ABC Remittance Corporation

ABC REMITTANCE CORPORATION
MONEY LAUNDERING AND TERRORIST FINANCING

PREVENTION PROGRAM (MLPP)
MAY 2016
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Revised MLPP - May 2016
ABC REMITTANCE CORPORATION

MONEY LAUNDERING AND TERRORIST FINANCING PREVENTION
PROGRAM
TABLE OF CONTENTS
I. Statement of Commitment
II.
Intent of the Manual ..
III.
Introduction ..
IV.
Principles and Policies to Combat Money Laundering
V.
Definition of Terms .
VI.
Choice of Remittance Agents and Partners ..10
VII.
Policy Guidelines and Procedures
10
VII.1 Client identification or Know Your Customer (KYC) .
10
VII.2 Record-Keeping
18
VII.3 Reporting of Covered/Suspicious Transaction
18
VII.4 Risk-Based Due Diligence in

Processing Remittance Instructions .
20
VIII.
Training Program.
25
IX.
Recruitment .
25
IX.
Internal Audit System 26
Independent Audit Program
27
XI.
Compliance Monitoring .
27
XII. Cooperation with Anti-Money Laundering Council ..
28
XIII. Designation of Compliance Officer ..
28
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THE ABC COMPLIANCE PROGRAM

I. STATEMENT OF COMMITMENT
Generally, Tthe objective goal of the Compliance Program aims to is to reinforcestrengthen
the internal processes to which identify and reduce minimize ccompliance risk within the
company.k within the Company.
We recognize are consciousaware that the purpose of the compliance functions objective,
which is to assistaid ABC Remittance Corporation in managing handling its compliance risk.
As definedherein understood, compliance risk is the risk of legal or regulatory sanctions,
financial loss, or loss to reputation the company may suffer as a result of its failure to comply
with all applicable laws, regulations, and codes of conduct and standards of good corporate
governance. It is sometimes alsalso known as integrity risk, given thatooccasionally referred
to as integrity risk as, because ABC Remittance Corporations reputation is dependent
onclosely connected with its adherence to principles of integrity and fair dealing.
Compliance risk covers the potential possibility for ABC Remittance Corporation to suffer
incur a financial loss from changes in laws, monetary, tax or other government regulations of
a country. This risk is increased higher in highly heavily regulated jurisdiction areas and
especially in turbulentunstable market conditions when where rules and regulations are
constantlyfrequently changingaltered. It is a significantn important qualitative risk which must
be monitored properlyitored and managed, as regulatory sanctions from non-compliancenoncompliance may merit heavy sanctions, especially in extreme cases, may involve not just
merewhich can lead to a taintedloss of reputation, ormonetary fines financial penalties, and
evenbut a revococation of license.
Compliance risk is brought about byk arises from a failure of inability to non-compliancey with
laws, regulations or codes applicable to the financial services industry. NoncomplianceAmong the consequences violators can face are can lead to fines, public
reprimands, enforced suspension of operations or in extreme cases, withdrawal of
authorization to operate.
From the standpoint of BSP, SEC, AMLC aAnd other regulatory bodies, an effective
Compliance Program should be able to reducedecreaseminimize the likelihoodpossibility of
findingrobability that ABC Remittance Corporation guilty of will be found to have
recklesslyirresponsibly disregardedoverlookinged or deliberatelyintentionally violatinged
banking laws, rules and regulations.
Because the regulatory environment is exceedingly complexDue to the complex nature of the
regulatory environment, we at ABC Remittance Corporation seek to fosterendeavor to create
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a culture that promotesof proactive compliance. We are aware of our dutyrecognize our
solemn duty to followadhere to the regulations based on a culture of accountability and
transparency in every endeavor that we undertake. We are committed to put in place the
appropriate processes to ensure a common understanding of, and compliance with, laws,
rules and regulations, through a continuing training and education program, and enhanced
monitoring and enforcement.
II. INTENT OF THE MANUAL

The ABC Remittance Corporation holds the beliefbelieves that money laundering undermines
the development of a strong Philippine economy and may be used as a ploy disguised way
inof facilitating monetary transfers to fund terrorist activities financial aids to terroristic
activities. This Manual therefore, intends Hence, this manual was written to be in
compliance notto comply not only with applicable laws and regulations such as RA
9160, as amended by RA 9194, otherwise known as the Anti-Money Laundering Act of
2001, its Implementing Rules and Regulations and the Updated BSP circular 706 series
of 2011, but also with the internationally accepted Anti-Money Laundering standards.
This manual can serve as aIt also intends to serve as a reference for the officers and staff of
ABC Remittance Corporation, as well as to nd in a way to its remittance business agents and
partners (tie-ups) in order to guide them in performingthe performance of their duties and
responsibilities in servicing remittance instructions., In particular, these are:particularly on the
proper customer identification or the Know Your Client (KYC) process, risk-based due
diligence in processing remittance instructions, monitoring and reporting of covered and
suspicious transactions, and records-keeping.
III. INTRODUCTION
ABC Remittance Corporation provides a service that makes international makes international
money transfer fast, convenient and affordable. By using Through the use of its electronic
remittance facilities and growing network of bank and non-financial institutional partners
worldwide, ABC aims to be the preferred choice for international money remittances of
Overseas Filipinothe Filipino Overseas Workers (OFW.)
Our Vision:
To be a leader in the remittance/fund transfer industry by providing quality services
that exceeds the expectations of our esteemed customers.
Our Mission:
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To build long term relationships with our customers, clients & partners and provide
exceptional customer services by pursuing business through innovation and
advanced technology.
Core values
We believe in treating our customers with care, respect and faith.Proper customer
treatment
GrowthWe grow through fuelled by creativity and innovation
We integrate honesty, integrity and business ethics into all aspects of our business
activitiesIntegration of business ethics in all company matters
Our Slogan
We provide the best .... for you!

