How to Report a Cross-Border Investment Scam: Filing Complaints in the Philippines and the UAE

This is a practical legal guide written from a Philippine perspective. It is not legal advice. Laws and procedures change; consult a qualified lawyer in each jurisdiction for case-specific counsel.

1) The Big Picture (What “cross-border” really means)

Cross-border investment scams often touch multiple legal systems at once—e.g., the victim in the Philippines (PH), the scammer or platform in the United Arab Emirates (UAE), funds routed through banks/exchanges in several countries, and communications over global apps. Because no single office can do everything, you should file in parallel with:

Regulators (to stop the scheme and trigger administrative sanctions);
Police/prosecutors (to open a criminal case);
Financial-intelligence/AML bodies (to freeze or trace funds);
Banks/exchanges (to attempt swift recalls or holds);
Courts (civil recovery, asset preservation).

Early, multi-track reporting dramatically increases the chances of freezing funds before they disappear.

2) What counts as an “investment scam”?

Typical red flags:

Promises of fixed high returns with little/no risk (Ponzi, pig-butchering, boiler rooms).
Unregistered investment contracts, tokens, or “packages” being sold to the public.
Unlicensed persons soliciting funds (cold calls, social media “gurus”, messaging-app groups).
Pressure to move to private chats, secrecy, or requests to deposit via crypto or obscure payment rails.

When in doubt, treat it as suspicious and preserve evidence (see §4).

3) Key legal hooks you’ll likely invoke

Philippines (PH)

Revised Penal Code (RPC) – Estafa (swindling) for deceit/defraud; syndicated/large-scale variants increase penalties.
Securities Regulation Code (SRC) – Selling unregistered securities or unlicensed solicitation; market-fraud provisions.
Cybercrime Prevention Act – If the scam used ICT/online systems (affects venue, evidence, penalties).
Financial Products and Services Consumer Protection Act (FPSCPA) – Lets financial regulators order restitution and impose administrative sanctions on regulated entities that mistreat consumers.
Anti-Money Laundering Act (AMLA) – Enables freezing/forfeiture of criminal proceeds (via AML mechanisms and the courts).

United Arab Emirates (UAE)

Penal Code & Cybercrime laws – Fraud/online deception.
Securities & markets laws – Onshore Securities and Commodities Authority (SCA); DFSA (DIFC) and FSRA (ADGM) for financial free zones.
AML/CFT framework – UAE FIU and Central Bank mechanisms for freezing/tracing.
Consumer protection – Central Bank (for banks/payment institutions); sectoral regulators for licensed investment firms.

Cross-border cooperation typically flows through: (a) FIU-to-FIU channels (Philippine AMLC ↔ UAE FIU), (b) police/prosecutor mutual legal assistance, and (c) regulator-to-regulator information sharing.

4) First 24–72 hours: preserve, notify, and try to freeze

Preserve evidence (do not edit or delete)

Full chat logs, emails with headers, voice notes, call recordings.
Screenshots of dashboards/wallets/transactions (also export raw data: CSV, PDFs).
Bank/crypto transaction references, hashes, wallet addresses, exchange order IDs.
Marketing posts, web pages (save URLs and timestamps); if possible, record a screen-capture video scrolling through content.
Keep packaging of any SIMs/phones used, and note device identifiers.

Make an incident log

Chronology (date/time zones), amounts, counterparties, accounts/wallets, platforms, names/aliases/phone numbers.

Contact your bank/exchange immediately

Request a payment recall/trace and temporary hold on recipient accounts. In PH, recall feasibility differs for InstaPay/PesoNet vs. wire/Swift; speed is crucial. In UAE, contact your bank’s fraud unit; request they file STRs and reach out to counterpart banks/exchanges.

Change passwords / enable 2FA; consider a fraud alert with credit bureaus if identity data was shared.

5) Where to file in the Philippines (step-by-step)

Tip: File with all relevant bodies below. Each has different powers.

A. Securities and Exchange Commission (SEC) – Regulatory/administrative

Use when: There’s public solicitation, “investment packages,” tokens/contracts offered to PH residents, or unlicensed selling. What it can do: Issue advisories/cease-and-desist orders (CDOs), investigate, fine, refer for criminal action, and under FPSCPA seek restitution from regulated players.

