Anti-money laundering compliance in the Philippines can feel intimidating because it mixes criminal law, banking rules, customer identification, data privacy, and government reporting. For Philippine businesses, the first practical question is not “Do I have a big transaction?” but “Am I a covered person under the Anti-Money Laundering Act, and do I have systems to detect and report risky transactions?” This guide explains who must comply, what Philippine law requires, how to build a workable AML program, what documents are usually needed, and the common mistakes that cause businesses to fail AMLC, BSP, SEC, Insurance Commission, or sector-specific compliance checks.

What anti-money laundering compliance means in the Philippines

Anti-money laundering compliance means having policies, people, records, and reporting systems that help prevent a business from being used to hide, move, or enjoy money or property from unlawful activity.

In simple terms, money laundering usually happens when dirty money is made to look clean. It often involves three stages:

Placement — illegal funds enter the financial or commercial system, such as through deposits, remittances, casino chips, real estate payments, or high-value purchases.
Layering — transactions are made complicated to hide the source, owner, or trail of funds.
Integration — the funds appear legitimate, such as through investments, properties, business income, loans, or corporate structures.

Philippine AML compliance is not only for banks. Depending on the business, it can cover remittance companies, financing companies, lending companies, insurance businesses, securities brokers, virtual asset service providers, casinos, real estate developers and brokers, jewelry and precious metals dealers, lawyers, accountants, company service providers, and other businesses classified as covered persons.

A covered person is expected to know its customers, understand beneficial ownership, monitor transactions, keep records, file required reports, avoid tipping off customers, and cooperate with lawful AMLC or regulator requirements.

Main Philippine laws and regulators

The central law is the Anti-Money Laundering Act of 2001, Republic Act No. 9160, as amended by:

RA No. 9194 (2003) — strengthened reporting and AMLC powers.
RA No. 10167 (2012) — expanded authority on freeze orders and bank inquiry.
RA No. 10365 (2013) — expanded covered persons and unlawful activities.
RA No. 10927 (2017) — included casinos as covered persons.
RA No. 11521 (2021) — further strengthened the AML framework, including additional covered persons, beneficial ownership, and targeted financial sanctions.

The key government body is the Anti-Money Laundering Council (AMLC). It is the Philippines’ financial intelligence unit. The AMLC receives and analyzes covered transaction reports and suspicious transaction reports, issues regulations and guidelines, applies for court orders when needed, and coordinates with law enforcement and foreign counterparts.

Other regulators also matter:

Business type	Usual regulator or supervising authority
Banks, quasi-banks, money service businesses, e-money issuers, payment operators, virtual asset service providers	Bangko Sentral ng Pilipinas
Securities brokers, investment houses, financing companies, lending companies, investment companies	Securities and Exchange Commission
Insurance companies, insurance brokers, pre-need companies, HMOs when applicable	Insurance Commission
Casinos, junket operators, gaming-related covered entities	PAGCOR and AMLC
Real estate developers and brokers	AMLC, with sectoral coordination involving DHSUD, PRC, HLURB legacy rules where relevant, and local permitting offices
Jewelry dealers, precious metals/stones dealers, company service providers, certain lawyers and accountants	AMLC, plus applicable professional or business regulators

The 2018 Revised Implementing Rules and Regulations of RA 9160, the 2021 AMLC Registration and Reporting Guidelines, the 2021 AML/CTF Guidelines for DNFBPs, the BSP’s AML/CFT regulations in the Manual of Regulations for Banks, and AMLC’s newer GoTRACS transaction reporting rules are especially important for day-to-day compliance.

Is every Philippine business required to register with the AMLC?

No. Not every sari-sari store, restaurant, contractor, importer, clinic, school, online seller, or ordinary corporation is automatically required to register with the AMLC.