From the above, ABC business modelGiven this, the business model is a collaborationis
basically tying-up with legitimate, reputable and AMLA compliant remittance companies,
foreign banks and financial institutions. The role of ABC is to provide the effective and efficient
fulfillment (last mile) service to comply with all business and regulatory requirements.
ABC exists in order to render effective and efficient services that adhere to the requirements
stipulated by the regulatory bodies.
The regulatory requirement as provided for in BSP Circular 706 series of 2011 is the
publication of a manuale creation of the manual that serves as a guide to prevent money
laundering and terrorist financing activities.the financing of terrorist activities.
V.
PRINCIPLES AND POLICIES TO COMBAT MONEY LAUNDERING

STATE POLICY
It is hereby declared the policy of the State to protect the integrity and confidentiality
of bank accounts and to ensure that the Philippines shall not be used as a moneylaundering site for the proceeds of unlawful activity. Consistent with its foreign policy,
the Philippines shall extend cooperation in transnational investigation and
prosecutions of persons involved in money laundering activities wherever committed
(Sec. 2 RA 9194; Rule 2 IRR)
The ABC Remittance Corporation recognizes the effect of money laundering to the economy
and theits dangers of it being used as a way to fund in terrorist financing activities. It vows to
fully support all local and international campaigns and efforts to combat money laundering
and terrorist financing activities.
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In line with this, the ABC Remittance Corporation in turn, vows to be committed in playing its
role in the fight against money laundering by conducting its remittance business within the
bounds of all applicable laws and regulations, by refraining to be associated wit h thoseh
agents and partners, and customers involved in unlawful/criminal activities, and by
maintaining the highest operating standards in the conduct of its business with due skill, care
and diligence.
Thus, ABC Remittance Corporation hereby adopts the following policies to combat money
laundering activities.
1. A strictly implementedstraightforward Customer Due Diligence policy to ensure that
satisfactory evidence of the customers identity within the context that all customers
provide sufficient evidence of identity. This is written in the context of Republic Act
9160 as amended by Republic Act 9194 and put in place an effective procedure for
verifying the bona fides of customers and determining their source of funds.
2. Clear and concise-cut polices that concern on records retention, and the protocol for
reporting suspicious activity. reporting of suspicious transactions.
3. Compliance with lawsLaw abidance to ensure that all transactions aret business i
performeds conducted in conformity with high ethical standards; that laws and
regulations are adhered to.
The company reserves the right to deny rendering services in situations when there is
suspicion concerningo, and that service shall not be provided where there is good reason
to believe that transactions are associated customer involvement with money laundering
activities.
4. Cooperation with competent authoritiesgoverning bodies such as Management shall
cooperate fully with the Anti-Money Laundering Council (AMLC) and the Bangko
Sentral ng Pilipinas (Central Bank of the Philippines) within the limits allowed provided
by law.
5. Submission of atting report to AMLC containing details on all covered transactions and
suspicious transactions within five (5) working days from occurrence thereof, unless
the Supervising Authority concerned prescribes a longer period not exceeding ten (10)
working days (Sec. 6 of RA 9194 amending Sec 9 RA 9160)
VI. Definition of Terms UnlessExcepts as otherwise defined herein, all terms used shall have
the same meaning as those terms that are defined in the AMLA, as amended, and its
RIRR.
(A) Money laundering is a crime whereby the proceeds of an unlawful activity as
herein defined are transacted, thereby, making them appear to have originated
from legitimate sources. It is committed by the following:
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1. Any person knowing that any monetary instrument or property represents,

involves, or relates to, the proceeds of any unlawful activity, transacts or
attempts to transact said monetary instrument or property.
2. Any person knowing that any monetary instrument or property involves the
proceeds of any unlawful activity, performs or fails to perform any act as a
result of which he facilitates the offense of money laundering referred to in
paragraph (1) above.
3. Any person knowing that any monetary instrument or property is required
under the act to be disclosed and filed with the Anti-Money Laundering
Council, fails to do so.
(B) Covered transaction (CT) is a transaction involving cashn cash or other
equivalent monetary instrument involving a total amount in excess of five hundred
thousand pesos (P500,000) within one banking day.
(C) Suspicious transactions (ST) are transactions with covered institutions,
regardless of the amount involved, where any of the following circumstances exist:
1. There is no underlying legal or trade obligation, purpose or economic
justification;
2. The client is not properly identified;
3. The amount involved is not commensurate with the business or financial
capacity of the client;
4. Taking into account all known circumstances, it may be perceived that the
clients transaction is structured in order to avoid being the subject of
reporting requirements under the AMLA, as amended;
5. Any circumstance relating to the transaction which is observed to deviate
from the profile of the client and/or clients past transactions with the covered
institution;
6. The transaction is in any way related to an unlawful activity or any money
laundering activity or offense under AMLA, as amended, that is about to be, is
being or has been committed; or
7. Any transaction that is similar or analogous to any of the foregoing.
(D) Monetary instrument refers to:
1. Coins or currency of legal tender of the Philippines, or of any other country;
2. Drafts, check, and notes;
3. Securities or negotiable instruments, bonds, commercial papers, deposit
certificates, trust certificates, custodial receipts or deposit substitute
instruments, trading orders, transaction tickets and confirmations of sale or
investments and money market instruments;
4. Contracts or policies of insurance, life or non-life, and contracts of suretyship;
and
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5. Other similar instruments where title thereto passes to another by