How to file:

Prepare a sworn complaint (see template in §12) with evidence annexes.
Ask for: (i) investigation, (ii) CDO against ongoing solicitation, (iii) referral for criminal prosecution, and (iv) coordination with AMLC.
If a PH-licensed broker, crowdfunding intermediary, or adviser is involved, identify their license numbers (if any).

B. National Bureau of Investigation (NBI) / Philippine National Police – Anti-Cybercrime Group (PNP-ACG) – Criminal

Use when: Fraud occurred online or via electronic means, or you need forensic help. What they can do: Open a criminal case, issue subpoenas, preserve data, liaise with foreign counterparts, elevate to prosecutors.

How to file:

Submit a complaint-affidavit with digital evidence.
Request data preservation notices to platforms (within legal limits) and assistance for cross-border requests.

C. Department of Justice (DOJ) – Prosecution / cybercrime coordination

Use when: You want preliminary investigation by prosecutors; cyber cases often go to designated cybercrime courts. Ask for: Prompt subpoenas, MLA requests where appropriate, and consideration of syndicated estafa where multiple offenders collaborated.

D. Anti-Money Laundering Council (AMLC) – Financial intelligence / asset freezing

Use when: Funds moved through banks/exchanges. What it can do: Receive information, work with covered institutions (STRs/CTRs), coordinate FIU-to-FIU with the UAE FIU, and seek freeze/forfeiture via proper legal channels.

Practical steps:

Provide AMLC with a concise fund-flow map, transaction proofs, and case numbers from SEC/NBI/PNP to anchor action.
Ask your banks/exchanges to file STRs and to cooperate with AMLC tracing.

E. Civil action in PH courts – Asset recovery

Use when: You identify assets, need preliminary attachment, or want damages/rescission. Consider: Filing a civil case alongside criminal proceedings. Ask counsel about ex parte measures (e.g., writ of preliminary attachment) to secure assets before judgment.

Venue & jurisdiction (practical notes):

Cyber-enabled cases can be filed where elements occurred or where ICT systems were used.
Coordinate venue across filings to reduce duplication and maintain a coherent record.

6) Where to file in the UAE (complementary steps)

If you are an OFW or PH-based victim with transfers to UAE accounts/platforms, don’t wait—file in the UAE, too.

A. Local Police / e-Crime portals – Criminal

Use when: Funds or suspects tie to the UAE (bank accounts, phone numbers, hosting, offices). What to do: File an online or in-person police report; obtain a case number. Upload PH complaint documents (notarized/translated if needed; see §10 for apostille/legalization).

B. Financial Regulators – Administrative/regulatory

SCA (onshore securities/investments),
DFSA (DIFC) and FSRA (ADGM) for free-zone financial firms,
Central Bank of the UAE (CBUAE) for banks/payment institutions and (now) insurance supervision.

What to do: Lodge a regulator complaint with your evidence pack and the police case number. Ask them to:

Verify licensing/authorization of the firm or promoters,
Issue public warnings or restrictions, and
Coordinate with the UAE FIU and counterpart regulators abroad.

C. UAE FIU / Central Bank – AML path

Victims don’t file STRs; banks/exchanges do. Push your UAE bank/exchange to:

File STRs into the UAE’s AML system,
Attempt intra-bank holds/recalls, and
Liaise with AMLC in PH for FIU-to-FIU coordination.

D. Civil claims in UAE courts

Onshore courts for onshore defendants or accounts.
DIFC/ADGM courts if the contract chooses those jurisdictions, the entity is based there, or you can use their Small Claims Tribunals for speed and lower cost (subject to limits).
Ask counsel if a “conduit” recognition route (via DIFC/ADGM to onshore) may help with enforcement.

