caution List…………..…………...33 10. Updating of Customer Information and CISSCs………33 H. Red Flags on Remittances……………………………………….33 I. Flagging and Monitoring of Transactions…………………...….34
J. Reporting Requirements and Process………………………….35 K. The Anti-Money Laundering Committee of the Bank……….. 41 L. Freeze Orders…… ……………………………………………….43 M. Record Keeping….………………………………………………..44 N. Confidentiality……………………………………………………. 45 O. Administrative Sanctions…………………………………………45 XII. COMPLIANCE ………………………….……………………………....45 XIII. AUDIT REVIEW ……………………………..………...……………….46 XIV. RECRUITMENT, EDUCATION AND TRAINING ……………..….…46 Annex 1. Bank Transactions Covered for Reporting under AMLA.…..…48 Annex 2. Format of Internal Report on Suspicious Transactions ……….49 Annex 3. Money Laundering Evaluation Record ………………………...50 Annex 4. Indications of Suspicious Transactions…………………..…..…51 Annex 5. Suspicious Transaction Report Form …………………………..59 Annex 6. Anti-Money Laundering Checklist and Questionnaire ………..61 Annex 7. KYC Form for any Correspondent Banking/Counter party relation……………………………………………………….……..62 Annex 8. Standard Interview or Account Opening Spiel APPENDIX: ……….……..63
List of Terrorist Individuals and Groups……………………64 Electronic Reporting Format and Specifications…………..65
Property of PSBank Data Classification: Confidential Revised December 2009
To establish specific policies and procedural guidelines to ensure proper identification of customers and facilitate tagging and reporting of transactions as required under the law. records and reports covered transactions. otherwise known as the Anti-Money Laundering Act (AMLA) of 2001.INTRODUCTION While striving to sustain economic development and poverty alleviation through. provides freezing. criminalizes money laundering. 2001 and took effect on October 17. 3. To ensure that officers and staff of the Bank clearly understand the responsibilities of the institution and each individual employee in carrying out the requirements of the anti-money laundering law and the accountabilities and penalties attached to noncompliance with such requirements. Property of PSBank Data Classification: Confidential Revised December 2009 3 . 9160. The anti-money laundering law is expected to strengthen the country’s financial institutions. 9160. as amended) and other relevant rules and regulations issued by the Bangko Sentral Ng Pilipinas and the Securities and Exchange Commission to combat money laundering. among others. seizure. No. 2002. It is also paramount that employees understand the concept of money laundering as a crime and the various activities and stages by which it is perpetrated in the economic system and through the different financial institutions. this manual aims to achieve the following: 1. The AMLA. 2003. In particular. R. 9194 (An Act Amending R. it imposes requirements on customer identification. was signed into law on September 29. OBJECTIVES This Manual serves as a comprehensive operating guideline for use of the Bank’s officers and employees in implementing the Anti-Money Laundering Law (Republic Act No. forfeiture and recovery of dirty money or property and provides international cooperation. 2. relaxes strict Bank deposit secrecy laws. On March 7. The Implementing Rules and Regulations took effect on April 2.A. 9160) was signed into law and took effect on March 23. Through the Anti-Money Laundering Council (AMLC). as amended. the Philippines realized the need to contribute its share and play a vital role in the global fight against money laundering. 2003. increase investors’ confidence and eventually ensure that the Philippines is not used as a site to launder dirty money to finance terrorists or legitimize organized crime fronts. To promote adequate awareness regarding the rationale of the enactment of the anti-money laundering law and its importance to the general economy. a revised Implementing Rules and Regulations was issued which took effect on September 7. Consequently. 2003. Republic Act No. 2001. corporate governance and public office transparency.A. The government thus recognized the compelling need to enact a responsive anti-money laundering legislation in order to establish and strengthen an antimoney laundering regime in the country.
Smuggling 11.A. airplanes. including those perpetrated by terrorists against non-combatant persons and similar targets 13. commonly called predicate crimes. The activity is commonly attached to crime syndicates that accumulate enormous amount of money from illegal activities. such as artwork. Graft and corrupt practices 4. Kidnapping for ransom 2. b. Swindling 10. is undertaking complex layers of financial transactions to separate the illicit Property of PSBank Data Classification: Confidential Revised December 2009 4 . Felonies or offenses of similar nature that are punishable under the penal laws of other countries. Robbery and extortion 6. Drug trafficking and related offenses 3. Qualified theft 9. Violations under the Electronic Commerce Act of 2000 12. Layering – The second step. Piracy on the high seas 8. which can be accomplished by depositing them in domestic Banks or other financial institutions. MONEY LAUNDERING PROCESS Money laundering is briefly defined as transactions that involve the conversion or transfer of money or proceeds to disguise its illicit or illegal origins and make it appear as coming from legitimate source. R. destructive arson and murder. include the following: 1. Cash might be physically shipped or smuggled abroad for deposit in foreign financial institutions. Fraudulent practices and other violations under the Securities Regulation Code of 2000 14. precious metals and expensive jewelry that can be resold by payment of check or funds transfer.PART A. it generally includes three basic components: a. or used to buy high value goods. Placement – The first step is the physical disposal of cash. These illegal or unlawful activities. Plunder 5. 9194 The Anti-Money Laundering Law of 2003 I. Although money laundering often involved a complex series of transactions. Hijacking. Cash being the most common medium of exchange is frequently used by criminal elements to conceal the origin of funds and ownership of the same. known as layering. Jueteng and masiao 7. Financial institutions shall then be used to exchange the cash into other forms of monetary instruments to perpetually conceal the criminal activity.
particularly in leisure and tourism industries. Resale of high value goods and monetary instruments. 2. Wire transfer of deposited cash. bonds. Amount involved is not commensurate with the business or financial capacity of the client. purpose or economic justification. and 4. Client’s transaction is structured in order to avoid being the subject of reporting under the requirements of AMLA. g. No underlying legal or trade obligation. c. 3. II. Client is not properly identified. Transaction is in any way related to an unlawful activity or offense that is about to be. is being or has been committed. Any transaction that is similar or analogous or identical to any of the foregoing. e. This might involve a number of techniques such as using front companies to lend the proceeds back to the owner or using funds of deposits in foreign financial institutions as security for domestic loans. Money laundering perpetrators usually set up shell companies. d. Shell companies are legal entities that have no business substance of their own right but through which financial transactions may be conducted. Indicators of Suspicious Transactions/Seven Elements a. traveler’s checks and similar instruments. THE CRIME OF MONEY LAUNDERING Money Laundering is a crime whereby the proceeds of an unlawful activity are transacted. It is committed by the following: Property of PSBank Data Classification: Confidential Revised December 2009 5 . Investment in real estate and legitimate businesses. The directors of these companies are often local attorneys acting as nominees to obscure the identity of beneficial owners through restrictive Bank secrecy laws and attorney-client privileges. c. thereby making them appear to have originated from legitimate sources. Conversion of deposited cash into monetary instruments such as stocks. f. Integration – The last step where wealth derived from the illicit activities are made to appear legitimate. In this way illicit money make its way back to the financial system as legitimate funds. These are typically registered in offshore havens as a common tool in the layering phase. b.funds from their source and disguise the audit trail. Any circumstances relating to the transaction which is observed to deviate from the profile of the client and/or the client’s past transaction with the Bank. This phase may involve such transactions as: 1.
c) Any person knowing that any monetary instrument or property is required under the AMLA to be disclosed and filed with the AntiMoney Laundering Council. Identifying the ownership of the account(s) as well as those using safe-custody facilities. transacts or attempts to transact said monetary instrument or property. Loan Operating Units) Property of PSBank Data Classification: Confidential Revised December 2009 * 6 . 1. Predicting with relative certainty the types of transactions in which a customer is likely to be engaged. and have effective procedures for verifying the bona fide identity of new customers. The Bank is forewarned in All requirements are to be strictly complied by and applicable to all Bank units (SBUs. Asset Recovery & Mgt Group. the Bank shall obtain competent evidence of the customer’s identity. Preventing the creation of fictitious accounts. b) Any person knowing that any monetary instrument or property involves the proceeds of any unlawful activity. Branches. OFAC Listed Clients The AMLA System would have a negative list verification system that shall be able to verify if a customer is in a negative list such as OFAC list (Office of the Foreign Assets Control) and the Bank’s own negative list and database. 2. or relates to. Treasury. Remote Banking. performs or fails to perform any act as a result of which he facilitates the offense of money laundering referred to in paragraph a) above. Remittance. 3. the proceeds of any unlawful activity.a) Any person knowing that any monetary instrument or property represents. The rule on Know Your Customer is always coupled with the responsibility to know and understand the customers’ business. 5. Trust. Know your customer** In all its financial transactions. fails to do so. BASIC PRINCIPLES TO COMBAT MONEY LAUNDERING The Bank adopts the following principles and policies in its institution-wide drive to combat money laundering: 1. Determining any unusual transaction activity or activity that is disproportionate to the customer’s known business. Determining the true identity of all customers seeking to conduct significant business transactions with the Bank. 4. III. involves.
Dealings with shell companies and corporations should be undertaken with extreme caution as these maybe abused by money launderers. Branches. Remote Banking. Shell companies are legal entities which have no business substance in their own right but through which financial transactions may be conducted. that laws and regulations are adhered to.entering into any financial transactions on any person listed in the said OFAC list. or of the business of its partners. procedures and training All requirements are to be strictly complied by and applicable to all Bank units (SBUs. Loan Operating Units) Property of PSBank Data Classification: Confidential Revised December 2009 * 7 . a company search or inquiry shall be made to ensure that such entity has not been or is not in the process of being dissolved. and that service is not provided where there is good reason to believe that transactions are associated with money laundering activities. shut down. Cooperation with law enforcement agencies Within the legal constraints relating to customer confidentiality. Asset Recovery & Mgt Group. Know Your Customers’ Business** Legal existence of customers that are corporations or other business entities must be properly established. Policies. 3. This includes taking appropriate measures allowed by law if there are reasonable grounds for suspecting money laundering. Remittance. Compliance with laws The Bank shall ensure that business is conducted in conformity with high ethical standards. a search or inquiry with SEC or other relevant Regulatory Agency shall be made. Trust. wound up or voided. 4. or that its business or operations has not been or is not in the process of being closed. In addition to the documentary and other identification procedures required. phased out or terminated. Before establishing a business relationship with a corporation or juridical entity. In case of doubt as to the veracity of the corporation or identity of its directors and/or officers. Disclosure of information regarding covered and suspicious transactions shall be made in accordance with legal requirements 5. Treasury. 2. a Board of Director’s Certification as to the purposes of the owners/stockholders in acquiring the shell company should also be obtained. the Bank shall cooperate fully with law enforcement agencies.
c) Securities dealers. money payment remittance. commodities or financial derivatives based thereon. the Bank shall implement specific procedures for customer identification. are informed of these policies and adequately trained in matters covered herein. record keeping and retention of transaction documents and reporting of covered and suspicious transactions. COVERED INSTITUTIONS The following institutions are covered by the Anti-Money Laundering Law: a) Banks. mutual funds. money changers. cash substitutes and other similar monetary instruments or property supervised or regulated by the Securities and Exchange Commission. brokers. valuable objects. b) Insurance companies and all other institutions supervised or regulated by the Insurance Commission. To ensure that true and full identity of all Bank customers is established and to understand the nature of customer’s business. V. 2008. 3. and transfer companies and other similar entities and other entities administering or otherwise dealing in currency. the Bank is required to implement and observe the following: 1. non-Banks. To promote adherence to these principles. 2. quasi-Banks. DUTIES AND OBLIGATIONS OF COVERED INSTITUTIONS (Revised: September 2008) As a covered institution under the Anti-Money Laundering Law. common trust funds. To report covered and suspicious transactions to the Anti-Money laundering Council within ten (10) working days from occurrence thereof as per Circular 612 dated June 13. pre-need companies and other similar entities.The Bank shall adopt policies consistent with the principles set out in this Manual. trust entities and all other institutions and their subsidiaries and affiliates supervised or regulated by the BSP. investment houses and other similar entities managing securities or rendering services as investment agent. Property of PSBank Data Classification: Confidential Revised December 2009 8 . or consultant. advisor. salesmen. close-end investment companies. and ensure that all officers and staff. To preserve and store all records of all business transactions for a period of at least 5 years. unless Supervising Authority prescribes longer period or upon verified/ confirm knowledge of the Bank on basis for such suspicious transaction. foreign exchange corporations. wherever located. IV.
00 but not more than twice the value of the monetary instrument or property involved in the offense.000. Failure to report covered/suspicious transaction Imprisonment of 6 months to 4 years or fine of P100.000 to P1.000. PENALTIES Following are the penalties imposed by law for the commission of the crime of money laundering as well as other acts that violate the requirements of the AMLA: Nature of crime/violation Transacting or attempting to transact any monetary instrument or property the represents. or both Failure to keep records for five (5) years from the date of transaction or date when the account was closed.000.VI. involves or relates to the proceeds of any unlawful activity.500. VII. Performing or failure to perform any act which. AUTHORITY TO INQUIRE INTO BANK DEPOSITS A.000.000 to P500. the Anti-Money Laundering Council may also impose administrative fines on officers/ employees of covered institutions of P100.000 to P500. Malicious Reporting (with malice or in bad faith) Imprisonment of 6 months to 1 year or fine of P100.000 to P500.000 Breach of confidentiality Imprisonment of 3 to 8 years and fine of P500. Anti-Money Laundering Council (AMLC) Property of PSBank Data Classification: Confidential Revised December 2009 9 .00. Imprisonment of 4 to 7 years and fine of not less than P1.000.000. as a result. Apart from the criminal penalties.000.000.00 but not more than P3. facilitates the offense of money laundering. (Money laundering crime) Penalties Imprisonment of 7 to 14 years and fine of not less than P3.000 to P500. IRRs & other resolutions.000. or both Imprisonment of 6 months to 4 years and fine of P100.000 for any violations of the AMLA.
