Understanding AFASA and the Industry Protocol: Legal Framework and Implementation Challenges

Description

Course Description

This webinar provides bank directors, officers, and employees with a practical, law-centered overview of AFASA (Republic Act No. 12010) and the three BSP circulars implementing key parts of the Act. It then connects those requirements to the AFASA Industry Protocol and examines potential legal exposure for institutions and individuals when AFASA duties are breached. The course follows the full response chain: prevention and detection, BSP inquiry and information sharing, temporary holding and coordinated verification, and accountability.

Learning Outcomes

By the end of the webinar, participants should be able to:

  • Summarize the purpose and operational implications of BSP Circular Nos. 1213, 1214, and 1215.
  • Identify key control, inquiry, temporary-hold, verification, customer-notice, and reporting responsibilities.
  • Explain how the Industry Protocol coordinates institution-to-institution action and account-owner communications.
  • Distinguish potential institutional, administrative, civil, and criminal liabilities under AFASA and relevant BSP rules.
  • Apply the framework to a fictional scam-related transaction scenario and identify escalation and documentation steps.

Course Topics

  1. BSP Circular No. 1213

Information technology risk management

AFASA’s requirements for protecting access to financial accounts

  • Risk-based security controls for electronic financial services
  • Fraud management systems for monitoring and responding to suspicious transactions
  • Account enrollment, customer verification, and authentication controls
  • Assigning responsibility for controls and monitoring their effectiveness
  1. BSP Circular No. 1214

BSP inquiries into financial accounts and information sharing

  • The purpose, scope, and key terms of the Circular
  • The role of the BSP Consumer Account Protection Office (CAPO)
  • How institutions receive, process, and respond to BSP inquiry requests and orders
  • Rules for sharing account information with authorized authorities
  • Safeguards for confidentiality, secure transmission, access, and recordkeeping
  1. BSP Circular No. 1215

Temporary holding of disputed funds and coordinated verification

  • Which institutions and electronic fund transfers are covered, and which are excluded
  • When a temporary hold may be initiated and how long it may remain in place
  • Institutions’ responsibilities for verifying disputed transactions
  • Notices and remedies for affected account owners, including beneficiaries
  • When funds may be returned or released
  • Consumer complaint escalation and reporting requirements
  1. AFASA Industry Protocol

How institutions coordinate their response to disputed transactions

  • The process from receiving a disputed transaction report to tracing and resolving the funds
  • The roles of originating, receiving, and subsequent receiving institutions
  • Account owners’ responsibilities during verification
  • Service timelines, escalation steps, and customer communications
  • Information-sharing, documentation, confidentiality, and security controls
  • Preventing malicious reports and tracing funds across multiple transactions
  1. Legal Liabilities for AFASA Violations

Institutional responsibilities and individual accountability

  • AFASA-prohibited acts and potential criminal consequences for individuals and institutions
  • When an institution may be required to reimburse an account owner because of inadequate controls or failure to exercise the required diligence
  • Potential liability for failing to hold disputed funds when required
  • Administrative consequences for holding funds improperly or beyond the permitted period
  • Potential consequences of malicious or bad-faith reporting
  • Protections for institutions and personnel acting in good faith and in accordance with BSP rules or orders
  • Practical steps for documenting decisions, escalating concerns, and reducing legal risk

Resource Speakers from the BANGKO SENTRAL NG PILIPINAS and BANKERS ASSOCIATION OF THE PHILIPPINES

ATTY. ELMORE O. CAPULE
Deputy Governor
Corporate Services Sector, BSP

ATTY. CHARINA B. DE VERA-YAP
Managing Director
Consumer Financial Health and Empowerment Sub-Sector, BSP

ATTY. JANICE G. AYSON-ZALES
Director
Consumer Complaints and Resolution Office, BSP

MS. ROCHELLE D. TOMAS
Director
Consumer Protection & Market Conduct Office, BSP

ATTY. ALAIN BERT G. REGIS
Director
Consumer Account Protection Office, BSP

MS. MARICRIS A. SALUD
Deputy Director
Technology Risk & Innovation Supervision Department, BSP

MR. CESAR C. SANTOS, JR.
Managing Director
BAP Data Exchange, BAP

Target Participants:

Representatives from all interested BAIPHIL member and non-member banks and other financial institutions under BSP jurisdiction, particularly the following:

– Board of Directors
-Senior Management
-Branch Banking Sector
-Regional/Branch Heads or any authorized branch personnel
-Personnel from the Consumer Protection Department/Unit
-Fraud Management Team
-CCO and Compliance Officers
-CRO and Operational Risk Officers
-IT Officers
-Legal Department/Group
-Frontline Personnel
-Compliance Personnel
-Internal Auditors

Schedule:
11  November 2026, Wednesday, 9:00 AM – 4:30 PM

Training Fee per Participant:
Member Institution – Php 3,920.00
Non-Member Institution – Php 5,040.00
*VAT Inclusive

REGISTER HERE!