7) Cross-border strategy that actually works (playbook)

Parallel filings: SEC (PH) + NBI/PNP + AMLC and Police/Regulators (UAE).
Bank/exchange pressure: Provide formal police/regulator case numbers to fraud units to justify holds.
FIU-to-FIU bridge: Request AMLC ↔ UAE FIU coordination in writing (through your bank and investigators).
Asset-first mindset: Identify accounts, wallets, platforms quickly; pursue interim measures (attachment/freeze).
One evidence pack: Same dossier for all agencies (localized cover sheet per jurisdiction).
Translations & legalization: Get certified translations (EN/AR) and apostilles/legalization where required (see §10).
Civil + criminal: Don’t rely on criminal cases alone for restitution; file civil to preserve/collect assets.
Victim clustering: If others were duped, coordinate—larger victim groups can justify urgent regulatory and AML action.

8) Evidence & chain-of-custody (how to make your proof usable)

Affidavits: Sworn statements narrating facts in order.
Forensic copies: Export raw chat histories, metadata, and original files (don’t only rely on screenshots).
Hashing: If possible, compute hash values (e.g., SHA-256) for files you’ll submit to show they weren’t altered.
Headers & logs: Email full headers; platform access logs if available.
Crypto: Record wallet addresses, TX hashes, exchange ticket IDs, KYC account IDs (if any).
Banking: Official transaction histories, remittance slips, chargeback reference numbers.

9) Working with banks/exchanges (PH & UAE)

Immediate recall: Some rails allow payment recall if funds remain. Provide: date/time, amount, sender/recipient details, reference numbers, and the fraud report/case number.
Card chargebacks: If you used a card, ask your issuer about chargebacks (watch strict time limits).
VASPs/Exchanges: Many require a law-enforcement request or court order to freeze. File police/regulator complaints first, then send the case number to the exchange compliance team.

10) Cross-border documents: notarization, apostille & legalization

The Philippines issues apostilles (via DFA) for use abroad.
The UAE accepts properly apostilled or legalized documents; for Arabic-language proceedings, use certified translations.
For police reports/regulatory filings online, scanned apostilled PDFs are commonly acceptable; courts may require originals later.
A Special Power of Attorney (SPA) may be needed to engage UAE counsel; prepare it early and get it apostilled/legalized.

11) Realistic timelines & expectations

Freezing within days is possible if you act fast and the money still sits in an account—less likely after it’s layered (moved/converted).
Criminal investigations can be lengthy; civil actions may yield faster interim relief (attachments/injunctions).
Recovery is never guaranteed; success improves with speed, complete evidence, and multi-agency coordination.

12) Practical tools: templates & checklists

A) Complaint-Affidavit (Philippines) – Outline

Title: Affidavit-Complaint for Estafa, Violations of Securities Laws, and Cybercrime-Related Offenses Affiant: Full name, citizenship, address, ID details Respondents: Individuals/entities (real names and known aliases) Narrative:

Background and how solicitation began (dates, channels).

Specific misrepresentations/promises made.

Payments made (amounts, dates, accounts/wallets).

Platform details (website/app names, numbers, emails).

Discovery of fraud and subsequent events.

Damages suffered. Legal bases: Estafa; SRC (unlicensed/unregistered activity); Cybercrime; FPSCPA (as applicable). Reliefs sought: Investigation, issuance of subpoenas, prosecution; coordination with AMLC; referral to SEC for CDO; asset preservation. Annexes: Banking proofs, chats, emails, screenshots, website captures, IDs, witness statements. Jurat: Notarization details.

B) UAE Police/Regulator Filing – Outline

Complainant details (passport/Emirates ID if resident; PH passport if visitor/OFW).
Incident summary with dates, channels, amounts, and UAE ties (bank accounts, offices, numbers).
Evidence list and PH case numbers (SEC/NBI/PNP/DOJ/AMLC references).
Requested actions: Freeze/trace funds; contact platforms; refer to Public Prosecution; regulator to verify licensing and issue warnings; liaise with PH authorities.
Attachments: Apostilled PH affidavits, translations, screenshots, transaction proofs.

C) Evidence Checklist (both PH & UAE)

IDs, addresses, contact info of all parties.
Bank statements, remittance slips, chargeback tickets.
Crypto TX hashes, wallet addresses, exchange order IDs.
Chat/email exports with metadata; call logs/recordings.
Screenshots of websites/apps and WHOIS/domain info (if available).
Any contracts/receipts/“investment packages.”

