TRANSACTION REPORTING

Transaction Reporting
TRANSACTION REPORTING

Covered Transaction Report (CTR)

A Single Timing of Reporting:

CASH transaction
Within five (5) working days
CTR from the date of occurrence
Amount in excess of (unless the AMLC prescribes a
different period not exceeding
PHP5,000,000.00 (or its
15 working days)
foreign currency equivalent)

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 Transaction Reporting
Suspicious Transaction Report (STR) – regardless of amount
No underlying legal or Timing of Reporting: Structuring
trade obligation,
purpose or economic Within 5 days from the
justification. occurrence thereof Deviates from client’s
profile and/or the past
transactions
Client not properly
identified STR
Related to an unlawful
activity, or any money
Amount not laundering activity or
commensurate with offense is about to be,
client’s business or is being or has been
financial capacity Similar or analogous
committed
circumstances

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 Transaction Reporting
Other Suspicious Circumstances [Rule 3.a.15, TFPSA IRR]

• Wire transfers between accounts, w/o visible legal, economic/business purpose,

especially if the wire transfers are effected through countries which are identified or
connected with terrorist activities;
• Sources and/or beneficiaries of wire transfers are citizens of countries which are
identified or connected with terrorist activities;
• Repetitive deposits or withdrawals that cannot be satisfactorily explained or do not make
economic or business sense;
• Value of the transaction is grossly over and above what the client is capable of earning;
• Client is conducting a transaction that is out of the ordinary for his known business
interests;
• Deposits by individuals who have no known connection or relation with the account
holder;
• Client is receiving remittances from a country where none of his family members is
working or residing;

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 Transaction Reporting
Other Suspicious Circumstances [Rule 3.a.15, TFPSA IRR]
• Client was reported and/or mentioned in the news to be involved in terrorist activities;
• Client is under investigation by LEAs for possible involvement in terrorist activities;
• Transactions of individuals, companies or NGOs/NPOs that are affiliated or related to people
suspected of having connection with a terrorist individual, organization, association or group of
persons;
• Transactions of individuals, companies or NGOs/NPOs that are suspected of being used to payor
receive funds from a terrorist individual, organization, association or group of persons;
• The NGO/NPO does not appear to have expenses normally related to relief or humanitarian
efforts;
• The absence of contributions from donors located within the country of origin of the NGO/NPO;
• The volume and frequency of transactions of the NGO/NPO are not commensurate with its
stated purpose and activity; and
• Any other transaction that is similar, identical or analogous to any of the foregoing.
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 Transaction Reporting -
Examples of Alerts and Red Flag Indicators (ARRGC)
1. There is no underlying legal or trade obligation, purpose or economic justification
• Customers asking to combine winnings and his and her own cash not played in the casino into
casino cheques
• Two or more customers frequently wagering against one another on even money game.
• Customer requests to add cash to casino winnings and then exchanging the combined cash and
winnings for a single cheque
• Patrons pass a large quantity of chips, cash, or TITO tickets between themselves, in an apparent
effort to conceal the ownership of the chips, cash, or TITO
• Use of third parties to purchase casino chips.
2. The client is not properly identified
• Client refused to provide details/ provide fake details
• Customer due diligence challenges, e.g. refusals, false documents, one-offs, tourists passing
trade
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 Transaction Reporting -
Examples of Alerts and Red Flag Indicators (ARRGC)
3. The amount involved is not commensurate with the business or financial capacity of the client
• Client’s gaming/ cage activity dramatically increases with no known substantiation for the source
of those funds
• Client’s gaming/ cage activity or wagers incommensurate to the profile originally established by
the covered person
4. Structuring
• A patron requests information about how to avoid AMLC reporting requirements
• Multiple players requesting for payments to the same beneficiary (except for customers of junket
operators)
• Requesting the division of winnings or prize money, which exceeds the reporting threshold, to be
broken down into cash and chips below the reporting threshold in order to exchange it at the
cashier’s desk

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 Transaction Reporting -
Examples of Alerts and Red Flag Indicators (ARRGC)
5. Deviation from the profile of the client and/or the client’s past transactions with the covered person
• Dramatic or rapid increase in size and frequency of transactions for a regular card holder.
• Client request for winner cheques without commensurate gaming activities/ winnings
6. Related to an unlawful activity
• Use of fraudulent identity/ credit cards/ payment cards to perform any form of cage transactions
• Client(s) who perform the transactions are found to be known or related associates of criminal/
wanted persons
• Funds involved in the transaction/ activity originates from casino cheat/ scam or another other
offenses as described under the AMLA
7. Any transaction that is similar or analogous to any of the foregoing
• Supposed winnings do not correspond with recorded winnings.
• Use of credit cards to purchase casino chips.
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 Transaction Reporting - Timing
Occurrence - date of determination of the suspicious nature of
the transaction, which determination shall be made not
exceeding ten (10) calendar days from date of transaction

