2017 AML/CFT Information

Awareness Campaign
Anti-Money Laundering Council Secretariat
Definition of
Money Laundering
WHAT IS MONEY LAUNDERING?

 Money laundering is the process by which illegally

obtained funds are given the appearance of
having been obtained legitimately.
 To disguise their illegal origin and enable criminals to enjoy
these proceeds without compromising their illegitimate source.

 A transnational crime and a global problem

 HOW MUCH MONEY IS INVOLVED IN
MONEY LAUNDERING?
 In 2012, estimated $2-3 trillion is laundered
worldwide each year!
 IMF estimate approximately of 2% to 5% of world
Gross Domestic Product
 However, due to the illegal nature of the
transactions, precise statistics are not
available…it is therefore impossible to produce a
definitive estimate of the amount of money …
globally laundered every year.
• Why do criminals launder money?

hide wealth
avoid prosecution & asset seizure
evade payment of taxes
increase profits
to give…air of legitimacy to illegally obtained funds
• Consequences of Money Laundering :

 undermines financial systems

 expands crime
 criminalizes society
 reduces revenue & control
 embeds corruption
 destabilizes government
 HOW IS MONEY LAUNDERING COMMITTED?
(SEC. 4, AMLA, AS AMENDED)
Knowing that 1) TRANSACTS 4) ATTEMPTS OR
CONSPIRES TO
any monetary COMMIT

instrument or 2) CONVERTS,
property TRANSFERS,
represents, DISPOSES, MOVES, 5) AIDS, ABETS,
involves, or ACQUIRES, ASSIST IN,
COUNSELS
relates to the POSSESSES OR
proceeds of USES
any unlawful
activity 3) CONCEALS OR 6) FACILITATES

DISGUISES

7) Intentionally fails to submit CTR or STR to the AMLC

ELEMENTS OF MONEY LAUNDERING
(SEC. 4, R.A. NO. 9160, AS AMENDED)

Unlawful Activity

Dirty Money
Money
Laundering
Circumstances
amounting to ML (7)

Knowledge
 SIMPLE MONEY LAUNDERING
SCENARIO
Jack Predicate Offense (Unlawful Activity)
kidnapped
the Criminal Proceeds (Monetary Instrument/Property)
daughter
of Jill Jack
demanded
and received
ML Acts
Php5 million
as ransom
money Jack remitted
the money in
smaller parts
to his
cohorts

Knowledge that the MI/P represents, involves, or relates to the proceeds

of the unlawful activity
STAGES OF MONEY LAUNDERING
SCENARIO PRIOR TO AMLA ENACTMENT
In June 2000, FATF placed the Phils in its list of Non-
Cooperative Countries and Territories (NCCT) for the ff:
1. It has no existing anti-money laundering law;
2. It has no financial intelligence unit;
3. The Phils has a very strict bank deposit secrecy law; and
4. Phil. banks and financial institutions do not report
suspicious transactions.

NCCT =
Sanctions imposed by jurisdictions not by the FATF

With the enactment of the AMLA and its amendments, the

Phils was removed from the NCCT list and no longer subject to
FATF monitoring since 11 February 2005.
 EVOLUTION OF THE AMLA
R.A. No. 9160 (took effect on 17 Oct.
2001) – only threshold reporting, AMLC’s executive
freeze

R.A. No. 9194 (took effect on 23 Mar 2003) –

freezing power given to courts, STR now required

R.A. No. 10167 (took effect on 6

Jul 2012) – ex parte petitions
R.A. No. 10365 (took effect on
7 Mar 2013) – expanded CP,
additional predicate crimes

