AMLC Registration and Reporting Guidelines
AMLC Registration and Reporting Guidelines
Manila, Philippines
Table of Contents
2.6 E-Return Upload ………. 2-23
Annexes
B. System Codes
B.1 Revised Transaction Codes ………. B-1
B.2 Currency Codes ………. B-33
B.3 Country Codes ………. B-38
C. Mandatory Fields ………. C-1
D. Examples of Red Flags and Alerts ………. D-1
E. Typologies ………. E-1
Table of Contents
Anti-Money Laundering Council
Manila, Philippines
General Provisions
Part 1
AMLC Registration and
Reporting Guidelines
I. Legal Framework
The goal of a large number of criminal acts is to generate a profit for the individual or group that
carries out the act. Money laundering is the processing of these criminal proceeds to disguise their
illegal origin. This process is of critical importance, as it enables the criminal to enjoy these profits
without jeopardising their source.1
The Implementing Rules and Regulations took effect on 02 April 2002. Subsequent revisions to
the Implementing Rules took effect on 07 September 2003, 15 September 2012 and 09 August
2017, respectively.
Section 4 of the AMLA, states that: Money Laundering Offense – Money laundering is committed
by any person who, knowing that any monetary instrument or property represents, involves, or
relates to the proceeds of any unlawful activity:
R.A. No. 10927 which took effect on 29 July 2017 effectively amends Section 1. Section 3(a) of
the AMLA to include casinos as “Covered Persons”. Single cash transactions of casinos in excess
of five (5) million pesos or its equivalent in any other currency, must be reported to the Anti-
Money Laundering Council (AMLC).
1
http://www.fatf-gafi.org.
Covered Persons (CPs) which are mandated by the AMLA, to submit covered and suspicious
transaction reports (CTRs/STRs) to the AMLC are as follows:
The term “Covered Persons” shall exclude lawyers and accountants acting as independent
legal professionals in relation to information concerning their clients or where disclosure of
information would compromise client confidences or the attorney-client relationship,
provided, that they are authorized to practice in the Philippines and shall continue to be
subject to the provisions of their respective codes of conduct and/or professional
responsibility or any of its amendments.
B. Submission of CTRs beyond 12:01 am of the day following the 5th working day from
occurrence of the transaction shall be considered as non-submission of CTRs and
may be subject to appropriate administrative sanction, if circumstances so warrant.
C. All CPs shall report to the AMLC all covered transactions, regardless of the mode of
payment used in the settlement thereof, including transactions in checks, fund
transfers, and/or debiting or crediting of accounts, except those transactions
covered under the no/low risk transactions (Part 1 – General Provisions, Item VII).
For jewelry dealers in precious metals and jewelry dealers in precious stones as
defined, covered transaction is a transaction in cash or other equivalent monetary
instrument involving a total amount in excess of one million pesos (P1,000,000.00).
Covered persons are encouraged to develop their own list of alerts or red flag
indicators taking into account the nature of their business, type of customers and
risks involved.
See Annex D for examples of Examples of Alerts, Red Flags and Suspicious Indicators
Where a responsible officer of the covered person conducts inquiries and obtains
what it considers to be a satisfactory explanation of the activity or transaction, it
may conclude that there are no grounds for suspicion, and therefore take no further
action. However, where the inquiries do not provide a satisfactory explanation of
the activity or transaction, an internal report should be made and be properly
escalated to the designated compliance officer and/or review committee to
determine if there are grounds for suspicion warranting the submission of the STR.
The reporting chain, with reasonable timeframes starting from flagging, analysis,
investigation, escalation and until the final decision is made, shall be clearly written
in the covered person’s Money Laundering and Terrorist Financing Prevention
Program (MLPP). Covered persons should ensure that proper controls are in place
to guarantee confidentiality of the process and that no “tipping – off” of customers
will happen at all times during the entire proceedings. For this reason, the
Compliance Officer shall have access to all customer information files and
transactions through the electronic or manual customer monitoring system.
1. Covered persons shall report to the AMLC all suspicious transactions within
five (5) working days from the occurrence thereof.
G. Uploading of KYC Documents is mandatory, if the reason for suspicion will fall under
any of the following Predicate Crimes:
However, if the AMLC Secretariat, requests for the KYC Documents for STR
previously filed with the AMLC, wherein, subject of the STR has an existing money
laundering case, CPs should be able to upload said KYC documents.
See Part 4, Chapter 2.3 of the AMLC Registration and Reporting Guidelines for a step-
by-step procedure of the Uploading of KYC Documents.
A. The following non-working days are excluded from the counting of the prescribed
reporting period:
weekend (Saturday and Sunday)
official regular national holiday
officially declared national holiday and workday suspensions
B. A “non-reporting day” may be declared by the AMLC Secretariat when the File
Transfer and Reporting facility (FTRF), used by the CPs in transmitting their electronic
reports to AMLC is unavailable to all CPs for at least five (5) consecutive hours during
the day.
AMLC-declared “non-reporting day” is excluded from the counting of the
prescribed reporting period.
The Executive Director, or in his/her absence, the Officer-in-Charge of the
AMLC Secretariat is authorized to declare such day as a “non-reporting day.
B. For CPs under the supervisory authority of the Securities and Exchange Commission
(SEC):
C. For CPs under the supervisory authority of the Insurance Commission (IC):
Online Registration
System
Part 2
AMLC Registration and
Reporting Guidelines
ONLINE REGISTRATION
INTRODUCTION
One of the many functions of the Anti-Money Laundering Council (AMLC) is “To require and
receive covered or suspicious transaction reports (CTRS/STRs) from covered institutions”
(section 7.1 of R.A.9160). Section 1 of RA 10365 amends Section 3 of R.A 9160 to expand the
coverage of the law; it changes the definition from covered institutions to covered persons,
whether natural or juridical.
In addition, Rule 9C (3) of the 2016 RIRRs of the AMLA states that “All covered persons shall
register with the AMLC’s electronic reporting system within ninety (90) days from the effectivity
of this RIRR”.
In order to transmit CTRs and STRs, CPs need to register with the AMLC in order to be given
access to the AMLC Portal.
The Online Registration System for CPs will allow Compliance Officers to manage their user
accounts as well as that of their alternates. The system will also provide a means of monitoring
CP’s user accounts by requiring Compliance Officers to update their information every two (2)
years.
GUIDELINES
a. Secretary Certificate and/or Board Resolution and/or General Information Sheet for COs
of Banks, Insurance Companies, Securities Companies, Financing Companies, Lending
Companies, Pre-Need Companies and all other Covered Persons registered with the SEC
as a Corporation.
b. Certificate of Associated Persons for APs of Brokerage Companies.
c. DTI Certificate for Pawnshops/Money Service Businesses, registered as Single
Proprietorship as well as a Document, notarized and signed by the owner of the
MSB/Pawnshop designating him/her as the PDO, if the PDO is not the owner of the
MSB/Pawnshop.
a. Download the Gnu Privacy Guard (GPG) software from www.amlc.gov.ph under the
Reporting Tools tab.
b. Install the GPG Software.
c. Generate public key.
d. Export public key (file extension is .asc);
Be ready with your exported asc file as this will be needed during online
registration
e. Get and save the AMLC public key (amlc.asc) from www.amlc.gov.ph under the
Reporting Tools tab.
3. Once Items 1-2 have been performed/ accomplished, COs/APs/PDOs may now proceed with
the Online Registration (https://portal.amlc.gov.ph).
4. Registration will be processed daily; cut-off time is 1:00 PM, registration received after 1:00
PM will be processed the following day.
5. The Secretariat will issue a Certificate of Registration, with the facsimile signature of the
AMLCS Executive Director or the Officer-in-Charge, to successfully - registered CPs, upon
request. The said certification will be sent via email as a PDF file.
6. A two (2) year mandatory update of the registration via the Online Registration System is
required. Failure to update the registration will result in the deactivation of the CPs user
access in the AMLC Portal.
7. List of successfully registered MSBs and Pawnshops will be published in the AMLC website,
to be updated monthly.
2. Covered Person Registration page will appear, please read the instructions first before proceeding
to Step 1 of 3.
Note: Be sure to have a scanned copy of your document/s stating your appointment as the
CO/AP/PDO; have generated your public key using Kleopatra and have your exported asc file
before proceeding to the next page (Step 2 of 3).
Doc/s showing
appointment of
Compliance Officer
Key details
can be seen
in Kleopatra
If alternate generated a public key, please continue with the key details
For
Alternate
with
Public
key; check
on Key
details
6. After you click Save, a window will appear, showing that Registration has been successful. Please
take note of your Reference No. You will need this to check the status of your Registration.
8. After the CO/AP/PDO and alternate have validated their email addresses, this page will appear,
just click “Agree”.
10. Once AMLC has processed your Registration, you will receive an email from AMLC whether
Registration has been approved or disapproved. Below is a sample email of an approved
Registration.
11. Once registration has been approved, log-in to https://portal.amlc.gov.ph to change your password.
Please log in using the first 6-digits or first 9-digits of your institution code, email address and system
generated password.
Transaction Security
Protocol
Part 3
AMLC Registration and
Reporting Guidelines
Transaction Security Protocol
GUIDELINES
A. The File Transfer and Reporting Facility using the Hypertext Transfer Protocol over Secure
Socket Layer (FTRF v 2.0) shall be used by the CPs in transmitting their respective reports.
B. Hypertext Transfer Protocol over Secure Socket Layer (HTTPS) is a private, secure and
graphical method of accessing web page information and/or sending information across a
web. It is especially useful for encrypting forms-based information as it passes between
clients and servers. HTTPS which is implemented under the File Transfer and Reporting
Facility (FTRF v 2.0) will address the efficiency, integrity and security concerns of data
collection from the Covered Persons.
C. File Transfer and Reporting Facility (FTRF) has the following features:
a. Secure upload – provides data encryption, server authentication and message integrity;
b. Self-signed Digital Identification & Certificate – allows encrypting and digital signing of
messages; and
D. The self-signed digital identification shall be implemented for all CPs. AMLC and the CPs
shall use the Gnu Privacy Guard (GPG) software for their encryption and authentication and
the GPG supported algorithm (MD5) for their signing. Installer of the said software shall be
provided by AMLC upon registration.
E. The compliance officer of the CP shall generate his private key as well as public key using
GPG which shall be uploaded during the Online Registration.
F. The signed public key of the AMLC shall be used by the CPs to:
a. Encrypt the electronic files (CTR/STR in csv format) to be submitted to AMLC; and
b. Verify the signature of the files they will receive from AMLC.
H. The signed private key of the AMLC shall be used by AMLC to:
a. Decrypt the encrypted files sent by the CPs which were encrypted using AMLC’s signed
public key; and
b. Sign the electronic files they will send to the CPs.
I. The signed public key of the CP shall be used by the AMLC to:
a. Encrypt the validation messages that AMLC will send to the CP; and
b. Verify the signature of the files AMLC will receive from the CPs.
L. In cases wherein the public key is compromised, superseded or no longer in use, CPs should
perform the recovery procedure, only if they have successfully performed the back-up
procedure of their existing private and public keys, to be able to continue to encrypt file.
Otherwise, a new pair of public and private keys shall be generated and to be uploaded via
the Online Registration System.
Select components to
install. Check Kleopatra,
GpgEX, and Gpg4win
Compendium, then
uncheck other
components. Click Next.
Choose Start
Menu folder for
the Gpg4win
shortcuts. Enter
Gpg4win, then
click Install.
La
Click Finish.
Enter Details,
then click
Advance
Settings.