B. • Violations of Dangerous Drugs Act of 2002 • Hijacking • Destructive Arson • Murder • Including acts perpetrated by terrorists against noncombatant persons and similar targets Procedure for examination without a court order: AMLC shall issue a resolution authorizing the inquiry into or examination of any deposit or investment with the Bank. In case of violation. Neither may such reporting be published or aired in any manner or form by the mass media. the contents thereof. whether or not such reporting results in any criminal prosecution under the Anti-Money Laundering Law or any other Philippine law. the media. 3(i) of the Implementing Rules of the AMLA or a money laundering offense as defined in the AMLA. directly or indirectly. or any other information in relation thereto. or other similar devices. D. When reporting covered or suspicious transactions to the Property of PSBank Data Classification: Confidential Revised December 2009 10 . in accordance with the Rules of Examination of the BSP. the concerned officer and employee of the Bank shall be held criminally liable. are prohibited from communicating. Bangko Sentral Ng Pilipinas (BSP) The BSP may inquire into or examine any particular deposit or investment with the Bank when the examination is made in the course of a periodic or special examination. entity.The AMLC may inquire into or examine any particular deposit or investment with the Bank: a. the Bank and its officers and employees. b. to any person. electronic mail. Safe Harbor Provision No administrative. Confidentiality Requirements When reporting covered or suspicious transactions to the AMLC. Without court order in cases where the unlawful activity is any of the following: • Kidnapping for ransom. Upon order of any competent court when it has been established that there is probable cause that the deposits or investments involved are related to an unlawful activity as defined in Sec. C. in any manner or by any means. the fact that a covered or suspicious transaction report was made. criminal or civil proceedings shall lie against any person for having made a covered transaction report or a suspicious transaction report in the regular performance of his duties and in good faith.
After an investigation conducted by the AMLC and upon determination that probable cause exists that a monetary instrument or property is in any way related to any unlawful activity as defined under Section 3 (i). Considering the intricate and diverse web of related and interlocking accounts pertaining to the monetary instrument(s) or property(ies) that any person may create in the different covered institutions. The freeze order shall be effective for twenty days unless extended by the Court of Appeals upon application by the AMLC. 1405. as amended. FREEZE ORDERS Pursuant to Rule 10 of the Implementing Rules and Regulations of the R.A.A. 9194. No.2 of the Revised Implementing Rules and Regulations of the R. their branches and/or other units. and monetary instruments or properties named in the application of the AMLC but also all other related web of accounts pertaining to other monetary instruments and properties. Covered institutions shall prepare and maintain documentation. the AMLC may apply to the Court of Appeals for the freezing. relationships and transactions All requirements are to be strictly complied by and applicable to all Bank units (SBUs. the funds and sources of which originated from or are related to the monetary instruments or properties subject of the freeze order. Loan Operating Units) Property of PSBank 11 Data Classification: Confidential Revised December 2009 * . not only of the monetary instruments or properties in the names of the reported-owner(s)/holder(s). the Bank and its officers and employees. Said records and files shall contain the full and true identity of the owners or holders of the accounts involved in the covered transactions and all other customer identification documents.A. on their customer accounts. Trust. Branches. b. Treasury. All records of all transactions of covered institutions shall be maintained and safely stored for five years from the dates of transactions or dates when the accounts were closed. 9194 which specifically states that: “When the AMLC may apply for the freezing of any monetary instrument or property: a. RECORD KEEPING** Pursuant to Rule 9. as amended. Remittance.A. the AMLC may file an ex-parte application before the Court of Appeals for the issuance of a freeze order on any monetary instrument or property subject thereof prior to the institution or in the course of the criminal proceedings involving the unlawful activity to which said monetary instrument or property is any way related. R.AMLC. No. 7891 and other similar laws. VIII. IX. Asset Recovery & Mgt Group. 6426. Remote Banking. in accordance with the aforementioned client identification requirements. R. Covered institutions shall undertake the necessary adequate security measures to ensure the confidentiality of such file. c. shall not be deemed to have violated R.A. No.
The same information is provided for in the messages sent to the correspondent Banks abroad. completion of a standard account opening form d. Messages sent to correspondent Banks are formatted to contain all originator information and a duly filled up prior to releasing said messages. address. The Branch/Unit Head (BH)/Branch Services & Control Officer (BSCO) and Account Officer (AO) at Head Office/Center are expected at all times to establish the identity of their clients and comply with the Bank’s policies in keeping official file of such identification documents. place and date of birth. The Bank requires complete originator information prior to processing of incoming transfers. Customer Identification/ Customer Acceptance Policy 1. the bank must keep all records until the case has been closed. should the sending Bank fail. The Bank adopts the revised MT103 message format (June 2006) to incorporate the following details regarding the remitter: A. In case required information is insufficient. They must observe the following procedures when an account is opened: a. personal presence of the account holder b. X. remitter. BANK POLICIES AND PROCEDURES** A. Asset Recovery & Mgt Group. Treasury. Remittance. Remote Banking. Account no or Unique ID Number B. Loan Operating Units) Property of PSBank 12 Data Classification: Confidential Revised December 2009 . relationship or transaction can be so reconstructed as to enable the AMLC. comparison of signatures with live signatures * All requirements are to be strictly complied by and applicable to all Bank units (SBUs. telephone numbers. and/or the courts to establish an audit trail for money laundering. Branches. Address The above details should be required as well for all outgoing remittances regardless of amount.such that any account. scrutiny of original identification documents c. Trust. PART B. verification of photograph on IDs presented and on person presenting such documents e. Remitter's Name C. NOTE: Where case has been filed in courts. the Bank shall request for an amendment from the originating Bank. purpose of remittance. transaction is terminated and the remittance returned to the originating Bank. XI. CROSS-BORDER ISSUES The Bank requires full disclosure of required information of beneficiaries of wire transfer: name. Outward remittance transactions are limited only to non-trade remittances and to clients who have existing accounts with the Bank.
c. (Revised December 2009) The following scenarios will cause the account be classified Medium or High Risk. Pre-existing accounts in process to complete the 11 required information. Final approval by the Branch Head/BSCO is necessary before an account is opened. High Risk a.Under Secretary . d. among others. business or profession. c. f. b. Accounts whose financial profile changed. using the standard interview or account opening spiel/script. 3.Deputy Commissioners 2) Elected Officials from President to Municipal Mayors Source Comelec Website – Branches may refer to local list of government elected post to supplement the list in the Banks ICDB. e. d. Property of PSBank Data Classification: Confidential Revised December 2009 13 . Client indicated that account will be used for OFW remittances.2.Executive Department Secretary .Commissioner . Remittance Business. All accounts are generally classified Low Risk upon account opening provided they were able to supply the 11 required information as provided for by the AML Law. Accounts of Financial Institutions/Rural Banks. Non-Resident accounts from countries identified as one of the Non-Cooperative Countries and Territories (NCCT) by FATF. Nature of Business/Source of income involves Foreign Exchange. Medium Risk a. b. Accounts which failed to update the required information every 2 years. Remittances tie up accounts. Clients shall be required to accomplish the Application and Agreement for Deposit Account (AADA) which shall contain vital information on client. g. Client was identified as a Politically Exposed Persons (PEPs) PS Bank define PEPs/Potentate Accounts as 1) Appointed officials from Judiciary and Executive Departments .Judicial from SC Justices down to RTC Judges . All prospective clients shall be subject to initial interview by the Customer Service Associate-New Accounts Clerk (CSA-NAC) and the BSCO to further establish the client's moral character and business reputation and the purpose of the account opening. Pawnshop. Accounts that were allowed to be opened with BBG authorized approval despite failure to provide the complete 11 required information. Previously reported STR account but business owner decided to keep the account open and for close monitoring.
O. d. as acceptable photo-bearing valid Ids. f.. Box number is not sufficient) c. g. b. Signature (signature cards must be updated at least every two (2) years) a. For large corporate accounts. Type of Ownership f. public position held and/or name of employer Official ID (e. Immigrant visa issued by the foreign government in the country of residence g.. Date and place of establishment e. Duly-accomplished AMLA KYC form 5. e-mail address) Date and place of birth Nationality Occupation. Certificate of residency issued by the Philippine Embassy or Consulate in the foreign country of residence. The same should be subject to the Bank’s internal policies on acceptable Ids. e. c. TIN/SSS/GSIS No. no. Name and address of beneficiaries (if applicable) j. (Revised: December 2009) Property of PSBank Data Classification: Confidential Revised December 2009 14 . social security records. driving license) bearing photograph of the customer h. Immigrant Card / Certificate of Registration c. Legal status. Pursuant to MORB X695 Valid Identification Cards (IDs) for Financial Transactions and BSP Circular No. Complete name of institution b. Complete institution’s address (P. The following minimum information should be obtained:(Revised: September 2008) Individual Customer Complete name including middle/maiden name Complete permanent address (P. Type of account and nature of banking relationship j. Information on Remitter (if applicable) k. Passport issued by the country of origin d. fax no. Philippine government-issued IDs e. i. e-mail address) d.. Certificate of residency issued by the foreign government in the country of residence. residence permit. Contact Numbers (business tel. For Foreign Nationals a. association documents or business license g.. Type of account and nature of banking relationship l. Board Resolution depicting the authorized signatory for the transaction/Secretary’s Certificate i. fax no. Alien Certificate of Registration b.4.. 608 dated May 20. h. no. 2008. the Bank shall consider the following government issued ID documents. Corporate/Juridical Customer a. Box number is not sufficient) Contact Numbers (business/residential tel. financial statement of the business or a description of the customer’s principal line of business h. passport. Major Credit Card f.O. such as an incorporation document. partnership agreement. All documents shall be checked against original copies.g.
j. d. r. utility bill.g. identity card. b. s. i. h. d. 7. the AO or BH shall purposely visit the office/residence of the said client and require them to sign the signature card in her presence. passport. m. BSP Circular No. e. 608 by adding “Passports issued by Foreign Governments shall also be considered Valid Identification Documents. SEC or IC. Verification of customer names vs negative file information is done thru ICDB (Integrated Customer Databank System) at the account opening and loan application phases. birth certificate. n. p. a letter from a public authority). HDMF IDs) Certification from the National Council for the Welfare of Disabled Persons Department of DSWD Certification Integrated Bar of the Philippines ID Company IDs issued by Private Entities or Institutions Registered with or Supervised or Regulated either by the BSP. 2009 “ Valid Identification Cards (IDs) for Financial Transactions” amended BSP Circular No. Verify client’s name against ICDB/PEP/other AMLA terrorist/watch list database. The CSA-NAC/BSCO shall perform the following verification procedures: a. 657 dated June 16. c. 6. The authorized signatories whether for individual or corporate accounts shall be required to personally open the account and to have their signatures affixed in the CISSC in the presence of an Operating Officer for signature authentication.a. l. In case of a payroll Property of PSBank Data Classification: Confidential Revised December 2009 15 . o. tax assessment.g. Passport Driver’s license Professional Regulations Commission (PRC) ID National Bureau of Investigation (NBI) clearance Police clearance Postal ID Voter’s ID Barangay Certification Government Service Insurance System (GSIS) e-Card Social Security System (SSS) Card Senior Citizen Card Overseas Workers Welfare Administration (OWWA) ID OFW ID Seaman’s Book ACR/Immigrant Certificate of Registration Government office ID (e. k. f. AFP. and other verifiable personal information are required up front. proofs of residence and relationship. c.. Confirm the permanent address (vs. b. q. bank statement. t. g. If the authorized signatories cannot come personally to the Bank to open the account. Confirm the date of birth from an official document (e.”(Revised December 2009) Note: For Remote Banking Processes: Valid IDs. social security records). Call the residential/office number to validate the authenticity of the given information.
Where the company is registered abroad. Where there is any doubt. or terminated. 10. wound up or voided. 12. No opening of accounts shall be allowed without face-to-face contact. or that its business or operations has not been or is not in the process of being closed. Prospective clients referred by bank employees or valued clients shall not be exempted from the interview and submission of the documentary requirements. documents comparable to what is normally required from a corporate client should be examined. Where the overseas company is not a known customer. If he cannot visit the branch. Where the person who opens the account is not the person who will be operating the account. Business principals must provide the Bank with documents on the business legal status (e. or those proposing "one-shot deals” shall not be entertained.) when opening a business account. verification or submission of additional documents or use of third party introduction.account opening. Property of PSBank Data Classification: Confidential Revised December 2009 16 . All signatories to the account must be properly identified. based on documents submitted. the latter should be identified and checks conducted as for an individual account holder.g. etc. 15. sole proprietorship. The Branch/Unit Head/BSCO/AO may request assistance from MBTC Foreign Branches and subsidiaries abroad in undertaking this task. 11. The Branch/Unit Head/BSCO/AO may request assistance from MBTC Foreign Branches and subsidiaries abroad in undertaking this task. 13. partnership. The Bank may also consider to have KYC outsourcing. the authorized branch personnel must be the one to visit the company to ask the customer to sign the necessary documents in his presence. the employee himself must visit the accommodating branch to open his account personally. phased out. 14. even duly-endorsed by their Human Resource Officer. "Walk-ins" who are not expected to maintain a continuing relationship with the Bank. shut down. which have no business substance in their own right should be undertaken with extreme caution. 9. 8. Hence. opening of payroll account should also be in accordance with face-to-face contact with the concerned branch personnel and the client. all company documents should be verified. the status of the corporate client to ensure that the customer that is a corporate or juridical entity has not been or is not in the process of being dissolved. or incorporation or association. unless authorized by the Bank to use risk mitigating measures to by-pass face to face requirement thru independent contact with customer by the bank. Income Tax Return/Audited Financial Statements must be reviewed. The Branch Head/BSCO/AO must verify. the certificate of registration should be verified. Signatories to the account must be properly identified. Dealings with suspected shell companies and corporations. A referral letter duly signed by the referring bank employee/valued clients shall also be required. The nature of the company's business should be recorded.
notary public) c. Pending revision of CISSC. A “Thank you” letter shall be sent via mail. purpose of opening the account and other special tag on account e. Thank you letters must be sent to client’s present address. During account opening.” c. 17. Confirm the validity of the official documents provided through certification by an authorized person (e. a. disconnected phone/returned mail should warrant further investigation) b.g. All undelivered and returned “Thank you” letters received by Head Office – General Services Division (HO-GSD) shall be endorsed by Customer Service Division to the concerned units for investigation. Inquire from bank references given e. source of funds and intended nature of the business relationship. among other information. The following statement shall be indicated (typewritten or rubber stamped) on the upper left hand portion of the envelope: “If undelivered please return to P..g. embassy official. The following procedures shall be undertaken after account opening: a. etc.. shall be stamped at the mid-right section of the existing CISSC. the Bank requires disclosure of information as to the purpose of account. Opening of Individual Accounts 1. the requirement for the information on source of funds.16. B. Post-Validation Procedures shall be the responsibility of the BH and/or BSCO of the branch concerned. Box __________. PEP. Ocular inspection of place of business b. Conduct inquiry on the company’s status d. Contact the client/entity by telephone to confirm the information supplied (e. Property of PSBank Data Classification: Confidential Revised December 2009 17 .O.g.
