– Philippine AML/CTPF Structure and Supervising Authorities

• Core functions of BSP

– BSP AML Regulations (Updates as of 2024)

– Memorandum to BSP Supervised FIs (Updates as of 2025)

– Elements of Sound ML/TF/PF Risk Management Framework (with discussion on common relevant findings/issues)

– Q&A

Director

Financial System Integrity Department (FSID)

Bangko Sentral ng Pilipinas

Atty. Leigh Vhon G. Santos Manager

FSID, BSP

– Risk Management Practices on Handling Adverse or Negative Media Reports

– Q&A

Deputy Director

FSID, BSP

I. Contents of a Suspicious Transaction Report (STR)

A.     Regulatory expectation (GoTRACS): STRs must be complete, accurate, and timely, with required supporting documents uploaded.

B.     “Meaningful” STR – must answer:

1.     WHO – persons/entities involved; roles; relationships.

2.     WHAT – activity of concern; suspected offense

3.     WHEN – date(s), frequency, and patterns of transactions.

4.     WHERE – branches, channels, locations, jurisdictions involved.

5.     WHY – clear grounds for suspicion.

6.     HOW – type of transactions (cash, wire transfers, cash couriers, other instruments).

C.     Mandatory uploading of KYC documents (GoTRACS, Ch. II, Sec. 4.8): For STRs involving certain serious predicate crimes, such as (1) Kidnapping for ransom, drug trafficking, graft and corrupt practices; (2) Hijacking, destructive arson, murder; (3) Financing of terrorism; (4) Anti-trafficking (violations of Secs. 4–6 of Anti-Trafficking in Persons Act); (5) Online Sexual Abuse or Exploitation of Children (OSAEC) / Child Sexual Abuse or Exploitation Materials (CSAEM); and (6) Offenses under the Strategic Trade Management Act related to proliferation of Weapons of Mass Destruction and its financing.

II. Potential Suspicious Circumstances & Red Flag Indicators (Annex “U” – GoTRACS)

A.     System and controls requirement: Covered persons must have systems that alert responsible officers to circumstances that may give rise to suspicion of ML/TF.

B.     Reference for institutions: Use Annex “U” (Typologies, Red Flags, and Suspicious Indicators) to calibrate your internal red flag library and transaction monitoring scenarios.

III. Timeliness of STR Filing (GoTRACS Filing Codes & Determination Date)

A.     General principle: Covered persons must establish/determine suspicion within the prescribed 10-day or 60-day period and file the appropriate GoTRACS STR by the next working day using the correct filing code.

B.     GoTRACS Filing Codes:

1.     STRR – Regular suspicious circumstance.

2.     STRA – On AMLC instruction

3.     STRHP – High-priority predicate crimes.

4.     STRHU – Highly unusual transactions.

C.     Determination Date: Date when the covered person knew or ought to have known the suspicious nature of the transaction, or was advised/alerted that a transaction/series of transactions may relate to an unlawful activity or suspicious circumstance.

D.     Key timelines by scenario:

1.     Transactions with suspicious circumstances (AMLA / TFPSA):

i.     Establish existence of suspicious circumstance within 10 calendar days from transaction or determination date.

ii.     File STRR next working day.

2.     Transactions/persons related to an unlawful activity (Rule 3, 2018 IRR):

i.     Up to 60 calendar days to establish that transaction or person is related to an unlawful activity/ML offense.

ii.     File STRR next working day.

3.     Referrals from AMLC:

i.     If the unlawful activity is specified: establish suspicion within 10 days from receipt; file STRR next working day.

ii.     If the unlawful activity is not specified: up to 60 days from receipt to determine; file STRR next working day.

iii.     If the Executive Director requires STRA: file within next working day from receipt or as stipulated; ESOA & KYC mandatory.

4.     High-priority predicate crimes:

i.     Suspicion must be established on the date of the transaction/activity.

ii.     File STRHP next working day.

5.     Highly unusual/suspicious transactions (STRHU):

i.     For immediately apparent suspicion (e.g., accounts subject to bank inquiry/freeze/APO; known TF-related; sanctions-listed persons; cases requiring urgent law enforcement action).

ii.     File STRHU next working day.

6.     Targeted Financial Sanctions (TFS):

i.     On target/potential target matches and related accounts, file STRR (trigger code “G”) on the same day the freeze is implemented; KYC documents mandatory.

7.     TMS-generated alerts:

i.     Within 60 calendar days from case creation date arising from TMS alerts, establish suspicion.

ii.     File STRR on the next working day after the 60-day period.

Executive Director

Anti-Money Laundering Council Secretariat (AMLC)