Validity Period of AMLA Registration for Real‑Estate Agents in the Philippines
(Republic Act No. 9160, as amended; 2018 IRR; AMLC Registration & Reporting Guidelines for Real‑Estate Brokers/Developers, 2021)
1. Overview
Since 2018, real‑estate professionals—including developers, brokers, salespersons, appraisers and “any person who, for a fee, acts as an intermediary in the sale or lease of real property”¹—have been expressly classified as “covered persons” under the Anti‑Money Laundering Act (AMLA). Consequently, they must register with the Anti‑Money Laundering Council (AMLC) before lawfully offering real‑estate services worth ₱7.5 million or more (or its foreign‑currency equivalent) in a single transaction or a series of linked transactions.
The AMLC issues a Certificate of Registration (COR) through its online goAML portal once the entity or individual has completed the on‑boarding requirements. The COR’s lifespan and the rules on its renewal are the focus of this note.
2. Legal and Regulatory Basis
| Instrument | Key provision on validity |
|---|---|
| AMLA (RA 9160, as amended by RA 10927) | Authorises the AMLC to require registration and to impose administrative sanctions for non‑compliance. |
| 2018 IRR of the AMLA | Designates real‑estate brokers/developers as covered persons and mandates their registration “in accordance with AMLC‑issued guidelines.” |
| AMLC Registration & Reporting Guidelines for Real‑Estate Brokers/Developers (ARRG‑RE, 2021) | Sec. 9 & Sec. 10 set the validity, renewal period and updating requirements of the COR. |
| AMLC Regulatory Issuances (e.g., ARI No. 1‑2021) | Prescribe standard monitoring fees and late‑renewal penalties. |
3. Who Must Register and Maintain a Current COR?
| Class of real‑estate professional | Licensing body | AMLA registration required? |
|---|---|---|
| Real‑estate brokers | PRC‑REB License (3‑year validity) | Yes – separate from PRC licence. |
| Developers & Project Owners | DHSUD registration | Yes. |
| Salespersons (accredited under a broker) | PRC accreditation (1‑year renewable) | Yes, if they independently close covered transactions; otherwise they operate under the broker’s COR. |
| Real‑estate appraisers & consultants | PRC | Yes, if they directly facilitate sales/leases above the threshold. |
4. Validity Period of the COR
| Aspect | Rule |
|---|---|
| Initial validity | Two (2) years counted from the date shown on the COR. |
| Effectivity of renewal | A renewed COR likewise carries a fresh two‑year validity. |
| Cut‑off for filing renewal | At least thirty (30) calendar days before the COR’s expiry date. |
| Lapse of validity | Failure to renew on time automatically renders the COR expired on its anniversary date; no grace period is provided. |
| Administrative fee | Currently ₱2 000 per renewal (subject to change by AMLC). Late applications attract a surcharge that accrues per day of delay. |
Practical memory aid Think of the COR as similar to a PRC professional ID: both last 2 years (for AMLC) or 3 years (for PRC) and must be renewed ahead of their expiry to stay in good standing.
5. Renewal Mechanics
Online Update of Registration Profile Logging in to the goAML Supervision Portal, the covered person must:
- Confirm or revise organisational data (ownership, officers, authorised users).
- Re‑attach an up‑to‑date Board Resolution (for entities) or Sworn Affidavit (for sole proprietors/individual licensees) naming the Compliance Officer (CO).
- Upload the latest Know‑Your‑Customer (KYC) Manual and Money‑Laundering/Terrorist‑Financing Risk Assessment.
Payment of Monitoring Fee The system generates a payment reference. Settling the fee via any of AMLC’s partner banks automatically tags the application as “Complete”.
Issuance of the new COR The portal releases the renewed COR in PDF form, downloadable and printable for on‑premise display.