From the initial interview. Vanuatu. The BSCO/CSA-NAC shall ensure that the CISSCs/SRCs are completely accomplished with the minimum information. rampant in drug dealing activities. CBRCD/EBSD. the Bank should be able to assess the customer’s risk profile taking into consideration the client’s territory. • The true and full identity of the person/business entity on whose behalf the transaction is being conducted Note: Validation fields for online enrollment and forgotten Username or Passphrase should be derived from integrated customer data based on records in our deposit and loan systems. Panama.e. • The true and full identity of the representative/s and the nature of his/their capacity and duties. i.countries identified as tax havens. corruption and organized crimes. The servicing branch/unit shall perform enhanced due diligence before opening accounts or accommodating clients whose country of origin is among those classified as “high risk” --. The BH/BSCO shall check the accuracy and completeness of all information on the CISSC. for multiple factor authentication. customer information and account ownership in our deposit and loan systems. The Bank should however. Seychelles. and security tokens. Nauru. Palau and Niue which were publicly cited in various US government agency reports. 3. ILAPS (Intra-net Loan Application Processing System) and ILS (Integrated Loan System). 2. whether face-to-face in our Branches or online. employment or occupation. Enrollments go through a two-step approval process involving Branch Officers and centrally. 3270. Business relationships with individuals holding important public positions and with persons or companies clearly related to them may expose a bank to Property of PSBank Data Classification: Confidential Revised December 2009 18 . Minimum requirements shall be sufficient for a client considered as “low” risk. profession. b. Some examples are Colombia. documents and information gathered. are vetted vs. and transactional integrity shall be ensured by the use of ATM or ePINs as the case may be.“Source of Funds : ______________ Purpose of Opening: __________________” NOTE: When accomplishing the Customer Information Specimen Signature Cards (CISSC)/Signing Rules Card (SRC): a. give particular attention to clients identified as “high” risk. account ownership. particularly the account number indicated on the front and back portions thereof and the client’s source of funds before affixing his/her signature on the ‘Approved by’ portion. business. Initial enrollments of accounts. Due diligence must be performed to obtain more information about the source of funds to justify transaction with the Bank. RM. Proper identification.
the Bank. Risk Management Office and IAG. Top management clearance must be sought before these are to be processed any further. One must also consider that even after leaving public office. source of bills payment.or purely online products and services. thru the BSP Credit Bureau and other positive and negative databases. target of fund transfer. the information on the remitter like address and source of fund should be recorded. Politically Exposed Person (PEP) involvement ii. which would still subject them to STRs. Opening of Account by a Corporate/Juridical Person Property of PSBank Data Classification: Confidential Revised December 2009 19 . If account will be used for remittance. C. for early reporting to Compliance Office. As Remote Banking interfaces with our deposit and loan systems. Under certain circumstances. Ownership and management i. and positions or designations. 8. Remote Banking clients need to designate the particular functionalities of all enrolled accounts. CRM and AMLA systems. namely as source of fund transfer. The authorized BBG Officer shall approve client’s opening of accounts for PEPs in the New Accounts policy. its officers and employees themselves can be exposed to charges of money laundering. enrollments and transactions thereof must be incorporated in said pattern recognition and monitoring system. And prior to rollout of cyber.significant reputation and/or legal risks. Following are elements that should be further considered: a. 4. internally. accounts of ex-PEPs may exhibit suspicious transactional behavior. and target of bills payment. BSCO/BH shall enhance due diligence to assure greater level of understanding of the correspondent institution. if they know or should have known that funds stemmed from corruption or other serious crimes. related accounts. through our ICDB. Quality of anti-money laundering controls correspondent Bank Downstream correspondent clearing of 7. TPAs are restricted to being target or recipient accounts only. Such persons are commonly referred to as “potentates”. and any unusual movements or deviations should be the subject of automatic STRs. Actual names and designations of PEPs should be uploaded and updated in our ICDB for pre-screening in account openings and loan applications. 5. business affiliations. For Remote Banking Processes: PEP accounts should be bird-dogged in our automated AML system. any deviation from the client’s business or risk profile. average balances and other indicators would be captured by the Group’s automated AMLA system for proper intervention by the concerned parties. Politically Exposed Persons (PEPs) would be filtered. and externally. as to names and pseudonyms. 6. Such clients must be tagged as PEP special accounts and closely monitored. Based on its assessment of the risk indicators.
b. the Bank also implemented the use of the AMLA Checklist & Questionnaire (See Annex 6) which aims to establish the identity of the persons who control the operations of the business entity. Determine customer’s legal beneficiaries as well as the client’s personal or business background. c. Corporate client(s) shall be required to submit the original copies of the corporate business papers which shall be compared with the photocopies to confirm the authenticity of the documents. Property of PSBank Data Classification: Confidential Revised December 2009 20 . type of transactions. The opening of an account shall be immediately verified with the corporation's main office. ask why the customer is opening an account at that location. asked for a prior bank reference. Note: In case the certificate is still being processed by the BSP. etc. d. the customer shall be e. Thereafter the Bank officer shall affix his signature. the BH/BSCO shall verify the authenticity of the certificate presented to the BSP Supervision and Examination Department III. to determine authenticity of Board Resolution and the identities of the officers authorized to sign in behalf of the firm if actually connected with the said corporation. the customers’ handling of accounts as well as his credit standing can be inquired/validated. if the authorized signatories cannot personally appear. For corporate accounts and financial institutions. a Bank officer shall visit the place of business and ensure that the authorized signatories sign the signature cards in his presence. Prior to opening the account. Opening of accounts without face-to-face contact with customer and anonymous accounts and accounts under fictitious names are prohibited.1. the nature of its operations. For corporation or large individual accounts. require the client to submit the proof of filing in lieu of the photocopy. If it is not in the area served by the branch. The authorized signatories whether for individual or corporate accounts shall be required to personally open the account and to have their signatures affixed on the CISSC and SRC (if necessary) in the presence of an operating officer for signature authentication. Consider the customer’s residence or place of business. In case of associations/corporations. 2. If the client is a Foreign Exchange Dealer/Remittance Agent. In this way. require client to present the original BSP Certificate of Registration and to submit a photocopy of the certificate. Note: The servicing branch/office shall observe the following: a. thru the fastest means of communication available.
The correspondent Bank’s/counter parties’ business and customer base • • • Type of businesses the correspondent Bank/counter parties’ engages in Type of markets the correspondent Bank serves Involvement in certain business segments internationally recognized as creating particular vulnerability to money laundering. . The Bank should consider the type of risk indicators in initiating the correspondent Banking relationship. • The Bank should review pronouncements from regulatory agencies and international bodies. corruption or terrorist financing Substantial part of business income derived from higher risk clients • Property of PSBank Data Classification: Confidential Revised December 2009 21 . 2. such as the FATF. The risk indicators to be considered are as follows: a. The correspondent Bank’s/counter parties’ domicile • Jurisdiction where the correspondent Bank is based and/or where its ultimate parent is headquartered. Correspondent Banking 1. corruption or terrorist financing. b. other jurisdictions such as members of the Financial Action Task Force (FATF) have more robust regulatory environments representing lower risks. to evaluate the degree of risk presented by the jurisdiction in which the correspondent Bank is based and/or in which its ultimate parent is headquartered. Certain jurisdictions are internationally recognized as having inadequate anti-money laundering standards. Correspondent Banking refers to activities of the Bank having direct connection or friendly relations with another Bank. financial institution/counter-parties’ remittance information if applicable. and on a continuing basis. insufficient regulatory supervision or presenting greater risk for crime. The Bank may give appropriate weight to each risk factor as it deems necessary. to ascertain what reasonable due diligence or enhanced due diligence it will undertake.D. The correspondent Bank’s/counter parties’ ownership and management structures • Location of owners • Corporate legal form • Transparency or ownership structure • Location and experience of management • Involvement of politically exposed persons (PEPs) in the management of ownership c. On the other hand.
3. The Anti Money Laundering Checklist and Questionnaire / KYC Form for any Correspondent Banking/counter party relation (See Annex 6 and 7) shall be prepared at all times. Based on its assessment of the risk indicators, the Bank may need to perform an enhanced due diligence to assure greater level of understanding of the correspondent institution. Following are elements that should be further considered: a. Ownership and management b. Politically Exposed Person (PEP) involvement c. Quality of anti-money laundering controls of correspondent Bank d. Downstream correspondent clearing 4. The Bank should not enter into a correspondent Banking/financial institution counter party relationship with shell Banks. It should also guard against establishing relations with respondent foreign financial institutions that permit their accounts to be used by shell Banks. 5. A shell Bank is a Bank that: • Does not conduct business at a fixed address in a jurisdiction in which the shell Bank is authorized to engage in Banking activities; • Does not employ one or more individuals on a full time business at this fixed address; • Does not maintain operating records at this address; and • Is not subject to inspection by the Banking authority that licensed it to conduct Banking activities. 6. Treasury Division and other operating units of PSBank shall ensure that requesting correspondent banks/counter parties have properly established testing arrangement with the Bank prior to accommodating requests for AMLA purposes. In situations involving branches, subsidiaries or affiliates, the Bank should consider the parent of the correspondent Bank in determining the extent of required due diligence. If the correspondent entity is an affiliate not substantially and effectively controlled by the parent, the Bank should review both the parent and the correspondent entity. Note: In implementing the requirements of the Anti-Money Laundering Law, Treasury Group/Branch Banking Group and other operating units of the Bank shall be responsible for prescribing acceptable customer identification documents and the detailed guidelines/procedures in obtaining information and accomplishing customer identification forms and records. 7. Upon receipt of proposal from correspondent bank/financial institution to establish relationship, Treasury Group shall:
Property of PSBank Data Classification: Confidential Revised December 2009
a. Request for the submission of the following updated/latest documents: • Annual Report • Statement of Condition • Terms and Conditions • List of Major Correspondents b. Request for background, credit information and /or account relationship from at least four (4) of the applicant bank’s major correspondents, preferably from or through banks which are also Metrobank’s correspondents maintaining branches, offshore units or representative offices in the Philippines. c. If applicant bank can service and meet our international requirements, recommend for approval of Finance and Operations Group Heads the proposal to establish correspondent banking relationship. d. Once approved, forward a copy of the approval letter to Finance, Remittance and Treasury Operations. e. Send acceptance letter to the new correspondent bank and provide them with our latest annual report, terms and conditions and AML questionnaire. E. Remittance Tie-Ups (Revised December 2009) Remittance Tie-Ups refers to activities of the Bank having direct connection or friendly relations with another financial institution/counter-parties. The Bank should consider the type of risk indicators in initiating the remittance tie-up relationship, and on a continuing basis, to ascertain what reasonable due diligence or enhanced due diligence it will undertake. The Bank may give appropriate weight to each risk factor as it deems necessary. 2. The risk indicators to be considered are as follows: a. The financial institution/counter parties’ domicile • Jurisdiction where the counterparty is based and/or where its ultimate parent is headquartered. Certain jurisdictions are internationally recognized as having inadequate antimoney laundering standards, insufficient regulatory supervision or presenting greater risk for crime, corruption or terrorist financing. On the other hand, other jurisdictions such as members of the Financial Action Task Force (FATF) have more robust regulatory environments representing lower risks. • The Bank should review pronouncements from regulatory agencies and international bodies, such as the FATF, to evaluate the degree of risk presented by the jurisdiction in which the counterparty is based and/or in which its ultimate parent is headquartered. b. The counter parties’ ownership and management structures
Property of PSBank Data Classification: Confidential Revised December 2009
• • • • •
Location of owners Corporate legal form Transparency or ownership structure Location and experience of management Involvement of politically exposed persons (PEPs) in the management of ownership
c. The counter parties’ business and customer base • • • Type of businesses the counter parties’ engages in Type of markets the counterparties’ serves Involvement in certain business segments internationally recognized as creating particular vulnerability to money laundering, corruption or terrorist financing Substantial part of business income derived from higher risk clients
3. The Anti Money Laundering Checklist and Questionnaire / KYC Form for any counter party relation (See Annex 6 and 7) shall be prepared at all times. Based on its assessment of the risk indicators, the Bank may need to perform an enhanced due diligence to assure greater level of understanding of the correspondent institution. Following are elements that should be further considered: a. Ownership and management e. Politically Exposed Person (PEP) involvement f. Quality of anti-money laundering controls of correspondent Bank 4. The Bank should not enter into a financial institution counter party relationship with shell Banks. It should also guard against establishing relations with respondent foreign financial institutions that permit their accounts to be used by shell Banks. 5. Business Development Unit (BDU) and other operating units of PSBank shall ensure that requesting counter parties have properly established testing arrangement with the Bank prior to accommodating requests for AMLA purposes. In situations involving branches, subsidiaries or affiliates, the Bank should consider the parent of the counterparty in determining the extent of required due diligence. If the counetrparty entity is an affiliate not substantially and effectively controlled by the parent, the Bank should review both the parent and the couterparty entity. Note: In implementing the requirements of the Anti-Money Laundering Law, BDU and other operating units of the Bank shall be responsible for prescribing acceptable customer identification
Property of PSBank Data Classification: Confidential Revised December 2009
For those with outsourced services on account acquisition such as PLD: the process of completing the KYC requirements are bundled and incorporated in the outsource contract. credit information and /or account relationship from at least four (4) of the applicant counterparties’ major correspondents. i. terms and conditions and AML questionnaire. Request for background. offshore units or representative offices in the Philippines. Request for the submission of the following updated/latest documents: • Annual Report • Statement of Condition • Terms and Conditions • List of Major Correspondents g. Likewise new products being developed must likewise have defined Money Laundering Risks and needed controls to protect the interest of the bank and the general public will be protected. Remittance and BDU. BDU shall: f. j. Once approved. the dealer coordinator assigned in the respective dealer center is the one properly doing the KYC Property of PSBank Data Classification: Confidential Revised December 2009 25 . It is the responsibility of the concerned Account Officer to complete the KYC. h.documents and the detailed guidelines/procedures in obtaining information and accomplishing customer identification forms and records. The Account Officer must at all times conduct the proper KYC and the KYCB during the loan application to establish the true identity of the applicant as well as that of his/her business. Send acceptance letter to the new counterparty and provide them with our latest annual report. 3. documentary information of all the requirements e.g. As to the Auto Loans-Dealer Sales. 2. forward a copy of the approval letter to Finance. Upon receipt of proposal from financial institution/counterparty to establish relationship. F. preferably from or through banks which are also Metrobank’s correspondents maintaining branches. the proper KYC is still being followed. acceptable photo-bearing Ids. Loan Application Processing 1. Thus. 7. If applicant couterparty can service and meet our international requirements. recommend for approval of Finance and Operations Group Heads the proposal to establish remittance-tie ups relationship. updated financial statements/Income Tax Return. All solicited application forms and documents are transmitted to Loans Process Support Department (LPSD) for proper validation and document verification.