The duty to register generally applies when the business falls within the AMLA definition of a covered person. However, even businesses that are not covered persons will still encounter AML requirements in practice because banks, payment providers, investors, counterparties, and regulators may ask for:

SEC or DTI registration documents
Articles of Incorporation or partnership documents
General Information Sheet
Beneficial ownership information
Mayor’s permit or business permit
BIR Certificate of Registration
Latest income tax returns or audited financial statements
Board resolutions and secretary’s certificates
IDs of directors, officers, authorized signatories, and beneficial owners
Source of funds and source of wealth explanations
Contracts, invoices, deeds of sale, import documents, or remittance details

This is why a non-covered business can still suffer delayed bank account opening, frozen transactions, rejected international transfers, or enhanced due diligence if its documents do not clearly show who owns the business, where the money came from, and what the transaction is for.

Covered persons under Philippine AML law

The AMLA uses the term covered persons to identify businesses and professionals that have direct AML duties.

Common covered persons include:

Financial institutions

These include banks, offshore banking units, quasi-banks, trust entities, non-stock savings and loan associations, pawnshops, foreign exchange dealers, money changers, remittance and transfer companies, e-money issuers, payment system operators, and virtual asset service providers when regulated as such.

Securities and investment-related businesses

These include securities dealers, brokers, salesmen, investment houses, investment agents, mutual funds, investment companies, and other entities supervised by the SEC in relation to securities and investment activity.

Insurance sector

These include insurance companies, insurance agents and brokers, professional reinsurers, reinsurance brokers, holding companies, and other persons supervised by the Insurance Commission when covered by AML rules.

Casinos and gaming-related covered persons

Casinos, including internet-based and ship-based casinos, became covered persons under RA No. 10927. Casino cash transactions exceeding the statutory threshold are reportable, and suspicious transactions must be assessed regardless of amount.

Real estate developers and brokers

RA No. 11521 expressly included real estate developers and real estate brokers as covered persons when they engage in buying and selling real estate. Real estate is a major AML risk area because high-value properties can be used to park illicit funds, hide beneficial ownership, or move value through nominees.

Dealers in precious metals and precious stones

Jewelry dealers and dealers in precious metals or precious stones may become covered persons for cash transactions above the AMLA threshold.

Lawyers, accountants, and company service providers

Lawyers and accountants may be covered when they perform specified activities for clients, such as managing client money, securities, or assets; organizing contributions for company creation or operation; creating, operating, or managing juridical persons or arrangements; or buying and selling business entities.

However, legal privilege and professional secrecy must be handled carefully. The AML framework does not simply turn every legal consultation or accounting engagement into a reportable matter. The covered activity and the nature of the transaction matter.

Offshore gaming operators and service providers

RA No. 11521 also included offshore gaming operators and their service providers as covered persons. In practice, this area has received close regulatory attention because of cross-border funds, nominee arrangements, labor concerns, tax issues, and possible links to other offenses.

Covered transaction vs suspicious transaction

Many businesses confuse these two. They are different.

Type of report	Main trigger	Is suspicion required?	Practical example
Covered Transaction Report (CTR)	Transaction exceeds a legal threshold	No	A cash transaction above the applicable AMLA amount
Suspicious Transaction Report (STR)	Red flags, suspicious circumstances, or reasonable grounds to suspect ML/TF/PF risk	Yes	Customer uses nominees, refuses to identify beneficial owner, or transaction has no clear business purpose

A covered transaction is not automatically illegal. It is reportable because it crosses the legal threshold.

A suspicious transaction may be reportable even if the amount is small. The issue is not only the peso value. The issue is whether the facts show suspicious circumstances.

Current AMLA transaction thresholds businesses should know

The usual statutory thresholds include:

Transaction category	Reporting threshold
General covered transaction in cash or other equivalent monetary instrument	Over PHP 500,000
Jewelry dealers, precious metals dealers, precious stones dealers	Cash transaction over PHP 1,000,000
Casino covered transaction	Cash transaction over PHP 5,000,000 or equivalent
Real estate developers and brokers	Cash transaction over PHP 7,500,000 or equivalent

For most covered persons other than casinos and real estate brokers/developers, AMLC reporting may consider the mode of settlement depending on the applicable rules and reporting format. For casinos and real estate developers or brokers, the covered transaction trigger is focused on covered cash transactions.