Note:
Name – Name of Compliance Officer
Email – Email address of Compliance Officer
Comment – Name of the company
From Key
Material, select
DSA: 2,048 bits
(default).
Check + Elgamal :
2,048 bits
(default).
From Certificate
Usage, check
Signing,
Encryption and
Certification.
Click Ok.
From the
Certificate
Creation Wizard
window, click
Next.
Click Finish.
From your
desktop, double
click Kleopatra.
The Kleopatra
main window will
be displayed on
the screen.
Click the name of
the compliance
officer, then click
Export
Certificates.
Note: The default filename of the public key is the key fingerprint.
Please be ready with the exported asc file as you will need this for
ONLINE REGISTRATION
Get a copy of the AMLC public key (amlc.asc) from www.amlc.gov.ph under Reporting Tools
then save this to your local drive.
From your
desktop, double
click Kleopatra.
The Kleopatra
main window will
be displayed on
the screen.
Click Import
Certificates.
Select the
directory where
you have saved
the AMLC.asc,
then click Open.
The imported
public key will
be displayed on
Kleopatra –
Imported
Certificates tab.
From your
desktop, double
click Kleopatra.
From Kleopatra
main window,
click Anti-Money
Laundering
Council’s public
key.
Check Anti-
Money
Laundering
Council, then
check I have
verified the
fingerprint.
Click Next.
Select Certify
only for
myself, then
click Certify.
Click
Finish.
Open
Kleopatra.
From My
Certificates
tab, click the
name of the
key owner
(Compliance
Officer).
From the
menu bar,
click File
then select
Export
Certificates.
On My
Certificates
tab, click the
name of the
key owner
(Compliance
Officer).
From the
menu bar,
click File
then select
Export
Secret Keys.
Create a
filename for
your secret
key backup
and select
the
directory
where you
want to
save the
backup of
secret key
(USB) then
click Save.
Follow the
procedure in
installing the
GPG Software.
Once installed,
Open Kleopatra
then click File
then Select
Import
Certificate.
Select the
directory
where the
backup of
your public
key (.asc) is
saved then
click Open.
To import
your secret
key, click
file then
select
Import
Certificate.
Certificate
Import
Result
window will
appear then
click Ok.
Reporting Procedures
Part 4
AMLC Registration and
Reporting Guidelines
COVERED/SUSPICIOUS TRANSACTION REPORT
1
1.1 Data Elements Chart (Format Code 1.0) – BSP/SEC
Supervising Agency
BSP/SEC
Supervising Agency
Institution/Branch Code
Report Date
Reporting Institution
Report Type
Format Code
Submission Type
DETAIL RECORD
Transaction Data
FIELD
NO. FIELD NAME TYPE LENGTH FORMAT VALUE/REMARKS
D-1 Detail Record Indicator Text 1 D D - for Detail
Transaction Date/ 8/ 9(8)/ YYYYMMDD
*D-2 Number
Transaction Date & Time 14 9(14) YYYYMMDDHHMMSS
D-3 Transaction Code Text 5 X(5) AMLC Transaction Codes
must be unique per
D-4 Transaction Reference No. Text 20 X(20)
transaction date
Account No./PN No./Client
D-5 Text 40 X(40)
Stock Ref. No./Certificate No.
Old Account No./PN No./Client
D-6 Text 40 X(40)
Stock ref. No.
Greater than 0 w/ or w/o
D-7 Transaction Amount (Php) Number 20 9(18).99
decimal value
D-8 Transaction Amount (FX) Number 17 9(15).99 Optional
optional; mandatory if FX
D-9 FX Currency Code Text 3 X(3)
amount <> null
D-10 Nature/Purpose of Transaction Text 200 X(200)
yyyymmdd; date should not
D-11 Inception/Effectivity Date Number 8 9(8)
be less than 20011017
yyyymmdd; date should not
D-12 Maturity Date /Expiry Date Number 8 9(8)
be less than the inception date
Greater than 0 w/ or w/o
D-13 Amount of Claim/Dividend Number 20 9(18).99
decimal value
D-14 No. of shares/units Number 20 9(18).99 Greater than 0
Greater than 0 w/ or w/o
D-15 Net Asset Value Number 17 9(15).99
decimal value
D-16 Name of Correspondent Bank Text 90 X(90)
D-17 Address
Subject Data
Detail Record–Party details (Multiple)
ACCOUNT HOLDER/CUSTOMER
D-A-1 Party Type Flag Text 1 X A – Accountholder/Customer
D-A-2 Customer Reference Number Text 30 X(30)
Y – if acct. holder/customer is
Name Flag a corporation
D-A-3 Text 1 X
N – if acct. holder/customer is
an individual
D-A-4 Name Text
Last name of account
Last Name 100 X(100)
holder/customer
First name of account
First Name 100 X(100)
holder/customer
Middle name of account
Middle Name 50 X(50)
holder/customer
D-A-5 Address Text
Room No./Office Name,
Address1 100 X(100) Bldg./House No., Street,
Subd./ Brgy.
Address2 100 X(100) District, Town, City
Address3 100 X(100) Province, Country , ZIP
for corporate accts.- current date
> date and date > 1521 ; for
Birthdate/Registration Date individual accts. - date < current
D-A-6 Number 8 9(8)
date and the difference between
current date and birthdate must
be less than 150
D-A-7 Place of Birth/Registration Text 90 X(90) City, Municipality, Country
D-A-8 Nationality Text 40 X(40)
ID1 – Passport
ID2 – Driver’s License
ID3 – PRC ID
ID4 – NBI Clearance
ID5 – Police Clearance
ID6 – Postal ID
D-A-9 ID Type Text 4 X(4)
ID7 – Voter’s ID
ID8 – TIN
ID9 – Barangay Certification
ID10 – GSIS e-Card/UMID
ID11- SSS
ID12 – Senior Citizen Card
BENEFICIARY
Details of Suspicion
Reason for Suspicion
SI1- There is no underlying legal or
trade obligation, purpose or
economic justification.
SI2- The client is not properly
identified.
SI3- The amount involved is not
commensurate with the
business or financial capacity
of the client.
SI4- The transaction is structured
to avoid being reported.
SI5- There is a deviation from the
client’s profile/past
transactions.
SI6- The transaction is similar,
analogous or identical to any
D-D-1 Reason Memo 800
of the foregoing. (Additional
reason is required after a
semicolon i.e. SI6; The client
is…….)
PC1- Kidnapping for ransom
PC2- Drug trafficking and related
offenses
PC3- Graft and corrupt practices
PC4- Plunder
PC5- Robbery and Extortion
PC6- Jueteng and Masiao
PC7- Piracy on the high seas
PC8- Qualified Theft
PC9- Swindling
PC10- Smuggling
PC11- Violations under the Electronic
Commerce Act of 2000
TRAILER RECORD
FIELD
NO. FIELD NAME TYPE LENGTH FORMAT VALUE/REMARKS
T-1 Trailer Record Indicator Text 1 T T - for Trailer
T-2 Php Amount Total Number 20 9(18).99 Total Transaction Amount
Records Total of batch to be
T-3 sent Number 10 9(10) Total number of CTR/STRs
Note: Mandatory fields and parties are on a per transaction basis (Please refer to Annex C for the
complete list of mandatory fields and parties). Failure to provide required information shall result
in the rejection of the file.
Supervising Agency
Institution/Branch Code
Report Date
Reporting Institution
Report Type
Format Code
Submission Type
Transaction Parties
Transaction Date/Time
Transaction Code Policy Owner/ Beneficiary Insured Subject of
Transaction Ref. No. Customer Party Type Flag Party Type Flag Suspicion
Policy No./Certificate Party Type Flag Customer Ref. Customer Ref. No. Party Type Flag
No./ OR/Provisional Receipt No. Customer Ref. No. No. Name Flag Customer Ref. No.
Account No./Credit Card Name Flag Name Flag Name Name Flag
Php Amt of Premium/ Name Name Address (Present/ Name
Pymt/Excess/Advance Address (Present/ Address Permanent) Address (Present/
Premium/Top-ups/ Amt. Permanent) (Present/ Account No. Permanent)
of Capital Infusion Permanent) Birth/ Reg. Date Account No.
Birth/ Reg. Date
FX Amount of of Annual Place of Birth/ Account No. Place of Birth/ Birth/ Reg. Date
Premium/Excess/Advanc Birth/ Reg. Date Registration
Registration Place of Birth/
e Premium/Top-ups Place of Birth/ Nationality
Nationality Registration
FX Currency Code Registration ID Type
ID Type Nationality
Nature/Purpose of Nationality ID No.
ID No. ID Type
Transaction Relationship of Tel. No.
Tel. No. ID No.
Policy Effectivity Date Beneficiary to Nature of
Nature of Tel. No.
Maturity /Expiry Date Insured Business/
Business/ Nature of Business
Php Amount of Designation of Employment
Employment / Employment
Dividend/CSV/ Beneficiary Code
Policy Loan
Policy Amount/Face
Value/Contract Trustee Payor/Trustor Transactor
Details of
Value/Sum Insured (Php) Party Type Flag Party Type Flag Party Type Flag Suspicion
Policy Amount/Face Customer Ref. No. Customer Ref. No. Customer Ref. No.
Value/Contract Name Flag Name Flag Name Flag
Value/Sum Insured (FX) Name Name Name
Policy/Insurance/Product Address (Present/ Address (Present/ Address (Present/ Reason
Type Permanent) Permanent) Permanent) Narrative
Terms of Insurance Account No. Account No. Account No.
PART 4: Chapter 1- Covered/Suspicious Transaction Report 1-11
1.4 Electronic Record Format (Format 1.0 – IC)
HEADER RECORD
FIELD NO. FIELD NAME TYPE LENGTH FORMAT VALUE/REMARKS
H-1 Header Record Indicator Text 1 H H - for Header
H-2 Supervising Agency Number 1 9 3 -IC
9(11)/ AMLC Library (for IC-
H-3 Institution Code Number 11/18
(18) supervised)
yyyymmdd; not
greater than current
H-4 Report Date Number 8 9(8)
date; not less than
20011017
H-5 Report Type Text 3 X(3) CTR,STR
H-6 Format Code Number 2 99 1
A- add, E-
H-7 Submission Type Text 1 X(1) edit/correction, D-
delete, T-test
DETAIL RECORD
Transaction Data
FIELD NO. FIELD NAME TYPE LENGTH FORMAT VALUE/REMARKS
D-1 Detail Record Indicator Text 1 D D - for Detail
Transaction Date/ 8/ 9(8)/ YYYYMMDD
*D-2 Number
Transaction Date & Time 14 9(14) YYYYMMDDHHMMSS
AMLC Transaction
D-3 Transaction Code Text 5 X(5)
Codes
must be unique per
D-4 Transaction Reference No. Text 20 X(20)
transaction date
Policy No./Certificate No/
D-5 Text 40 X(40)
OR/Provisional Receipt no.