R.A. No. 10927 (took effect on 29 July 2017) –

inclusion of casinos (internet and ship-based); single casino cash
transaction in excess of Php5 million
 SALIENT FEATURES OF THE
AMLA, AS AMENDED
1. Criminalizes ML;
2. Identifies and defines predicate offenses to ML;
3. Creates a financial intelligence unit or implementing
agency;
4. Imposes compliance requirements re: customer
identification, record-keeping and reporting of covered
and suspicious transactions;
5. Relaxes strict bank deposits secrecy laws;
6. Provides for inquiry into/freezing of dirty money/property.
7. Introduced civil forfeiture without the necessity of
conviction or criminal prosecution; and
8. Provides for international and domestic cooperation.
 SALIENT FEATURES OF THE LATEST
AMENDMENT (R.A. NO. 10927)
1. Inclusion of land-based, ship-based and internet-
based casinos;
2. Casino cash transaction (involves receipt and payout
of cash by a casino to a customer or to any person in
his/her behalf;
3. Exceeding Php5 Million casino cash transaction;
4. Freeze order ipso facto lifted after the lapse of six (6)
months from issuance – if no case filed vs person
whose account was frozen;
5. F.O. or A.P.O. limited only to the amount of cash or
property or value which the court finds probable
cause to be proceeds of a crime.
 UNLAWFUL ACTIVITY
1. Kidnapping for ransom;
2. Drug Trafficking and other violations of the
Comprehensive Dangerous Drugs Act of 2002;
3. Graft and Corruption under R.A. No. 3019, as
amended;
4. Plunder (R.A. No. 7080, as amended);
5. Robbery and extortion;
6. Jueteng and Masiao (PD 1602);
7. Piracy (RPC & PD 532);
UNLAWFUL ACTIVITY
8. Qualified Theft under Art. 310, RPC;
9. Swindling or fraud (”estafa”) under Art.
315, RPC;
10. Smuggling under R.A. Nos. 455 and
1937;
11. Violations of Electronic Commerce Act of
2000 (R.A. No. 8792) – hacking, data and identity,
online selling of counterfeit items, etc.;

12. Hijacking (and other violations under R.A.

No. 6235), destructive arson and murder,
as defined under the RPC;
UNLAWFUL ACTIVITY
13. Fraudulent practices and other
violations under the Securities Regulation
Code of 2000 (R.A. No. 8799) – investment
scams;

14. Terrorism and conspiracy to commit

terrorism;
15. Financing of terrorism (FT) including the
attempt and conspiracy to commit FT (R.A.
No. 10168);
16. Frauds and other illegal exactions and
transactions under Articles 213, 214, 215,
and 216 of the RPC;
 UNLAWFUL ACTIVITY
17. Bribery under Articles 210, 211, and 211-A of the
RPC, and Corruption of Public Officers under Article
212 of the RPC;
18. Malversation of Public Funds and Property under
Articles 217 and 222 of the RPC;
19. Forgeries and Counterfeiting under Articles 163,
166, 167, 168, 169, and 176 of the RPC;
20. Violations of Sections 4 to 6 of R.A. No. 9208
(Anti-Trafficking in Persons Act of 2003) – white
slavery/human trafficking;
 UNLAWFUL ACTIVITY
21. Violations of Sections 78 to 79 of P.D. No. 705
(Revised Forestry Code of the Phils., as amended);
22. Violations of Sections 86 to 106 of R.A. No.
8550 (Phil. Fisheries Code of 1998);
23. Violations of Sections 101 to 107, and 110 of
R.A. No. 7942 (Phil. Mining Act of 1995);
24. Violations of Section 27 (c), (e), (f), (g), and (i) of
R.A. No. 9147 (Wildlife Resources Conservation and
Protection Act);
25. Violation of Section 7(b) of R.A. No. 9072
(National Caves and Cave Resources Management
Protection Act);
 UNLAWFUL ACTIVITY
26. Violation of R.A. No. 6539 (Anti-Carnapping Act of
2002);
27. Violation of Sections 1, 3 and 5 of P.D. No. 1866,
as amended (the decree Codifying the Laws on
Illegal/Unlawful Possession, Manufacture, Dealing In,
Acquisitions or Dissipation of Firearms, Ammunition
or Explosives);
28. Violation of P.D. No. 1612 (Anti-Fencing Law);
29. Violation of Section 6 of R.A. No. 8042 (Migrant
Worker’s and Overseas Filipinos Act of 1995) – illegal
recruitment;
 UNLAWFUL ACTIVITY
30. Violation of R.A. No. 8293 (Intellectual Property Code)-
infringement of trademark, copyright. Patent, etc;

31. Violation of Section 4 of R.A. No. 9995 (Anti-Photo and

Video Voyeurism Act of 2009);
32. Violation of Section 4 of R.A. No. 9775 (Anti-Child
Pornography Act of 2009);
33. Violation of Sections 5, 7, 8, 9, 10(c), (d) and (e), 11, 12,
and 14 of R.A. No. 7610 (Special Protection of Children
Against Abuse, Exploitation and Discrimination); and
*Felonies or offenses of a similar nature that are punishable
under the penal laws of other countries.
 WHO ARE COVERED PERSONS?