endorsement assignment or delivery.
(E) Transaction refers to any act establishing any right or obligation or giving rise to
any contractual or legal relationship between the parties thereto. It also includes
any movement of funds by any means with a covered institution.
(F) Unlawful activity refers to any act or omission or series or combination thereof
involving or having direct relation to the following:
1. Kidnapping for ransom under Article 267 of Act No. 3815, otherwise known as
the Revised Penal Code, as amended;
2. Section 4, 5, 6, 8, 9, 10, 12, 13, 14, 15, and 16 of Republic Act No. 9165,
otherwise known as the Comprehensive Dangerous Drugs Act of 2002;
3. Section 3 paragraphs B, C, E, G, H, and I of Republic Act No. 3019, as
amended; otherwise known as the Anti-Graft and Corrupt Practices Act;
4. Plunder under Republic Act No. 7080, as amended;
5. Robbery and extortion under Articles 294, 295, 296, 299, 300, 301, and 302
of the Revised Penal Code, as amended;
6. Jueteng and masiao punished as illegal gambling under Presidential Decree
No. 1602;
7. Piracy on the high seas under Revised Penal Code, as amended and
Presidential Decree No. 532;
8. Qualified theft under Article 310 of Revised Penal Code, as amended;
9. Swindling under Article 310 of the Revised Penal Code, as amended;
10. Smuggling under Republic Act Nos. 455 and 1937;
11. Violations under Republic Act No. 8792, otherwise known as the Electronic
Commerce Act of 2000;
12. Hijacking and other violations under Republic Act No. 6235; destructive
arson and murder, as defined under the Revised Penal Code, as amended,
including those perpetrated by terrorists against non-combatant persons
and similar targets;
13. Fraudulent practices and other violations under Republic Act No. 8799,
otherwise known as the Securities Regulation Code of 2000;
14. Felonies or offenses of a similar nature that are punishable under the penal
laws of other countries.
(G) Compliance Monitoring Officer The person in-charge in the Company
responsible for ensuring compliance of all personnel and staff to applicable laws
and regulations of various regulatory bodies, including that of the Anti-Money
Laundering Council.
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(H) Customer - refers to any person or entity that keeps account, or otherwise
transacts business with a covered institution and any person or entity on whose
behalf an account is maintained or a transaction is conducted, as well as the
beneficiary of said transactions. A customer also includes the beneficiary of a trust,
an investment fund, a pension fund or a company or person whose assets are
managed by an asset manager, or a grantor of a trust.
(I) Shell Company a Legal entity that has no substance in doing business but being
used as financial intermediary that financial transactions may be conducted.
(J) Shell Bank - a Shell company incorporated as a bank or made to appear to be
incorporated as a bank but has no physical presence and no affiliation with a
regulated financial group. It can also be a bank that (a) does not conduct business
at a fixed address in a jurisdiction in which the shell bank is authorized to engage;
(b) does not employ one or more individuals on a full time basis at this fixed
address; (c) does not maintain operating records at this address, and (d) is not
subject to inspection by the authority that licensed it to conduct banking activities.
(K) Beneficial Owner - refers to natural person(s) who ultimately owns or controls a
customer and/or the person on whose behalf a transaction is being conducted. It
also incorporates those persons who exercise ultimate effective control over a
legal person or arrangement.
(L) Politically Exposed Person or PEP - an individual who is or has been entrusted
with prominent public positions in the Philippines or in a foreign state, including
heads of state or of government, senior politicians, senior national or local
government, judicial or military officials, senior executives of government or state
owned or controlled corporations and important political party officials.
(M)
Correspondent banking refers to activities of one bank (the correspondent

bank) having direct connection or friendly service relations with another bank (the
respondent bank).
(N) Fund/wire transfer - refers to any transaction carried out on behalf of an

originator (both natural and juridical) through a financial institution (Originating
Institution) by electronic means with a view to making an amount of money
available to a beneficiary at another financial institution (Beneficiary Institution).
The originator person and the beneficiary person may be the same person.
(O)Cross border transfer - any wire transfer where the originating and beneficiary
institutions are located in different countries. It shall also refer to any chain of wire
transfers that has at least one cross-border element.
(P) Domestic Transfer - any wire transfer where the originating and beneficiary
institutions are located in the same country. It shall refer to any chain of wire
transfers that takes place entirely within the borders of a single country, even
though the system used to effect the fund/wire transfer may be located in another
country.
(Q)Originating institution - refers to the entity utilized by the originator to transfer
funds to the beneficiary and can either be (a) a covered institution as specifically
defined by these Rules and as generally defined by the AMLA, as amended, and
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its RIRR, or (b) a financial institution operating outside the Philippines that is other
than covered institutions referred to in (a) but conducts business operation and
activities similar to them
(R) Beneficiary institution - refers to the entity that will pay out the money to the
beneficiary and can either be (a) a covered institution as specifically defined by
these Rules and as generally defined by the AMLA, as amended, and its RIRR, or
(b) a financial institution operating outside the Philippines that is other than
covered institutions referred to in (a) but conducts business operations and
activities similar to them.
(S) Intermediary institution - refers to the entity utilized by the originating and
beneficiary institutions where both have no correspondent banking relationship
with the intermediary institution. It can either be (a) a covered institution as
specifically defined by these Rules and as generally defined by the AMLA, as
amended, and its RIRR, or (b) a financial institution operating outside the
Philippines that is other than covered institution referred to in (a) but conducts
business operations and activities similar to them.
(T) Remittance Partner (Tie-up) an entity with whom ABC Remittance Corporation
has a business agreement for processing remittance transactions. A remittance
partner based abroad and who will accept remittance transactions is called either
an Agent or a Subsidiary/Affiliate, while remittance partners based here in the
Philippines and who will be used as a channel for distribution of the remittance to
its final beneficiary is called a Fulfillment partner or a Courier or an Outlet.
VII.
VIII.
Choice of Remittance Agent and Partner

1.
To ensure that it deals only with legitimate entities, ABC Remittance Corporation
shall identify prospective business agents and partners from among the known
and reputable entities in the remittance business, including reputable foreign
correspondent banks, and are known to be regulated/subject to anti-money
laundering and combating terrorist financing laws and regulations.
2.
Relationship with the preferred business tie-up (agent and fulfillment partner)
shall be established with the signing of a Memorandum of Agreement (MOA).
3.
Local business tie-ups (i.e. fulfillment partners, couriers, outlets) shall be

subjected to background checking. A due diligence on the partners Anti Money
Laundering program shall be conducted to ensure that they are compliant to BSP
requirements. The same should have undergone the Anti-Money Laundering
Seminar conducted by the Bangko Sentral ng Pilipinas (BSP).
POLICY GUIDELINES
VII.1 Customer Identification or Know Your Customer (KYC) Process
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A KYC policy should increase the likelihood thatensures that ABC Remittance
Corporation is in compliance with all laws and regulations. It also makes sure that
ABC Remittance Corporation and adheres to sound and recognized business
practices that will protect the good name of the company.engages in good
business practice that will uphold the companys reputation.
Thus, a KYC policy should decrease the likelihood thatlessen the possibility of
ABC becomingwill become a victim of illegal activities perpetrated by fraudulent
people. its customers.
The best stage to do KYC will be best implementedis before the relationship with
the customer begins. ABC, its agents, subsidiaries/affiliate, tie-ups, fulfillment
partners, couriers and outlets are enjoined to observe proper identification of
clients. The ABC Anti-Money Laundering Questionnaire (Annex A) must be filledup.
Moreover, if a remitter opens an account at the agent/subsidiary/affiliate abroad, it
will be the responsibility of the agent/subsidiary/affiliate to establish and record
the identity of the remitter. ABC then takes in thiscaptures this information
throughwith the use of its system and from the exchange file instructions.
Agents/subsidiaries/affiliates shall ensure that all necessary information,
pertaining to KYC, of the client/customer/remitter shall be properly documented
and included in the exchange file, and that these documents presented are
thoroughlycarefully inspected.
VII.1.1 General Information/Documents Required
a. ABC shall obtain satisfactory evidence of the true and full identity,
representative capacity, domicile, legal capacity, occupation or business
purposes of clients, as well as other identifying information on those clients,
whether they be occasional or usual, through the use of documents such
as, but not limited to:
i.
Identificationity documents, such as passports, birth certificates,