D-6 Account No./Credit Card No. Text 40 X(40)
Php Amount of Annual
Premium /Excess/Advance
Greater than 0 w/ or
D-7 Premium/Payment/Top- Number 20 9(18).99
w/o decimal value
ups/Amount of Capital
Infusion
FX Amount of Annual
D-8 Premium /Excess/Advance Number 17 9(15).99 Optional
Premium/Top-ups
Optional; mandatory if
D-9 FX Currency Code Text 3 X(3)
FX amount <> null
Nature/Purpose of
D-10 Text 200 X(200)
Transaction
yyyymmdd; date
D-11 Policy Effectivity Date Number 8 9(8) should not be less
than 20011017
yyyymmdd; date
D-12 Maturity Date/Expiry Date Number 8 9(8) should be between
the transaction date
Subject Data
Detail Record–Party details (Multiple)
POLICY OWNER/CUSTOMER
D-O-1 Party Type Flag Text 1 X O – Policy Owner/Customer
D-O-2 Customer Reference Number Text 30 X(30)
Y – if policy owner/customer
Name Flag is a corporation
D-O-3 Text 1 X
N – if policy owner/customer
is an individual
D-O-4 Name Text
Last name of policy
Last Name 100 X(100)
owner/customer
First name of policy
First Name 100 X(100)
owner/customer
Middle name of policy
Middle Name 50 X(50)
owner/customer
D-O-5 Address Text
Room No./Office Name,
Address1 100 X(100) Bldg./House No., Street,
Subd./ Brgy.
Address2 100 X(100) District, Town, City
Address3 100 X(100) Province, Country , ZIP
for corporate accts.- current
date > date and date > 1521 ; for
Birthdate/Registration Date individual accts. - date < current
D-O-6 Number 8 9(8)
date and the difference
between current date and
birthdate must be less than 150
D-O-7 Place of Birth/Registration Text 90 X(90) City, Municipality, Country
D-O-8 Nationality Text 40 X(40)
ID1 – Passport
ID2 – Driver’s License
D-O-9 ID Type Text 4 X(4) ID3 – PRC ID
ID4 – NBI Clearance
ID5 – Police Clearance
TRUSTEE
D-U-1 Party Type Flag Text 1 X U - Trustee
D-U-2 Customer Reference Number Text 30 X(30)
Name Flag Y – if trustee is a corporation
D-U-3 Text 1 X
N – if trustee is an individual
D-U-4 Name Text
Last Name 100 X(100) Last name of trustee
First Name 100 X(100) First name of trustee
Middle Name 50 X(50) Middle name of trustee
D-U-5 Address Text
Room No./Office Name,
Address1 100 X(100) Bldg./House No., Street,
Subd./ Brgy.
TRAILER RECORD
FIELD
FORMAT
NO. FIELD NAME TYPE LENGTH VALUE/REMARKS
T-1 Trailer Record Indicator Text 1 T T - for Trailer
T-2 Php Amount Total Number 20 9(18).99 Total Transaction Amount
Records Total of batch to be
T-3 sent Number 10 9(10) Total number of CTR/STRs
Note: Mandatory fields and parties are on a per transaction basis (Please refer to Annex C for the
complete list of mandatory fields and parties). Failure to provide required information shall result
in the rejection of the file.
* For Column B, the use of the Transaction Date & Time is mandatory for CASA, Time Deposit, Foreign
Exchange and Remittance Transactions; for all other transaction codes, the time of transaction shall be
optional.
2.1 Encrypting of Files (done after CP has created a CSV file – Format1.0)
Select Anti-
Money
Laundering
Council’s public
key, then click
Add.
Select the
Compliance
Officer’s
private key,
then click Sign
& Encrypt.
Click Finish.
Click LOGIN
There are nine (9) options or links available in CP User Main Page:
b. CTR/STR File Upload provides access for the registered CP user to upload the
electronic CTRs and STRs.
c. CTR/STR File Upload History gives the option for the registered CP user to
inquire and view the files uploaded; only files uploaded by the particular CP can be
viewed.
d. Logout will log the CP user out of the system and go back to CP User Login
Page.
e. KYC Docs Upload provides access for the registered CP user to upload KYC
Documents for STRs.
h. STR Attachment Upload gives the option for the registered CP user to
upload a STR attachment, provided that the STR has been uploaded and processed
i. STR Attachment History gives the option for the registered CP user to check
the status of the STR attachment that has been uploaded.
Upon successful
login, Click File
Upload link or
icon
The file upload
window will be
displayed on the
screen.
Click Browse
button to locate
the file to be
uploaded.
Note: Only files with [.csv.gpg] or [.csv.enc] or [.csv.pgp] as extension at the end of the filename will
be accepted for uploading through the FTRF. The filename should follow the file naming convention
123456yyyymmddss of 123456789yyyymmdd where:
After the Upload button is clicked and upon every successful upload, the “Upload Confirmation
Receipt” is displayed.
If a CP user wants to search view files that have been uploaded, click
Note: The Upload Confirmation Receipt does not guarantee that all CTRs/STRs
in the CSV file/s have been uploaded. To check the status of the submission, files
should be viewed in the File Upload History Page.
From the
User Main
Page, click
>FILE
UPLOAD
HISTORY.
To view specific
past date or date
range, click
(calendar icon) to
specify START
DATE and END
DATE.
Click >SEARCH to
start the search.
a. If the transaction count is equal to the number of good transactions, the CP can
save a copy of the confirmation receipt by clicking on the “SAVE REPORT TO FILE”
button, or the “PRINT” button to have a printed copy for filing.
b. If the transaction count is not equal to the number of good transactions, the CP
should select the report file with Bad Transactions and click on the “Download
Validation Message” button. The validation message of the selected uploaded file
will be sent via email. Check the validation message for the details of the error/s
and make the appropriate correction.
To search another date or date range, click> CLEAR button before entering the new search
dates.
The customer reference number (CRN) will be mandatory for the Account
Holder Party or Subject of Suspicion Party, whichever is applicable for the
above mentioned predicate crimes.
Uploading of KYC Documents for a CRN of a subject STR will only be done once,
if a subsequent STR is filed on the same CRN, CPs need not re-upload the
corresponding KYC Documents.
Log-on to https://portal.amlc.gov.ph
A successful log-in will show the Covered Persons’ User Main Page. Click on KYC Docs upload,
to go to the Upload window.
Click Add/New (No STRs filed) button to enable the KYC Docs Upload Facility.
*After the Save button is clicked and upon every successful upload, the “KYC Upload Confirmation
Receipt” is displayed.
Click on Add/New STR (Existing STRs) to enable the Upload of KYC Docs for Existing STRs.
Fill up the mandatory fields and attach KYC documents, then click the Upload button.
To update type in the CRN with a previously filed KYC Documents, then click the Find button.
After the Update/Upload button is clicked and upon every successful update, the “KYC Update
Confirmation Receipt” is displayed.
Please note, that a successfully processed and uploaded STR is required before a
Covered Person can upload an STR attachment.
Click LOGIN
From the
User Main
Page, click
>STR
Attachment
Upload.
A registered CP User can search/view anytime the STR attachment/s uploaded for the
registered CP he is representing. Status of each attachment is indicated in the search result.
From the
User Main
Page, click
>STR
Attachment
History.
Check the result of the STR Attachment, Status should show “Processed”
otherwise, re-upload the attachment.
Rule 10, E.4 paragraph 2 of the 2016 Revised Implementing Rules and Regulations of Republic
Act No. 9160, as amended states that:
“The covered person shall also submit to the AMLC, through the internet, an electronic
detailed return in a format to be prescribed by the latter.”
For uniformity of E-Returns Format, CP user should first download the Electronic Return
Template. This template is an excel worksheet where CPs must encode their E-Returns.
The excel file contains two sheets, 1st sheet is for the main account and the 2nd sheet is for
the related account/s.
1st Sheet is for the Main Account which is the subject of the Freeze Order
Table 1 is for materially linked accounts as defined under Rule 3-Definition of Terms, R.1-5 of
the 2016 Revised Implementing Rules and Regulations of Republic Act No. 9160, as amended
Table 2 should include related accounts wherein Account Holder (Subject of Freeze Order)
is either the Sender or Recipient of funds to/from another account holder
In the Electronic Returns Upload Facility, select between CA-GR AMLC Case and AMLC
Resolution then click Proceed.
If CA-GR AMLC Case is selected, enter the Case Number then click Browse to attach the E-
Return file.
B. A single report format (Format 1.0) applicable to all covered persons shall be adopted
for both CTRs/STRs in which the following MANDATORY fields shall be strictly filled up.
C. The CTR/STR report file has three (3) parts identified by the Record Indicator located at
the first field of every record with values H, D, or T:
1. The Header Record identifies the Covered Person (CP), up to branch level, where the
transaction occurred. A file may have several header records, if the reporting CP has
several transactions from different branches to report;
2. There is one Detail Record for every transaction to report. Since the file may contain
transactions from several branches, each group of Detail Records from one (1) branch
is preceded by a Header Record; and
3. Trailer Record (T) is the last record of the file and contains the total peso amount of
the transactions and the total number of transactions in the file.
D. The CTR/STR may be submitted in four (4) types.
1. The CTR/STR with submission type value “A” refers to a new CTR/STR to be submitted
to AMLC.
2. The CTR/STR with submission type “E” edits or amends the previously submitted,
uploaded and successfully processed CTR/STR with ERRONEOUS VALUE.
Note: The Institution code, Transaction date and reference number of the corrected
transaction must be the same as the original transaction.
3. The CTR/STR with submission type “D” is a request to delete the previously
submitted, uploaded and successfully processed CTR/STR. This shall be followed by
an email request stating the reason for deletion. Email to be sent at
[email protected]
HEADER RECORD
H-1. Header Record Indicator - This is the first field of the electronic record and will
contain “H” to indicate that it is the beginning of the electronic file being sent by
the CP to AMLC.
H-2. Supervising Agency – This field represents the supervising agency (whether BSP
or SEC) of the reporting covered person.
H-3. Institution Code – This refers to the 11-digit code or 18-digit code of the
reporting CP which came from the BSP codes for BSP-supervised CPs or the 11-
digit code for SEC-supervised CPs as assigned by the AMLC.
H-4. Report Date – Date of report in year, month, day format (YYYYMMDD). It should
not be greater than the current date and not less than 20011017.
H-5. Report Type – Identifies whether report is CTR or STR.
H-6. Format Code – This identifies the format of the record.
H-7. Submission Type – Indicates whether the report being submitted is new,
correction of previously submitted report and for deletion.
DETAIL RECORD
D-1. Detail Record Indicator – Contains “D” indicating start of detail record for each
and every transaction belonging to the same date and transaction group defined
in the header record.
D-2. Transaction Date – Date when transaction occurred in year, month, and day
format (YYYYMMDD). Date should not be greater than the current date but not
less than 20011017.
D-3. Transaction Code – Refers to the type of transaction based on AMLC’s table of
codes.
D-4. Transaction Reference No. – Refers to the unique reference number assigned by
the reporting covered person to its individual transaction per transaction date.
D-5. Account No. /PN No. /Client Stock Ref. No. – Refers to the assigned Account
Number of the client or Promissory Note No. for loans, etc. or Client Stock Ref.
No. for securities.
D-6. Old Account No. /PN No. /Client Stock Ref. No. – Refers to the previously
assigned Account Number of the client or Promissory Note No. for loans, time
deposit etc. or Client Stock Ref. No. for securities.
D-O-5. Address of Other Participant – Gives the detailed address of the other
party/person/entity involved in the transaction other than the beneficiary,
counterparty, etc., specifying the Room No./Office Name, building/house no.,
street, Barangay, District, Town, City, Province, Country, and ZIP code.
D-O-6. Account No. of Other Participant - Refers to the account no. of the other
participant being credited/debited.
D-I-1. Party Type Flag - Indicates that the person/corporation is the Issuer (I)
D-I-2. Customer Reference Number - Refers to the CP’s reference number of their
client. This will serve as reference for the static data to be submitted by the
reporting institution.