1. Banks, non-banks, quasi-banks,

trust entities, foreign exchange
dealers, pawnshops, money
changers, remittance and transfer
companies and other similar entities
and all other persons and their
subsidiaries and affiliates supervised
or regulated by the Bangko Sentral ng
Pilipinas.
 WHO ARE COVERED PERSONS?
2. Insurance companies, pre-need companies and
all other persons supervised or regulated by the
Insurance Commission.

3. (i) Securities dealers, brokers, salesmen,

investment houses and other similar persons
managing securities or rendering services as
investment agent, advisor, or consultant,

(ii) Mutual funds, close-end investment

companies, common trust funds, and other
similar persons, and

(iii) Other entities administering or otherwise

dealing in currency, commodities or financial
derivatives based thereon, valuable objects, cash
substitutes and other similar MI/P supervised or
regulated by the Securities and Exchange
Commission.
 WHO ARE COVERED PERSONS?

4. Jewelry dealers in precious metals,

who, as a business, trade in precious
metals, for transactions in excess of
One million pesos (P1,000,000.00);

5. Jewelry dealers in precious stones,

who, as a business, trade in precious
stones, for transactions in excess of
One million pesos (P1,000,000.00);

6. Company service providers who

provide services to third parties,
i.e.,formation agent , director
PREVENTIVE MEASURES

Customer
Identification
(KYC)

Transaction Record
Reporting Keeping
 CUSTOMER IDENTIFICATION
(KNOW YOUR CUSTOMER RULE)

For individual clients, covered persons shall:

- establish and record the true identity of their
clients based on official documents.

- establish appropriate systems and methods

based on internationally-compliant standards
and adequate internal controls for verifying and
recording the true and full identity of their
customers.
Valid Identification Document

Individual customers and designated

representative/s of a corporate or
juridical entity who engage in a financial
transaction with a covered person, for
the first time, shall be required to present
the original and submit a clear copy of at
least one (1) valid photo-bearing ID
document issued by an official authority
 Valid Identification Document

The term “OFFICIAL AUTHORITY” shall refer to any of the

ff:
a. Gov’t. of the Republic of the Philippines;
b. Its political subdivisions and instrumentalities;
c. GOCCs and GFIs; and
d. Private entities or institutions registered with or
supervised or regulated either by the BSP or SEC or IC.
Examples: Passport, driver’s license, PRC ID, NBI/Police clearance, Postal ID,
Voter’s ID, Senior Citizen, company IDs of entities registered with the BSP, SEC or
IC.

Minors, who are beneficiaries of remittances/fund transfers, may be allowed

to present the original and submit a clear copy of one (1) valid photo-bearing
school ID duly signed by the principal or head of the school.
HIGH RISK CUSTOMERS

1. Raises doubt as to the accuracy of

any information or document provided
or the ownership of the entity;
2. No underlying legal or trade
obligation, purpose or economic
justification;
3. The amount transacted is not
commensurate with the business or
financial capacity/profile of the
customer
HIGH RISK CUSTOMERS

4. Structuring of transactions in order to

avoid being the subject of covered
transaction reporting; or

5. Knowing that a customer was engaged

or currently engaging in any unlawful
activity as enumerated in the AMLA;

6. A customer from a country that is

recognized as having inadequate
internationally accepted anti-money
laundering standards.
ENHANCED DUE DILIGENCE REQUIRES:
1. Obtain additional information
(other than the minimum)
2. Conduct validation procedures on
any or all of the information provided
3. Obtain senior management
approval for establishing business
relationship.
Minimum information to be obtained from individual
customers and representatives of juridical
entities/companies
1. Name;
2. Present address;
3. Date and place of birth;
4. Nature of work, name of employer or nature of self-employment/
business;
5. Contact details (phone numbers and email address/es);
6. Specimen signature;
7. Source of funds.
8. Permanent address;
9. Nationality;
10.Tax identification number, Social Security System number or
Government Service Insurance Number, if any; and
11. Name, present address, date and place of birth, nature of work
and source of funds of beneficial owner or beneficiary, whenever
applicable.
How do we validate individual customers?