Suspicious transactions are different. A suspicious transaction can be reportable regardless of amount.

Red flags Philippine businesses should not ignore

A red flag does not automatically mean the customer is guilty. It means the business should review, document, and decide whether enhanced due diligence or STR filing is required.

Common Philippine AML red flags include:

A customer refuses to give valid ID, TIN, address, source of funds, or beneficial ownership information.
A buyer wants to pay large amounts in cash when a bank transfer would be normal.
Payments are split into smaller amounts to avoid a reporting threshold. This is often called structuring or smurfing.
A company’s declared business does not match its transaction volume.
A customer uses multiple unrelated third parties to pay for one purchase.
Funds come from or go to high-risk jurisdictions without a clear explanation.
A foreign buyer uses a Filipino nominee for property or business ownership without a legitimate structure.
A customer insists on rushing a transaction and avoiding normal documentation.
A person claims to represent a corporation but cannot produce a board resolution, secretary’s certificate, or authority to sign.
A real estate buyer wants the deed of sale to show a lower price than the actual payment.
A client frequently changes instructions on who should receive money.
A politically exposed person, close associate, or family member is involved in an unusually complex transaction.
A transaction appears connected to scams, illegal online lending, investment fraud, trafficking, corruption, tax crimes, smuggling, illegal gambling, or other unlawful activity.

Under the AMLA, predicate or unlawful activities include many offenses under Philippine law, such as drug trafficking, kidnapping, graft and corruption, plunder, robbery and extortion, swindling or estafa under the Revised Penal Code, smuggling, violations of securities laws, terrorism financing, trafficking in persons, and certain tax offenses under the National Internal Revenue Code.

Step-by-step AML compliance guide for Philippine businesses

Step 1: Confirm whether your business is a covered person

Do not rely only on your SEC primary purpose or business name. Look at what the business actually does.

Ask:

Are you regulated by the BSP, SEC, Insurance Commission, PAGCOR, or AMLC as a covered sector?
Do you move, hold, exchange, remit, invest, transfer, or manage money or value for customers?
Do you sell high-value assets such as real estate, jewelry, precious metals, or precious stones?
Are you a lawyer, accountant, or service provider forming companies or managing client assets?
Do you deal with virtual assets, e-money, remittances, payments, lending, financing, or securities?
Do you receive high-value cash payments from customers?

If the answer is yes, review the AMLA, the AMLC guidelines for your sector, and the regulations of your supervising authority.

Step 2: Register with the AMLC if required

Covered persons must register with the AMLC’s online registration system or applicable AMLC portal. Registration allows the covered person to submit reports electronically and comply with AMLC reporting rules.

Usual registration preparation includes:

Board or management designation of a compliance officer
Corporate information
Principal office and branch information
Contact details
Ownership and management details
Proof of business registration
Regulatory license or authority, if applicable
Money Laundering/Terrorism Financing Prevention Program
Internal reporting chain
Authorized users for AMLC reporting systems

AMLC portal processes have evolved, including online registration and reporting systems. Covered persons should maintain updated registration information because outdated compliance officer details, inactive email addresses, or old authorized users can cause missed AMLC notices and failed reporting.

Step 3: Appoint a competent compliance officer

A compliance officer should have enough authority to escalate issues, require documents, stop risky transactions, and interact with regulators. In small businesses, this may be a senior officer or owner-manager. In larger institutions, this is usually a dedicated compliance function.

The compliance officer should not exist only on paper. In real examinations, regulators look for actual participation, minutes, approvals, reports, training records, alerts, and documented decisions.

Step 4: Prepare a Money Laundering/Terrorism Financing Prevention Program

A Money Laundering/Terrorism Financing Prevention Program, often called an MTPP or AML/CTF program, is the business’s written compliance manual.