6. Updates Outside the Biennial Cycle
Even before the 2‑year mark, a covered person must file an Update of Registration within thirty (30) days when any of the following occurs:
| Triggering event | Examples |
|---|---|
| Corporate changes | Merger, change of name, change in primary office address, transfer of beneficial ownership ≥ 25 %. |
| Compliance Officer turnover | Resignation or replacement of CO or alternate CO. |
| Licensing status | Suspension/ revocation of PRC or DHSUD licence. |
| Material changes in business model | Expansion from brokerage to project development; adoption of entirely online sales channels. |
Failure to file these timely updates is deemed “willful violation” under Sec. 4(d), Rule V of the IRR, exposing the entity to fines and possible disqualification of corporate officers.
7. Consequences of an Expired or Lapsed COR
| Effect | Statutory/Regulatory Basis |
|---|---|
| Prohibition on transacting covered real‑estate sales/leases. | AMLC ARRG‑RE, Sec. 11(a). |
| Refusal of banks to accept proceeds or deposits from unregistered agents. | AMLC Advisory‑2021‑003; banks must verify the counterparty’s COR. |
| Graduated administrative fines (₱10 000‑₱500 000 per violation, plus daily penalty) | Rule V, Sec. 4, AMLA IRR; AMLC Resolution No. 64‑2020 (Schedule of Penalties). |
| Public listing as a “non‑compliant covered person.” | AMLC may publish names on its website. |
| Possible predicate offence in criminal prosecution if absence of COR is linked to money‑laundering. | Sec. 4, AMLA. |
8. Coordination with Other Licences and Registrations
| Regulator | Licence | Term | Interaction with AMLC COR |
|---|---|---|---|
| Professional Regulation Commission (PRC) | Real‑Estate Broker ID | 3 years | PRC renewal does not renew AMLC COR automatically. |
| Department of Human Settlements & Urban Development (DHSUD) | Developer’s or Broker’s Registration | Annual | AMLC renewal is independent but both agencies share sanction data. |
| Bureau of Internal Revenue (BIR) | TIN and COR for taxation | Indefinite | BIR requires AMLC COR copy when auditing large‑value transactions. |
9. Record‑Keeping & On‑Going Obligations During the 2‑Year Period
| Obligation | Regulatory deadline |
|---|---|
| Customer Due Diligence (CDD) | Before perfection of sale or lease. |
| Covered Transaction Report (CTR) for single cash receipt ≥ ₱7.5 million | Within 5 working days of the transaction. |
| Suspicious Transaction Report (STR) | Within 5 working days from detection of suspicion. |
| Retention of records (customer files, deeds, contracts, CTRs/STRs, CDD info) | 5 years from date of transaction or from account closure, whichever is later. |
| Training of staff | At least once every 24 months; proof of attendance may be required upon renewal. |
10. Common Pitfalls & Compliance Tips
- Start renewal preparations 60 days before expiry. Board resolutions and updated risk assessments often take time to secure.
- Monitor the e‑mail linked to your goAML account. AMLC sends renewal reminders and deficiency notices electronically.
- Keep separate compliance files for PRC, DHSUD and AMLC requirements; dates seldom align.
- Designate an alternate Compliance Officer in the COR to avoid lapses caused by CO turnover.
- Document “nil” reports. If you have no covered transactions within a reporting period, retain evidence of “nil submissions” in case of an AMLC audit.
11. Conclusion
The AMLA registration of real‑estate professionals is not a one‑time corporate formality; it is a renewable licence with a strict two‑year validity. Lapses in renewal expose brokers, developers and even individual agents to immediate operational restrictions and significant monetary penalties, apart from reputational harm. A robust calendar system, early preparation of renewal documents and continuous monitoring of regulatory issuances are therefore essential parts of a Philippine real‑estate firm’s compliance culture.
Disclaimer: This article is for general informational purposes only and does not constitute legal advice. For specific concerns, consult the AMLC regulations in force and seek professional counsel.
¹ 2018 IRR, Rule 2, Sec. 1(g).