Quick answer

A covered person must file a Suspicious Transaction Report (STR) with the Anti-Money Laundering Council (AMLC) when, after appropriate review, it determines that a completed or attempted transaction is suspicious. No minimum amount applies.

Under Section 9(c) of the Anti-Money Laundering Act (AMLA), the statutory rule is filing within five working days from “occurrence,” unless the AMLC prescribes a different period of no more than 15 working days. The AMLC has prescribed a shorter operational deadline under its current Guidelines on Transaction Reporting and Compliance Submissions (GoTRACS): the STR must be filed electronically by the next working day after suspicion is established or the transaction is determined to be suspicious.

The filing duty belongs to the covered person—not ordinarily to the customer, victim, employee acting personally, or general public. A private individual who notices possible fraud or money laundering should report it through the appropriate institution, police, National Bureau of Investigation, or other competent authority rather than attempting to file an AMLC STR.

What makes a transaction suspicious?

Under the AMLA, a transaction with a covered person is suspicious, regardless of its value, when any of the following circumstances exists:

There is no underlying legal or trade obligation, purpose, or economic justification.
The client is not properly identified.
The amount is not commensurate with the client’s business or financial capacity.
Considering all known circumstances, the transaction appears structured to avoid AMLA reporting requirements.
The transaction deviates from the client’s profile or past transactions.
The transaction is in any way related to an unlawful activity or AMLA offense that is about to be committed, is being committed, or has been committed.
The transaction is similar or analogous to any of the circumstances above.

These are statutory categories, not a checklist requiring proof of a crime. One circumstance may be enough if the facts reasonably support the determination. Conversely, an unusual transaction is not automatically suspicious: the covered person should examine its purpose, the customer’s explanation, available records, source of funds, expected account activity, related parties, and other relevant circumstances.

The current statutory definition appears in Republic Act No. 11521, which amended the AMLA.

There is no peso threshold for an STR

An STR may be required for ₱100, ₱100,000, ₱10 million, or any other amount. Suspicion—not value—is the trigger.

This distinguishes an STR from a Covered Transaction Report (CTR), which is generally triggered by an applicable monetary threshold. A transaction may be:

reportable only as suspicious;
reportable only as a covered transaction;
neither, depending on the facts; or
both covered and suspicious.

If the same transaction qualifies as both covered and suspicious, the AMLA directs the covered person to report it as a suspicious transaction, rather than treating the CTR as a substitute for the STR.

Transactions deliberately divided into smaller amounts may themselves indicate structuring. Staying below a CTR threshold does not prevent STR reporting.

When does the filing clock start?

For an STR, “occurrence” under GoTRACS means the establishment of suspicion or the determination that the transaction is suspicious, not necessarily the date on which the transaction was initiated or completed.

The current sequence is therefore:

A transaction, attempted transaction, alert, information, or other circumstance triggers review.
The covered person promptly conducts the review required by its anti-money laundering and counter-terrorism-financing controls.
Its authorized compliance officer, committee, or decision-maker establishes that the matter is suspicious.
The covered person files the STR by the next working day.

For example, if suspicion is formally established on a Monday that is a reporting day, the STR is ordinarily due on Tuesday. If the next day is officially treated as a non-working or non-reporting day under the applicable rules or an AMLC declaration, the institution should apply the current GoTRACS calendar provisions and check the AMLC’s official announcements.

A covered person should not manipulate the determination date, keep a clearly suspicious alert indefinitely “under review,” or delay escalation to create more filing time. Its reporting chain should specify who reviews alerts, what due diligence may be conducted, when escalation occurs, who makes the final decision, and how both filing and non-filing decisions are documented.

Attempted and rejected transactions can be reportable

The suspicious activity need not succeed. Current AMLC reporting guidelines cover attempts, including situations in which a customer abandons, cancels, or is prevented from completing a transaction after being asked for identification, source-of-funds information, beneficial-ownership details, or supporting documents.

A rejected or blocked transaction should therefore not be dismissed merely because no money ultimately changed hands. The institution should preserve the attempted-transaction details and assess whether the surrounding circumstances establish suspicion.

Examples that may warrant review include:

repeated attempts to transact just below a reporting threshold;
refusal or inability to provide credible identification;
use of apparently false, altered, or inconsistent documents;
unexplained use of nominees, multiple accounts, or unrelated intermediaries;
rapid movement of funds with no apparent lawful purpose;
activity materially inconsistent with the customer’s declared occupation or business;
unexplained transfers involving persons or locations associated with unlawful activity; and
a transaction abandoned immediately after compliance questions are raised.

These are indicators, not automatic findings. The conclusion must rest on the available facts and the covered person’s documented, risk-based assessment.

Who must file?

