AMLC Registration & Renewal Guidelines in the Philippines
(A comprehensive legal-practice primer as of July 2025)
1. Statutory & Regulatory Foundations
| Layer | Instrument | Key Provisions on Registration/Renewal |
|---|---|---|
| Primary law | Republic Act No. 9160 (Anti-Money Laundering Act, “AMLA”) and its amendments (RA 9194 - 2003, RA 10167 - 2012, RA 10365 - 2013, RA 10927 - 2017, RA 11521 - 2021) | §3(a) defines covered persons (CPs); §7 empowers the Anti-Money Laundering Council (AMLC) to “require reporting, registration, and examinations.” |
| Implementing rules | 2016 Revised Implementing Rules & Regulations (RIRR), last amended in 2021 to align with RA 11521 | Part 1(3.2) obliges every CP to register with the AMLC e-registration system and keep the registration active. |
| AMLC issuances | - AMLC Regulatory Issuance (ARI) No. 1-2020: “Rules on the Registration and Renewal of Registration of Covered Persons.” - AMLC Regulatory Issuance No. 5-2021: “Revised AMLC Registration and Reporting Guidelines (ARRG)” (supersedes the 2018 ARRG). - AMLC Resolution Nos. 125-2020 & 64-2021: set transitional renewal deadlines & penalties. - FAQ Circulars dated 2021-2024 refine digital‐portal steps. |
Provide granular instructions, documentary checklists, validity periods, administrative penalties, and technical specifications for the AMLC Registration & Reporting System (ARRS) and goAML platform. |
Bottom-line mandate: No covered person may operate or file transaction reports unless it keeps an active Certificate of Registration (COR) renewed on schedule.
2. Who Must Register & Renew
Traditional Financial Institutions
- Universal, commercial, thrift & rural banks; quasi-banks
- Trust entities, pawnshops, remittance & transfer companies (RTCs/MSBs)
- Offshore banking units; electronic-money issuers (EMIs)
Capital-Market Intermediaries
- Securities brokers/dealers, investment houses, mutual fund distributors
- Insurance companies, brokers & agents
Designated Non-Financial Businesses and Professions (DNFBPs)
- Casinos (land-based, online & shipboard)
- Real-estate developers & brokers (for single transactions ≥ ₱7.5 million)
- Jewel, precious metal & stone dealers
- Lawyers, accountants, and other independent legal professionals when they engage in trust/formation services
Virtual Asset Service Providers (VASPs) – required since RA 11521 & BSP Circular 1108-2021.
Branches and subsidiaries register through the Head/Parent Office account but must be enumerated individually in the annex of outlets.
3. Registration Life-Cycle at a Glance
| Phase | Period | Portal | Outcome |
|---|---|---|---|
| Initial Registration | Before commencing operations | AMLC Registration & Reporting System (ARRS) (https://portal.amlc.gov.ph) |
Issuance of COR valid for 24 months from approval date. |
| Renewal | Begin 60 days before COR expiry; hard deadline exact expiry date | ARRS dashboard → Renew Registration | New COR valid for another 24 months. Registration of branches/outlets and user accounts carried over but editable. |
| Lapse / Grace Period | None. Expiry date is final. | — | Account automatically deactivated. CP cannot upload CTR/STRs; may face penalties. |
| Reactivation | Any time after lapse | Reactivation module + explanation letter + proof of fee payment | COR re-issued; penalties assessed separately. |
4. Documentary Requirements for Renewal
| Document | Notes |
|---|---|
| Board/Partner Resolution designating Primary Designated Officer (PDO) and Alternate (or sole proprietorship owner’s notarized affidavit). | Must quote authority to sign AMLC forms and certify material accuracy. |
| Latest General Information Sheet (GIS) or Articles of Partnership/Co-op docs. | Must be SEC/CDA-stamped and not more than one year old. |
| Regulatory License/COC (BSP, SEC, IC, PAGCOR, PCAB etc.) | Proves the CP is still duly authorized by its Supervising Authority. |
| Valid Government IDs of PDO & Alternate. | Passport, PhilSys ID, Driver’s license; must be clear scans. |
| Proof of Transactions (for dormant entities). | If no covered transactions filed in the last cycle, an explanation letter is mandatory. |
Scans must be in PDF, ≤ 5 MB per file, legible at 200 dpi. Originals must be produced upon onsite examination.
5. Step-by-Step Renewal Procedure
- Calendar the expiry. ARRS sends auto-emails 90, 60, 30, and 7 days before lapse; do not rely solely on them.
- Log in at https://portal.amlc.gov.ph with multi-factor credentials of the PDO.
- Click “Renew Registration.” Review pre-populated information; update contact numbers, email, responsible officers, branch list.
