Philippines Anti-Money Laundering Act (RA 9160)

Republic Act No. 9160, as amended.

The processing or handling of proceeds of unlawful activity through acts defined by law, often to conceal their criminal origin or facilitate their use.

Placement, layering, and integration.

The introduction of illicit proceeds into the financial system or another channel where they can be processed.

The use of transactions or transfers to obscure the origin, ownership, or movement of illicit proceeds.

The reintroduction or use of illicit proceeds in the legitimate economy so that they appear to come from lawful sources.

No. They are analytical concepts; criminal liability depends on the elements of the applicable statutory offense.

The Anti-Money Laundering Council or AMLC.

The Governor of the Bangko Sentral ng Pilipinas as chairperson, the Insurance Commissioner, and the Chairperson of the Securities and Exchange Commission.

A person or entity within the categories designated by the AMLA, as amended, that must comply with applicable anti-money laundering obligations.

A transaction exceeding an applicable statutory reporting threshold for the relevant category of covered person, subject to the AMLA and implementing rules.

A transaction exhibiting statutory indicators of suspicious activity, regardless of amount, under the Anti-Money Laundering Act.

No. Suspicious transaction reporting is based on legally specified indicators and may apply regardless of transaction amount.

A report submitted by a covered person concerning a transaction that meets an applicable covered transaction reporting threshold.

A report submitted by a covered person concerning a transaction meeting the statutory criteria for suspicious activity.

More than PHP 500,000 within one banking day, subject to the applicable statutory category and current rules.

A single casino cash transaction involving more than PHP 5 million or its equivalent, subject to applicable law.

Covered transactions are primarily threshold-based, while suspicious transactions depend on specified indicators of potential unlawful activity.

The process of identifying and verifying customers and relevant beneficial owners, understanding relationships, and assessing associated risks.

Additional verification, investigation, or monitoring measures applied to customers or transactions presenting elevated money laundering or terrorist financing risk.

The natural person who ultimately owns or controls a customer or on whose behalf a transaction or activity is conducted, as defined by applicable rules.

It helps determine who ultimately controls assets or transactions despite intermediaries or formal ownership structures.

A person entrusted with a prominent public function, including relevant related persons as defined by applicable regulations.

No. PEP status is a risk consideration requiring appropriate due diligence, not proof of wrongdoing.

The examination of financial activity to identify patterns, anomalies, or indicators that may require further review or reporting.

The division of transactions into smaller amounts or separate operations, potentially to evade reporting or detection requirements.

A form of structuring involving multiple persons or transactions used to distribute financial activity and potentially avoid scrutiny.

A legal entity with little or no substantial independent operations, which may be used lawfully or misused to conceal financial activity or ownership.

Shell companies can have legitimate purposes; investigators must establish relevant unlawful activity and the statutory elements of the offense.

An arrangement in which one person formally holds an interest or acts on behalf of another, requiring examination of actual ownership and control.

The systematic identification and tracking of property, funds, or other assets through records and transactions to determine their origin, movement, control, or location.

The analysis of relevant financial activity, assets, income, liabilities, and transactions to identify inconsistencies or investigative leads.

An examination of where the money used in a particular transaction originated.

An examination of how a person accumulated their overall assets or wealth.

Source of funds concerns money used in a specific transaction; source of wealth concerns the broader origin of accumulated assets.

To organize deposits, withdrawals, transfers, purchases, and related events chronologically for analysis and verification.

A visual representation of the movement of money or assets among accounts, persons, or entities.

A circumstance or pattern suggesting elevated risk or a need for further investigation, without independently proving criminal conduct.

To identify unexplained discrepancies that may warrant lawful investigation and verification.

The discrepancy may have lawful explanations and does not independently establish the elements of a money laundering offense.

To authorize examination of specified deposits or investments under the conditions and safeguards prescribed by law.

No. Its authority is governed by statutory conditions, applicable court authorization requirements, exceptions, and procedural safeguards.

A legal measure restricting dealings with specified monetary instruments or property under the conditions and procedures established by law.

To prevent the dissipation or transfer of assets while authorized legal proceedings or investigations continue.

A legal proceeding seeking forfeiture of monetary instruments or property related to unlawful activity under applicable statutory and procedural requirements.

Freezing temporarily restricts dealing with assets; forfeiture results in their legal confiscation or transfer following the required proceedings.

Possible structuring, while considering the complete transaction pattern, reporting rules, and legitimate explanations.

Verify the commercial purpose, counterparties, beneficial ownership, transaction records, and possible unlawful connections before drawing conclusions.

No. Investigators must examine lawful income, assets, liabilities, possible underlying unlawful activity, and the applicable offense elements.

A valid legal basis and compliance with applicable bank secrecy, AMLA, court authorization, and procedural requirements.