The duty applies to “covered persons” under the AMLA. Depending on the activity and applicable regulatory definitions, these include:

banks, non-bank financial institutions, trust entities, foreign-exchange dealers, pawnshops, money changers, remittance and transfer companies, and other BSP-supervised or regulated persons;
insurance companies, pre-need companies, and other persons supervised or regulated by the Insurance Commission;
securities dealers, brokers, investment houses, investment companies, funds, and other specified SEC-supervised or regulated persons;
casinos, including internet- and ship-based casinos with respect to their Philippine operations;
designated jewelry, precious-metal, and precious-stone dealers;
specified company service providers;
persons professionally providing specified services involving client money, securities, accounts, corporate contributions, legal arrangements, or business entities;
real estate developers and brokers; and
other persons brought within the statutory or regulatory definition, including regulated businesses that perform covered financial services.

Whether a business is a covered person can depend on what it actually does, not merely its corporate name or registration category. A business uncertain about its status should examine the complete statutory definition, its regulator’s rules, and current AMLC issuances.

Special rule for lawyers and accountants

Independent lawyers and accountants are not required to report information obtained in circumstances protected by professional secrecy or legal professional privilege. The AMLA also excludes qualifying independent legal professionals in relation to protected client information or where disclosure would compromise client confidences or the attorney-client relationship.

This is not a blanket exemption for every commercial or financial service performed by a lawyer or accountant. Coverage may depend on:

the precise service being provided;
whether the professional is acting independently;
whether the activity falls within a designated covered service;
how the information was obtained; and
whether privilege or professional secrecy legally applies.

Because an incorrect privilege determination can have serious consequences, doubtful cases should be reviewed promptly by Philippine counsel experienced in AML compliance without disclosing the contemplated report to the customer.

How an STR should be filed

A covered person should file electronically through the AMLC reporting facility using its registered institutional access. The AMLC Portal provides the covered-person registration and electronic reporting facilities; hard-copy submission should not be assumed to satisfy the current process.

A sound response usually includes these steps:

Secure the alert and records. Preserve transaction data, instructions, identification documents, account information, communications, device or channel information, and relevant system logs.
Review the full relationship. Examine linked accounts, prior activity, counterparties, beneficial owners, stated business, transaction purpose, and source and destination of funds.
Conduct proportionate due diligence. Seek ordinary supporting information when appropriate, but do not question the customer in a manner that reveals an STR is being considered.
Escalate promptly. Follow the institution’s written reporting chain and record each material review and decision time.
Make and document the determination. State the facts supporting suspicion. If no STR is filed, document the reason for that decision.
Prepare an accurate narrative. Explain who was involved, what occurred or was attempted, when and where it happened, how it was conducted, why it is suspicious, and how related transactions or parties connect.
File by the next working day. Submit through the AMLC’s prescribed electronic facility and retain the system acknowledgment or other proof of filing.
Continue appropriate monitoring. A filed STR does not necessarily end the review. Later related activity may require additional or supplemental reporting under current instructions.

The narrative should distinguish verified facts from customer statements and institutional analysis. It should not accuse a person of a crime as an established fact unless the institution has reliable official information supporting that statement.

Evidence and records to preserve

The file should allow an examiner or investigator to reconstruct the transaction, review, decision, and filing. Preserve, as applicable:

customer and beneficial-owner identification;
account-opening and customer-due-diligence records;
declared occupation, business, income, expected activity, and risk rating;
transaction slips, transfer instructions, deposit records, checks, contracts, invoices, and receipts;
source-of-funds or source-of-wealth documents;
relevant emails, messages, call records, and branch notes;
IP addresses, device identifiers, access logs, and authentication records where lawfully maintained;
sanctions, politically exposed person, adverse-information, and internal screening results;
monitoring alerts and linked-account analysis;
analyst findings and escalation records;
the final filing or non-filing decision and its basis;
the STR submission acknowledgment, corrections, and follow-up communications; and
any lawful request or directive received from AMLC, law enforcement, or the regulator.

The AMLA generally requires transaction records to be safely stored for five years. Customer-identification, account, and business-correspondence records are also subject to statutory and sector-specific retention rules. Longer retention may be required when a case, investigation, court order, regulatory direction, or legal hold is pending. Records relating to unusual or suspicious activity should remain confidential and access-controlled.

Do not tip off the customer or anyone else

A covered person and its directors, officers, and employees must not communicate, directly or indirectly, that an STR:

has been filed;
is about to be filed;
is being considered;
contains particular information; or
has led to AMLC interest or action.

This prohibition extends beyond an express statement. Changing language, contacting a customer unusually, sharing the report internally without a need to know, or warning another party may reveal the contemplated or completed filing.