A practical AML program should include:

Business risk assessment
Customer acceptance policy
Customer due diligence procedures
Enhanced due diligence procedures
Beneficial ownership identification
Politically exposed person screening
Sanctions and targeted financial sanctions screening
Transaction monitoring rules
Covered transaction and suspicious transaction reporting process
Internal escalation chain
Record retention rules
Data privacy and confidentiality controls
Staff training plan
Independent audit or compliance testing
Board or senior management oversight
Procedures for branches, agents, brokers, and representatives
Handling of attempted transactions
Handling of law enforcement, subpoena, court, or AMLC requests

The program should match the actual business. A copied template that does not reflect real products, customer types, transaction channels, and branch operations is a common audit weakness.

Step 5: Perform customer due diligence

Customer due diligence (CDD) means identifying and verifying the customer and understanding the purpose of the transaction or relationship.

For individual customers, this usually includes:

Full name
Date and place of birth
Nationality
Present and permanent address
Contact number and email
Government-issued ID
TIN when applicable
Occupation or business
Source of funds
Purpose of transaction
PEP status when relevant

For corporate customers, this usually includes:

SEC registration or DTI registration
Articles of Incorporation, bylaws, partnership documents, or equivalent
Latest General Information Sheet
Beneficial ownership information
Board resolution or secretary’s certificate
IDs of authorized signatories
Business address and contact details
Nature of business
Source of funds and source of wealth
Audited financial statements, tax returns, contracts, invoices, or permits when needed

A beneficial owner is the natural person who ultimately owns, controls, or benefits from the customer or transaction. A corporation cannot be the final beneficial owner. If Company A owns Company B, the covered person must look through the chain until it identifies the natural persons who ultimately own or control the structure.

Step 6: Risk-rate customers and transactions

Not all customers carry the same risk. A risk-based approach means applying stronger checks where risk is higher.

Typical risk factors include:

Risk factor	Lower risk example	Higher risk example
Customer	Long-established local company with clear filings	Shell company with nominee owners
Product	Regular payroll account	High-value cross-border transfers
Geography	Low-risk local transactions	High-risk or sanctioned jurisdictions
Channel	Face-to-face verified customer	Non-face-to-face or agent-based onboarding
Payment method	Bank transfer from customer’s own account	Multiple third-party cash payments
Purpose	Clear business purpose supported by contracts	No apparent economic or lawful purpose

Enhanced due diligence may require additional IDs, proof of income, tax returns, audited financial statements, deeds of sale, loan agreements, import documents, proof of inheritance, donation documents, or explanations of source of wealth.

Step 7: Screen for sanctions, terrorism financing, and proliferation financing

Covered persons must have controls for targeted financial sanctions related to terrorism, terrorism financing, proliferation of weapons of mass destruction, and proliferation financing.

This means screening customers, beneficial owners, authorized signatories, counterparties, and sometimes vessels, entities, or jurisdictions against relevant sanctions lists and AMLC issuances. If there is a true match, the business must follow the required freeze, reporting, and non-dealing procedures.

A weak sanctions process is risky because the required action may be urgent. Staff should know the difference between:

A false match
A potential match needing review
A confirmed or target match requiring immediate action

Step 8: Monitor transactions after onboarding

CDD is not a one-time event. Businesses must monitor whether transactions remain consistent with what they know about the customer.

Examples:

A small retail business suddenly receives repeated multi-million peso transfers from unrelated individuals.
A real estate buyer’s funds come from several companies not named in the sale documents.
A remittance customer repeatedly sends amounts just below reporting thresholds.
A foreign company with no Philippine operations buys assets through local nominees.
A customer previously classified as low risk appears in negative media related to fraud or corruption.

The BSP has reminded supervised financial institutions to incorporate negative media screening into CDD and ongoing transaction monitoring. For non-bank covered persons, the same practical lesson applies: adverse news should trigger review, not automatic closure, unless the facts require it.

Step 9: File CTRs and STRs correctly and on time

Covered persons must file complete, accurate, and timely reports through the AMLC’s electronic reporting facilities.