drivers licenses, employment identification cards, and other similar
identity documents, which are verifiable from the institution issuing the
same; The identifying documents should provide evidence of true name
or names used, permanent address, date of birth, nationality, and office
address. They should include at least one bearing a photograph and be
pre-signed. The identifying documents, which are considered most
reliable, are official identity cards and passports issued by the
government. While identification documents that are easily obtained in
any name, e.g., medical cards, credit cards and student identification
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cards may be used, they should not be accepted as the sole means of
identification.
ii.
Incorporation and partnership papers, for corporate accounts. These

documents should be certified as true copies from the issuing
government agency.
iii.
Duly notarized sSpecial authorizations for representatives., which must

be duly notarized.
iv.
Other pertinent and reasonable documents as may be deemed

necessary under the prevailing circumstances
b. Where applicable, Clients should be notified made aware of ABC explicit

policy which states thatthat business transactions will not be conducted
with applicants who fail to provide identification evidence of their identity,
but without detractingrogating from the ABC obligations to report suspicious
transactions. In cases whenWhere initial checks fail to identify the applicant,
or give rise to suspicions that the information provided is false, additional
verification measures should be undertaken to determine whether the
transaction will proceedto proceed with the business. Details of the
additional checks are to be recorded.
c. Where applicable, when ABC acquiresUpon ABCS acquisition
the
business of another financial sector company or covered institution, either in
whole or as a product portfolio, it is not necessary for the identity of all
existing customers to be re-identified, provided that:
i. all customer account records are acquired with the business; and
ii. due diligence inquiries do not raise any doubtare not questionable as to
whether the anti-money laundering procedures previously adopted by
the acquired business have satisfied Philippine requirements.
iii If during the business relationship, ABC has reason to doubt:
a. the accuracy of the information relating to the customer's identity;
b. that the customer is the beneficial owner; or the intermediary's
declaration of beneficial ownership, or
c. if there are any signs of unreported changes,
ABC shall take further measures to verify the identity of the customer or the
beneficial owner, as applicable. Such measures may include the following:
a. referral of names and other identifying information to criminal
investigating authorities
b. review of disciplinary history and disclosure of past relevant
sanctions.
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d. Where applicable, ABC Customer Identification Program must include

procedures for responding to circumstances in which ABC cannot establish
the true identity of a customer.the identity of a customer cannot be
established by ABC. These procedures should describe, among others, the
following:
1. When ABC should not open an account;
2. The terms under which a customer may conduct transactions
while ABC attempts to verify the customers identity;
3. When ABC should close an account after attempts to verify the
customers identity fails;
4. When ABC should file a Suspicious Transaction Report.
VII.1.2 Individual Clients/Customers Documentary Requirements
a.
As stated in BSP Circular 706 Series of 2011, governing the acceptance of

valid ID cards for all types of financial transaction by a customer and the
authorized signatory/ies of a corporate or juridical entity, including financial
transactions involving Overseas Filipino Workers (OFWs)., in order to
promote access This is to promote access of Filipino to services offered by
formal financial institutions, particularly those residing in the remote areas,
as well as to encourage and facilitate remittances of OFWs through the
banking system:
(1) Customers and the authorized signatory/ies of a corporate or juridical
entity who engage in a financial transaction with ABC Remittance
Corporation for the first time shall be required tomust present the original
and submit a clear copy of at least one (1) valid photo-bearing ID
document issued by an official authority.
For this purpose, the term official authority shall refer to any of the
following:
a. Government of the Republic of the Philippines;
b. Its political subdivisions and instrumentalities;
c. GOCCs; and
d. Private entities or institutions registered with or supervised or regulated
either by the BSP, SEC or IC.
Valid Ids include the following:
1. Passport including those issued by foreign governments
2. Drivers license
3. PRC ID
4. NBI clearance
5. Police clearance
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6. Postal ID
7. Voters ID
8. Tax Identification Number
9. Barangay certification
10. GSIS e-Card
11. SSS card
12. Senior Citizen card
13. OWWA ID
14. OFW ID
15. Seamans book
16. Alien Certification of Registration/Immigrant Certificate of Registration
17. Government office and GOCC ID (e.g., AFP, HDMF IDs)
18. Certification from the NCWDP
19. DSWD certification
20. IBP ID; and
21. Company IDs issued by private entities or institutions registered with
or supervised or regulated either by the BSP, SEC or IC.
(2) BStudents who are beneficiaries of remittances/fund transfers under the
age of eighteen and who are not yet of voting age, may be allowed to
present the original and submit a clear copy of one (1) valid photo-bearing
school ID duly signed by the school principal.principal or head of the
school.
(3) Where the customer or authorized signatoryFor foreign residents is a
non-Philippine resident, similar IDs duly issued by the foreign government
where the customer is a resident or a citizen may be presented.
(4) ABC shall require their customers or authorized signatory to submit a
clear copy of one (1) valid ID on a one-time basis only at the
commencement of business relationship. in order to consummate the
business relationship. CThey shall require their clients are also required to
submit an updated photos and other relevant information on the basis of
risk and materiality.
(5) ABC Skcyash may classify identification documents based on its
reliability and ability to validate the information indicated in the identification
document with that provided by the customer.
(6) For special casesWhenever it deems necessary, ABC may accept other
IDs not enumerated above provided that it shall not be the sole means of
identification.
(7) In case the identification documents mentioned above or other
identification documents acceptable to the company do not bear any photo
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of the customer or authorized signatory, or the photo bearing ID or a copy

thereof does not clearly show the face of the customer or authorized
signatory, ABC may utilize its own technology to take the photo of the
customer or authorized signatory.ABC reserves the right to use its own
technology to take the customers photo if the identification documents
presented above, or those deemed acceptable by the company, does not
bear a clear photo of the customer.
VII.1.3 Corporate and Juridical Entities Documentary Requirements.
a. DAverage due diligence requires that ABC Remittance Corporation shall
obtain the following minimum information and/or documents before
establishing business relationships:
1. Certificates of Registration issued by the Department of Trade and
Industry for single proprietors, or by the Securities and Exchange
Commission, for corporations and partnerships, and by the BSP, for
money chargers/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;
5. Latest General Information Sheet which lists the names of
directors/trustees/partners, principal stockholders owning at least
twenty percent (20%) of the outstanding capital stock and primary
officers such as the President and Treasurer;
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; and
9. For entities registered outside the Philippines, similar documents and/or
information shall be obtained duly authenticated by the Philippine
Consulate where said entities are registered.
VII.1.4 Politically Exposed Person (PEPs) The company shall establish and
record the true and full identity of PEPs as well as their immediate family
members and the entities related to them and conduct enhanced due
diligence to them taking into consideration their position and the risks
attendant thereto.
VII.1.5 Correspondent Banking - Because of the risk associated with dealing
with correspondent accounts where it may unknowingly facilitate the
transmission, or holding and management of proceeds of unlawful
activities or funds intended to finance terrorist activities, ABC shall conduct
enhanced due diligence. ABC may rely on the customer identification
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process undertaken by the respondent bank. In such case, it shall apply