The Bank will observe the dictum of “when in doubt. Other documents such as marriage certificate or birth certificate provided by the client can help in establishing the identity of the borrower/co-borrower/JSS.Loans Processor shall perform additional validation/authentication/KYC procedures prior to booking as follows: • Check if the duplicate clear copies of the 2 IDs presented are acceptable and valid based on the following features: • Check the consistency of the customer data on the ID vs. ask the client to submit additional IDs and perform additional verification procedures as needed in establishing the identity of the client. the loan applicant should be accordingly identified. Loans Review Servicing Department (LRSD) . Compare signatures on IDs presented vs signatures on loan documents. is inadequate due to meager information or validation sources. validate signature versus the signature on Signature Verification System. • Compare the photo of the borrower/co-borrower/JSS if these match with all IDs presented. the following minimum customer information provided to the Bank by the client in the Validation Sheet. • If repeat Bank loan client. • Check if the photocopies have stamp “original seen” or “signatureverified” and with initial of the Marketing Assistant or Account/Branch Officer.for the prospective loan borrower. affix initial on PN/CAML a “Signature Verified” stamp on the said documents then initial or sign in full over printed name. Application Form and ITR. • If existing Bank depositor. application form. use these ID’s as basis for performing signature verification on loan documents. Hence. the Bank will bar the creation of the client relationships and file the necessary STRs. either by the Bank or third party service providers. • If the IDs are found to be valid and acceptable. stay out. 4. • For corporate or partnership or single proprietorship accounts. Anti-Money Laundering Day-to-Day Policies and Controls 1. Loans Review Servicing Department (LRSD) . Note: For Remote Banking Processes: Whenever CDD. or reticence on the part of clients. Acceptance of Foreign Currency Checks a. If ok.” • G. Foreign currency checks/drafts accepted either for deposit or as collection items shall be subject to the following conditions: o First endorsed checks/drafts (not second-endorsed) Property of PSBank Data Classification: Confidential Revised December 2009 26 . validate signature versus all loan documents and IDs available in the credit folder.Loans Processor shall also properly establish legal existence of customers • When in doubt. marriage contract and loan guaranty when applicable.
Dollar Demand Draft is a dollar denominated draft drawn on Metrobank. Only checks payable to the depositor. d.o o Not postdated/stale-dated (issued 6 months earlier) Free from any technical defects b. Erroneous classifications shall be subject to MIS charges from Remittance Department. signed at the back) by the payee.. Corrections shall be noted in the received manifold. Acknowledge receipt of checks in the supporting Manifolds. If there are erroneous check classifications. Sale and issuance of Dollar Demand Draft a. The Bank shall allow sale of MC/GCs only to existing depositors of the Bank. Property of PSBank Data Classification: Confidential Revised December 2009 27 . Philippines issued by PSBank Head Office and branches. c. the branch officer should be immediately advised via e-mail to correct. Authorized personnel of Remittance Department (Processing Center) shall perform the following: o o Verify completeness and accuracy of information in the manifold. scanned or photocopied (both face and reverse side). All FX checks shall be microfilmed. b. Dollar Demand Draft shall be issued and made payable only to a specific payee and shall not in any instance be made payable to “CASH” or “BEARER”. prior to dispatch. Each check for deposit must be properly endorsed (i. o 2. Dollar Demand Draft shall always bear the full signature of any two-branch officers of the issuing unit at the time of issuance. The words “PAYEE’S ACCOUNT ONLY” shall be stamped diagonally at the upper left corner of the FXDD and shall always bear the check written amount. Client’s Account Number must be legibly written by the client on the reverse side of the check.O. to “CASH. Sale and Issuance of Manager’s Checks / Gift Checks (Revised: September 2008) a. Date and time of receipt shall also be indicated in the Manifold to monitor the clearing period. Second-endorsed checks should be rejected. For collection items that are erroneously credited outright should be reversed / corrected the same day. Review proper classification of checks received. if microfilmer or scanner is not available.” or to “bearer” shall be accepted for deposit.e. Purpose of sale must be specified and name of the payee. 3. H. c. Sale of $DD must be covered by a duly accomplished application form. Sale of $DD will only be allowed to existing depositors of the Bank to ensure that the applicant has been duly identified. New York for the account of PSBank.
) o Mode of Payment o Amount in Words and in Figures o In favor of (Payee of MC/GC) o Name and signature of the applicant/purchaser o Purpose o Authorized Representative portion (if applicable) Note: If the application is via a representative. 4. Manager’s Checks / Gift Checks payable to Cash. That transactions involving said instruments should be accordingly reported to the AMLC. Acceptance of Second-Endorsed Checks As a general rule. PSBank personnel shall consider a check as spurious or fake if it does not contain the security features set by the drawee bank or security features of the check have been maliciously altered. 5. d. Bearer and Numbered Accounts shall not be allowed. These were clearly done with a criminal intent and therefore reportable. At a glance. e. the payee of the check shall be encouraged to open an account with proper identification papers. acceptable IDs should be required from the representative. Property of PSBank Data Classification: Confidential Revised December 2009 28 . all second endorsed checks shall not be accepted for deposit because of the risk involved in receiving the same. The following information needed to obtain : o Reference No. spurious/fake checks may appear to use the same logo and other security features of an authentic/valid checks. to avoid second endorsed check deposits. f. through the Compliance Officer if there is reasonable ground to suspect that said transactions are being used to launder funds of illegitimate origin. Whenever possible. c. (MC/GC Serial No. The payee of a MC/GC must be a specific person or entity. g.b. In filling-out the application form for Manager’s Checks / Gift Checks. Preparing the BSP Report of Crimes & Losses does not absolve us from the requirement of submitting the corresponding STR. Spurious checks are defined as those that are materially altered. That the deposit or said instruments shall be subject to the same requirements/scrutiny applicable to cash deposits. the branch shall use the Application for Fund Transfer (AFT) to document the sale and issuance of MC/GC. Spurious Checks Spurious/fake checks are checks that were illegally/unlawfully printed or altered to defraud banks or the payee.
draft. The term also includes Automated Clearing House Transfers. and other similar manual origination means) externally from clients or internally from within the banking group/entities. deceit or fraud prior issuance/negotiation of the check. The financial institution shall allow wire transfer electronically (internet transfer) only upon its prior approval.a. Only if there is swindling. The financial institutions should be governed by a Manually Initiated Funds Transfers (MIFT) Policies and Procedures for funds transfer requests that are manually initiated (via fax. Guidelines for Fund Transfers a. c. Returned checks due to closed account or insufficient funds issued for a consideration are not automatically reportable under AMLA. d. or during the Example issuance of check after 6 months of account closure When in doubt report. While it is discretionary upon the banks to report a STR. transfers made at Automated Teller Machine (ATM) and point of sale terminals. The policies and procedures should specify personnel that will be responsible for ensuring compliance with the guidelines on funds transfers transactions. e. 6. either locally or internationally in local or foreign currencies. Fund Transfer is remittances of funds from one bank to another. f. d. messenger. This may include movement of money between customers or between accounts of the same customer of the Bank. file transfers. The policies and procedures shall also provide for independent review by appropriate personnel to monitor and ensure continued compliance with the institution’s polices. Transfers can be effected by teletransmission. b. AML COMMITTEE will make the determination of the offense. electronic mail. non-reporting bears the risk of the penalty. The Bank should maintain a policies and procedures manual for funds transfers that are reasonably designed to prevent the Property of PSBank Data Classification: Confidential Revised December 2009 29 . procedures and guidelines on funds transfers. Bouncing check is a criminal law violation of Batas Pambansa (BP) 22 but it is not an unlawful activity under AMLA except when it falls Article 315 of the Revised Penal Code. Not all dishonored checks are reportable only those related to swindling b. manager’s check or certified check depending on the request of the applicant. telephone. c.
in some cases. At a minimum. • Provide education and/or training of personnel. No. in some cases. Whenever possible. Authentication: A cryptographic process used to verify the sender and. Bank approved acceptable identification). No.financial Institution from being used to facilitate money laundering and the financing of terrorist activities. The term “validation” applies to various methods used by both sending and receiving parties to verify the identity of the sender of a message. Some validation methods also verify elements in the message including but not limited to amount. the manual must incorporate policies. • File reports (including covered transaction/suspicious transactions reports). The Bank should not accept funds transfer instruction from and/or pay-out funds transfers to non-customers. • Respond to regulators/law enforcement requests. j. Property of PSBank Data Classification: Confidential Revised December 2009 30 . i. unless in cases where the initiating party is an authenticated primary customer of a sending group or unit of the Bank. value date and currency. used to verify the sender and.g. procedures and internal controls to: • Verify customer information (KYC).A. Signature Verification: A matching of signature or other representation from a source document request to a document pre-signed by a Bank customer and held on file by the Bank. particularly those instance stated under Rule 3. Some specific validation methods are: Test Key: An algorithmic computation method using a fixed set of factors known only to the sender and receiver. g. the receiving bank must do the due diligence on the beneficiary of the fund.b1 of the Revised Implementing Rules and Regulations (R.A. Every effort should be made to provide the client with an electronic banking solution. Validation must be performed by all banks. or other documents held by the customer (e. used to verify the sender. • Provide security procedures. h. the full text of a message.9160. as amended by R. If the fund sender/remitter is not a bank or coming from non-FATF member or non-compliant countries on AML. other elements of the message. • Verify transactions that show indicators of suspicious transactions. manually initiated funds transfer instructions should not be the primary delivery method. 9194).
2. Business Accounts 1. The originating/remitting branch/office shall require the remitter to indicate the purpose of the remittance and his/the remitting company’s complete address and contact numbers (residential/office or tel. identification document maybe combined with any supplementary ID’s.g. sole proprietorship. n. k. The following identification documents shall be required: a. Individual ID’s for each signatory Certificate of Filing of Business Name Employer Identification Number Certificate or Articles of Incorporation/Partnership/Association. For additional verification. m. The Remittance Teller or Agent shall require each prospective customer to provide any valid government issued identification document pursuant to BSP Circular 608 dated May 20. d. Business principals should provide evidence of legal status (e. e. etc. 3. 2008. partnership. Number/e-mail/fax) in the remittance application form and shall see to it that the following information regarding the beneficiary/claimant are completely provided: full name of the beneficiary complete address of the beneficiary telephone number (if any) name and complete address of the branch/bank where funds are to be remitted 5. Corporate Resolution g. Consider the purpose and source of funds used to process the transaction. account number (for remittances by way of credit to account) l.00 should be questioned.Telephone Callback: A procedure used to verify the authenticity of a message received by telephone.000. By-Laws f. License to Operate Business. b. 4. No relationship shall be established and no wire transfer shall be processed without satisfactory identification. Cash transactions over $2. or incorporation or association) when opening a business account. 3. perform a visual check of the business to verify the actual existence of the business and that the business has the capability of providing the services described. When circumstances allow. Property of PSBank Data Classification: Confidential Revised December 2009 31 . The Bank places a return phone call to the customer using a pre-determined telephone number on file within the Bank. c. provided that such ID contains a photo ID as required under the Bank’s policy on the matter. if applicable 2. 1.
h. The employee who is processing the transaction should make a note in the forms/documents for reference purposes. c. retail versus wholesale. Signature cards for dormant accounts shall also be segregated from active files and held under joint custody. Segregated dormant accounts shall be placed under joint custody of two (2) responsible officers/employees. For large commercial accounts. the following information may be obtained while in the process of establishing the relationship: a. f. description of the business operations. and the anticipated volume of cash sales. Banks shall exert all efforts to prevent checking and savings accounts from becoming dormant. Entries to dormant account ledgers shall be verified and approved by a e. The above information may not necessarily be a major requirement but these can be obtained during the process of interviewing the applicant. a short letter should be sent to the depositor encouraging him to use his account. All transactions affecting dormant accounts shall be subject to audit by the internal auditor. b. 7. a. A trial balance of dormant account ledgers shall be taken periodically and balances with the general control account by an employee other than the bookkeeper.e. list of major suppliers and customers and their geographic locations.4. All inquiries on dormant accounts shall be coursed to one officer who should obtain sufficient identification from the inquirer to assure that he is entitled to the information. and whether international transactions are expected to be routine. When it becomes apparent that an account is inactive. A separate ledger control for dormant accounts shall be maintained. His initials shall be placed next to the entry on the ledger sheet. Dormant Accounts a. Dormant or inactive accounts shall be verified directly with depositors. d. description of the business’s primary trade area. b. o. designated officer. As a matter of policy.. and d. Property of PSBank Data Classification: Confidential Revised December 2009 32 . g. c. i. description of the customer’s principal line of business.
8. updating of CISSCs is required every two (2) years. In lieu of the General Information Sheet. based on the date of last approval of the CISSC in the SVS. the General Information Sheet shall be accessed from the SEC website. Moreover. Compliance Office to provide the website of PEP and OFAC List.CCED to update AML blacklisted names as needed or upon advice from Compliance Office. H.CCED to secure approval for access to PEP and OFAC website and update source group on a monthly basis. 9. b. It shall be the responsibility of the branches/units concerned to retrieve all unused checks from the depositor of closed accounts to prevent further negotiation and/or use.05. Further. Bank shall use the updated CISSCs to obtain the required information that need to be disclosed by the depositors. Letters shall be sent to depositors within two (2) months before the 2-year expiry period. Branches shall manually prepare the Notification Letters for Updating of CISSCs to remind depositors that their signatures cards are due for updating. A semestral report on deposit accounts transferred to dormant shall be rendered to bank management. as matter of practice and procedure. 10. the following procedures are being implemented by the Bank: a. among others. d. are also shown. the Bank accepts outward and inward fund transfers only from existing depositors who have already undergone the KYC process. clients are required to indicate the purpose and/or nature of the Property of PSBank Data Classification: Confidential Revised December 2009 33 . IT-SSD to upload PEP and OFAC List by overwriting previous records.2007.i. Uploading to ICDB.Caution List (Revised December 2009) For uploading of PEP and OFAC List in the Bank’s ICDB. Updating of Customer Information and CISSCs (Revised December 2009) Per Bank’s Policies and Procedures PP-2007-021 “Updating of Customer Information and Specimen Signature Cards (CISSCs)” dated 09. CAG. Closed Accounts The depositor whose account is being closed (client or bank-initiated due to improper handling) shall be required to surrender all unused checks to the BH/BSCO or CSA-NAC. CAG. Red Flags on Remittance For remittance transactions. the Bank shall require its Corporate and Juridical customers to accomplish and update every 2 years an Anti-Money Laundering Checklist and Questionnaire where other significant data such as ownership interest and management information. For loan transactions. c.