1. Confirming the date of birth from a duly authenticated

official document;
2. Verifying the permanent address through evaluation of
utility bills, bank or credit card statement or other
documents showing permanent address or through on-site
visitation;
3. Contacting the customer by phone, email or letter (such as
sending of “thank you letters”); and
4. Determining the authenticity of the identification documents
through validation of its issuance by requesting a
certification from the issuing authority or by any other
means.
 Minimum information and/or documents to be obtained
for juridical entities (companies)

1. Certificates of Registration
 DTI - single proprietors;
 SEC - for corporations and partnerships; and
 BSP - for money changers/foreign exchange dealers
and remittance agents;
2. Articles of Incorporation or Association and By-Laws;
3. Principal business address;
4. Board or Partners’ Resolution duly certified by the
Corporate/Partners’ Secretary authorizing the signatory
to sign on behalf of the entity;
Minimum information and/or documents to be obtained
for juridical entities (companies)

5. Latest General Information Sheet;

6. Contact numbers of the entity and authorized signatory/ies;
7. Source of funds and nature of business;
8. Name, present address, date and place of birth, nature of
work and source of funds of beneficial owner or beneficiary,
if applicable.

* For companies registered abroad, similar documents and/or

information (#1 to #8) shall be obtained: (i) duly
authenticated by a senior officer or designated officer of the
covered person assigned in the country of registration; or
(ii) notarized and consularized by the Philippine
Consulate/Embassy where these companies are
registered.
How do we validate information submitted by
juridical entities (companies)?

1. Require submission of Audited Financial

Statements conducted by a reputable accounting
or auditing firm;
2. Inquiring from the supervising authority the status
of the entity;
3. On-site visitation of the company; and
4. Contacting the company thru phone, email or
letter (“thank you letters”).
Question:

Can a covered person (e.g. a

remittance agent) rely on the KYC
conducted by another covered
person (such as a bank)?
“third-party reliance”
Covered Transaction Report (CTR)
Within five (5) working
• Single days from the date of
transaction occurrence (unless the AMLC
prescribes a diff period not
exceeding 15 working days)
One banking *2016 RIRR
(business) day

Amount in CTR AMLC

excess of
Php500,000.00
or its foreign
currency
equivalent
SUSPICIOUS TRANSACTION REPORT
(STR)
Within 5-15
No underlying legal or
working days
trade obligation,
purpose or economic
from the date
justification. of occurrence
*2016 RIRR

Client not properly

identified STR AMLC

Amount not
commensurate with
client’s business or Determination date of the
financial capacity suspicious nature of the transaction
not exceeding 10 calendar days
from transaction date
*2016 RIRR
SUSPICIOUS TRANSACTION REPORT (STR)

• Structuring
Within 5-15
working days
from the date
of occurrence
Deviates from client’s *2016 RIRR
profile and/or the past
transactions
STR AMLC

Related to an unlawful
activity, or any money
laundering activity or
offense is about to be,
is being or has been
committed
QUESTION:
•In cases where the transaction:
breached the Php500,000.00
threshold; and
there are suspicious
circumstances are present
•What type of report to generate?
CTR? STR?
CONFIDENTIALITY OF REPORTS
(3)
Rule # 1
Officers and employees of covered persons are
prohibited from communicating, directly or
indirectly, in any manner or by any means, to any
person, the fact that a covered or suspicious
transaction report was made, the contents thereof,
or any other information in relation thereto.

Rule # 2
Neither will such reporting be published or aired in
any manner or form by the mass media, electronic
mail, or other similar devices.
CONFIDENTIALITY OF REPORTS
(3)
Rule #3

The members of the AMLC, the Executive Director, and all

the members of the Secretariat shall not reveal, in any
manner, any information known to them by reason of their
office. This prohibition shall apply even after their
separation from the AMLC.

**In case of violation of the foregoing, the concerned officer

and employee of the covered person shall be held criminally
liable. The responsible reporter, writer, resident,
publisher, manager and editor-in-chief shall also be held
criminally liable.
RECORD KEEPING

• 5 years from the date of transaction

• Exception: Until the money laundering

case against a client is decided by a
court with finality.
RECORD KEEPING
• Records must contain the full and true
identity of client

• Documents must be kept in their

original form

• Digitized form allowed

 SUMMARY
• Risk profiling/scoring
• Ongoing monitoring of customers
-Completeneess
-Accuracy
-Timeliness
• CTR
• STR
• Training programs
• Record-keeping
THE PHILIPPINES’ FINANCIAL
INTELLIGENCE UNIT
 AMLC LOGO

• Adopted in 4 January 2016

• Young Philippine eagle
rendered in blue, red, and
yellow strokes
 THE ANTI-MONEY
LAUNDERING COUNCIL

• GOVERNOR NESTOR A.
ESPENILLA, JR.