the rules on Third Party reliance treating the respondent bank as the Third
Party as defined therein. In addition, the correspondent bank shall:
(a) Gather sufficient information about the respondent institution to
understand fully the nature of the respondents business and to
determine from publicly available information the reputation of the
institution and the quality of supervision, including whether it has been
subject to money laundering or terrorist financing investigation or
regulatory action.
(b) Assess the respondent institutions anti-money laundering and
terrorist financing controls.
(c) Obtain approval from senior management before establishing
correspondent relationships.
(d) Document the respective responsibilities of each institution.
(e) With respect to "payable-through accounts", be satisfied that the
respondent bank has verified the identity of, and performed on-going due
diligence on, the customers having direct access accounts of the
correspondent and that it is able to provide relevant customer
identification data upon request by the correspondent bank.
VII.1.6 Fund/Wire Transfer - Because of the risk associated with dealing with
fund/wire transfers, ABC shall prevent from being utilized unknowingly in
transmitting proceeds of unlawful activities or funds intended to finance
terrorist activities because of the risk associated with dealing with fund/wire
transfers. Thus, ABC shall take the following necessary measures:
(a) ABC shall not accept instructions to pay-out fund transfers to noncustomer beneficiary, unless it has conducted thegone through the process
of conducting necessary procedures neededcustomer due diligence to
establish the true and full identity and existence of said beneficiary. Should
the originator and beneficiary be the same person, ABC may rely on the
customer due diligence conducted by the originating institution provided
the rules on Third Party reliance are met, treating the originating institution
as Third Party as therein defined;
(b) The originating institution shall not accept instructions to fund/wire
transfer from a non-customer originator, unless it has conducted the
necessary customer due diligence to establish the true and full identity and
existence of said originator;
(c) In cross border transfers, if the originator is a high risk customer as
herein described, ABC shall conduct enhanced due diligence on the
beneficiary and the originator if he/she is a high risk customer. In cases
whenWhere additional information cannot be obtained, or any information
or document provided is false or falsified, or result of the validation process
is unsatisfactory, ABC shall refuse to effect the fund/wire transfer or the
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16
pay-out of funds without prejudice to the reporting of a suspicious

transaction to the AMLC when circumstances warrant;
(d) Whenever possible, manually initiated fund transfer (MIFT) instructions
should not be the primary delivery method; electronic solutions are
preferred for clients.. Every effort shall be made to provide client with an
electronic solution. However, where MIFT is utilized, the existing rules on
validation procedures as prescribed by Circular No. 436 dated 18 June
2004 shall apply;
(e) Cross border and domestic fund/wire transfers and related message
amounting to P50,000 or more or its equivalent shall include accurate and
meaningful originator information from its originator. The following are the
originator information that shall remain with the transfer or related message
through the payment chain:
1. Name of the originator;
2. Address. If none, or in its absence the national identity number or
date and place of birth of the originator; and
3. Account number of the originator. If none, or in its absence, a unique
reference number must be included.
(f) Should any wire transfer amounting to P500,000 or more or its
equivalent be unaccompanied by the required originator informationn, the
ABC shall exert all efforts to establish the true and full identity and
existence of the originator by requiring additional information from the
originating institution or intermediary institution. It shall likewise apply
enhanced due diligence to establish the true and full identity and existence
of the beneficiary. WheIn cases when re additional information cannot be
obtained, or any information or document provided is false or falsified, or
result of the validation process is unsatisfactory, the beneficiary institution
shall refuse to effect the fund/wire transfer or the pay-out of funds without
prejudice to the reporting of a suspicious transaction to the AMLC when
circumstances warrant.
VII.1.7 FX dealers/Money changers/ Remittance agents ABC shall require
their customers who are foreign exchange dealers, money changers and
remittance agents to submit a copy of the certificate of registration issued
to them by the BSP as part of their customer identification document. The
certificate of registration shall be for each head office, branch, agent, subagent, extension office or business outlet of foreign exchange dealers,
money changers and remittance agents.
VII.1.8 Shell company/ Shell bank - Because of the dubious nature of shell
banks, no shell bank shall be allowedShell banks will not be permitted to
operate or be established in the Philippines because of its dubious nature.
ABC shall refuse to enter into, or continue, correspondent reserves the
right to refuse to establish a banking relationship with them, as well as . It
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17
shall likewise guard against establishing relations with foreign financial