Important timing points:

Covered transaction reports are generally filed within the period prescribed by AMLA and AMLC rules, commonly within five working days from occurrence, unless a different AMLC-prescribed period applies.
Suspicious transaction reporting must follow the current AMLC reporting rules. Under newer GoTRACS guidance, the deadline and meaning of “occurrence” focus on the establishment or determination of suspicion.
If a transaction is both covered and suspicious, treat it according to the applicable reporting rule and reporting code. Do not assume that filing a CTR removes the need to assess STR filing.

The internal reporting chain should be fast. A business that needs 15 internal approvals before deciding whether to file an STR will likely miss deadlines.

Step 10: Keep records for at least five years

Covered persons must maintain customer identification and transaction records so transactions can be reconstructed if AMLC, regulators, prosecutors, or courts need an audit trail.

As a practical rule, keep:

Customer information forms
ID copies and verification results
Corporate documents
Beneficial ownership declarations
Risk assessment results
Transaction documents
Monitoring alerts
Internal investigation notes
CTR and STR filing confirmations
Board approvals and compliance committee minutes
Training attendance records
Audit reports
AMLC or regulator correspondence

Records are generally retained for at least five years from the relevant transaction, account closure, termination of relationship, or occasional transaction. If a case, investigation, or AMLC instruction applies, preserve records longer.

Step 11: Protect confidentiality and avoid tipping off

Covered persons, officers, and employees must not tell the customer that a suspicious transaction report has been filed or that the customer is under AML review. This is commonly called tipping off.

Bad examples include:

“Sir, we reported you to AMLC already.”
“Ma’am, your transaction looks suspicious, so we filed an STR.”
“We cannot process this because AMLC might investigate you.”
Sending internal STR documents to the customer or broker.

A safer approach is to use neutral operational language, such as requesting additional documents for compliance review, subject to the business’s approved procedures.

Documents commonly needed for AML compliance

Document	Used for	Practical notes
SEC Certificate of Incorporation or DTI Certificate	Proof of legal existence	Foreign entities may need apostilled or authenticated equivalents
Articles of Incorporation, bylaws, partnership agreement	Authority, purpose, ownership structure	Check if business activity matches actual transactions
Latest General Information Sheet	Directors, officers, stockholders, beneficial ownership	Banks often require the latest stamped or submitted version
Beneficial ownership declaration	Identifying natural persons behind the entity	Watch out for nominee shareholders and layered ownership
Board resolution or secretary’s certificate	Authority of signatories	Usually notarized; banks may require original or certified copy
Government IDs and passports	Identity verification	Foreign passports may be required for non-Filipino owners
BIR Certificate of Registration	Tax registration	Often requested for business account opening
Mayor’s permit/business permit	Local business authority	Renewal delays can affect onboarding
Audited financial statements and ITRs	Source of funds, capacity, business legitimacy	Startups may submit contracts, invoices, bank statements, or capitalization documents
Contracts, invoices, deeds, import/export documents	Transaction purpose	Essential for unusual or high-value transactions
AML policies and MTPP	Compliance framework	Should be approved by board or senior management
Training and audit records	Proof of implementation	Regulators look for actual evidence, not just manuals

Special issues for foreigners and foreign-owned Philippine businesses

Foreigners doing business in the Philippines often encounter AML checks when opening bank accounts, buying condominium units, investing in corporations, receiving dividends, lending money to Philippine affiliates, or remitting funds from abroad.

Common issues include:

Apostille or authentication of foreign documents

Foreign corporate documents, board resolutions, certificates of incumbency, powers of attorney, and notarized documents may need an apostille if issued in a country that is part of the Apostille Convention. If the country is not an Apostille Convention member, consular authentication may be required.

Foreign ownership and nominee risks

AML compliance intersects with foreign ownership restrictions. Foreigners generally cannot own private land in the Philippines, subject to limited exceptions such as hereditary succession. Certain industries also have nationality limits under the Constitution, the Foreign Investments Act, public utility rules, land laws, and special statutes.