D-I-3. Name of Issuer Flag - “N” if issuer is an individual, “Y” if issuer is a corporation.
D-S-7. Birthdate of Subject of Suspicion – Date of birth of the subject or the registration
date in case of corporation or partnership. For individual accounts, the
difference between the current date and the birthdate must be less than 150
and should also be less than the current date. For corporate accounts,
registration year must be greater than 1521 but less than the current date.
D-S-8. Place of Birth/Registration of Subject of Suspicion – Birth place of the subject
(City, Municipality, Country).
D-S-9. Nationality of Subject of Suspicion – Nationality of the subject.
TRAILER RECORD
T-1. Trailer Record Indicator - Contains “T” indicating start of trailer record of every
file.
T-2. Total CTR Amount – refers to the total/sum of all peso transaction amounts in
the file.
T-3. Records Total – refers to the number of transactions included in the file.
HEADER RECORD
H-1. Header Record Indicator - This is the first field of the electronic record and will
contain “H” to indicate that it is the beginning of the electronic file being sent by
the CP to AMLC.
H-2. Supervising Agency – This field represents the supervising agency (IC Supervised)
of the reporting covered person.
H-3. Institution Code – This refers to the 11-digit code of the reporting CP which came
from the BSP codes for BSP-supervised CPs or AMLC codes for IC-supervised CPs.
H-4. Report Date – Date of report in year, month, day format (YYYYMMDD). It should
not be greater than the current date and not less than 20011017.
H-5. Report Type – Identifies whether report is CTR or STR.
H-6. Format Code – This identifies the format of the record.
H-7. Submission Type – Indicates whether the report being submitted is new,
correction of previously submitted report and for deletion.
DETAIL RECORD
D-1. Detail Record Indicator – Contains “D” indicating start of detail record for each
and every transaction belonging to the same date and transaction group defined
in the header record.
D-O-2. Customer Reference Number - Refers to the CP’s reference number of their
client. This will serve as reference for the static data to be submitted by the
reporting institution.
D-O-3. Name of Policy Owner Flag - “N” if policy owner is an individual, “Y” if policy
owner is a corporation.
D-O-4. Name of Policy Owner/Customer – Refers to the name of the
person/corporation who owns the insurance policy specifying the last name,
first name, middle name of the individual person or the registered name of the
corporation/partnership.
D-O-5. Address of Policy Owner/Customer – Gives the detailed address of the policy
owner specifying the Room No. /Office Name, building/house no., street,
Barangay, District, Town, City, Province, Country, and ZIP code.
D-O-6. Birthdate/Registration Date – Date of birth of the policy owner if individual or
the registration date in case of corporation or partnership. For individual
accounts, the difference between the current date and the birthdate must be
less than 150 and should also be less than the current date. For corporate
accounts, registration year must be greater than 1521 but less than the current
date.
D-O-7. Place of Birth/Registration – Birth place of the policy owner (City, Municipality,
Country).
D-O-8. Nationality – Nationality of the policy owner.
D-O-9. ID Type – Type of ID presented by the policy owner (SSS, GSIS, Company, etc.).
D-O-10. Identification No. – Identification No. of the policy owner.
D-O-11. Telephone No. – Contact number of the policy owner.
D-O-12. Nature of Business - Specifies the occupation of the policy owner or nature of
the business of the corporation or partnership.
D-I-1. Party Type Flag - Indicates that the person/corporation is the Insured (I).
D-I-2. Customer Reference Number - Refers to the CP’s reference number of their
client. This will serve as reference for the static data to be submitted by the
reporting institution.
D-I-3. Name of Insured Flag - “N” if Insured is an individual, “Y” if Insured is a
corporation.
D-I-4. Name of Insured – refers to the persons or parties who are protected by an
insurance policy giving the last name, first name, middle name of the individual
person or the registered name of the corporation or partnership. Indicates who
directly/indirectly benefited from the transaction.
D-I-5. Address of Insured – Gives the detailed address of the insured if insured name is
given specifying the bldg./ house no., street, Barangay, District, Town, City,
Province, Country, and ZIP code.
D-I-6. Account No. of Insured - Refers to the account no. of the insured to be
credited/debited.
D-U-6. Account No. of Trustee - Refers to the account no. of the trustee.
D-R-1. Party Type Flag - Indicates that the person/corporation is the Payer/ Trustor(R).
D-R-2. Customer Reference Number - Refers to the CP’s reference number of their
client. This will serve as reference for the static data to be submitted by the
reporting institution.
D-R-3. Name of Policy Owner Flag - “N” if Payor/Trust or is an individual, “Y” if
Payer/Trust or is a corporation.
D-R-4. Name of Payor/ Trustor – Identifies the name of the payor/ trustor specifying
the last name, first name, middle name or the registered name of the
corporation or partnership.
D-R-5. Address of Payor/ Trustor - Gives the detailed address of the payor/ trustor
specifying the Room No./Office Name, building/ house no., street, Barangay,
District, Town, City, Province, Country and ZIP code.
D-R-6. Account No. of Payor/ Trustor- Refers to the account no. of the payor/ trustor.
D-T-1. Party Type Flag - Indicates that the person/corporation is the Transactor (T).
D-T-2. Customer Reference Number - Refers to the CP’s reference number of their
client. This will serve as reference for the static data to be submitted by the
reporting institution.
D-T-3. Name of Transctor Flag - “N” if Transactor is an individual, “Y” if Transactor is a
corporation.
D-T-4. Name of Transactor - Identifies the person who made the transaction other than
the insured, beneficiary, trustee, etc., specifying the last name, first name,
middle name of the individual person or the registered name of the corporation
or partnership.
D-T-5. Address of Transactor – Gives the detailed address of the transactor involved in
the transaction other than the insured, beneficiary, trustee, etc., specifying the
Room No./Office Name, building/house no., street, Barangay, District, Town,
City, Province, Country, and ZIP code. The address of the other participant is
divided into 3 fields of 30 characters each (address1, address2, address3).
D-T-6. Account No. of Transactor - Refers to the account no. of the transactor.
TRAILER RECORD
T-1. Trailer Record Indicator - Contains “T” indicating start of trailer record of every
file.
T-2. Total CTR Amount – refers to the total/sum of all Philippine peso transaction
amounts in the file.
T-3. Records Total – refers to the number of transactions included in the file.
Name Flag
A name flag “Y” indicates that the subject is an entity and should use a single
name field.
The name flag “N” indicates that the subject is an individual and should use the
3-field name - last name, first name, and middle name.
For BSP/SEC
Party Flag
The party flag value “A” is for the account holder/client of the reporting
institution.
The party flag “B” is for the beneficiary/recipient of the transaction.
The party flag “C” is for the counterparty/remitter/source of the transaction.
For transactions involving parties other than the accountholder, beneficiary and
counterparty, the party flag “P” for other party shall be used. This may be
applicable for securities transactions with 3rd party brokers.
The party flag “I” refers to the issuer of securities/product/investment
instruments.
The party flag “T” is for the transactor. This is the person executing the
transaction.
The party flag “S” is for the subject of suspicion.
For IC
Party Flag
The party flag value “O” refers to the policy owner.
The party flag “B” refers to the beneficiary/recipient.
The party flag “I” refers to the insured.
The party flag “U” refers to the trustee.
The party flag “R” refers to the payor/ trustor.
The party flag “T” is for the transactor. This is the person executing the
transaction.
The party flag “S” is for the subject of suspicion.
J. The parties in the detail record are not mandatory for all transactions. Attached as Annex
C, is the summary of the required parties per transaction. Failure to provide the
mandatory parties shall cause the rejection of the file.
K. For multiple valued name field, such as &/or account holders’ names, multiple
beneficiaries etc., each name shall be preceded by their corresponding party flags.
Example:
For Joint Accounts:
If Name Flag = N
A,1234,N,DELA CRUZ,JUAN,REYES,123 ABC STREET,MAKATI CITY,MAKATI PHILIPPINES
2000,19700101,MANILA PHILS.,FILIPINO,ID1,XX1234567,7210202,REAL ESTATE,
A,5678,N,DELA CRUZ,MARIA,ALCANTARA,123 ABC STREET,MAKATI CITY,MAKATI
L. The address is divided into address 1 (Room No. /Office Name, building/house no., street,
barangay), address 2 (District, Town, City) and address 3 (Province, Country Code, Zip
Code).
M. For STRs.
2. In cases where in the perpetrator is not identified, CPs shall use the Name Flag Y and
use the term “Unknown” in the Subject of Suspicion Name.
3. The reporting institution shall choose the applicable Reason for Suspicion as
enumerated in Chapter 2 – Data Elements. For reasons other than the specified, the
institution shall use the “SI6” followed by a semi-colon and the reason for suspicion.
Note: Please make sure that the reason for suspicion indicated in SI6 does not fall in
any one of the Suspicious Indicators or Predicate Crimes before using SI6.
Example:
xxx,SI6;suspected boiler room operations, the client was named in one foreign news
article xxx
4. The transaction code “ZSTR” shall be used if the subject is not an accountholder of
the reporting institution or is an accountholder but has no monetary transaction with
the covered person at the time the suspicious activity is determined.
2
Presentation materials on Intelligence Analysis & Intelligence Reports: A Workshop for FIUs held on 11 July
2008.
6. The narrative should contain all the details and events leading to the suspicion
including other information which might be of help or importance to the report, i.e.
where the possible violation took place, related litigations, relation to other
transactions, description of supporting documents, etc.
a. Additional documents may be attached to the STR through the AMLC Portal. An
STR attachment may be any of the recognized file types (.xls,.doc, .docx, .pdf,
.bmp, .jpeg, .jpg , .tiff, .tif).
i. A facility in the AMLC portal allows the submission of this attachment. To
upload an attachment, please make sure that the STR has been uploaded
in the AMLC portal before uploading attachments. Please make sure you
enter the complete eleven (11) or eighteen (18) digit institution code for
the uploaded STRs; if the institution code used is that of the branch please
ensure that you input this in the institution code field, then enter the
transaction date and transaction reference number of the STR where the
file will be attached.
6. Bulk Reporting of STRs allows the reporting of multiple STRs, of at least five (5) STRs.
Bulk reporting involves two (2) types:
a. B1 –transactions included should involve the same suspicious transaction
indicator, and refer to the same accountholder and account number. See
Chapter 1 of the Reporting Procedures Manual, item 1.5 for the format of
reporting.
Note: CPs have the option to file STR on each suspicious transaction or in bulk,
pursuant to the guidelines of B1 and B2.
N. Key fields – the key fields consist of the institution code, transaction date and transaction
reference number. Together, they should be unique at all times. This means that the
transaction reference number should be distinct per transaction date per institution.
O. All amount values must not contain commas or special characters except the decimal
point to indicate centavos, i.e., P550,120.50 should be encoded as 550120.50.
P. Validity of each field values in terms of length and data type must be observed.
Q. The number of commas must be less than one from the required total number of field
values
field1,field2,field3,field4
Total Fields =4
Total Commas =3
Note: field3 should always be followed by a comma whether or not field4 has data
N,Lastname,Firstname,Middlename or
N,Lastname,Firstname,
R. CTR/STR reports should reflect where the transaction occurred, i.e. Head Office or
branch. This is identified by the institution code in the Header record which must be 11
or 18 digits (up to branch level). There may be several detail records less than one (1)
header record to report several transactions of one branch, and there may be several
header records in one (1) file to report transactions of several branches.