- Upload documents listed in §4.
- E-sign the Renewal Declaration & Undertaking (check-box + typed name).
- Submit. System displays tracking number; email confirmation follows.
- AMLC processing (3-15 working days). Status shows Pending – In Review.
- Download new COR. Once approved, it’s downloadable in PDF with QR code.
- Update goAML user profile to ensure continuous STR/CTR filing.
- Board ratification. Best practice is to note renewal in the next board minutes.
No government fee is presently collected for renewal; costs are internal (notarization, scanning, etc.).
6. Compliance Timetable (2023-2026 Cohort Example)
| Initial COR Issue Window | Renewal Filing Window | New Expiry |
|---|---|---|
| 1 Jan 2023 – 31 Mar 2023 | 1 Jan 2025 – 31 Mar 2025 | 31 Mar 2027 |
| 1 Apr 2023 – 30 Jun 2023 | 1 Apr 2025 – 30 Jun 2025 | 30 Jun 2027 |
| 1 Jul 2023 – 30 Sep 2023 | 1 Jul 2025 – 30 Sep 2025 | 30 Sep 2027 |
| 1 Oct 2023 – 31 Dec 2023 | 1 Oct 2025 – 31 Dec 2025 | 31 Dec 2027 |
Staggered renewals ease AMLC’s review load; follow your own COR date.
7. Penalties & Enforcement
| Violation | Typical Administrative Fine (AMLC fining matrix) |
|---|---|
| Failure to renew BEFORE expiry | ₱10,000 per calendar day of delay (small entities) up to ₱100,000 per day (large banks/casinos). |
| Operating unregistered / lapsed | Suspension recommendation to BSP/SEC/IC; public naming in AMLC Annual Report. |
| Misrepresentation or falsified docs | Fine up to ₱5 million plus possible criminal referral under §14 AMLA. |
| Late STR/CTR filing caused by deactivation | Separate fine schedule (₱30k–₱2M per late report). |
Penalties accrue until full compliance & payment. AMLC may accept a compromise settlement (usually 60-80 % of computed fine) for first-time violators that self-disclose and remediate.
8. Special Topics & Recent Updates
8.1 Virtual Asset Service Providers (VASPs)
- BSP Circular 1108-2021 classifies VASPs as CPs. They must upload their BSP Certificate of Authority and confirm blockchain-analytics tool subscription upon renewal.
8.2 Real-estate Brokers & Developers
- April 2024 FAQ clarifies that individual brokers renew under their PRC license; corporate developers must submit the HLURB/ DHSUD permit and sample contract-to-sell.
8.3 Integrated Reporting: goAML v 5.6
- Since November 2023, the COR QR code must be linked inside goAML. System auto-checks COR validity at each STR/CTR upload.
8.4 Alignment with the Financial Action Task Force (FATF) ICRG Action Plan
- Demonstrable registration coverage rate is a FATF performance indicator. Timely renewals help the Philippines exit the “gray list.”
9. Practical Compliance Tips
- Maintain a living AMLC file (soft & hard copy) with updated docs ready.
- Use corporate email addresses for PDO & Alternate; personal addresses often get blocked by firewalls.
- Rotate officers in ARRS immediately upon HR changes; do not wait for renewal.
- Automate calendar reminders at least 90 & 45 days pre-expiry.
- Perform test uploads in goAML quarterly; a dormant account is often flagged for onsite examination.
10. Frequently Asked Questions
| Q | A |
|---|---|
| Can we renew earlier than 60 days before expiry? | Yes, system allows up to 90 days advance filing, but renewal date resets to approval date (not original expiry). |
| Do sole proprietors need board resolutions? | No; a Notarized Affidavit of Sole Proprietor suffices. |
| What if there were no covered transactions for two years? | Renewal is still mandatory; attach an “Explanation of Zero Reports” letter. |
| Is there a physical COR? | Since 2022, the AMLC issues digital CORs only; print-outs bearing the QR code are acceptable during BSP/SEC exams. |
| Are subsidiaries abroad covered? | Only Philippine-incorporated or branch offices operating in the Philippines fall under AMLC jurisdiction. |
11. Conclusion
Regular, punctual renewal of AMLC registration is more than a box-ticking exercise—it is a regulatory linchpin connecting your institution to the national anti-money-laundering and counter-terrorism-financing (AML/CTF) architecture. By internalizing the timelines, maintaining up-to-date records, and institutionalizing a compliance culture, covered persons avoid costly penalties, reputational damage, and possible criminal exposure.
Disclaimer: This article is for general information only and does not constitute legal advice. For specific situations, consult counsel or the AMLC Secretariat.