13) Choosing the right forum(s): quick matrix

Goal	Philippines	UAE
Stop ongoing solicitation	SEC advisory / CDO	SCA/DFSA/FSRA public warnings & restrictions
Start criminal case	NBI / PNP-ACG → Prosecutors	Police → Public Prosecution
Freeze/trace funds	Banks/exchanges + AMLC (FIU)	Banks/exchanges + UAE FIU / CBUAE
Consumer redress vs. regulated firms	SEC/BSP/IC under FPSCPA	Central Bank / sector regulators
Civil recovery & interim attachment	PH courts (consider cyber venue)	Onshore, DIFC, or ADGM courts (incl. SCTs)

14) Common pitfalls (and how to avoid them)

Waiting to compile “perfect” evidence—file early and keep supplementing.
Relying on screenshots only—export raw data and headers.
Reporting only in PH when funds/accounts are in UAE (or vice-versa).
Not pushing banks/exchanges for parallel recall/hold and STR filing.
Forgetting translations/apostilles, which delays UAE actions.
Sharing too much personal data publicly—send full evidence only through official channels or counsel, in line with PH Data Privacy Act and UAE data-protection rules.

15) Frequently asked tactical questions

Q1: Can I get my money back if it went into a crypto wallet? Possibly. If it reached a centralized exchange (CEX), freezing is feasible with a case number. If it stayed in self-custody, focus on tracing (blockchain analytics) and identifying off-ramps.

Q2: Do I have to fly to the UAE? Not necessarily at the start. Many filings can be done online or via counsel empowered by an apostilled SPA. Police/prosecutors may later require in-person steps or remote authentication.

Q3: Which should I file first: criminal or regulatory? File both. A regulator’s advisory/CDO helps banks and FIUs justify freezes. A police report gives case numbers that unlock compliance doors at banks/exchanges.

Q4: Can we stop the scammer from leaving the Philippines? Only a court can issue a Hold Departure Order in a criminal case; DOJ may issue immigration lookout notices (informational). These require an active case and specific grounds.

16) Action plan you can copy-paste (first two weeks)

Day 0–2

Freeze attempt: contact banks/exchanges (PH & UAE); request recall/hold; ask them to file STRs.
File NBI/PNP-ACG report (PH) and police e-crime (UAE). Get case numbers.

Day 3–5

File SEC complaint (PH) asking for CDO and referral for prosecution.
Send your case numbers to banks/exchanges; escalate to compliance/legal.

Day 6–10

Submit a concise dossier to AMLC (PH) and note UAE police case details for FIU-to-FIU coordination.
If warranted, instruct counsel to seek civil attachment (PH court or UAE court appropriate to assets).

Day 11–14

File with UAE regulators (SCA/DFSA/FSRA/CBUAE**, depending on where the firm sits).
Prepare translations/apostilles for any documents regulators or courts request.

17) When to hire counsel (and who)

Immediately if losses are material, or funds touched multiple banks/exchanges.
PH counsel with securities/cyber/AML experience; UAE counsel aligned to onshore or free-zone venue (DIFC/ADGM) as needed.
Ask about flat-fee work for initial filings and urgent interim relief applications.

18) Final reminders

Speed + completeness are your best allies.
File in both PH and UAE if there are ties to each; don’t wait for one to finish.
Keep a single evidence repository and update all agencies when new facts arise.
Recovery is uncertain—but well-executed parallel filings significantly improve outcomes.

Appendix: One-page cover letter (use with any regulator/bank/FIU)

Subject: Cross-Border Investment Fraud Report – Request for Freeze/Investigation Parties: [Your full name, IDs] vs. [Entity/aliases] Summary (≤200 words): Who approached you, what was promised, dates, amounts, rails (bank/crypto), why it’s fraudulent (unlicensed/unregistered/false statements). Jurisdictional ties: Philippines victim; UAE [bank/exchange/account/platform] used; communications via [apps]. Attachments: Evidence index (bank TX, wallet TX, chats, emails, screenshots), sworn affidavit, police/regulator case numbers. Requests: (1) Investigate and issue urgent freeze/hold; (2) open case and coordinate with AMLC/UAE FIU; (3) advise on further requirements. Contact: Your phone/email; counsel (if any).

If you want, I can turn these checklists and templates into fill-in-the-blank forms (Word/PDF) you can use immediately.