STIR is generated from the DEPOSIT system which validates all the Bank’s transactions regardless of the mode of payment use or type of transaction: deposit or loan transactions or any other miscellaneous transaction that a customer will undertake. To support the day-to-day evaluation of transactions for possible suspicious items. Flagging and Monitoring of Transactions (Revised: September 2008) 1. the Bank continuously reviews the propriety of transactions conducted by clients to possibly detect structured or covered transactions. b. the branch personnel and other operating units of the Bank shall regularly review the Suspicious Transaction Indicator Report (STIR). Sources and/or beneficiaries of wire transfers are citizens of countries which are identified or connected with terrorist activities. I. especially if the wire transfers are effected through countries which are identified or connected with terrorist activities. without visible economic or business purpose. For legal persons and arrangements. c. Wire transfers between accounts. The following are the Red Flag Indicators which should be investigated and elevated by concerned employees as soon as these are detected in their respective operations: a.remittance. Property of PSBank Data Classification: Confidential Revised December 2009 34 . the Bank takes reasonable measures to understand their ownership and control structure. The Bank requires disclosure of the beneficial owner. and takes reasonable measures to verify the identity of the beneficial owner such that the financial institution is satisfied that it knows who the beneficial owner is. Repetitive deposits or withdrawals that cannot be explained or do not make sense. The Bank shall devise a system of flagging and monitoring transactions that qualify as suspicious transactions regardless of amount or covered transactions involving amounts below the threshold to facilitate the process of aggregating them for purposes of future reporting of such transactions to the AMLC when their aggregate amounts breach the threshold. On top of the verification process above to establish the purpose of the business relationship and/or nature of the transaction. The “Suspicious Transaction Indicator Report” (STIR) was designed to capture transactions or series of transactions that were structured to avoid suspicion and possible reporting to the proper authorities. 2. 3.
The absence of contributions from donors located within the country of origin of the NGO. m. Incongruities between apparent sources and amount of funds raised or moved by the NGO. Client was reported and/or mentioned in the news to be involved in terrorist activities. An individual receiving remittances. Value of the transaction is over and above what client is capable of earning. Transactions of individuals. Client is under investigation by law enforcement agencies for possible involvement in terrorist activities. Reporting Requirements and Procedures* Property of PSBank Data Classification: Confidential Revised December 2009 35 .d. l. A mismatch between the pattern and size of financial transactions on the one hand and the stated purpose and activity of the NGO on the other. Deposits being made by individuals who have no known connection or relation with the account holder. j. o. q. companies or NGOs that are suspected as being used to pay or receive funds from revolutionary taxes. g. k. i. Any transactions or clients that have the characteristics of any of the above should be immediately reported to Compliance Office J. h. Client is conducting a transaction that is out of the ordinary for his known business interest. The NGO does not appear to have expenses normally related to relief or humanitarian efforts. n. p. but has no family members working in the country from which the remittance is made. identical or analogous to any of the foregoing. Transactions of individuals. e. Any other transaction that is similar. f. companies or non-governmental organizations (NGOs) that are affiliated or related to people suspected of being connected to a terrorist group or a group that advocates violent overthrow of a government.
c. The bank may use Electronic Signatures. the case facts will be elevated to the X-Man queue of all the AMLA Committee using the AMLA Decision Template for disposition. Enters his/her decision in the prescribed XMan approval screen. If the matter is for automatic reporting to AMLCS. 2. If decision is to report.) g. NOTEs: 1) AMLA Committee Members will receive SMS advising them of their needed actions. at least 4 AMLA Committee members must vote in favor of reporting the case as STR.. CAG. If the matter will require detailed review by the bank’s internal AMLA Committee. CBRCD discover a suspected fake/falsified documents from clients. Additionally. 2) Majority decision must be made before the process can flow to the next step (i. Officer/supervisor reviews the merits of the issue reported and makes a decision to approve the incident as reportable under existing rule or not. the Suspicious Transaction Report to AMLCS will be generated. Once a unanimous decision is arrived. (See Annex 4) • Scenario 1: Elevation of scenarios/cases which are not surfaced by any system a. e. the corresponding AMLCS STR following the prescribed formats will be generated. 2009 on reporting of fake/falsified document/s submitted by client . f. AMLA Process details of reporting elevation to cover STR required reports generation that will be covered by the X-Man System. For STR.1. electronic and hard copy reports will be submitted to AMLCS As agreed upon during the AML Committee Meeting held on October 16. where LOD. X-Man will review the transaction details if the case is for automatic report submission or for further AMLA Committee deliberation. Staff/Officer who originally discovered a possible crime/losses/suspicious transactions accesses X-Man to encode the details of the transaction/situation b. NOTEs : 1.e. Bank also adopts the following procedures in reporting possible suspicious transaction: (Revised December 2009) Issues and Discussions FOR LOAN Committee Agreements/ Discussions Property of PSBank Data Classification: Confidential Revised December 2009 36 . X-Man reviews the scenario and classifies if incident is reportable to AMLCS as STR d.
• Submitted fake ID/Business Papers • Submitted fake ITR • Submitted fake TCT/other related docs such as RETR.CAG must enroll the borrower in the ICDB negative info .CAG must report the case to Compliance Office within 24 hrs. If documentary deficiency was discovered by CAG. Thus. General Rule: If PRIOR to encoding. LPSD discovered the possibly spurious docs the application will not proceed. Thus the transaction is similar or analogous to the grounds or reasons why a transaction is deemed spurious (swindling etc). etc. . If documentary deficiency was discovered by LOD during booking B. NOT REPORTABLE Agreement: Since the case is not even contained in our database and the fraud was prevented from the start. thus. If loan application was ENCODED & it was found out that certain documents used were fabricated & falsified. Tax Declaration. • Submitted fake AFS/SAL • Submitted fake proof of employment documents (Cert. Payslip) • Provided erroneous address/contact information Property of PSBank Data Classification: Confidential Revised December 2009 37 . depending on who discovered the spurious documents used: Dispositions as agreed upon by the AML Committee: 1. of Employment. there is no need to report such cases because there is no transaction yet. . For Evaluation This will be subject to evaluation. Elevation to Compliance Office is not needed.There is no need to elevate this case to AML Committee. the loan application was disapproved: DISPOSITION: -FOR AUTOMATIC REPORTING as RCL & STR due to submission of falsified documents as contained under BSP Cir. 587 (on Reporting of Crimes & Losses) and STR because the client is not properly identified if ID docs are faked or it was an attempt to defraud the bank. 2.CAG must coordinate with CO on submission of RCL & STR to BSP & AMLC . The case will form part of the monthly summary report of the AML Committee to Board.TRANSACTIONS: A.
• Scenario 2: AMLA System elevation of possible suspicious transactions a. AMLA System generates a list of possible AMLA suspicious transactions. General Rule: If PRIOR to account opening. .Compliance Office to elevate to AML Committee for decision to report or not and if there is need to include subject in the ICDB negative list. there is no need to report such use of fake documents. Branch discovered use of spurious docs and does not open the account. . Elevation to Compliance Office is not needed Dispositions as agreed upon by the AML Committee: .CO coordinates with LOD on submission of RCL & STR to BSP & AMLC NOT REPORTABLE Agreement: Since the account was not opened. If documentary deficiency such as fake IDs & other deficiency were discovered by CBRCD in the course of dayto-day verification of documents/media submitted.If Branch justifications & result of evaluation indicates that indeed a possible fraud or falsification of documents existed and decided to close the account.LOD to elevate to AML Committee thru the Compliance Office for disposition . FOR DEPOSIT TRANSACTIONS: A.BOD to coordinate with Compliance Office for reporting to regulatory bodies. Branch will endorse to BOD for AUTOMATIC REPORTING as RCL & STR. -Branch to coordinate with CAG to include in the ICDB negative list B.or loan release: DISPOSITION: . which will be on queue to the line officers for negative confirmation. Property of PSBank Data Classification: Confidential Revised December 2009 38 .CBRCD requires the Branch to explain or provide justifications why a possible fake document was accepted .
CBRCD Staff/Officer tags a transaction in CDRS 2 as suspicious and provides basis of his/her observations. electronic and hard copy reports will be submitted to AMLCS g. The Bank may use Electronic Signatures. d. X-Man System generates a list of possible AMLA suspicious transactions. Once a unanimous decision is arrived. 2. The X-Man Reporting pile will classify the items for automatic reporting and those items that will require careful review and evaluation by the internal AMLA Committee. NOTEs : 1. Compliance Officer converts electronic file to the required CSV formats and electronically transmits the same.) f. the Suspicious Transaction Report to AMLCS will be generated. which will be on queue to the line officers for negative confirmation. Line Supervisors (Dept head/Division Heads for HO units or BSCO/AOO for BBG) makes negative confirmation on items on their queue. Officer/supervisor reviews the merits of the issue reported and makes a decision to approve the incident as reportable under existing rule or not. e. f. AMLA Committee Members will receive SMS advising them of their needed actions. Items that were given negative confirmation by the line officers/supervisors and other items that are not for automatic reporting will queue to the bank’s Internal AMLA Committee for disposition. Property of PSBank Data Classification: Confidential Revised December 2009 39 . b. Within 24 hours. which are not acted within 24 hours.e. Officer indicates. will immediately queue to the X-man reporting pile.b. Line Supervisors (Dept head/Division Heads for HO units or BSCO/AOO for BBG must indicate NOT for reporting and corresponding justification why a transaction should not be considered Suspicious. • Scenario 3 CDRS 2 system elevation of possible suspicious transactions a. For STR. Within 24 hours. Majority decision must be made before the process can flow to the next step (i. Also provides other details as necessary. Enters his/her decision in the prescribed CDRS approval disposition screen/ X-Man screen c. c.. d. Possible STRs which are not acted within 24 hours. Possible STRs. e. Also submits the required hard copy to the respective regulatory offices within the required 5 days turn around time. will immediately queue to the X-man reporting pile. 2. “NOT for reporting” and corresponding justification why a transaction should not be considered Suspicious. at least 4 AMLA Committee members must vote in favor of reporting the case as STR. NOTEs: 1. From CDRS 2 the transaction will flow in to X-man System.
no/low risk” transactions. This will cover the receipt of spurious checks through the central clearing dept. 3. 2. as a matter of rule all spurious checks are automatically reported as STR and Crimes and Losses. 2005. for which reporting of covered transaction was deferred and covered under Circular Letter dated June 16. However.f. the corresponding AMLCS STR following the prescribed formats will be generated. • Scenario 4 . h.000 within one (1) Banking day (See Annex 1 for detailed listing): 12) Auto debit arrangement 13) Payroll 14) ATM deposit/withdrawal 15) ATM bills payment 16) Other ATM/Internet Banking transactions 17) Buy/Sale of government/private securities 18) Trust transactions 19) Loan releases/payments 20) Inward/outward remittances 21) Foreign currency buying/selling 22) Sale of ROPA 1) 2) 3) 4) 5) 6) 7) 8) Cash/check deposit Cash withdrawal Check encashment Credit/Debit Memo Fund transfer Bills payment Collection Miscellaneous transactions 9) Sale of MC/DD/TT 10) Check warehousing 11) Remittance BSP Circular Letter No.CDRS 1 system elevation of possible suspicious transactions NOTEs: 1. 2. the procedure that will be followed will be similar to scenario 1. Covered Transaction Report (Revised: December 2009) a.2. While this process does not flow in to the X-man unlike CDRS 2.g above. CL-2009-037 “Anti-Money Laundering Council (AMLC) Resolution No. following scenario 2. Additionally. The X-Man Reporting pile will classify the items for automatic reporting and those items that will require careful review and evaluation by the internal AMLA Committee. 58 dated May 25. b. i. Following are different transactions that must be reported by the Bank to the Anti-Money Laundering Council whenever the amount involved exceeds Php500. If the matter is for automatic reporting to AMLCS. amended AMLC Resolution No.g. 24 dated 18 March 2009”. 2005 by excluding “Transactions between Banks and government agencies” from among the “non-cash. All “covered transactions” shall be generated centrally at Head Office in accordance with the electronic reporting format (See Appendix) prescribed by Property of PSBank Data Classification: Confidential Revised December 2009 40 . X-Man will review the transaction details if the case is for automatic report submission or for further AMLA Committee deliberation.