For Covered Persons with Different Branches, the CTR/STR Format Structure should be as
follows:
U. File Name convention for CPs with 11-digit institution code- 999999yyyymmddss.csv
where 999999 = first 6 digits of institution code, yyyymmdd = reporting date (year,
month, day the report is sent to AMLC), ss = sequence number from 01-99 representing
number of files transmitted for the day (batch number or number of transmission).
Default sequence no. is 01.
A. The amount indicated in the CTRs or STRs shall include all taxes, or other fees incidental
to the execution of the transaction, except in the following transactions:
Inward remittance, which shall be reported at the amount actually received by the
client, net of taxes or other charges (or net proceeds).
Net proceeds of sale of securities and/or similar instruments by the client.
Time Deposit Pay-out, where in the amount to be reported is the amount actually
credited/ received by the client.
B. The sale of Real and Other Properties Acquired (ROPA) shall be reported at the time of
the execution of the Contract to Sell, or any similar contract, at its total contract price. Any
installment payments and the subsequent execution of a Deed of Absolute Sale and
issuance of a new Transfer Certificate of Title (TCT) to the buyer need not be reported.
E. For CTRs/STRs involving numbered accounts, the covered person is required to use the
real names of the account holders in the submission of CTRs/STRs.
o If a new Account Number was issued upon rollover, this should be reported
as a new placement, indicating the new and the old account number in the
transaction data fields.
o If upon roll-over, the client made an additional placement of more than Php
500,000.00, a CTR should be filed indicating the new amount of placement.
H. The Customer Reference Number (CRN) is an optional field for CTRs and STRs, this will
be used for future static data submission. However, CRN is mandatory for the Account
Holder Party or Subject of Suspicion Party, whichever is applicable for Suspicious
Transaction Reports, wherein reason of Suspicion will fall in any of the following
predicate crimes: 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; and Financing of
Terrorism. CRN will also be used in the uploading of KYC documents.
AMLC exempts the presenting bank from filing an STR relative to its receipt of a spurious
check from a depository bank that has no clearing facilities. This amends Resolution No.
10, Series of 2007 which states that:
In as much as the presenting bank is not privy to the transaction between the depository
bank and its client, it is not required to file an STR relative to the fraudulent issuance of
the spurious check. It is upon the depository bank and the drawee bank to report the
transaction of their respective clients, i.e., the depository and the drawer respectively.
Highlights of STR reporting by banks for spurious checks are as follows: (All other
mandatory fields must have entries including optional fields, if available).
Depository Bank
Account holder/Client - Name of Depositor/Client
Account Number - Account Number of Client/Depositor
Peso Amount - Amount in Check
Beneficiary - Name of Payee in Check
Counterparty - Name of Issuer of Check; if available
Correspondent Bank - Name of Drawee Bank
Drawee Bank
Account holder/Client - Name of Client/Issuer of Check
Account Number - Account Number in Check
When the total amount of the regular annualized premiums for the entire year,
regardless of the mode of payment (monthly, quarterly, semi-annually or annually),
exceeds Php500,000.00, such amount shall be reported as a covered transaction
upon payment of the initial premium, even if the amounts of the amortizations are
less than the threshold amount.
Premiums for the renewal of the insurance policies under the same terms and
conditions need not be reported provided that CTRs are submitted on the initial
premium payment.
For initial payment wherein the Policy Owner have not been issued an Insurance
Policy, any receipt of Payment in excess of Php500,000.00 should be reported using
the transaction code NREC (Receipt of Initial Payment for Insurance Policy).
Once the policy owner has been issued an insurance policy, a CTR should again be
filed using the transaction code pertaining to Purchase of Insurance, wherein
transaction date is the date of issuance of the Insurance Policy.
Reporting of CT/ST shall be on a per order basis (order refers to the executed
instructions given for buying or selling of each issue); settlement transactions need
not be reported.
Ex. Client instructed broker to buy Php 1,000,000 worth of Meralco shares.
Broker bought P300,000 worth of Meralco shares in the morning and P400,000
worth of Meralco shares in the afternoon.
Broker will report the purchase of P700,000 worth of Meralco shares.
For bundled transactions, reporting shall still be on a per done order basis.
For issues with multiple values within the day, the data for the “NET ASSET VALUE”
field shall be averaged.
For block sale, the executing brokers shall be indicated in the counterparty field.
L. Deferred reporting shall be applicable to covered transactions only. The responsibility of
CPs to report suspicious transactions, where applicable, remains. Should there be
further adjustments/modifications in the application thereof; the foregoing policy shall
be prospective.
N. To ensure that only authorized officials will be allowed to send reports to AMLC
electronically, there shall be a registration and continuous data updating of business
units, and their authorized compliance officers.
O. Functional trainings for authorized persons are usually conducted on the last
Wednesday of the month or upon announcement by the AMLCS.
P. Rejected transaction due to invalid codes (transaction, currency and country) should be
sent again using submission type A. Please take note that the reference number of the
original transaction should be used for the resent transaction.
Q. The AMLC Web Services is a facility for CPs to transmit CT/STRs automatically. To avail
of the service, CPs should send an email to the Secretariat ([email protected])
requesting enrolment to the facility. Thereafter, an email shall be sent by the Secretariat
with the attached Registration Form and Web Services specifications.
R. For COs handling multiple CPs under the same company umbrella, a single User Account
may be arranged to be able to log-on and submit CTRs/STRs of the different
subsidiaries/affiliates. To apply for this arrangement, an email request specifying the list
of subsidiaries/affiliates to be grouped should be sent.
S. The advisory icon in the AMLC portal which contains advisories, resolutions and
guidelines shall be the main process of communication with the CPs. The "New
Advisory" icon will flash whenever a new advisory is published, and will continue to do
so until such time the user opens or reads the advisory.
T. Electronic returns for Freeze orders shall be uploaded in the AMLC portal, guidelines
please refer to Chapter 2.6.
U. Updates on the UNSC Designated list (include both the Taliban 1988 Sanctions List and
the Al-Qaida Sanctions List) shall be posted in both the AMLC website and AMLC portal
for reference and guidance.
ANNEXES
SAMPLE CSV File (Format 1.0)
FIELD
NO. FIELD NAME TYPE LENGTH FORMAT VALUE/REMARKS
H-1 Header Record Indicator Text 1 H H - for Header
H-2 Supervising Agency Number 1 9 1 – BSP, 2-SEC
BSP Library (for BSP
supervised)
9(11) / AMLC Library (for SEC-
H-3 Institution Code Number 11/18 (18) supervised)
yyyymmdd; not greater than
current date; not less than
H-4 Report Date Number 8 9(8) 20011017
H-5 Report Type Text 3 X(3) CTR,STR
H-6 Format Code Number 2 99 1
A- add, E- edit/correction, D-
H-7 Submission Type Text 1 X(1) delete, T-test
Note: Header Record consists of seven (7) fields; these 7 fields will be inputted from Columns A-G
FIELD
NO. FIELD NAME TYPE LENGTH FORMAT VALUE/REMARKS
D-1 Detail Record Indicator Text 1 D D - for Detail
yyyymmdd; not greater than
current date; not less than
D-2 Transaction Date Number 8 9(8) 20011017
D-3 Transaction Code Text 5 X(5) AMLC Transaction Codes
must be unique per transaction
D-4 Transaction Reference No. Text 20 X(20) date
Account No./PN No./Client
Text 40 X(40)
D-5 Stock Ref. No./Certificate No.
Old Account No./PN No./Client
D-6 Stock ref. No. Text 40 X(40)
Greater than 0 w/ or w/o decimal
D-7 Transaction Amount (Php) Number 20 9(18).99 value
D-8 to D-17……..
Country Code of Correspondent Country Code (Refer to Systems
Number 3 9(3)
D-18 Bank Code, Chapter 8.3)
Column T, Row 2
Note: Subject Data will immediately follow the details of the transaction data, D-A-1 (Account
Holder Party Flag) should be inputted at Column U, same row as that of the transaction data.
Note: Trailer Record will occupy the last row of the file to be uploaded, there are only three (3)
fields, which will only be inputted from Columns A-C.
Below is a complete CSV file (Format 1), which consists of a Header Record, Detail Record
(Transaction Data and Subject Data) and a Trailer Record.
BSP
SEC
BUY SECURITIES (CTR)
H,1,99999901001,20170330,CTR,1,A
D,20170329,SBYS,REF1,ACCT123,,1000000,,,INVESTMENT,,,,5555,180,,,,,,A,1234,N,DELA
CRUZ,JUAN,REYES,123 ABC STREET,MAKATI CITY,MAKATI PHILIPPINES
2000,19700101,MANILA PHILS.,FILIPINO,ID1,XX1234567,7210202,REAL
ESTATE,I,,Y,MERALCO,,,
T,1000000,1
H,1,99999901001,20170330,STR,1,A
D,20170329,SSLS,REF1,ACCT123,,1000000,,,INVESTMENT,,,,5555,180,,,,,,A,1234,N,DELA
CRUZ,JUAN,REYES,123 ABC STREET,MAKATI CITY,MAKATI PHILIPPINES
2000,19700101,MANILA PHILS.,FILIPINO,ID1,XX1234567,7210202,REAL ESTATE,I,,Y,SAN
MIGUEL,,,S,5678,N,DELA CRUZ,MARIA,ALCANTARA,123 SAMPLE STREET,MALATE,MANILA
PHILIPPINES 2000, ,19720203,MANILA PHILS.,FILIPINO,ID1,XX7654321,7280202,,
PC33,CLIENT WAS ALLEGEDLY INVOLVED IN MARKET MANUPULATION XXX.
T,1000000,1
IC
POLICY LOAN AVAILMENT
H,3,99999901001,20170330,CTR,1,A
D,20170329,NPLN,REF1,POLICY123,,2500,,,LOAN,20130321,20140321,600000,,,,,,,,O,1234,N
,DELA CRUZ,JUAN,REYES,123 ABC STREET,MAKATI CITY,MAKATI PHILIPPINES
2000,19700101,MANILA PHILS.,FILIPINO,ID1,XX1234567,7210202,REAL
ESTATE,I,1234,N,DELA CRUZ,JUAN,REYES,123 ABC STREET,MAKATI CITY,MAKATI
PHILIPPINES 2000,POLICY123,19700101,MANILA
PHILS.,FILIPINO,ID1,XX1234567,7210202,REAL ESTATE,B,1234,N,DELA
CRUZ,JUANA,SANTOS,123 ABC STREET,MAKATI CITY,MAKATI PHILIPPINES
2000,POLICY123,19990101,MANILA PHILS.,FILIPINO,CHILD,Y,MBA
T,1000000,1
B1,A,20170330,1234561,882165,TORRES,ALVIN,A.,8 TIMES
ST.,QC,MM,19800402,MANDALUYONG CITY,FILIPINO,ID 1,908933,CAR DEALER,SI1,EVENTS
LEADING TO THE SUSPICION
12345600000,20170327,CDEPC,REF1,50000
12345600000,20170327,CPMD,REF2,501000,,,,,,,,B,MERIN,JOSHUA,CATAIN,
12345600000,20170328,CWDLO,REF3,100000
12345601001,20170328,CTRIA,REF4,400000,,,,,,,,A,SANTIAGO,ARLENE,JOSE,
12345601002,20170329,CDEPC,REF5,60000
First column of each STR is the party type of the name indicated in Row 1
BULK 2 (B2)
B2,A,20170330,SI1,NARRATIVE
12345600000,20170327,CECCW,REF1,787945,10000,,,TORRES,ALVIN,AGNO,23 ERMITA
ST,MALATE, MANILA,19800318
12345600000,20170327,KCCPA,REF2,3125123458687589,8000,,,SANTIAGO,ARLENE,JOSE,20
JIMENEZ ST.,LUBANG,OCCIDENTAL MINDORO 5109,19791213
12345600000,20170328,CWDLA,REF3,45686,10000,,,BENSON,CONRAD,DANTE,POBLACION
MONTEVISTA,COMPOSTELA,DAVAO 8803,19790201
12345601001,20170328,KCCPA,REF4,5468564812357896,15000,,,CO,ALEXANDER,CRUZ,PO
BLACION OCAMPO,NABUNTURAN,DAVAO 8800,19780914
12345601002,20170329,KCCPA,REF5,7589325475683214,25600,,,VASQUEZ,RONALDO,
CANLAS,10 AGONCILLO ST.,LUBANG,OCCIDENTAL MINDORO 5109,19750512
First column of each STR is the institution code where the transaction occurred
Purchase of Traditional
N NPTLC Life Insurance Policy - Purchase of traditional life insurance policy in cash
CASH
Purchase of Traditional Purchase of traditional life insurance policy by
N NPTLD Life Insurance Policy- debiting plan holder’s bank account/redemption of
Debit Memo investment/policy
Purchase of Traditional
Purchase of traditional life insurance policy through
N NPTLM Life Insurance Policy -
manager's check/cashier's check/other checks
MC/CC/OC
Purchase of Traditional Purchase of traditional life insurance policy using two
N NPTLP Life Insurance Policy - or more pay types (cash, checks, credit card, debit
Mixed Payments from account, wire)
Purchase of Traditional
Purchase of traditional life insurance policy using
N NPTLR Life Insurance Policy -
credit card
Credit Card payment
Purchase of Traditional Purchase of traditional life insurance policy using
N NPTLS Life Insurance Policy - other sources (dividends from other policy, benefits,
Other source etc.)