Member:
•CHAIRPERSON
SEC TERESITA J. HERBOSA
CHAIRPERSON

Member:
•COMMISSIONER
INSURANCE DENNIS B. FUNA
COMMISSIONER
 FUNCTIONS OF THE AMLC

Requires, receives, and analyses CTRs and STRs

Investigates STRs, CTRs deemed suspicious, and other

violations of the AMLA

Ask SAs and CPs, or ask assistance from foreign

states, to determine true identity of owner of money or
property subject of STR, or believed to be proceeds of
crimes
 FUNCTIONS OF THE AMLC
Causes the filing of ex parte petitions to freeze and
bank inquiry, petitions for civil forfeiture, and
complaints for ML
Formulate measures to counteract ML and TF
Develops AML/CFT educational programs and
conducts AML/CFT trainings and lectures
Coordinate domestically and internationally
Imposes administrative sanctions and penalties

Require the LRA and RDs to submit reports on real

estate transactions exceeding Php500,000
FUNCTIONS OF THE AMLC
(UNDER THE TF SUPPRESSION LAW)

Investigates financing of terrorism

Issues without delay ex parte freeze

order against terrorist funds or property
 THE AMLC SECRETARIAT

The AMLC is assisted by a Secretariat headed by an Executive

Director
Executive Director

Technical
Services Staff

Compliance Legal Information Administrative

and Services Management and Financial
Investigation Group and Analysis Services
Group Group Division

56
LEGAL REMEDIES UNDER THE AMLA, AS
AMENDED
• Civil
 Freezing of accounts, policies, investments, other assets
 Application for bank inquiry
 Forfeiture/confiscation of assets
• Criminal
 Money laundering under Section 4, AMLA, as amended
 Violation of confidentiality
• Administrative
 Violations of the AMLA, as amended and RIRRs
 KYC, record-keeping, failure to submit CTRs and STRs
FREEZING
• For money laundering cases:
Need to establish probable cause that the
assets are related to an unlawful activity
Need AMLC Resolution
Filed: Court of Appeals Presiding Justice
(Manila) or the Executive Justices (Cebu, CDO)

CA issues a freeze order within 24 hours upon

filing of the petition
Effective initially for 20 days, may be extended
up to 6 months
FREEZING
• For TF cases under RA No. 10168
• AMLC on its own or upon request of the Anti-Terrorism
Council may freeze property or funds:
 related to FT or acts of terrorism; or
 of any person/s , terrorist organization, in relation
to whom there is probable cause to believe that
they are committing or attempting or conspiring to
commit, or participating in or facilitating the
commission of FT or acts of terrorism.
• Effective twenty (20) days only subject to extension up
to 6 months by the Court of Appeals
 DUTIES OF THE CPS AND GOVERNMENT AGENCIES
UNDER FREEZE ORDER

DUTY #1 – IMPLEMENT THE FREEZE ORDER IMMEDIATELY UPON

RECEIPT OF FREEZE ORDER (Rule X.E.1, 2016 Updated RIRRs)

DUTY #2 – FREEZE RELATED ACCOUNTS IMMEDIATELY

If related accounts cannot be determined immediately (due to
volume, complexity of transactions or other justifiable reasons),
freeze within reasonable period and submit supplemental return to
CA. (Rule X.E.2, 2016 Updated RIRRs)
 DUTIES OF THE CPS AND GOVERNMENT AGENCIES
UNDER FREEZE ORDER

DUTY # 3 – FURNISH COPY OF FREEZE ORDER TO OWNER OR

HOLDER (Rule X.E.3, 2016 Updated RIRRs)

DUTY # 4 – SUBMIT DETAILED RETURN WITHIN 24 HRS FROM

RECEIPT OF FO (Rule X.E.4, 2016 Updated RIRRs)

• Written and by personal delivery, to the CA

• Electronic detailed return to the AMLC
 CONTENTS OF DETAILED RETURN FOR CPS
(RULE X.E.5, 2016 UPDATED RIRRS)

• Account numbers, description of monetary instrument,

property or proceeds
• Name/s of owner of accounts, personal properties, real
property (inc. possessor and/or occupant)
• Value of account/properties as of time of freeze
• Other relevant information as to status and nature of frozen
account/properties
• Date and time of service of freeze
• Basis for identification of related accounts
CAN THE CP LIFT THE EFFECTS OF THE FREEZE
ORDER ON ITS OWN VOLITION?