Using a Filipino nominee to hide the real foreign owner can create serious problems. It may trigger AML red flags and can also raise issues under the Anti-Dummy Law, corporation law, tax law, property law, and sector-specific licensing rules.

Source of funds from abroad

A bank or covered person may ask for:

Foreign bank statements
Sale documents for property abroad
Employment contracts or payslips
Tax returns
Company dividends or board approvals
Loan agreements
Inheritance or donation documents
Proof of business income

A simple statement like “funds from abroad” is often not enough for a high-value transaction.

Politically exposed persons

A foreign customer may be a politically exposed person (PEP) if the person holds or held a prominent public position, or is a close family member or associate of such person. PEP status does not mean the transaction is illegal, but it normally requires enhanced due diligence.

Common AML compliance mistakes in the Philippines

1. Treating AML as a bank-only issue

Real estate developers, brokers, jewelry dealers, casinos, remittance businesses, lending and financing companies, virtual asset businesses, and certain professionals may have direct AMLC obligations.

2. Registering with AMLC but not implementing the program

Registration is only the start. The business still needs actual CDD, risk rating, monitoring, training, reporting, and recordkeeping.

3. Accepting “representatives” without proof of authority

For corporate customers, always verify who can sign, pay, receive funds, and give instructions. Ask for a board resolution, secretary’s certificate, special power of attorney, or equivalent authority.

4. Ignoring beneficial ownership

The name on the SEC papers is not always the real controlling person. Layered corporations, nominees, trust-like arrangements, and informal side agreements require deeper review.

5. Filing reports late because suspicion was debated too long

A business may take reasonable steps to validate facts, but it should not use internal review as an excuse to miss AMLC deadlines. The reporting chain should clearly state who decides and within how many days.

6. Telling customers about STRs

Tipping off can create separate liability. Staff should be trained on what they can and cannot say.

7. Collecting documents but not reviewing them

Having a folder of IDs and permits is not enough. Someone must check whether the documents are valid, consistent, current, and relevant to the transaction.

8. No audit trail for decisions

If the business decides not to file an STR after review, document why. Regulators often examine whether the decision was reasonable based on the facts known at the time.

9. Weak branch or agent controls

Money service businesses, real estate networks, pawnshops, financing companies, and sales-agent-heavy operations often fail because head office policies do not reach branches, brokers, or agents.

10. Forgetting data privacy

AML compliance requires collecting sensitive information, but the Data Privacy Act of 2012, RA No. 10173, still requires lawful processing, proper access controls, security measures, and privacy-conscious retention.

Practical AML compliance checklist

Area	Minimum practical control
Governance	Board or senior management approval of AML program
Registration	AMLC registration and updated authorized users
Compliance officer	Designated officer with real authority
Risk assessment	Written assessment of products, customers, geography, channels, and delivery methods
CDD	Customer identification, verification, and purpose of transaction
Beneficial ownership	Natural persons identified and documented
EDD	Additional checks for high-risk customers and transactions
Sanctions screening	Screening of customers, beneficial owners, signatories, and counterparties
Transaction monitoring	Rules for unusual activity, thresholds, and patterns
Reporting	CTR/STR procedures, deadlines, escalation, and filing proof
Recordkeeping	At least five-year retention and searchable records
Training	Role-specific staff training, not just generic lectures
Audit/testing	Periodic independent review of AML controls
Confidentiality	No tipping off; restricted access to STR-related files
Data privacy	Secure storage and limited access to personal data

What happens if a business fails to comply?