6. Internal operating expenses of Banks. Araneta 2. The CTR shall be transmitted within ten (10) Banking days from transaction date. The Covered Transaction Report (CTR) shall be sent to the AMLC in encrypted electronic form either via leased lines or through Internet facilities. Transactions involving fund transfers between same account holder within same Bank. d. K. In case of subsequent corrections or major change in the CTR. Caparas SVP/ Operations Group Head SVP/ Remote Banking Head VP/ Chief Audit Executive VP/ Chief Risk Officer VP/ Collections &Remedial Mgt. Emma B. Co 3. Only authorized officials of the Bank shall be allowed to send the CTR electronically to AMLC. There are some covered transactions that are exempted from reporting to the AMLC. 4. 5. No corresponding hard copy report is necessary. Llanera 5. Transactions between Banks operating in the Philippines. Group Head FVP/ IT Head VP/ Chief Compliance Officer AVP/Bank Operations Division 41 .the Anti-Money Laundering Council. Jaime Valentin L. a different CTR shall be prepared for the corrected batch to ensure identification and appropriate disposition on the part of the AMLC. Gomez Members: 1. Jaydee P. Dela Cruz 7. e. Patricia L. Operating units responsible for the data generation shall be as follows: Transaction Type Transactions captured by the deposit system Transactions captured by the Loan System ATM Transactions Remittances Sale of ROPA Treasury transactions Trust Transactions Responsible Unit IT Division IT Division IT Division Remittance Unit Remedial Management Treasury Operations Trust Department c. Roll-over of placements. Castaneda 4. Ma. Revised December 2009 . Property of PSBank. 3. Neil Estrellado 6. Grace G. 2. Loan interest/principal payments debited from deposit account maintain in the lending bank. The Anti-Money Laundering Committee of the Bank (Revised: December 2009) The Bank’s Committee on Anti-Money Laundering is composed of: Chairman :Noli S. Francis C. to wit: 1. Transactions between BSP and Banks. Reproduction of any part of this Manual without the Bank’s consent and authorization is punishable.
record keeping. Attempted or completed schemes of syndicates such as use of spurious Bank documents in order to defraud the public and can cause damage to the Bank in terms of reputation and legal risks. Submit updates for notation of the Audit Committee and Board of Directors on the Reports on Suspicious Transactions reported to the AMLCS and the Report on Crimes and Losses submitted to BSP. submitted to the President. including criteria or basis on what comprise a suspicious transaction. 5. . 7. In view of the required turn around time in submission of report (within 5 working days from date of discovery/confirmation of the suspicious transaction as per Bank’s practice) an email advice may be routed to all members and chairman for comments and consensus to report or not to report. and reporting of covered and suspicious transactions. Reproduction of any part of this Manual without the Bank’s consent and authorization is punishable. Internal and external fraud to determine appropriate actions to be undertaken by the Bank.NOTE: The Chief Compliance Officer will act as the Secretary of the Committee The duties and responsibilities of the Bank’s Anti-Money Laundering Committee are as follows: 1. which should be. c. The frequency on the conduct of AML Committee meeting will be as necessary. In case of unresolved issues. Audit Committee or the Board whichever is appropriate. 4. conduct investigation and analysis of the following but not limited to: a. 3. 2. Review internal policies and guidelines pertaining to reporting of Suspicious Transaction Reports. IRR dated Sept. Revised December 2009 42 . Property of PSBank. b. 2003) Review possible suspicious transaction reports (STR) prior to submission of report to AMLC. Based on the recommendations of Fraud Investigation Units (RMO and IAG) or the Compliance Officer. Cases of employee lapses related to failure to comply with the requirements of AMLC on customer identification. given the rules set on deciding STR cases and in the discharge of the committee reports.g. Recommend revisions of the Anti Money Laundering Manual for submission to the board of directors to ensure Bank’s full compliance to the Anti Money Laundering revised Implementing Rules and regulations. the chairman may opt to call for an immediate meeting for the committee to finalize its recommendation or position on certain crucial transactions. (e.
Property of PSBank. property or related web of accounts as of the time they were frozen iv. All relevant information as to the nature of the monetary instrument or property . Review and define scenarios that may result to a suspicious transaction trigger or alerts. The amount of the monetary instrument. Freeze/forfeiture orders and letter of authority to inquire/examine certain accounts/ transactions/documents shall be promptly coordinated with AMLCS through the Head of Legal Department by the head of the concerned operating unit prior to complying with such orders/letters. L. Within 24 hours from receipt of the freeze order. by personal delivery. Upon receipt of the freeze order issued by the Court of Appeals and upon verification by the Bank that the related web of accounts originated from and/or are materially linked to the monetary instrument or property subject of the freeze order. Review and approve system requirements. a detailed written return on the freeze order. 7. 2. Coordinate with PSB Anti Money Laundering Committee and AMLC regarding updates and other anti money laundering issues that need to be cascaded within PSBank. the Bank should freeze these related web of accounts wherever these funds may be found. 4. FO received shall be sent immediately to all branches through email and/or fax. Revised December 2009 43 . Freeze Orders (FOs) from the Court of Appeals shall be received by Compliance Officer. Bank shall likewise immediately furnish a copy of the notice of the freeze order upon the owner or holder of the monetary instrument or property or related web of accounts subject thereof. Upon receipt of the notice of the freeze order. in coordination with the Compliance Unit/Officer and Legal Department. Branches concerned. Reproduction of any part of this Manual without the Bank’s consent and authorization is punishable. FREEZE ORDERS 1. The account number(s) ii. specifying all the pertinent and relevant information which shall include the following: i. policies and procedures to ensure Bank’s AMLA compliance.6. 3. the Compliance Unit/Officer shall coordinate with Legal Department for proper direction on course of action to be taken in accordance with existing laws/regulations and policies and immediately freeze the monetary instrument or property and related web of accounts subject thereof. shall submit to the Court of Appeals and the AMLC. The name(s) of the account owner(s) or holder(s) iii. All inquiries/communication/directives relating to FO/Instructions from the AMLC shall be coursed through the Compliance Unit/Officer.
Upon expiry of the 20-day period of the freeze order issued by the Court of Appeals. Records shall be retained as originals in such forms as are admissible in court pursuant to existing laws and the applicable rules promulgated by the Supreme Court. evidence for prosecution of criminal activity. In addition to the required full documentation of customer relationships. the funds and sources of which originated from and/or are materially linked to the monetary instrument(s) or property(ies) subject of the freeze order(s). Any information on the related web of accounts pertaining to the monetary instrument or property subject of the freeze order vi. RECORD KEEPING Transaction records should be sufficient to permit reconstruction of individual transactions so as to provide. The time when the freeze thereon took effect “Related Web of Accounts pertaining to the monetary instrument or property subject of the freeze order” is defined as those accounts. and the type and identifying number of any account involved in the transaction. 5. if necessary. Revised December 2009 44 . These include. the following: • • • • • Account application forms Customer identification documents Specimen signature cards Transaction records Business correspondence In cases of closed accounts. Property of PSBank. Examples of the necessary components of transaction records include: customer’s (and beneficiary’s) name. address (or other identifying information normally recorded by the intermediary). the Bank strictly requires that following policies on record keeping must be observed: 1. the Bank should not lift the effects of the freeze order without securing official confirmation from the AMLC that the Court of Appeals has already lifted the Freeze Order. but not limited to.v. A complete record must be maintained in the branch/department/unit for all items/documents/ records transmitted . the type and amount of currency involved. 2. M. Records of all customer accounts and transactions must be maintained and stored for a period of five (5) years reckoned from the date of the transaction. Reproduction of any part of this Manual without the Bank’s consent and authorization is punishable. the nature and date of the transaction. All heads of departments/branches/units must ensure that customer records are properly safe kept in accordance with the Bank’s records retention policy. records should be preserved and safely stored for a period of at least five (5) years from the date of closure of the accounts.
3. N. Confidentiality All officers and employees of the Bank are strictly prohibited from disclosing to any person. including clients. Compliance Office Branch Head/BSCO 45 5. In order to promote awareness and ensure proper compliance with the requirements of the AMLA. E-mail copies of the covered/suspicious transaction report should be limited to the persons required to be furnished under the prescribed reporting process. instructions and policies issued by the AMLC/BSP/SEC relating to the prevention of money laundering. resolutions.for safekeeping in the Bank’s offsite storage area. Function/Responsibility Development and issuance of Operating Manual on Anti-Money Laundering and dissemination of all memorandum circulars. Property of PSBank. Reproduction of any part of this Manual without the Bank’s consent and authorization is punishable. Audit Group. COMPLIANCE Compliance with the requirements of the Anti-Money Laundering Law as contained in the Bank’s AMLA Operating Manual shall be the responsibility of each officer and staff of the Bank under the guidance and supervision of the respective heads of the business or operating units. 4. Issuance and enforcement of supplementary internal operating guidelines for branches Reporting of Covered and Suspicious transactions Periodic compliance checking to ensure proper implementation by business/operating units Designated Officer/Unit Compliance Office Compliance Office Refer to IX (b) and (c) Auxiliary Compliance Officer. following are the support functions and responsibilities of designated units in the Bank: 1. In case a money laundering case based on any record kept by the Bank has been filed in court. 2. O. In case of relocation or transfer of assignment of personnel. such record file must be retained beyond the required 5-year retention period until it is confirmed that the case has been finally resolved or terminated by the court. Administrative sanction/s may be imposed by management in accordance with the Bank’s Code of Ethics and Behavior. the responsible officer must properly turnover the records to the person who assumes the position.Administrative Sanctions Bank officers and staff who may be found violating any of the requirements under this manual shall be asked by the Compliance Office to submit his/her written explanation/s within 48 hours. 3. XII. the fact that a covered or suspicious transaction has been or is being reported to the AMLC. Revised December 2009 . Monitoring of Branch’s/Business Unit’s compliance .
shall undergo training on a regular/periodic basis. the ultimate responsibility for the proper supervision. detect any money laundering activities. 46 . Over all responsible for ensuring compliance by the Bank with provisions of the Anti-Money Laundering Law and its Implementing Rules and Regulations. 8. EDUCATION AND TRAINING The Bank should institute adequate screening and recruitment procedures for Bank personnel including designated compliance officer/s. officers and staff. techniques and procedures to test compliance with the requirements under this manual. the Audit Group includes as part of its regular audit programs. as amended. Revised December 2009 a. In compliance with RA 9160. Compliance Office Note: Notwithstanding the foregoing duties and responsibilities. & extend investigative services to properly document money laundering report. as amended by RA 9194. 6. All Audit reports must have an AMLA sub-section that will cover how compliant is the HO Unit and branches in terms of its faithfulness to its duties as employees of covered institution. Record retention. Employee training and other educational support programs shall be as follows: . to make them fully aware of their responsibilities and accountabilities in implementing the Anti-Money Laundering guidelines contained in this Manual. Likewise. Reproduction of any part of this Manual without the Bank’s consent and authorization is punishable. including refresher trainings. Property of PSBank. AUDIT REVIEW The Internal Audit Group shall include in their audit program. d. all Bank employees. Serve as liaison between the Bank and the AMLC in matters relating to compliance with the provisions of the Anti-Money Laundering Law and its Implementing Rules and Regulations. reporting and compliance pursuant to the AMLA. its Revised Implementing Rules and Regulations shall rest with the Bank and its Board of Directors. specific audit programs/procedures on AML. and. XIV. focused mainly on the following: Compliance with minimum identification requirements as part of the Bank’s KYC policy.with AMLA requirements and monthly submission of Compliance Checklist to Compliance Office. XIII. c. Personnel Training Head of Business Unit Training Division (in coordination with Compliance Office) Compliance Office 7. Reporting of covered and/or suspicious transactions. b. RECRUITMENT. Adequacy of AMLA training programs for employees. and the AML policy of the Bank.
Revised December 2009 47 . . This shall include the nature of offenses and penalties under the AMLA. as well as resolutions. to update them of any changes in the laws and/or regulations and to keep them abreast with changes and/or additions to the Bank’s internal processes to combat money laundering. line supervisors and managers shall be provided with a higher level of education that will cover all aspects of the anti-money laundering procedures. they shall be trained to properly handle unusual transactions and/or non-regular customers particularly where large cash transactions are involved. the Bank’s Compliance Officer shall issue Compliance Bulletins to remind key personnel of their responsibilities. (AMLA Reinforcement Training) d) Periodically. This training module will likewise focus on actual cases and examples that were encountered by the bank to provide a higher level of learning among the participants. Training goal is for them to be able to identify suspicious transactions and to properly implement procedures when confronted with a transaction deemed to be suspicious. (Basic AMLA Training) b) Front-line personnel such as New Accounts Clerks and Tellers deal directly with customers and are usually the first point of contact with potential money launderers. e) The Anti-Money Laundering Operating Manual. the requirements for verification of customer identity and retention of records and the responsibilities and internal reporting procedures and done on an annual basis.a) Training shall be provided to all new employees of the Bank for them to acquire a general understanding and appreciation of the background to money laundering. instructions and policies issued by the AMLC/BSP/SEC relevant to money laundering shall be posted in the Bank’s InfoChannel to provide easy access to information by officers and staff in all of the Bank’s branches/offices nationwide. Reproduction of any part of this Manual without the Bank’s consent and authorization is punishable. bulletins. c) Rank and file. Property of PSBank. the need to be able to identify suspicious transactions and report such transactions to appropriate Bank authorities. internal memoranda. Because of their vital role.
Prepaid card purchase 5. ATM Deposit ATM withdrawal ATM bills payment Fund Transfer Order Checkbooks 1. Credit card payment C. 2. Inward remittance 3. 6. 8. Loan availment Loan payment Loan repricing Loan renewal Loan pretermination LC (Import/Export) Doc. 4. Cash Deposit Cash withdrawal Encashment Check deposit Certificate of Time C. Premium/plan payment 3. Regular Trust Fund 9. Auto debit arrangement 18. 5. 3. 19. 3. Debit Memo 9. 7. IBODI – foreign E. Credit Card 1. Fiduciary-safekeeping 11. I. Contributions/subscript ions K. 9. 2. 3. ANNEX 2 . 4. Credit card cash advance 3. Payroll B. 4.ANNEX 1 BANK TRANSACTIONS COVERED FOR REPORTING UNDER AMLA A. Transfers (local) 10. Fiduciary-Escrow 14. Investment Management Fund F. Collection 12. Loan payment 8. Loan release 7. Special time deposit 8. Buy Fx 2. Check warehousing 15. New business for insurance. Bills payment 11. 4. Outward remittance 2. Claims/maturities H. Prepaid card loading G. Buy Sell Lodgments Upliftment EQ in EQ out H. Reproduction of any part of this Manual without the Bank’s consent and authorization is punishable. 4. Withdrawal/redemption 3. Expense payment 5. Purchase security/asset 4. Purchase of MC/DD/TT 14. 2. SWIFT transactions J. Sell Fx E. educational plan 2. Remittance 1. Bills Purchase 16. Treasury 1. 6. Credit bills-export I. Fiduciary-Executorship 13. pension. Trust Transactions 1. 5. IBODI – Govt 2. Collection Outgoing guarantee Clean collection (export) 10. 5. Fiduciary-Bond issues M. F. Fiduciary-Pre-need plan 17. Revised December 2009 48 . D. Remittance 17. FX Retail 1. Credit Memo 7. FiduciaryAdministratorship 16. Common Trust Fund 10. IBODI – private D. 3. 5. Consumer Banking 1. Property of PSBank. 2. Fiduciary-guardianship 12. Remote Banking 1. 15. 2. Deposit 6. Institutional Banking 1. FiduciaryCustodianship L. Earnings 6. Securities G. Miscellaneous transactions 13. Credit card purchase 2. J. Fiduciary-Life insurance Trust 18. 3. Core Deposits/Withdrawals 1.