Purchase of Traditional
Purchase of traditional life insurance policy through
N NPTLT Life Insurance Policy –
Payment Channels
Payment Channels
Purchase of Traditional
Purchase of traditional life insurance policy via wire
N NPTLW Life Insurance Policy -
or fund transfers
Wire/Fund Transfers
Payment of benefits or claims as provided under the
N NPYBC Pay Benefits/Claims
insurance policy or pre-need plan.
Pay cash surrender value - the amount due the
Pay Cash Surrender Value assured/plan holder, net of outstanding policy loans
N NPYCV
(CSV)/Equity Value and interest thereon, upon the surrender of the policy
before its maturity date
Withdrawal of dividend earned on the insurance
N NPYDV Pay Dividends
policy or pre-need plan
Receipt of provisional payment of sourced insurance
Receipt of Provisional
N NREC policy, wherein the actual policy has not been issued
Insurance Payment
since underwriting is still ongoing.
Reinsurance transaction is an agreement between a
ceding company and one or more reinsurers whereby
the ceding company agree to cede, and the reinsurer
N NREIT Reinsurance Transaction
agree to accept the reinsurance of all the risks written
by the ceding company which falls within the terms
subject to the limits specified therein.
Refund of excess premium payment shall cover over
Refund of Premium payment of premiums for traditional policies and
N NRPPY
Payment refund of top-ups or excess premiums for variable or
unit-link policies.
Buy – Precious
O OBPSM Purchase of Precious Stones/Metals
Stones/Metals
GROUP LEGEND:
C -Current Acct./Savings Acct.; D - Time Deposit; F - Foreign Exchange; I - Trade; K - Credit Cards; L - Loans;
N - Insurance; R - Remittance; S - Securities; T - Treasury; U - Trust/Investment Mgmt. Acct./Custodianship;
O – Others (Dealers Precious Stones and Metals/DNFBs etc.)
MANDATORY PARTY
STOCK OR REF. NO.
(D-D-2) NARRATIVE
(D-8) FX AMOUNT
(D-D-1) REASON
(D-9) FX CODE
NUMBER
BSP/SEC
TRANSACTION TITLE
CA/SA
CBPDK Bills Purchase/Discounting - OC X X X X A
CBPDM Bills Purchase/Discounting - MC/CC X X X X A
CBPRC Bills Purchase/Discounting - Cash X X X X A
Bills Purchase/Discounting - Credit
CBPRK
Memo X X X X A
CBPYC Bills Payment - Cash X X X A,B
CBPYD Bills Payment - Debit Memo X X X X A,B
CBPYM Bills Payment - MC/CC/OC X X X A,B
CCBCE Clean Bills for Collection (Export) X X X X A
CCBI Credit Bills - Import X X X X A
CCKCL Check Clearing X X X X A
CCMC Cancelled/Stale MC/CC/DD/TC X X X X A,B
CCOL Collection X X X X A
CCUTD
Check Cutting Services – Debit from X X X X A
Account
CDEBP Payroll Account - Debit X X X X A
CDEPC Deposit - Cash X X X X A
CDEPK Deposit - Check X X X X A
CDEPS Salaries/Pension- Credit X X X X A
CECCL Electronic Cash Card - Loading X X X X A
CECCP Electronic Cash Card - Purchase X X X X A
CECCW Electronic Cash Card - Withdrawal X X X X A
CENC Encashment X X X X A
COCKD On-Us Check Deposit X X X X A,C
CPCC Prepaid Card reversal X X X X A
CPCL Prepaid Card Loading X X X X A
CPCP Prepaid Card Purchase X X X X A
CPDOB Deposit – through other local bank X X X X X X A
CPMC Purchase of MC/CC/DD/TC - Cash X X X X A,B
Purchase of MC/CC/DD/TC - Debit
CPMD
Memo X X X X A,B
MANDATORY PARTY
STOCK OR REF. NO.
(D-D-2) NARRATIVE
(D-8) FX AMOUNT
(D-D-1) REASON
(D-9) FX CODE
NUMBER
BSP/SEC
MANDATORY PARTY
STOCK OR REF. NO.
(D-D-2) NARRATIVE
(D-8) FX AMOUNT
(D-D-1) REASON
(D-9) FX CODE
NUMBER
BSP/SEC
MANDATORY PARTY
STOCK OR REF. NO.
(D-D-2) NARRATIVE
(D-8) FX AMOUNT
(D-D-1) REASON
(D-9) FX CODE
NUMBER
BSP/SEC
MANDATORY PARTY
STOCK OR REF. NO.
(D-D-2) NARRATIVE
(D-8) FX AMOUNT
(D-D-1) REASON
(D-9) FX CODE
NUMBER
BSP/SEC
LOANS
Disposition of bank assets and ROPA
LADRD through donation X X X A
Cancellation of Contract to Sell of
LARCC
ROPA X X X A
LAREC Execution of the CTS of ROPA X X X A
LARF Foreclosed/Acquired Asset/ROPA X X X X A
LARLP Lease Payment on Asset and ROPA X X X A
Refund of Lease Payment on Asset
LARRL
and ROPA X X X A
Refund of Sale Payment on Asset and
LARRS
ROPA X X X A
LARSP Sale Payment of Asset & ROPA X X X A
Interbank Borrowing
LIBB (Regular/Foreign Currency
Denominated Unit) X X X X A
Interbank Lending (Regular/Foreign
LIBL
Currency Denominated Unit) X X X X A
Lease Contract Agreement
LLCAC
Cancellation X X X X A
LLCAG Lease Contract Agreement X X X X A
LLCAN Loan Cancellation X X X X A
Loan Availment (Regular/Foreign
LLNAC
Currency Denominated Unit) – Cash X X X X A
Loan Availment (Regular/Foreign
LLNAK Currency Denominated Unit) - Credit
Memo X X X X A
Loan Availment (Regular/Foreign
LLNAM Currency Denominated Unit) -
MC/CC/OC X X X X A
Loan Availment (Regular/Foreign
LLNAP Currency Denominated Unit) - Mixed
Payment X X X X A
Loan Availment (Regular/Foreign
LLNAW
Currency Denominated Unit) – Wire X X X X A
Loan Payment (Regular/Foreign
LLPRC
Currency Denominated Unit) – Cash X X X X A
Loan Payment (Regular/Foreign
LLPRD Currency Denominated Unit) - Debit
Memo X X X X A
MANDATORY PARTY
STOCK OR REF. NO.
(D-D-2) NARRATIVE
(D-8) FX AMOUNT
(D-D-1) REASON
(D-9) FX CODE
NUMBER
BSP/SEC
MANDATORY PARTY
STOCK OR REF. NO.
(D-D-2) NARRATIVE
(D-8) FX AMOUNT
(D-D-1) REASON
(D-9) FX CODE
NUMBER
BSP/SEC
MANDATORY PARTY
STOCK OR REF. NO.
(D-D-2) NARRATIVE
(D-8) FX AMOUNT
(D-D-1) REASON
(D-9) FX CODE
NUMBER
BSP/SEC
MANDATORY PARTY
STOCK OR REF. NO.
(D-D-2) NARRATIVE
(D-8) FX AMOUNT
(D-D-1) REASON
(D-9) FX CODE
NUMBER
BSP/SEC
MANDATORY PARTY
STOCK OR REF. NO.
(D-D-2) NARRATIVE
(D-8) FX AMOUNT
(D-D-1) REASON
(D-9) FX CODE
NUMBER
BSP/SEC
MANDATORY PARTY
STOCK OR REF. NO.
(D-D-2) NARRATIVE
(D-8) FX AMOUNT
(D-D-1) REASON
(D-9) FX CODE
NUMBER
BSP/SEC
MANDATORY PARTY
STOCK OR REF. NO.
(D-D-2) NARRATIVE
(D-8) FX AMOUNT
(D-D-1) REASON
(D-9) FX CODE
NUMBER
BSP/SEC
MANDATORY PARTY
STOCK OR REF. NO.
(D-D-2) NARRATIVE
(D-8) FX AMOUNT
(D-D-1) REASON
(D-9) FX CODE
NUMBER
BSP/SEC
MANDATORY PARTY
STOCK OR REF. NO.
(D-D-2) NARRATIVE
(D-8) FX AMOUNT
(D-D-1) REASON
(D-9) FX CODE
NUMBER
BSP/SEC
MANDATORY PARTY
STOCK OR REF. NO.
(D-D-2) NARRATIVE
(D-8) FX AMOUNT
(D-D-1) REASON
(D-9) FX CODE
NUMBER
BSP/SEC
MANDATORY PARTY
STOCK OR REF. NO.
(D-D-2) NARRATIVE
(D-8) FX AMOUNT
(D-D-1) REASON
(D-9) FX CODE
NUMBER
BSP/SEC
MANDATORY PARTY
STOCK OR REF. NO.
(D-D-2) NARRATIVE
(D-8) FX AMOUNT
(D-D-1) REASON
(D-9) FX CODE
NUMBER
BSP/SEC
MANDATORY PARTY
STOCK OR REF. NO.
(D-D-2) NARRATIVE
(D-8) FX AMOUNT
(D-D-1) REASON
(D-9) FX CODE
NUMBER
BSP/SEC
MANDATORY PARTY
STOCK OR REF. NO.