institutions that permit their accounts to be used by shell banks.
VII.2 Record-Keeping
1. Where applicable, ABC shall prepare and maintain documentation on their
customer relationships and transactions such that:
a. requirements of the Act are fully met;
b. any transactions done effected via ABC can be reconstructed and from
which the Council will be able to compile an audit trail for suspected money
laundering, when such a report is made to it;
c. ABC can satisfy within a reasonable time any inquiry or order from the
Council as to disclosure of information, including without limitation whether a
particular person is the customer or beneficial owner of transactions
conducted through the ABC.
2. The following document retention periods shall be followed:
a. All records of remittance transactions (i.e. remittance instructions from
agents/subsidiaries, transmittal to fulfillment partners, proof of receipts,
billings, etc.) shall be maintained and safely stored by ABC for five (5) years
from date of transaction.
b. If a money laundering case based on any record kept by ABC has been filed
in court, said file must be retained beyond the stipulated period until it is
confirmed that the case has been finally resolved or terminated by the
court.settled in court.
c. ABC shall retain records as originalskeep the records as originally obtained
in such forms in order for them to remainas are admissible in court. ABCand
shall ensure that these records are filed separately, labeled properly, boxed
and stored safely.
d. As provided for by the Anti-Money Laundering Law, violators will face a
penalty of imprisonment from 6 months to 1 year or a fine of not less than
P100K, but not more than P500K , both consequences.or both, shall be
applied and imposed on a person convicted for this violation.
3. Transaction documents may be retained as originals or copiesoriginal or duplicate
copies, on microfilm, or in soft copy, electronic form, provided that these will
besuch forms are admissible in court, pursuant to the Revised Rules of Court and
the E-Commerce Act and its Implementing Guidelines.
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18
4. If the records relate to on-going investigations or transactions that have been the
subject of a disclosure, they shall be retained beyond the stipulated retention
period until it is confirmed that the case has been closed and terminated
5. Where applicable, ABC shall designate at least two (2) persons responsible in the
safekeeping of all records, reporting to the Commission/Council any change in the
person/s responsible, if there is any.
VII.3 Reporting of Covered & Suspicious Transactions
1. It is within shall be the responsibility of ABCs responsibility to report all covered
and suspicious remittance transactions to the Compliance Monitoring Officer all
covered and suspicious remittance transaction. ABC incorporates an automated
AML, OFAC and KYC controls and reporting functionalities within its system.
2. The report shall be submitted within ten (10) days from occurrence thereof,
unless the Supervising Authority (BSP, SEC, IC etc.) concerned prescribes a
longer period not exceeding 10 working days., This shallto be prepared in the
prescribed format and forms and shall be submitted/transmitted in a secured
manner as prescribed in the AMLC Reporting Procedures document.
3. Where applicable, the mandatory Covered Transaction Report (CTR), shall be
filed before the Anti-Money Laundering Council, copy furnished the SEC, for
transactions in cash or other equivalent monetary instrument involving a total
amount in excess of the threshold limit of P500,000.00 within one (1) banking
day as provided under Section 3 (b) of R.A. 9160, ABC shall clarify the economic
background and purpose of any transaction or business relationship if its form or
amount appears unusual in relation to the business or financial capacity of the
customer and the customer has not been properly identified, or if the economic
purpose or legality of the transaction is not immediately clear, as where there is
no underlying legal, trade obligation, purpose, origin or economic justification, or
where the transaction is unusually large and complex.
4. Where the transaction or transactions do not fall within the threshold amount
provided in the definition of a covered transaction, and ABC has reasonable
grounds to believe that the source/s of the funds arise from or are in anyway
related to an unlawful activity, ABC shall file a Suspicious Transaction Report
before the Anti-Money Laundering Council, copy furnished the SEC. In this
regard, ABC should exercise due diligence by implementing adequate systems
for identifying and detecting suspicious transactions, especially where any of the
following circumstances exists:
a. there is no justifying legal or trade obligation, purpose or economic
justification;
b. the client is not properly identified;
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19
c. the amount involved is not commensurate with the business or financial

capacity of the client;
d. taking into account all known circumstances, it may be perceived that the
clients transaction is structured in order to avoid being the subject of
reporting requirements under the Act;
e. any circumstance relating to the transaction which is observed to deviate
from the profile of the client and/or the clients past transactions with the
covered institution;
f.
the transaction is in any way related to an unlawful activity or offense
under this Act that is about to be, is being or has been committed; or
g. any transaction that is similar or analogous to the foregoing.
In this regard, ABC shall exercise due diligence by implementing adequate
systems for identifying and detecting suspicious transactions.
5. The suspicion relates to a transaction considering all the circumstances of the
transaction. As a general principle, any transaction which causes ABC to have a
feeling of apprehension or mistrust about the transaction considering
a. its unusual nature or circumstances or,
b. the person or group of persons with whom they are dealing, and based on
the bringing together of all relevant factors including knowledge of the
person's or persons' business or background (as well as behavioral
factors) should be reported as a suspect transaction.
6. Suspect transactions are likely to involve a number of factors, which together
raise a suspicion in the mind of ABC that the transaction may be connected with
any unlawful activity.
VII.4 Risk-Based Due Diligence in Processing Remittance Instructions
1. ABC will accept remittance instruction only accepts remittance instructions from
its agents, subsidiaries/affiliates, tie-ups, and correspondent banks.
2. AThe agents/subsidiaries/affiliates mustshall ensure that remitters declare
thethe remitter declare the purpose of the remittance transaction as well as its
sourcebeing made and the source of fund. The declaration should be validated
through the identification papers presented., Ai.e. assessments will me made
whetherif the remittance amount is commensurate to the nature of job/business
of the remitter.
3. The fulfillment partners, accredited couriers and outlets should also pursue their
own verification initiatives d likewise perform their own diligent
checking/validations on establishing the identity of the beneficiary, source of
funds, and of the remitter/purpose of the remittance., if applicable.
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20
4. ABC accredited agents, subsidiaries/affiliates, tie-ups, fulfillment partners,

couriers, outlets shall use any or combination of the following to verify the
identity of the sender of an emailed or faxed message as well as verify its
authenticity, and ensure the integrity and authenticity of the exchange file.
i. Test Key - An algorithmic computation using a fixed set of factors known only
to the subsidiary/tie-up to authenticate the remittance instructions.
Note : ABC shall provide its remittance partners a unique set of codes for its use in its incoming and
outgoing remittance transactions.
ii. ABC will use the service of a secured FTP server to ensure security,
efficiency and speed in the delivery of the exchange file.
Note: ABC shall provide its remittance partners a unique set of login credentials.
iii. Designation of responsible personnel ABC shall require its remittance

partners to provide them with a list containing the submit the names of their
personnel authorized to transact/communicate with ABC, and likewise
designate specific persons with whom they can transact/communicate.
iv. Email address/fax ABC shall also require its remittance partners to submit
their official fax/email addresses where communications to/from ABC will be
coursed thru. for communication purposes. Likewise, ABC will provide its
official fax/email addresses to its remittance partners..
5. ABC shall immediately informl refer immediately to the concerned
agent/subsidiary/tie-up any discrepancy concerningin its remittance instructions
for clarification, correction, or further instruction.
6. Distribution channels (fulfillment partners, couriers, outlets) shall be expected to
exercise due diligence before credit/pay-out/delivery of the remittance amount
are effected/completed:
i. For Cash Pick-Up - DefinitiveThere should be positive identification of the
customer and verification of his/her signature is required.
ii. For Credit to Account of Beneficiary This is done only when account
number as indicated in the remittance instruction, matches the account
number appearing in the record of the correspondent bank.
The account
numbers indicated in the remittance instruction and the records of the
correspondent bank must match for this to be done.
iii. For Door to Door Delivery OnlyThis is delivered only by authorized
fulfillment partners/couriers can make deliveries upon the beneficiarys
presentation of proper identification. of the specified beneficiary.
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21
7. The procedures for processingin the processing of inward remittances from