• Highly unusual or suspicious transactions, activities or

circumstances conducted in the presence of, or immediately
known or apparent to, the personnel handling the transaction
shall be reported to the AMLC within five (5) working days from
the date of the transaction
• A “highly unusual” or suspicious transaction is one where, at
the moment of transaction, the person handling the transaction
has knowledge and reason to suspect that the funds being
transacted are related to an unlawful activity.

Basic AML-CFT Course Anti-Money Laundering Council Secretariat Document

 Transaction Reporting - Timing
No corresponding transaction, or when the TMS-generated alert
is only a ground for the covered person to conduct an internal
analysis, investigation and escalation, determination of the
suspicious nature of the circumstances shall be made within a
reasonable period of time

“Reasonable Time”
Trigger for File ZSTR within
Suspicion 60 calendar days to 5 days
determine

Basic AML-CFT Course Anti-Money Laundering Council Secretariat Document

 Transaction Reporting - Timing

If related to an unlawful activity:

60 calendar
Trigger for days – knew or 10 calendar day File STR within
Suspicion should have determination 5 days
known period

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 Transaction Reporting - Timing
Mandatory Uploading of KYC Documents for:

• Kidnapping for Ransom

• Drug Trafficking
• Hijacking; destructive arson; and murder, including those
perpetrated by terrorists against non-combatant persons and
similar targets
• Terrorism and conspiracy to commit terrorism
• Financing of Terrorism

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 Transaction Reporting
Covered Transaction also a Suspicious Transaction
[Section 1.2, Rule 22, 2018 IRR]
MALICIOUS REPORTING IS A
CRIMINAL OFFENSE!
In cases where the transaction breached the [6 months – 4 years imprisonment,
PHP5,000,000.00 threshold and there are P100,000 – P500,000
suspicious circumstances, report as STR. No probation]

Form and Quality of Report – 5Ws, 1H

WHO, WHAT, WHEN, WHERE, WHY, HOW
• Complete
• Accurate
• Timely

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 Transaction Reporting
AML/CTF Monitoring System
• All casinos shall adopt an ML/TF monitoring
system, including a name screening mechanism,
whether electronic or manual, that is
appropriate for their risk-profile and business
complexity in accordance with this framework.
The system shall be capable of generating timely,
accurate and complete reports, including CTRs
and STRs, and to regularly apprise the casino’s
Board of Directors, or the partners or the sole
proprietor, as the case may be on AML and CFT
compliance. (Section 15b, CIRR)

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 Transaction Reporting
REPORTING CHAIN:

CPs shall formulate a reporting chain under which a

possible suspicious transaction will be processed,
analyzed and investigated. The reporting chain
should include the designation of a Board Level or
approval Committee or the Chief Compliance
Officer as the ultimate decision maker on whether
or not the covered person should file a report to
the AMLC.

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 Transaction Reporting
Safe Harbor Provision

No administrative, criminal or civil proceedings

shall lie against any person for having made a
CTR or an STR in the regular performance of his
duties and in good faith, whether or not such
reporting results in any criminal prosecution
under the AMLA or any other Philippine law.

• DO NOT BE AFRAID TO FILE CTR AND STR! NON-REPORTING OF CTR

• CTR and STR are not necessarily proof that the
customer is involved in unlawful activity.
• CTR and STR are mere triggers for possible
investigation.
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AND STR IS A CRIMINAL
OFFENSE!
[6 month – 4 years imprisonment,
P100,000 – P500,000 fine, or both]
Anti-Money Laundering Council Secretariat Document
 Transaction Reporting
Confidentiality of Reports

• Covered persons, and their officers and employees,

are prohibited from communicating, directly or
indirectly, in any manner or by any means, to any
person or entity, or the media, the fact that a CTR or
STR has been or is about to be filed, the contents of
the report, or any other information in relation
thereto.
• Any information about such reporting shall not be
BREACH OF CONFIDENTIALITY
published or aired, in any manner or form, by the
mass media, or through electronic mail, or other IS A CRIMINAL OFFENSE!
[3 – 8 year imprisonment,
similar devices. P500,000 – P1,000,000]

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THANK YOU