(D-D-2) NARRATIVE
(D-8) FX AMOUNT
(D-D-1) REASON
(D-9) FX CODE
NUMBER
BSP/SEC
Fiduciary-Custodianship withdrawal -
UFCWK
credit memo X X X X A
Fiduciary-Custodianship withdrawal -
UFCWM
MC/CC/OC X X X X A
Fiduciary-Custodianship withdrawal -
UFCWW
Wire X X X X A
UFEPC Fiduciary-Escrow placement - cash X X X X A
Fiduciary-Escrow placement - debit
UFEPD
memo X X X X A
Fiduciary-Escrow placement -
UFEPM
MC/CC/OC X X X X A
UFEPW Fiduciary-Escrow placement - wire X X X X A
UFEWC Fiduciary-Escrow withdrawal - cash X X X X A
Fiduciary-Escrow withdrawal - credit
UFEWK
memo X X X X A
Fiduciary-Escrow withdrawal -
UFEWM
MC/CC/OC X X X X A
UFEWW Fiduciary-Escrow withdrawal - Wire X X X X A
Fiduciary-Guardianship placement -
UFGPC
cash X X X X A
Fiduciary-Guardianship placement -
UFGPD
debit memo X X X X A
Fiduciary-Guardianship placement -
UFGPM
MC/CC/OC X X X X A
Fiduciary-Guardianship placement -
UFGPW
wire X X X X A
Fiduciary-Guardianship withdrawal -
UFGWC
cash X X X X A
Fiduciary-Guardianship withdrawal -
UFGWK
credit memo X X X X A
Fiduciary-Guardianship withdrawal -
UFGWM
MC/CC/OC X X X X A
Fiduciary-Guardianship withdrawal -
UFGWW
wire X X X X A
Fiduciary-Life Insurance Trust
UFLPC
placement - cash X X X X A
Fiduciary-Life Insurance Trust
UFLPD
placement - debit memo X X X X A
Fiduciary-Life Insurance Trust
UFLPM
placement - MC/CC/OC X X X X A
Fiduciary-Life Insurance Trust
UFLPW
placement - wire X X X X A
MANDATORY PARTY
STOCK OR REF. NO.
(D-D-2) NARRATIVE
(D-8) FX AMOUNT
(D-D-1) REASON
(D-9) FX CODE
NUMBER
BSP/SEC
MANDATORY PARTY
STOCK OR REF. NO.
(D-D-2) NARRATIVE
(D-8) FX AMOUNT
(D-D-1) REASON
(D-9) FX CODE
NUMBER
BSP/SEC
MANDATORY PARTY
STOCK OR REF. NO.
(D-D-2) NARRATIVE
(D-8) FX AMOUNT
(D-D-1) REASON
(D-9) FX CODE
NUMBER
BSP/SEC
MANDATORY PARTY
STOCK OR REF. NO.
(D-D-2) NARRATIVE
(D-8) FX AMOUNT
(D-D-1) REASON
(D-9) FX CODE
NUMBER
BSP/SEC
PARTIES
A – Account Holder
B – Beneficiary/Recipient
C – Counter Party
I – Issuer of Product
S – Subject of Suspicion
P – Other Participant
T – Transactor
MANDATORY PARTY
(D-D-2) NARRATIVE
(D-D-1) REASON
ACCOUNT NO.
(D-9) FX CODE
IC
REVISED
TRANSACTION TITLE
CODE
NADV Advance Premium Payment X X X X X X X X X O,B
NCAPC Capital Infusion - Cash X X X O
NCAPM Capital Infusion - MC/CC/OC X X X O
NCAPW Capital Infusion - Wire X X X O
NCAPD Capital Infusion - Debit X X X O
NCLTR Cancel Reinsurance Transaction X X X X X X X X X O,B
NFFWV Full Fund withdrawal X X X X X X X X X O,B
NLOIP
Other Loans - insurance/pre- O,B
need X X X X X X X X X
NPFWV Partial fund withdrawal X X X X X X X X X O,B
NPLCA
Cancellation of Insurance O,B
Application X X X X X X X X X X
Cancellation of policy or plan by O,B
NPLCR
company thru rescission X X X X X X X X X X
NPLCV Voluntary Cancellation X X X X X X X X X X O,B
Purchase of Life with
NPLIC Investment Insurance Policy- X X X X X X X X X O,I,B
CASH
Purchase of Life with
NPLID Investment Insurance Policy - X X X X X X X X X X O,I,B
Debit Memo
Purchase of Life with
NPLIM Investment Insurance Policy - X X X X X X X X X O,I,B
MC/CC/OC
Purchase of Life with
NPLIP Investment Insurance Policy - X X X X X X X X X O,I,B
Mixed Payments
Purchase of Life with
NPLIR Investment Insurance Policy - X X X X X X X X X X O,I,B
Credit Card payment
Purchase of Life with
NPLIS Investment Insurance Policy - X X X X X X X X X O,I,B
Other source
MANDATORY PARTY
(D-D-2) NARRATIVE
(D-D-1) REASON
ACCOUNT NO.
(D-9) FX CODE
IC
MANDATORY PARTY
(D-D-2) NARRATIVE
(D-D-1) REASON
ACCOUNT NO.
(D-9) FX CODE
IC
MANDATORY PARTY
(D-D-2) NARRATIVE
(D-D-1) REASON
ACCOUNT NO.
(D-9) FX CODE
IC
PARTIES
O – Policy Owner/Holder
I – Insured
U – Trustee
B – Beneficiary
R – Payor/Trustor
S – Subject of Suspicion
T – Transactor
B. Cross Border investment fraud involving boiler room operations, recovery room, and
advance fee fraud4
1. Accountholders or clients are individuals or entities, which have just been registered
with SEC or DTI. There may be a common signatory for the accounts opened.
Normally, the signatory is not an incorporator. In some instances, the individuals
opening the account present themselves as owners of a domestic company, branch
head or consultant of a foreign entity.
2. Transactions in the domestic account are mostly inward remittances which are
immediately withdrawn in cash or by check issuances to different individuals. Said
transactions may also be “wire transferred” to another account in the Philippines or
overseas, leaving the account with minimal balance.
3. The remitters are located largely in the United States of America, United Kingdom,
Canada, Germany, Singapore, Hong Kong and Indonesia.
a. Remitters may be individuals, who are most likely victims of cross border
investment fraud. This may be considered as the placement stage of money
laundering.
3
http://www.austrac.gov.au/sa-brief-peps-indicators
4
http://www.amlc.gov.ph/images/NewsAnnouncements/crossborderinvestmentfraud.pdf
PART 4: Annex D – EXAMPLES OF ALERTS/RED FLAGS/SUSPICIOUS INDICATORS D-1
5. The accounts are usually active for a period of one (1) year. Entities operate within a
limited period to avoid detection. Thereafter, a new company with a similar nature
of business will emerge.
8. Sudden closure of bank accounts after being a subject of an adverse media expose.
E. Usage of transit accounts (mule accounts) with large, rapid movement of funds5
1. Funds were actively transferred in and out of the account on the same day or within
a short period of time with no absolute reason.
2. Immediate withdrawals upon receiving large amount of funds.
5
APG Yearly Typologies Report 2016, page 19.
6
APG Yearly Typologies Report 2016, page 19.
PART 4: Annex D – EXAMPLES OF ALERTS/RED FLAGS/SUSPICIOUS INDICATORS D-2
3. Large number of transactions conducted near border towns, ports and high risk
areas where smuggling activities are rampant.
4. Large amounts of funds transferred into unverified third parties accounts located
overseas on a frequent basis.
G. Terrorist Financing7
1. Entities
Details match those on sanctions lists
Small broker/intermediary; activity does not match business profile
Commercial entity acts as money-remittance business
2. Goods: Dual-use or proliferation-sensitive
3. Cash: Used for industrial transactions
4. Consignee: Freight-forwarding company or bank
5. Documents: False or altered (shipping, license, end-user certificate); innocuous
descriptions of goods or materials
6. Suspicious Indicators/Circumstances for Terrorist Financing under Rule 3.a.15 of the
IRRs of the TF Suppression Act.
Remittance in structured amounts to high-risk location for terrorism.
7
Items A-E, taken from the Training Materials on Countering the Financing of Terrorism and Proliferation of
Weapons of Mass Destruction through Effective Asset Freezing held on 18-19 October 2017 in Manila,
Philippines.
8
ADB’s Handbook on Anti-Money Laundering and Combating the financing of Terrorism for Nonbank
Financial Institutions.
PART 4: Annex D – EXAMPLES OF ALERTS/RED FLAGS/SUSPICIOUS INDICATORS D-3
Where relevant, money presented in unusual condition, for example, damp, odorous,
or coated with substance.
Where relevant, nervous or uncooperative behavior exhibited by employees and/or
customers.
Customer shows uncommon curiosity about internal systems, controls, and policies.
Customer has only vague knowledge of the amount of a deposit.
Customer presents confusing details about the transaction or knows few details about
its purpose.
Customer appears to informally record large-volume transactions, using unconventional
bookkeeping methods or “off-the-record” books.
Customer over-justifies or -explains the transaction.
Customer is secretive and reluctant to meet in person.
Customer is nervous, not in keeping with the transaction.
Customer is involved in transactions that are suspicious but seems blind to being
involved in money-laundering activities.
Customer’s home or business telephone number has been disconnected, or there is no
such number when an attempt is made to contact the customer shortly after opening
the account.
Normal attempts to verify the background of a new or prospective customer are
difficult.
Customer appears to be acting on behalf of a third party but does not inform the credit
institution staff.
Customer is involved in activity(ies) out of keeping for that individual or business.
Customer insists that a transaction be done quickly.
Inconsistencies appear in the customer’s presentation of the transaction.
Transaction does not appear to make sense or is out of keeping with usual or expected
activity for the customer.
Customer appears to have recently established a series of new relationships with
different financial entities.
Customer attempts to develop close rapport with the staff.
Customer uses aliases and a variety of similar but different addresses.
Customer spells his or her name differently from one transaction to another.
Customer uses a post office box or general delivery address, or other type of mail drop
address, instead of a street address when this is not the norm for the area concerned.
Customer provides false information or information that the staff of the bank or the
financial institution believe is unreliable.
Customer offers money, gratuities, or unusual favors to the credit institution staff for
the provision of services that may appear unusual or suspicious.
Customer pays for services or products via financial instruments, such as money orders
or traveler’s checks, without relevant entries on the instrument or with unusual
symbols, stamps, or notes.
The bank or the financial institution is aware that a customer is the subject of a money
laundering or terrorist financing investigation.
The bank or the financial institution is aware, or becomes aware, from a reliable source
(that can include media or other open sources) that a customer is suspected of being
involved in illegal activity(ies).
A new or prospective customer is known as having a questionable legal reputation or
criminal background.
Transaction involves a suspected shell entity (i.e., a corporation that has no assets,
operations, or other reasons to exist).
C. Identity Documents
D. Cash Transactions
Customer starts conducting frequent cash transactions in large amounts when this has
not been a normal activity for the customer in the past.
Customer frequently exchanges small bills for large ones.
Customer uses notes in denominations that are unusual for the customer, when the
normal practice in that business is different.
Customer presents notes that are packed or wrapped in a way that is uncommon for
the customer.
Customer deposits musty or extremely dirty bills.
Customer consistently makes cash transactions that are significantly below the
reporting threshold amount in an apparent attempt to avoid triggering the identification
and reporting requirements.
E. Economic Purpose
Opening accounts when the customer’s address is outside the local service area.
Opening accounts in other people’s names.
Opening accounts with names very close to other established business entities.
Attempting to open or operate accounts under a false name.
Account with a large number of small cash deposits and a small number of large cash
withdrawals.
Funds are being deposited into several accounts, consolidated into one, and transferred
outside the country.
Customer frequently uses many deposit locations outside of the home branch location.
Multiple transactions are carried out on the same day at the same branch but with an
apparent attempt to use different tellers.
Activity far exceeds activity projected at the time of opening of the account.