The AMLA protects good-faith reporting performed in the regular course of duty, but that protection does not excuse bad faith, malicious reporting, unauthorized disclosure, or noncompliance with reporting requirements. Section 14 of the AMLA, as amended by Republic Act No. 10365 and Republic Act No. 11521, provides criminal and administrative consequences for specified reporting and confidentiality violations.

Filing an STR does not automatically mean freezing the account

An STR is an intelligence report, not by itself a conviction, forfeiture judgment, or general authority to confiscate funds. A covered person should not represent to the customer that an STR proves criminal conduct.

Whether a transaction should be delayed, rejected, blocked, or an account restricted depends on separate legal and regulatory grounds, such as:

customer-due-diligence rules;
sanctions or terrorism-financing requirements;
fraud-prevention laws and regulations;
an AMLC freeze order;
a court order;
a lawful directive from a competent authority; or
the institution’s lawful contractual and risk controls.

Institutions should apply the correct legal basis and preserve the distinction between filing an STR and implementing a freeze or hold.

Common mistakes

Frequent compliance failures include:

applying the CTR threshold to suspicious transactions;
counting the deadline from the wrong date;
relying on the AMLA’s five-working-day baseline while overlooking the current next-working-day GoTRACS deadline;
treating an abandoned or rejected attempt as non-reportable;
postponing a final determination without a documented, legitimate reason;
filing a vague narrative that lists red flags but omits the underlying facts;
failing to identify linked transactions, counterparties, or beneficial owners;
omitting material information or reporting unverified allegations as facts;
filing through an unofficial channel or failing to retain proof of submission;
neglecting to document why a reviewed alert was not reported;
assuming that an STR automatically authorizes an account freeze; and
alerting the customer, another employee without a need to know, or an outside party.

When legal or compliance help is urgent

Obtain immediate advice from the institution’s compliance officer and, where appropriate, Philippine counsel if:

the next-working-day deadline is approaching or has already been missed;
staff disagree about whether suspicion has been established;
the suspected activity may involve terrorism financing, proliferation financing, sanctions, kidnapping, trafficking, cybercrime, public corruption, or another continuing offense;
an employee, officer, beneficial owner, or related company may be involved;
documents appear falsified or are being destroyed;
a customer asks whether a report has been filed;
the matter involves potentially privileged lawyer-client or accountant-client information;
an AMLC, court, police, NBI, BSP, SEC, Insurance Commission, or other official order or request has been received;
the reporting portal is unavailable close to the deadline; or
the institution discovers that an STR was late, incomplete, inaccurate, or filed under the wrong report type.

A portal problem should be documented immediately with timestamps, screenshots, error messages, help-desk communications, and the steps taken to submit through any officially authorized contingency process. Do not invent an alternative filing channel.

Frequently asked questions

Is every transaction above ₱500,000 suspicious?

No. A threshold transaction may require a CTR, but value alone does not necessarily make it suspicious. An STR is required when one or more suspicious circumstances exist. The same transaction may qualify for both, in which case it is reported as suspicious.

Can a small transaction require an STR?

Yes. There is no minimum amount. A small completed or attempted transaction may be suspicious because of its purpose, structure, parties, documents, relationship to other activity, or connection to an unlawful activity.

Must the covered person prove money laundering before filing?

No. An STR is not a criminal complaint requiring proof beyond reasonable doubt. The covered person must have a factual, documented basis for determining that the transaction falls within a statutory suspicious circumstance.

Is an unusual transaction automatically reportable?

Not always. It should be reviewed promptly. A credible explanation and supporting documents may resolve the concern, while inconsistencies, missing information, or additional facts may establish suspicion. The decision and its basis should be documented either way.

What if the transaction was attempted but stopped?

It may still require an STR. Current AMLC guidelines expressly include attempts when the circumstances establish suspicion.

When is the STR due?

Under current GoTRACS requirements, it is due within the next working day after suspicion is established or the transaction is determined to be suspicious. Check AMLC announcements for officially declared non-working or non-reporting days.

Can the customer be told that an STR was filed?

No. Tipping off is prohibited and may result in criminal liability.

Can a private person file an STR directly?

Ordinarily, no. The statutory STR duty is imposed on covered persons. An individual may report suspected fraud or criminal activity to their bank or other institution and to the appropriate law-enforcement or regulatory authority.

Where can the current rules be checked?

Consult the AMLC legal and regulatory issuances page, the AMLC Portal, Republic Act No. 9160, Republic Act No. 10365, and Republic Act No. 11521. Sector-specific BSP, SEC, Insurance Commission, PAGCOR, or other supervisory rules may impose additional controls.

This article provides general legal information, not legal advice, and does not replace the AMLA, current AMLC issuances, sector-specific regulations, or advice based on the actual documents and facts. Official sources and current procedures were checked on 3 September 2026.