NO. The covered person shall not lift the

effects of the freeze order without securing
written confirmation from the AMLC to
ascertain if a petition for civil forfeiture or
money laundering case has been filed.
(Rule X.C., 2016 Updated RIRRs)
APPLICATION FOR BANK INQUIRY
• An exception to the bank deposit secrecy laws (R.A.
1405; 6426; 8791)
• Generally, the AMLC files an application with the Court
of Appeals
 In KFR, terrorism and drug-related offenses, the AMLC,
on its own, may issue allowing bank inquiry.
• Bank accounts only
• Probable cause that proceeds in bank accounts are
related to an unlawful activity
APPLICATION FOR BANK INQUIRY

• Banks open records of bank accounts to

AMLCS investigators, and produce copies of
bank documents
• Account opening forms, statements of
accounts, deposit slips, withdrawal slips,
checks, credit memos, debit memos, etc.
• AMLC takes legal action against uncooperative
banks: non-submission of documents; failure
to submit within the given period
 CIVIL FORFEITURE
The seizure and confiscation in favor of the Government
of any monetary instrument or property that are related
to an unlawful activity under Section 3(i) or a money
laundering offense under Section 4, Republic Act No.
9160, as amended

• Non-conviction based;
• Filed by the AMLC in the name of the Republic.
• Regional Trial Court has jurisdiction
• Governed by A.M. No. 05-11-04-SC
CIVIL FORFEITURE

• Purpose: to confiscate laundered money and

assets that are proceeds of unlawful activities
• To prevent the launderer from using the funds
to commit more crime
• Should a defendant be convicted of the
unlawful activity (e.g. KFR, drug offenses,
estafa, etc.) first before his assets may be
forfeited?
NO. Forfeiture is not based on conviction.
 CIVIL FORFEITURE –
EQUAL VALUE ASSETS

Petition shall include other monetary instrument or

property of EQUAL VALUE, where monetary instrument or
property:

• Cannot be located despite due diligence

• Substantially altered, destroyed, diminished in value or
otherwise rendered useless
• Concealed, removed, converted or transferred
• Located outside the Philippines or brought outside the
jurisdiction of the court
• Comingled, such that it is difficult to identify or be
segregated
CRIMINAL PROSECUTIONS

• Criminal prosecution for money laundering

Transaction, facilitation, cooperation, etc.
Attempt, conspiracy, etc.
Failure to report
• Breach of confidentiality
• Malicious reporting
ADMINISTRATIVE

• Violations of the AMLA and RIRRs

KYC, CDD
Record-keeping
Errors in CTR/STR
Non-submission of bank documents
Obstruction of court orders and AMLC
actions
• Administrative due process
• Not adversarial like in a court
ADMINISTRATIVE SANCTIONS

• Rules on Imposition of Administrative

Sanctions
Took effect on 9 August 2017
• Warnings to a maximum fine of
Php500,000.00 per violation
• For better compliance with anti-money
laundering rules and to preserve the integrity
of the Philippine financial system.
 ADMINISTRATIVE PENALTIES:
ATTENDANT CIRCUMSTANCES
(DETERMINING BASE FINES)
• Asset Size:
Micro - Php3,000,000.00 and below
Small - Php3,000,000.01 to Php15,000,000.00
Medium - Php15,000,000.01 to Php100,000,000.00
Large A - Php100,000,000.01 to Php500,000,000.00
Large B - Php500,000,000.01 and above

• Gravity of Violation:
Grave - AMLC Remedies
Major - Total Disregard of Preventive Measures
Serious - Have great impact of AMLC’s ability to
prevent/combat ML
Less Serious - Hampers or delays AMLC’s compliance/investigation
functions
Light - No immediate impact on AMLC
 ADMINISTRATIVE SANCTIONS
• Non-penalty: reprimand, restoration

• Penalty: warning, fines

• Others: surcharge

• Discretion: publication, cancellation of AMLC

registration, recommendation to Supervising Authority
to disqualify responsible officers
THE PHILIPPINES’ FINANCIAL
INTELLIGENCE UNIT
Address : Anti-Money Laundering Council Secretariat
Room 507, 5th Floor, EDPC Building
Bangko Sentral ng Pilipinas (BSP) Complex
Mabini corner Ocampo Street, Malate
Manila, Philippines

Trunkline : +63-2-708-7701 local 3083, 3084

Fax : +63-2-708-7909
E-mail : secretariat@amlc.gov.ph /
amlc@bsp.gov.ph