Establishment of multiple accounts, some of which appear to remain dormant for
extended periods.
Customer and other parties to the transaction have no apparent ties to the country.
Transaction crosses many international lines.
Use of a credit card issued by a foreign bank that does not operate domestically by a
customer who does not live and work in the country of issue.
Cash volumes and international remittances in excess of average income for migrant
worker customers.
Transactions involving high volume international transfers to third-party accounts in
countries that are not usual remittance corridors.
Transaction involves a country known for highly secretive banking and corporate law(s).
Foreign currency exchanges that are associated with subsequent wire transfers to
locations of concern, such as countries known or suspected to facilitate money-
laundering activities.
Deposits followed within a short time by wire transfer of funds to or through locations
of concern, such as countries known or suspected to facilitate money-laundering
activities.
Transaction involves a country where illicit drug production or exporting may be
prevalent, or where there is no effective anti-money laundering system.
Transaction involves a country known or suspected to facilitate money-laundering
activities.
I. Personal Transactions
Customer appears to have accounts with several financial institutions in one geographic
area.
Customer has no employment history but makes frequent, large transactions or
maintains a large account balance.
The flow of income through the account does not match what was expected based on
the stated occupation of the account holder or the intended use of the account.
Customer makes one or more cash deposits to the general account of a foreign
correspondent bank (i.e., pass-through account).
Customer makes frequent or large payments through online payment services.
Customer runs large positive credit card balances.
Customer uses cash advances from a credit card account to purchase money orders or
drafts or to wire funds to foreign destinations.
Customer takes cash advance to deposit into savings or checking account.
Large cash payments for outstanding credit card balances.
Customer makes credit card overpayment and then requests a cash advance. Customer
visits the safety deposit box area immediately before making cash deposits.
Customer wishes to have credit and debit cards sent to international or to domestic
destinations other than his or her address.
Customer has numerous accounts and deposits cash into each of them with the total
credits being a large amount.
Customer deposits large endorsed checks in the name of a third party.
Customer frequently makes deposits to the account of another individual who is not an
employee or family member.
Customer frequently exchanges currencies.
Customer frequently makes automatic banking machine deposits just below the
reporting threshold.
Customer’s access of the safety deposit facilities increases substantially or is unusual in
light of their past usage.
Many unrelated individuals make payments to one account without any rational
explanation.
Third parties make cash payments or deposit checks to a customer’s credit card.
Customer gives power of attorney to a nonrelative to conduct large transactions.
Customer has frequent deposits identified as proceeds of asset sales, but the assets
cannot be substantiated.
Customer acquires significant assets and liquidates them quickly with no explanation.
Customer acquires significant assets and encumbers them with security interests that
do not make economic sense.
Customer requests movement of funds that are uneconomical.
High volume of wire transfers are made or received through the account.
Some businesses may be susceptible to the mixing of illicit funds with legitimate income.
This is a very common method of money laundering. These businesses include those that
conduct a significant part of their business in cash, such as restaurants, bars, parking lots,
convenience stores, and vending machine companies. On opening accounts with the
various businesses in its area, a financial institution would likely be aware of those that are
mainly cash based.
O. Securities Firm
Accounts that have been inactive suddenly receive large deposits that are inconsistent
with the normal investment practice of the client or their financial ability.
Any dealing with a third party when the identity of the beneficiary or counterparty is
undisclosed.
Client attempts to purchase investments with cash.
Client wishes to purchase a number of investments with money orders, traveler’s
checks, cashier’s checks, bank drafts, or other bank instruments, where the transaction
is inconsistent with the normal investment practice of the client or their financial ability.
Client uses securities or futures brokerage firm as a place to hold funds that are not
being used in trading of securities or futures for an extended period of time, and such
activity is inconsistent with the normal investment practice of the client or their financial
ability.
Client wishes monies received through the sale of shares to be deposited into a bank
account rather than a trading or brokerage account, which is inconsistent with the
normal practice of the client.
Client frequently makes large investments in stocks, bonds, investment trusts, or other
securities in cash or by check within a short time period, inconsistent with the normal
practice of the client.
PART 4: Annex D – EXAMPLES OF ALERTS/RED FLAGS/SUSPICIOUS INDICATORS D-13
Client makes large or unusual settlements of securities in cash.
The entry of matching buying and selling of particular securities or futures contracts
(called match trading), creating the illusion of trading.
Transfers of funds or securities between accounts not known to be related to the client.
Several clients open accounts within a short period of time to trade the same stock.
Unrelated clients redirect funds toward the same account.
Trades conducted by entities that you know have been named or sanctioned by
regulators in the past for irregular or inappropriate trading activity(ies).
Client is willing to deposit or invest at rates that are not advantageous or competitive.
Client attempts to purchase investments with instruments in the name of a third party.
Third-party purchases of shares in other names (i.e., nominee accounts).
Transactions in which clients make settlements with checks drawn by third parties or
remittances from third parties.
Proposed transactions are to be funded by international wire payments, particularly if
from countries where there is no effective anti-money laundering system.
The scheme involves the use of call centers operating in the Philippines for large-
scale investment fraud with operations in Country X and the Philippines under
various names, such as Birthright Brokers, AA Financial Group Incorporated and LB
Corporation (collectively referred to as “Birthright”).
Sales calls were made to elderly victims residing in Country X to sell fraudulent
certificates of deposits (CDs) and describe these CDs as investment vehicles insured
by the government of Country X. Victims are convinced to invest in the CDs and make
payments through the issuance of personal checks. Thereafter, the victims receive
fraudulent monthly account statements concerning their investments by mail. None
of the funds invested nor any of the promised interests have ever been returned or
paid to the victims.
The operators of the call centers allegedly used false names and business addresses
in brochures, business cards and marketing materials sent to the victims. The
operators also disguised their true location and names when making telephone calls
to the victims by using “Enchanted Drive” devices. These devices are plugged into a
USB port of a personal computer enabling the user to place calls over the internet.
The devices are assigned a specific area code and telephone number in Country X
which will always be displayed as the calling number to the person receiving the
phone call, no matter where the “Enchanted Drive” device and the caller are actually
located. According to investigation, the “Enchanted Drive” devices used in this
particular scam were assigned area codes corresponding to major cities in Country X
but the logs of the “Internet Protocol” (IP) addresses used by the said devices showed
that the calls were actually made from the Philippines.
After the victims had been convinced to invest in the fraudulent CDs, they were
advised to write a personal check in the amount of the investment, and Birthright
would arrange for a courier to retrieve the checks at the victims’ residences. These
checks were then sent to four (4) separate “virtual offices” and subsequently
forwarded to an address in Muntinlupa City, Philippines.
It was noted that sometime in December 2011, Birthright opened a new front
company known as “AA Financial Group Incorporated” with a new virtual office in
Country X to receive the victims’ checks. All mails for AA Financial Group
Incorporated were forwarded to an address in Biñan, Laguna, Philippines.
Based on the examination of the victims’ cancelled checks, prior to September 2011,
the vast majority of the funds collected by Birthright under the front company name
“Birthright Brokers” were deposited into an account in Universal Bank A in the
Philippines.
It was also revealed that between approximately September 2011 and January 2012,
cancelled checks issued by the victims to AA Financial Group Incorporated, totaling
approximately US$615,000.00, were deposited into two (2) accounts in Universal
Bank B in the Philippines.
C. Insurance Policy
A case involving life insurance, tax fraud and suspected undeclared gifts. In year N–
3, Ms Y took out a life insurance policy with an initial payment of €30,000
(~USD34,000). Additional payments of €60,000 (~USD68,000) were made in year N–
2 and N–1, and €50,000 (~USD56,500) was paid in year N. The following year, Ms Y
fully redeemed the policy. She stated that she needed money for a real estate
purchase. Additional enquiries and requests for documentation by the insurance firm
revealed that the payments had not been made by Ms Y but rather by her parents.
Actions such as these may be used to circumvent gift taxes. 9
Case of casino gambling debt payment used to conceal laundering of proceeds from
drug trafficking. In 2013, operatives of the jurisdiction X’s National Police arrested
person AC and five other individuals in the Philippines and confiscated/seized
433.236 kilograms methamphetamine hydrochloride estimated to be worth USD43.3
million. In October 2013, the AMLC (Philippines FIU) received a letter requesting a
financial investigation on the arrested persons together with a list of bank accounts
that were allegedly used in the drug transactions of the group.
A STR was also filed by Universal Bank against one of the accounts of person AC. The
narrative portion of the STR cited AC’s arrest for drug trafficking as the cause for
reporting, adding that AC is also known to be actively engaged in casino gambling.
Verification with the Department of Trade & Industry (DTI) showed that person AC
had two registered businesses, namely: A Trading and G Center. Certifications from
the Business Permit and License Office showed that A Trading had gross receipts of
only ~USD3,800 and that it had been closed since January 2011 while G Center was
registered as a new business only in March 2013 with a capital of only ~USD1,085
and only one employee. Further verification showed that person AC did not appear
as stockholder, incorporator or board member of any corporation registered in the
Philippines.
In spite of the small capitalization and meagre declared income of person AC’s
businesses, the AMLC Secretariat’s financial investigation revealed that AC’s bank
transactions involved more than USD8.6 million. One bank account was found to
have made more than 200 fund transfers amounting to more than USD2.16 million
to several individuals. The fund transfers were all made under the guise that they
were AC’s payment for gambling debts owed to the recipients of the transfer.
However, no documents were presented to prove that person AC owed large sums
of money by virtue of his gambling activities.
9
APG Yearly Typologies Report 2016, page 52
PART 4: Annex E – Typologies E-3
Financial investigations also showed that AC’s bank accounts received funds from
persons MST and CW who have also been charged with drug trafficking. Apart from
his bank accounts, person AC also owned several prime real estate properties, a
foreign currency trust account and money placement worth a significant amount. In
August 2014, the Court of Appeals granted the Petition filed by the AMLC for the
Issuance of a Freeze Order against the bank accounts, investments, real properties
and motor vehicles of Mr. AC and his cohorts. 10
E. Structuring
399 It was noted in company B’s account that large amounts of funds came through
online transfers and cash from different individuals. The accumulated funds flowed
from the company’s account in a structured manner through online cash/ATM
transfers to the personal accounts run by individuals who were either employees of
the company or were involved in other businesses. The funds were then taken out
from the personal accounts through online cash withdrawal. The matter was referred
for investigation.11
A complaint was lodged against the suspect who was believed to be involved in fraud.
The suspect ‘JKL’ opened an account at the branch of Bank X. At the time of account
opening the information provided by the suspect stated that he was working as an
Associate and dealing in property business. The account was opened for saving
purpose. Two officials of the government department lodged a complaint against the
individual and stated that their two cheques were stolen and issued with forged
signature amounting to PKR3,000,000 (~USD28,600) and Rs.2,500,000
(~USD23,800). The proceeds of both the cheques were credited to JKL account
through clearing. Some of the funds were immediately withdrawn in cash while the
remaining funds were returned to the issuing bank after receipt of complaint.
423 The suspect admitted using a different signature. Both signatures were very
different and therefore, a possibility of an unknown beneficial owner was suspected.
From the trail of transactions it was observed that the account was primarily used to
conduct transactions related to the stolen cheques and that no other significant
transactions took place in the account. The case was forwarded to LEA for necessary
action. 12
10
APG Yearly Typologies Report 2016, pages 65-66
11
APG Yearly Typologies Report 2016, page 80
12
APG Yearly Typologies Report 2016, page 83
PART 4: Annex E – Typologies E-4