AML non-compliance can lead to several consequences:

Administrative sanctions by AMLC or the supervising authority
Monetary penalties
Regulatory findings during examination
Suspension or revocation of registration or license
Difficulty maintaining bank accounts
Reputational damage
Criminal exposure for money laundering, failure to report, tipping off, or related offenses
Freezing, inquiry, or forfeiture proceedings involving suspicious property

The Supreme Court has recognized the strong public interest behind AML enforcement. In Republic v. Eugenio, G.R. No. 174629, the Court discussed AMLA bank inquiry powers in relation to bank confidentiality. In Ligot v. Republic, G.R. No. 176944, the Court recognized that a freeze order may issue upon probable cause that monetary instruments or property are related to unlawful activity, even without a prior criminal charge. In Republic v. Glasgow Credit and Collection Services, Inc., G.R. No. 170281, the Court dealt with civil forfeiture proceedings under the AMLA framework.

For businesses, the practical lesson is simple: AML compliance is not just paperwork. It creates the audit trail that shows the business acted responsibly when faced with high-risk transactions.

Frequently Asked Questions

Are all Philippine businesses required to register with the AMLC?

No. AMLC registration generally applies to businesses and professionals classified as covered persons under the AMLA and AMLC rules. However, non-covered businesses may still need to provide AML-related documents to banks, payment processors, investors, and counterparties.

What is the difference between KYC and CDD?

KYC means “know your customer.” CDD, or customer due diligence, is the broader compliance process of identifying the customer, verifying information, understanding the purpose of the relationship, identifying beneficial owners, risk-rating the customer, and monitoring transactions.

Is a covered transaction automatically illegal?

No. A covered transaction is reportable because it exceeds a legal threshold. It does not automatically mean the money is illegal. Suspicious transactions require a separate assessment of red flags and circumstances.

Can a small business be questioned by the bank for AML reasons?

Yes. Banks must perform CDD on customers. Even a small business may be asked for invoices, contracts, IDs, tax documents, or source of funds if transactions are unusual, large, inconsistent with the account profile, or connected to higher-risk counterparties.

What is beneficial ownership, and why do banks keep asking for it?

Beneficial ownership identifies the natural persons who ultimately own, control, or benefit from a company or transaction. Banks and covered persons ask for it because criminals often hide behind corporations, nominees, relatives, or layered entities.

Are real estate brokers covered by AMLA?

Yes, real estate brokers are covered persons when engaged in buying and selling real estate under the AMLA framework. A real estate broker handling high-value or suspicious transactions should have AMLC registration, CDD procedures, transaction monitoring, and reporting controls.

Do lawyers and accountants have to report clients to AMLC?

Only in covered circumstances. Lawyers and accountants may be covered when they perform specified financial, company formation, asset management, or transaction services. Ordinary legal advice, court representation, and privileged communications require careful treatment under the rules on professional secrecy and legal privilege.

How long should AML records be kept?

As a practical baseline, covered persons should keep customer and transaction records for at least five years, and longer if the account, customer, transaction, investigation, or case requires continued preservation.

What should a business do if a customer refuses to provide documents?

The business should follow its customer acceptance and CDD policy. Depending on the risk, it may decline the transaction, refuse onboarding, terminate the relationship, or assess whether an STR is warranted. The decision and reasons should be documented.

Can a business tell a customer that it filed an STR?

No. Covered persons, officers, and employees must avoid tipping off. STR-related information should be confidential and accessible only to authorized personnel.

Key Takeaways

Philippine AML compliance is governed mainly by RA No. 9160, as amended by RA Nos. 9194, 10167, 10365, 10927, and 11521.
Not every business is a covered person, but many businesses still face AML checks through banks, payment providers, regulators, and counterparties.
Covered persons must register with AMLC, conduct customer due diligence, identify beneficial owners, monitor transactions, keep records, and file required reports.
Covered transactions are threshold-based; suspicious transactions are red-flag-based and can be reportable regardless of amount.
Strong AML compliance depends on real implementation: trained staff, clear escalation, timely reporting, updated records, and documented decisions.
Foreign-owned businesses should pay special attention to apostilled documents, beneficial ownership, source of funds, and nominee arrangements.
A good AML program protects the business from regulatory penalties, bank account disruptions, reputational harm, and exposure to criminal or forfeiture proceedings.