receipts of payment instructions from tie-ups up to distribution of same to
different delivery channels with the end-view of satisfying the
remitter/beneficiaries. It does not include processes at the tie-ups end, or at the
distribution channels.
DOER
Processing Officer
Processing Officer
Processing Officer
Processing Officer
Processing Staff
Processing Staff
Processing Staff
Processing Staff
Processing Staff
ACTIVITY
Confirmation of Transaction
Download Payment Instruction batch files from the
tie-up web site or FTP folder.
Save the downloaded Payment Instruction batch
files to the assigned tie-up folders.
Verify the contents of the Payment Instruction as to;
total amount, number of items, message number
and Testkey codes..etc.
Log the Payment Instruction details (Transaction
date, amount, batch name and signature) on the
Tie-up Validation Sheet (Annex A).
Validate the indicated Testkey Code and Message
number based on the assigned Tie-up Testkey
Codes (Annex B)
Confirm the receipt of Payment Instruction batch
files to Tie-ups thru Email or other agreed mode of
communication.
Remittance Take-up
Log on to the Nautilus Remittance System. Go to
Remittance Take-up Menu.
Load the transaction on the Nautilus Remittance
System and save.
Note: In this stage an automated filtering of items
against the OFAC and PEP (Philippines) list is being
triggered by the system. A notification will be
prompted upon a match. A report must be prepared
for AMLAC.
Verify unassigned items.
Note: If no service code was provided on the
Remittance Instruction, the following rules will apply:
1. If the bank name and bank account number are
present the service mode must be Credit to Bank.
2. If home address is present the service mode
must be Door to Door Delivery.
3. If neither home address nor bank details are
present the service mode will be Cash Pick-up.
4. If either of the above premises were present, the
item should be lodged into AP account.
Preview and generate the Draft Prooflist of the
verified batch file.
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Processing Officer
Processing Officer
Processing Staff
Processing Staff
Processing Staff
Processing Staff
Processing Staff
Processing Staff
Processing Staff
Processing Staff
Processing Staff
Feedback Staff
Validate the contents of Draft Prooflist against the

raw batch file as to amounts, number of items,
exchange rate, service charges and sufficiency of
tie-up account balance to cover the transaction.
Note: PURGE the loaded batch if the exchange
rate applied or the total amounts and items vary
from the contents of the raw file.
POST transaction if all the necessary data are
correct.
Generate the Final Prooflist and save to the
designated tie-up folder/back up file using a PDF file
format.
Payout Routing and Dispatch
Go to Payout Dispatch Menu and click the
Routing tab.
Prepare the Transfer list for each service mode
(Deposit, Pick-up and Delivery) and Auto/manually
assign the Agents (courier, outlet and bank)
Go to Dispatch tab and prepare the Transfer File
for each Agent.
Go to Download tab and click each Agent.
(Note: The file will not be exported to Agents folder
if the Tie-up Balance is insufficient to cover the
transaction amount)
Under the Download menu generate the text alert
list.
Under the Document menu generate the transfer
list for each agent.
Note: Please refer to Annex A for the uploading
procedure in Cebuana Lhuillier, MLhuillier, MPI Web
service Application, Security Bank Digibanker and
BPI Connect Direct
Generate the Batch Summary Report.
Generate a PDF file for the Transfer List and Batch
Summary Report and save to the designated tie-up
folder/back-up.
Note: The designated back-up folder will contain the
Remittance Instruction file, Final Prooflist, Transfer
List and Batch Summary Report.
Feedback
All items with missing details lodged under AP
account shall be advised to respective tie-up as
soon
as
possible
for
their
appropriate
action/amendment instruction.
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23
Feedback Staff
Feedback Staff
Feedback Staff
Feedback Staff
Feedback Staff
Processing Officer
Feedback Staff
Feedback Staff
Processing Officer
Feedback Staff
Feedback Staff
Feedback Staff
Feedback Staff
IX.
Download immediately upon availability the status