: Other details of ID documents: Nature of Transaction or Source of Funds: Nature of Transaction or Source of Funds: B.INTERNAL REPORT ON SUSPICIOUS TRANSACTION Branch/Office _________________________________ CUSTOMER IDENTIFICATION A. : TIN/SSS/GSIS No. Individual Account Number : Name : Present address : Permanent address : Date of birth : Place of birth : Nationality : Name of employer (or nature of business if selfemployed): Address of employer/business: Contact Nos. Revised December 2009 49 . Reproduction of any part of this Manual without the Bank’s consent and authorization is punishable. Property of PSBank. Corporate/Juridical Entity Account Number : Registered Name: Date of registration: Address : Telephone No/s: Fax No/s : Nature of business : List of document/s presented to verify legal existence: Name of beneficiary (if applicable) : Address of beneficiary (if applicable) : Name of beneficiary (if applicable) : Address of beneficiary (if applicable) : DESCRIPTION/DETAILS OF SUSPICIOUS TRANSACTION: (Use additional/separate sheets if necessary) Name of front-line employee: Officer who prepared the report: Date of Report: Other instructions: ANNEX 3 .
PSBANK MONEY LAUNDERING SUSPICION EVALUATION RECORD AMLA COMMITTEE ELEVATION TEMPLATE (Revised November 2009) Date endorsed to AMLA Committee Case Reference Number: (to be assigned by Compliance Office) Customer Name: Address Date of Occurrence: Date of Suspicion was confirmed: Consummated? YES NO Amount involved: IDs submitted Bank Business Unit Relationship/s Metro Grp Relationship? YES NO Insurance Cover Discovered by/How Discovered Case Brief Description: Date Reported To AMLC BSP AMLA Committee Member 1. Neil Estrellado 6. Francis Llanera 6. Jaydee Caparas 8. Grace dela Cruz AMLA COMMITTEE DECISION TEMPLATE REPOR REPORT As HOLD needs T as C&L additional info/issue STR resolution COMMENTS . Noli Gomez 2. Emma Co 5. Revised December 2009 50 . Trixie Castaneda 4. Reproduction of any part of this Manual without the Bank’s consent and authorization is punishable. Property of PSBank. Jimi Araneta 3.
Amount is 20K or more involving crimes of theft. falsification. Regardless of amount is committed by an employee of the bank. an initial report submitted within deadline may be accepted: Provided. final reports on crimes and losses with incomplete information as required under SES Form 6G shall be considered erroneous reports and the concerned bank shall be required to submit amended reports subject to penalties on late reporting for Category B reports under Subsection X162.2 of the MORB. Property of PSBank. negligence and deceits or damage to bank properties and facilities. that a complete report is submitted not later than twenty (20) calendar days from termination of investigation. 2. Must be submitted to in two (2) copies: BSP SDC and BSP SITD. robbery. Important reminder to HRG/ BBG and other offices submitting reports on Crimes and Losses: Where a thorough investigation and evaluation of facts is necessary to complete the report. frustrated or attempted): • Purpose of transaction is questionable (no legal/trade/economic justification) • No proper identification of client or remitter (in the case of RTS. estafa . being presently committed or to be committed in the future • Any transaction that is similar or analogous to the above. swindling. insufficient/spurious IDs) • Amount of transaction not commensurate with business or financial capacity of client • Structuring of transaction amount to avoid 500K threshold • Transaction deviates from Customer Profile or past transactions of the account • Transaction is related to an unlawful activity or crimes mentioned under anti money laundering law (14 predicate crimes) that was committed in the past. credit card related or other crimes that may cause to the bank. Reporting Criteria for Crimes and Losses to BSP (whether consummated. NOTE REPORT SUBMISSION DATE: within 10 calendar days from date of knowledge of crime or incident as per BSP Cir 587. As defined in Cir 587 Negligence is: the failure to exercise the care which an ordinarily prudent person would use under the circumstances in the discharge of the duty then resting upon him 3. . 1. Reporting Criteria on Suspicious Transactions. include ANY of the following circumstances (whether consummated. Moreover. Reproduction of any part of this Manual without the Bank’s consent and authorization is punishable. frustrated or attempted). NOTE REPORT SUBMISSION DATE: within 5 banking days from date of determination/confirmation that transaction was suspicious (as per PSBank AMLA Manual) B.NOTES: A. Revised December 2009 51 . Amount of 100K per incident involving material loss or destruction of properties and facilities other than those arising from crimes. it will fall into this category: Client's address given I assume was a wrong which resulted to RTS. negligence included.
3 SR6. No clear source of funds. Violation of eCommerce Law 12. Failure to submit business documents.5 SR6. Reproduction of any part of this Manual without the Bank’s consent and authorization is punishable. murder 13. Property of PSBank.10 SR6.1 SR6. Application for FT. intention to use account for incoming remittances or outward remittances was not disclose as purpose of opening the account. unexplained incoming remittance to a regular account. cyclical pattern of loan transactions being paid up then re-availed.9 SR6. Hijacking.8 SR6. Felony or practices that are punishable under the new penal law Any transaction that is similar or analogous to the above. Graft and corruption 4. Account movements not reflective of nature of true customer’s business (in/out funds same day or for short period of time). of individuals. significant incoming remittances. (Groups known to be planning to overthrow the govt.4 SR6.2 SR6. Qualified theft 9. Kidnapping for ransom 2.14 SR7 . insufficient or use spurious IDs/ faked documents ITR etc) Failure to disclose source of funds/wealth. • Structuring of transaction amount • Transaction deviates from Customer Profile or past transactions of the account (unexplained improvements in ADBs. Transactions from FATF uncooperative countries) • Customer involved in unlawful activity or crimes mentioned under anti money laundering law (14 predicate crimes below) that was committed in the past. reactivated dormant accounts.6 SR6. • Amount of transaction not commensurate with business or financial capacity of client. arson.12 SR6. Revised December 2009 .13 SR6. Robbery or extortion 6. Plunder 5. CC/MC/GC/$DD not fully accomplished • Lacks or incomplete identification of client (including cases of RTS.ANNEX 4 INDICATIONS OF SUSPICIOUS TRANSACTIONS Xman General Templates Exception Code SR1 Exceptions Questionable Purpose of transaction OR No purpose/legal/trade/economic justification. Piracy at high seas 8. companies or NGOs that are suspected as being used to pay or receive funds from revolutionary taxes etc) • 52 SR2 SR3 SR4 SR5 SR6 SR6. Swindling 10. Drug trafficking 3. AMLA List/OFAC list. Smuggling 11. excessive purchases of FX. NGO does not appear to have expenses normally related to relief or humanitarian efforts. PEP. Fraudulent practices 14. Jueteng or Masiao 7. Negative information on Client based on ICDB. Failure to accomplish AMLA Questionnaire.11 SR6.7 SR6. being presently committed or to be committed in the future 1.
A business owner (e. drafts. Corporate account(s) where deposits or withdrawals are primarily in cash rather than checks. money transfers or other negotiable and readily marketable money instruments. traveler’s checks. etc. Frequent exchange of cash into other currencies. An account or customer that has frequent deposits or large amounts of currency that appear to have been withdrawn from other Banks (i. Retail deposits of numerous checks but rare withdrawals for daily operations. traveler’s checks and cashier’s checks. Property of PSBank. who purchases cashier’s checks.e.. a one-location storeowner) who makes several deposits on the same day at different Bank branches. especially one located in a haven country. Substantial increases in cash deposits without apparent cause especially if the same is transferred to another account not usually associated with the client. A request for loans to a company.Client failed or refused to disclosed purpose for opening the account . A depositor. Revised December 2009 .g.Source of remittance with no clear purpose or underlying legal basis Unusual cash purchases of drafts. A loan secured by a certificate of deposit or other investment vehicle of other Banks.XMAN STR Decision Parameters Reporting units Scenarios Exception Category SR 1 SR 1 SR1 SR1 SR1 SR1 SR1 SR1 X AMLA COM Automatic DISPOSITION (STR) X X X X X BBG BBG/ REMITTANCE BBG . Reproduction of any part of this Manual without the Bank’s consent and authorization is punishable. A customer who often visits the safety deposit box area immediately before making cash deposits just under the reportable threshold. wrapped in currency straps that have been stamped by the other Bank. Frequent request for Bankers drafts. with large amounts of cash. Wiring cash proceeds of a cash deposit to another country without changing the form of SR1 SR1 SR1 SR1 X X X X SR1 SR1 SR1 SR1 X X X X 53 .) An account or customers that frequently deposits of extremely dirty bills. or for a loan secured by obligations of an offshore Bank.
Client’s information on application form is inconsistent with the information on the IDs presented (name.Intentional changes in customer static information like spelling of name. Revised December 2009 . Property of PSBank.Client used aliases . spouse details in order to by pass ICDB detection .Client is PEP disapproved by mgt from opening account -Returned to Sender (RTS) thank you letter . Birthday. .Client requested to open a numbered account . This may indicate the customer has another source of cash. address.Failed to declare purpose of loan . Wire transfers between accounts.Transactions indicative of regular in/out deposit/ withdrawal on same day or within short period of time. without visible economic or business purpose.Client has no clear source of funds/wealth . especially if the wire transfers are effected through countries which are identified or connected with terrorist activities . birthday) . Etc . -Deposits being made by individuals who have no known connection or relation with the account holder.BBG BBG BBG BBG BBG/ REMITTANCE SBUs/PLPS/ Credit Admin/LOG currency. -Client is conducting a transaction that is out of the ordinary for his known business interest. Client failed or refused to disclosed purpose for opening the account A customer who operates a retail business and provides check-cashing service and does not make large draws of cash against checks deposited.Use of fake IDs .Use of fake IDs supporting documents . -An individual receiving remittances.Client failed to submit acceptable IDs . RETC. By-laws.Non-starter and investigation will show that SR1 SR1/SR2 X X SR1/SR5 X SR 2 SR 2 SR 2 SR 2 SR 2 SR 2 SR 2 SR 2 SR 2 SR 2 SR 2 SR 2 SR 2 X X X X X X X X X X X X X X SBUs PLPS/Credit Admin/LOG SBUs/PLPS/ Credit Admin/LOG Collections SR 2 SR 2 SR 2 X 54 . Reproduction of any part of this Manual without the Bank’s consent and authorization is punishable. but has no family members working in the country from which the remittance is made.Submission of spurious supporting documents ITR.
Property of PSBank. prior Banking relationships. alien registration card. a local address. A customer who presents unusual or suspicious identification documents that the Bank cannot readily verify. Source of remittance with no clear purpose or underlying legal basis A business that is reluctant to provide complete information regarding the purpose of the business. A customer who is reluctant to provide information needed for a mandatory report to have the report filed or to proceed with a transaction after being informed that the report must be filed. Revised December 2009 . driver’s license. or who refuses to provide information the Bank requires to open an account. or identification (passport. or its location.RMU/Fraud control Unit Collections RMU/Fraud control Unit Collections RMU/Fraud control Unit BBG BBG/ REMITTANCE BBG customer used faked IDs and spurious docs with intention to defraud the bank -Fraud initiated by the applicant and was turned in by agent (e. top performer) in good faith or a case of “nalusutan or naisahan” during the course of solicitation Client remains uncontacted and declared residence address w/c she has vacated prior to her auto loan application Reluctance to provide information when opening an account. officers or directors. A customer who has no record of past or present employment but makes frequent large transactions. Reproduction of any part of this Manual without the Bank’s consent and authorization is punishable. A customer who opens an account without references.).g. A customer whose home phone is disconnected. A business that is reluctant to reveal details about its activities or to provide financial statements. A customer who is unwilling to provide personal background information when opening an account or purchasing monetary instruments above a specified threshold. etc. A customer who includes no record of past or present employment on a loan application. A business that refuses to provide information to qualify customers for credit or other Banking services. A business that presents financial statements noticeably different from those similar X SR 2 SR 2 SR2 SR2 X X X SR2 SR2 X X SR2 SR2 X X SR2 X SR2 SR2 SR2 SR2 SR2 SR2 X X X X X 55 .
SBUs/PLPS/ Credit Admin/LOG businesses. Property of PSBank. Beneficiary of huge volume of unexplained remittances Instructing the Bank to transfer funds abroad and to expect an equal incoming wire transfer from other sources. usually in amounts below a reportable threshold. and then consolidating into a master account and transferring them outside the country. Example issuance of loan payment PDC (Post dated check) after 6 months of account closure -Repetitive deposits or withdrawals that cannot be explained or do not make sense. robbery. Numerous cash deposit transactions to conceal the total amount of transaction. Revised December 2009 56 . Reproduction of any part of this Manual without the Bank’s consent and authorization is punishable. Transferring funds into several accounts. Large cash deposits made by an individual or company whose business should not normally generate substantial amounts of cash. -Client is under investigation by law enforcement agencies for possible involvement in terrorist activities Amount is 20K or more involving crimes of theft. Client requested to open a numbered account Client used aliases Negative information on client obtained from ICDB Negative information on client obtained from OFAC LIST Negative information on client obtained from AMLC Terrorist list Client is PEP which disapproved by mgt from opening account Returned to Sender (RTS) thank you letter Use of fake IDs supporting documents Sources and/or beneficiaries of wire transfers are citizens of countries which are identified or connected with terrorist activities Client is conducting a transaction that is out of the ordinary for his known business interest. estafa or other deceits involving loss or damage to bank SR2 SR2 SR2 SR2 SR2 SR2 SR2 SR2 SR2 SR2 SR2 SR 2 SR2/SR5 SR3 SR3 SR3 SR3 SR4 SR4 X X X X X X X X X X X X X X X Collections/CSD/ LOG BBG BBG/Remittance BBG/Remittance BBG BBG X X SR 4 SR 4 X X BBG/SBU/HO Units . Client failed to submit acceptable Ids. swindling. Clients who wish to maintain several trustees’ accounts not consistent with type of business.