report from respective couriers, outlets and bank for
all the remittance items forwarded to them by ABC.
This will be sent to ABC using a prescribe file format
through FTP or Email.
Log on to ABC Remittance System Completion
Module. Upload the feedback file from various
couriers, outlets and banks.
Go the Feedback Menu and generate a status
report for the respective foreign Tie-ups.
Save a PDF File for the respective tie-ups.
Send the foreign tie-up Status report thru email.
Amendments
Validate the Testkey Code (Annex B) of the
incoming amendment instruction and log the
transaction on the respective tie-up validation forms
(Annex A).
Notes: All amendments, refunds and cancellation
must be supported by a coded advice from tie-ups.
Confirm receipt of the validated Amendment
Instruction through Email.
Go to Special Transactions, from the Amendment
menu search for the control number of the
transaction for amendment. Amend the details of
the transaction based on the received amendment
instruction.
Notes: Only cancelled and on-hold items can be
amended.
Check the details of the amended transaction
against the received amendment instruction, if
correct, go to Release Remittance Hold menu and
release the transaction.
Under the Payout Dispatch menu rout the
transaction to the assigned agent.
Dispatch the routed transaction
Download the dispatched item.
Print the Batch Summary Report and Transfer list
and save the soft copies to the back-up folder.
Training Program
1. ABC shall provide all its staff and personnel, ABC shall provide education and
training for all its staff and personnel, including directors and officers, with education
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24
and training ABC , to ensure that they are fully aware of their personal obligations
and responsibilities to in combating money laundering and to familiarize
themselvesbe familiar with theits system for reporting and investigating suspicious
matters.
2. ABC may, due to the scale and nature of its operations, assign the internal audit or
training functions to another entityperson (e.g. professional association, parent
company or external auditors). Where ABC delegates its responsibilities for audit
and training, due diligence is to be exercised to ensure that the persons appointed
are able to perform these functions effectively and the fact of such appointment
must be relayed in writing to the Council.
3. Timing and content of training for various sectors of staff will need to be adapted by
ABC for its own needs. The following may be included:.
a. New Staff. General background of money laundering, the ability to identify suspicious
transactions and method of reporting these to the appropriate designated point person within
ABC A general appreciation of the background to money laundering, the need to be able to
identify suspicious transactions and report such transactions to the appropriate designated
point within ABC. This training shall be provided to all new employees, regardless of level of
seniority.
b. Supervisors and Managers. A more comprehensive course higher level of instruction that
coversring all aspects of money laundering procedures should be provided to supervisors and
managers. This will include the offensces and penalties arising from the Act, procedures
relating to service of production and restraint orders, internal reporting procedures, and the
requirements for verification of identity and the retention of records.
4. ABC shall l, at least once a year, make arrangements for refresher coursestraining
at least once a year to remind key staff of their responsibilities and to make them
aware of any changes in the laws and rules relating to money laundering, as well as
the internal procedures of ABC.
X.
Recruitment Process
ABC Remittance Corporation commits itselfis committed to hiring individuals who reflect
diverse backgrounds, possess have the qualifications, values and potential necessary to
achieve company goals. These hiring policies involvearticulate sound practices to ensure
that this is achieved and risks to the company are minimized.company risk is minimized.
1. Posting Requirements
Once the listing for job openings job need evaluation has been completed, the
position may be posted oin Jobstreet, company website or newspaper
classified ads for candidates to apply. Use of search enginesfirms to source
candidates for a position may be considered.is permissible.
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25
2. Applicant Eligibility
A candidate must meet the qualification standard for the position. Human
resourcesThe company will conduct a record review of the candidate and
determine his/her eligibility for hire.
3. Applications for Employment
All internal and external applications for staff positions will be posted and
made available whether online or classified ads. Applications will comply with
all legal requirements.
4. Interview Process
CGenerally, candidates will be screened in order to determine whether they meet
thefor minimum requirements for the position. Those determined to meet the
requirements will be passed on to the hiring manager. Candidates selected will be
interviewed in person and progress to subsequent steps in the process based on
the interview results.
5. Offers of Employment
Compensation offered must be consistent with company policythe policies of
the Company. Employment offers are commitments on behalf of the Company.
It and must ensure that every offer made to an individual complies with
company and legal requirements.
6. Pre-Employment Background Reviews
Candidates will be subject to testing procedures. The company conducts
various checks on applicants for employment to ensure that individuals who
join the company workforce are qualified, have potential to be productive and
successful, and have honestly presented their qualifications on the
Employment Application.
8. Pre-Employment Physical Examinations
Physical examinations are not required by the company and are not conditional for
employment.The company does not generally require pre-employment physical examinations
as a condition of employment. However, the company reserves the right to require post-offer,
pre-employment physical exams in circumstances where the nature of the work renders it
appropriate or where law or regulation requires.
XI.
Internal Audit System
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26
The internal audit function associated with money laundering and terrorist financing
should be conducted by qualified personnel who are not affiliated independentwith of the
office being audited. S. It must have the support of the board of directors and senior
management is needed, as well and have a direct reporting line to the board or a board
level audit committee.
In addition to the function earlier mentioned, the internal audit shall also be responsible
for the following:
a. periodic and independent evaluation of the risk management;
b. degree of adherence to internal control mechanisms related to the customer
identification process, such as the determination of the existence of customers and
the completeness of the minimum information and/or documents establishing the
true and full identity of, and the extent and standard of due diligence applied to,
customers;
c. CT and ST reporting and record keeping and retention; and
d. Determination ofing the adequacy and effectiveness of other existing internal
controls associated with money laundering and financing terrorist activities.terrorist
financing.
The results of the internal auditInternal audit results shall be immediately communicated
to the board of directors. It must also be available forrs and shall be open for scrutiny by
BSP examiners in the course of the regular or special examination without prejudice to
the conduct of its own evaluation whenever necessary.
Results of the audit shall likewise be promptly communicated to the compliance office for
its appropriate corrective action. The Compliance Office shall regularly submit reports to
the board to inform them of managements action to address deficiencies noted in the
audit.
XII.
Independent Audit Program

An Anti-Money Laundering (AML) audit by an external independent auditing firm must be
conducted annually to determinesee whether ABC has an appropriate AML program.
An AML audit generally includes the following:
a.
b.
c.
d.
e.
f.
g.
XIII.
A full review of the company's AML compliance program manual

Testing of the company's AML Policy and Procedures
Customer Identification Procedure (CIP) review
Transactional testing and evaluation
CTRs and STRs filings review
Evaluation of AML training; and
Review of past audit reports to assess the efficacy of recommended implemented
changes
Compliance Monitoring
(Mechanism that ensures all noted deficiencies are corrected)
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27
1. All the audit findings and noted deficiencies shall be addressed and corrected.
The revisions must be recorded and integrated in the revised version of the MLPP
for review and approval by the ABC Board of Directors.
2. ABC shall ensure its continued compliance with the institution's policies,
procedures and guidelines on money transfers, particularly with regard to antimoney laundering.
3. Occasional review of It shall review from time-to-time its policies and and
procedures, implementation of and effect necessary revisions for product
developmentthe improvement of its products and services, as well as the
introduction ofintroduce better safeguards against money laundering.
XIV.
Cooperation with AMLC

Management shall cooperate fully with the Anti-Money Laundering Council (AMLC)
and the Bangko Sentral ng Pilipinas (Central Bank of the Philippines) within the
limits allowed by law.
A diligent and pro-active approach in cooperating with the Anti-Money Laundering
Council is the review and submission of required reports. In addition, a continuous
dialogue and inquiry shall be made with the authorities to ensure clear
understanding of rules and regulations.
Review and submission of reports is one way in which the management
cooperates with the Anti-Money Laundering Council through proactive and diligent
approaches. Constant communication with authority will be fostered in order to
ensure clear understanding of its stipulated rules and regulations.
XV.
Designation of Compliance Officer

1. ABC hereby appoints a Compliance Officer to advise its management and staff on
the issuing and enforcement of in-house instructions to ensurepromote adherence
to AMLA rules and regulations, including personnel training, reporting of suspicious
transactions, and generally, all matters relating to the prevention of money
laundering.
2. ABC hereby appoints a Compliance Officer with the following duties and
responsibilities:
a) EBe responsible for establishment and enactmenting ofand maintaining a
manual of compliance procedures in relation to the business of ABC;
b) ResponsibilityBe responsible for ensuring compliance by the staff of ABC
with the provisions of the Anti-Money Laundering Act.
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28
c) Serves as the linkAct as the liaison between ABC and the Anti-Money
Laundering Council (AMLC) concerning legal mattersin matters relating to
compliance with the provisions of the law;
d) Preparatione and submission of t to the AMLC written reports on ABCs
compliance with the provisions of the law, in such form and submitted at
such time as the AMLC may determine.
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29

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MONEY LAUNDERING AND TERRORIST FINANCING

Revised MLPP - May 2016