Amount is LESS than 20K involving crimes of theft. Sending or receiving frequent or large volumes of wire transfers to and from offshore institutions. A customer who suddenly pays down a large problem loan with no reasonable explanation as to the source of funds. substantial cash deposit composed of many small bills and coins. Reproduction of any part of this Manual without the Bank’s consent and authorization is punishable. Receiving wire transfers and immediately purchasing monetary instruments prepared for payment to a third party.Deviation from the usual volume of deposit or withdrawal amount.Beneficiary of huge volume of unexplained remittances . without visible economic or business purpose. . . frustrated or attempted.Sources and/or beneficiaries of wire transfers are citizens of countries which are identified or connected with terrorist activities -Value of the transaction is over and above what client is capable of earning. frustrated or attempted Regardless of amount is committed by an employee of the bank Single.Deviation from Deposit ADB profile . SR 4 X SR 4 SR4 SR4 SR5 SR5 SR5 SR5 X X X X X BBG BBG CREDIT ADMIN/BBG/ LOG/ COLLECTIONS BBG BBG BBG REMITTANCE REMITTANCE BBG SR 5 SR 5 SR 5 SR 5 SR 5 SR 5 SR 5 X X X X X X X SR 5 SR 5 SR 5 X X X BBG .BBG/SBU/HO Units HRG/BBG/HO Unit/Audit/Fraud Control Unit BBG BBG properties and facilities.Dormant account which was suddenly reactivated and with high volume of movements -Wire transfers between accounts. whether consummated. -Incongruities between apparent sources and amount of funds raised or moved by the NGO. Sudden inconsistent change in currency transactions or patterns. swindling. robbery.Deviation from the usual account movement in terms of period of deposit and withdrawals . Frequent exchanges of small bills for large bills or vice-versa. whether consummated. estafa or other deceits involving loss or damage to bank properties and facilities. Property of PSBank.Huge remittances from countries with FATF negative information . especially if the wire transfers are effected through countries which are identified or connected with terrorist activities . Revised December 2009 57 .
7 SR6. Dormant account which was suddenly reactivated and with high volume of movements Regularly depositing or withdrawing large amounts by wire transfers to. without an apparent business reason or when inconsistent with the customer’s business or history.Validated information that client is involved in any of the predicate crime Any individual or group that is engage in Kidnapping for ransom activities.6 SR6. Any individual facing a crime of plunder Any individual engage in robbery or extortion Jueteng or Masiao Priacy at the High Seas Qualified Theft . Any individual/group that has illegal drugs business/drug trafficking Any individual or group that coerces or attempts to coerce a Bank employee not to file any required record keeping or reporting forms.5 SR6. and almost immediately wire transfers all but a token amount to another city or country.BBG/Remittance BBG BBG BBG BBG BBG Central Clearing An account that sends and receives wire transfers (especially to/from Bank-haven countries). Property of PSBank. -A mismatch between the pattern and size of financial transactions on the one hand and the stated purpose and activity of the NGO on the other.1 SR6.2 SR6. from. An account that receives many small incoming wire transfers or makes deposits using checks and money orders.8 SR6.Validated information that client is involved in any of the predicate crime . when such activity is inconsistent with the customer business or history. -Cash or funds flow is a mismatch to the nature of business or declared purpose of transaction .3 X X X X X X SR6.4 SR6.Returned Check items due to due to closed account or insufficient funds issued for a consideration SR5 X SR5 X SR5 SR5 X X SR 5 X SR 5 SR6 SR6 SR6.9 X X X X X X . or through countries that are known sources of narcotics or whose Bank secrecy laws facilitate the laundering of money. Reproduction of any part of this Manual without the Bank’s consent and authorization is punishable. Revised December 2009 58 .
-The absence of contributions from donors located within the country of origin of the NGO. companies or non-governmental organizations (NGOs) that are affiliated or related to people suspected of being connected to a terrorist group or a group that advocates violent overthrow of a government. Use of spurious ATM card which was transacted in our ATM machine Any individual engage in a smuggling business Violation of eCommerce Law Hijacking.11 SR6.g.Drawee bank returned check items for reason spurious. deceit or fraud prior or during the issuance/negotiation of the check. SR6.14 SR 7 X X X X X X X X BBG BBG BBG BBG SR 7 SR 7 SR 7 SR 7 SR 7 . companies or NGOs that are suspected as being used to pay or receive funds from revolutionary taxes. -Transactions of individuals. Revised December 2009 59 . 13 SR6.9 SR6. -Client was reported and/or mentioned in the news to be involved in terrorist activities.12 SR6.13 SR6. -The NGO does not appear to have expenses normally related to relief or humanitarian efforts. raised amount or any indications of swindling. identical or analogous to any of the foregoing. murder Fraudulent practices Felony of practices that are punishable under the new penal law.10 SR6. Reproduction of any part of this Manual without the Bank’s consent and authorization is punishable. COE or even payslip. Property of PSBank. ITR.9 SR6. Spurious PSB checks or MCs presented OTC or thru clearing which are proven to be fake issuances -Fraud initiated by the agent himself such as tampering of income documents e.9 X Central Clearing Collections RMU/Fraud control Unit ATM Dept/BBG branches SR6.9 SR6. -Any other transaction that is similar.Central Clearing . -Transactions of individuals. arson.
(yyyy/mm/dd) AMLAC Form 51 H Supervising Agency : 1 1 ./Covered Risk*: D ( yyyy/mm/dd ) Trans.correction 3 . 40 char. Revised December 2009 ( max.ind 2 corp ( 16-20 char ) ( max. Typ : STR CTRS/STR/FX 1 . Holder Flag : Please fill this space if flag is Y Y Y .erased A. Reference No*: Account No. DETAIL RECORD Submission Type*: 1 Rep.SEC 3 .see instructions ) Part 1. Property of PSBank.name divided into three/fields Name of Acct.IC Report Date*: Format Code*: PART II. Holder*: ( max. Holder : Last Name . Type*: Ind.ANNEX 5 SUSPICIOUS TRANSACTION REPORT (STR) FORM SUSPICIOUS TRANSACTION REPORT ( STR ) ( Completely fill up all parts that apply . HEADER RECORD Header Record Indicator : Institution Code*: Bank industry main entity type of unit branch no. 90 char ) Please fill this space if flag is N Name of Acct.BSP 2 . 30 char ) 60 . ) B. : Php Amount*: FX Amount : FX Currency Code : Nature/Purpose of Trans.new 2 . Subject Data : Name of Acct.*: 1 .name concatenated N ./Corp. Transaction Data Detail Record Indicator : Trans Date*: Trans. Reproduction of any part of this Manual without the Bank’s consent and authorization is punishable.nil 4 .
name divided into three/fields Please fill this space if address of account holder flag is Y Please fill this space if address of account holder flag is N Address of Acct.Brgy ( max. Reproduction of any part of this Manual without the Bank’s consent and authorization is punishable. 30 char ) Y . : Telephone No. No. 90 char ) 0 Please fill this space if flag is N Name of Beneficiary : Last Name . : SSS/GSIS/Registration No. Holder : Bldg/No. : Nature of Business : ( yyyy/mm/dd ) ( max. 30 char ) ( max. Revised December 2009 ( max. 30 char ) ( max. 30 char ) 61 . Holder Flag : Address of Acct. Beneficiary Data Name of Beneficiary Flag : Please fill this space if flag is Y Y Y . Property of PSBank.name divided into three fields Name of Beneficiary : ( max. Holder* Y ( max.name concatenated N .name concatenated N .First Name Middle Name Address of Acct. 30 char ) ( max.St. 30 char ) District/Town/City Province/Country/Zip Birthdate of Account Holder* Tax Acct. 90 cha ) ( max. 35 char ) In case of multiple account holders ( joint account etc ) please accomplish the form contained in annex " A" for the subsequent names C.
address concatenated N . Counterparty : Name of Counterparty Flag : Please fill this space if flag is Y Y ( max. 30 char ) ( max. Reproduction of any part of this Manual without the Bank’s consent and authorization is punishable. 30 char ) ( max. Property of PSBank.address divided into three fields Address of Beneficiary : ( max. 30 char ) Y Y . 30 char ) Bldg/No. 90 char.address divided into three fields Address of Counterparty : ( max. 30 char ) ( max.name concatenated N . Revised December 2009 62 .address concatenated N .name divided into three fields Name of Counterparty : Please fill this space if flag is N Name of Counterparty : Last Name First Name Middle Name Address of Counterparty Flag : Please fill this space if flag is Y ( max. 30 char ) ( max. 30 char ) ( max. ) Please fill this space if flag is N Address of Beneficiary : ( max. 30 char ) Y Y .St. ) Y .First Name Middle Name Address of Beneficiary Flag : Please fill this space if flag is Y ( max. 90 char. ) . 90 char.Brgy District/Town/City Province/Country/Zip Please accomplish the form contained in Annex "B" for additional beneficiaries D.
St. 30 char ) ( max. Property of PSBank.Brgy ( max. Revised December 2009 63 . 30 char ) ( max. 30 char ) ( max. 30 char ) Y . 30 char ) District/Town/City Province/Country/Zip .name concatenated N .St.name divided into three fields Name of Other Participant : ( max. 30 char ) ( max. 90 char ) Please fill this space if flag is N Name of Other Participant : Last Name First Name Middle Name Address of Other Participant Flag : Please fill this space if flag is Y ( max. Other Participants Data Name of Other Participant Flag : Please fill this space if flag is Y Y Y . 30 char ) ( max.Please fill this space if flag is N Address of Counterparty : ( max.address divided into three fields Address of Other Participant : Please fill this space if flag is N Address of Other Participant : Bldg/No.Brgy District/Town/City Province/Country/Zip E. Reproduction of any part of this Manual without the Bank’s consent and authorization is punishable. 30 char ) Y ( max.address concatenated N . 30 char ) Bldg/No. 30 char ) ( max.
30 char ) Y Y . 30 char 64 .name concatenated N .address concatenated N . 30 char ) District/Town/City Province/Country/Zip Country Code of Correspondent Bank : F. 30 char ) ( max.Brgy ( max. 90 char ) Please fill this space if flag is N Address of Correspondent Bank : Bldg/No. Property of PSBank.address divided into three fields ( max.Correspondent Bank : Address of Correspondent Bank Flag : Please fill this space if flag is Y ( max. Revised December 2009 ( max. Reproduction of any part of this Manual without the Bank’s consent and authorization is punishable. 30 char. 30 char ) ( max.name divided into three fields Issuer of product/Policy Owner/Payor/Trustor : ( max. Product/Services Data Name of Issuer Flag : Please fill this space if flag is Y Y Y . 90 char. 30 char ) Y Y .St.St. ) Address of Issuer of Product/Policy Owner/Payor/Trustor : Please fill this space if flag is N Address of iIssuer of Product/Policy Owner/Payor/Trustor : Bldg/No. 30 char ) ( max.Brgy . 30 char ) ( max.address concatenated N .address divided into three fields Address of Correspondent Bank : ( max. ) Please fill this space if flag is N Issuer of product/Policy Owner/Payor/Trustor : Last Name First Name Middle Name Address of Issuer Flag : Please fill this space if flag is Y ( max.
Reproduction of any part of this Manual without the Bank’s consent and authorization is punishable. 800 char ) Narrative*: ( max. Revised December 2009 65 . Property of PSBank. DETAILS OF SUSPICION Reason*: ( max.) District/Town/City ( max. 1000 char ) . 30 char ) ( max. 30 char ) Province/Country/Zip Start/Inception/Effectivity Date : yyyy mm dd Maturity/Expiry Date : yyyy mm dd Amount of Claim : Php Amount of Annual Premium : FX Amount of Annual Premium : G.
of STRs*: Institution Name : Prepared by : Signature : Recommending Approval : GRACE G. Reproduction of any part of this Manual without the Bank’s consent and authorization is punishable. TRAILER RECORD Trailer Record Indicator : T Total Amount of Transaction ( Php )*: Total No.PART III. Revised December 2009 66 . Property of PSBank. DELA CRUZ Signature : Approved by : Philippine Savings Bank 1 Position : Date : Position : Vice-President Compliance Officer ( at least Vice President ) Date : Position : With rank of at least Senior Vice President Signature : Date : .
St. 30 char ) ( max.ANNEX " A " Form for Multiple Account Holders Please accomplish this form for each account holder Name of Account Holder Flag : Please fill this space if flag is Y Y . 90 char ) Please fill this space if flag is N Address of Account holder : Bldg/No. Reproduction of any part of this Manual without the Bank’s consent and authorization is punishable. 30 char ) ( max. Revised December 2009 67 .address divided into three fields Address of Account holder : ( max.Brgy ( max.address concatenated ( max. 30 char ) ( max. 30 char ) District/Town/City Province/Country/Zip .Name divided into three fields Name of Account Holder : ( max. 90 char ) Please fill this space if flag is Y Name of Account Holder : Last Name First Name Middle Name Address of Account Holder Flag : Please fill this space if flag is Y Y .name concatenated N . Property of PSBank. 30 char ) N . 30 char ) ( max.
Reproduction of any part of this Manual without the Bank’s consent and authorization is punishable. 30 char ) ( max.Birthdate of Account Holder yyy mm dd ANNEX " B " Form for Additional Beneficiaries Please accomplish this form for each beneficiary Name of Beneficiary Flag : Please fill this space if flag is Y Y .name concatenated N . 90 char. Property of PSBank. 30 char ) . Revised December 2009 68 . ) Please fill this space if flag is N Name of Beneficiary : Last Name First Name Middle Name ( max.name divided into three fields Name of Beneficiary : ( max. 30 char ) ( max.
90 char. Property of PSBank. Reproduction of any part of this Manual without the Bank’s consent and authorization is punishable. ) Please fill this space if flag is N Address of Beneficiary : Bldg/No. 30 char ) ( max.address concatenated N .Brgy ( max.Address of Beneficiary Flag : Please fill this space if flag is Y Y . 30 char ) ( max.St. Revised December 2009 69 . 30 char ) District/Town/City Province/Country/Zip .address divided into three fields Address of Beneficiary : ( max.
ANNEX 6 ANTI MONEY LAUNDERING CHECKLIST AND QUESTIONNAIRE .
Reproduction of any part of this Manual without the Bank’s consent and authorization is punishable. Revised December 2009 71 .ANNEX 7 KYC FORM FOR ANY CORRESPONDENT BANKING / COUNTER PARTY RELATION . Property of PSBank.
Revised December 2009 72 . Reproduction of any part of this Manual without the Bank’s consent and authorization is punishable. Property of PSBank.ANNEX 8 STANDARD INTERVIEW OR ACCOUNT OPENING SPIEL/ SCRIPT .
Reproduction of any part of this Manual without the Bank’s consent and authorization is punishable.APPENDIX LIST OF TERRORIST INDIVIDUALS AND GROUPS (For a complete list. Revised December 2009 73 . Property of PSBank. see OFAC list in the Info channel) .
APPENDIX ELECTRONIC FORMAT AND SPECIFICATIONS FOR REPORTING OF COVERED AND SUSPICIOUS TRANSACTIONS . Property of PSBank. Reproduction of any part of this Manual without the Bank’s consent and authorization is punishable. Revised December 2009 74 .
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