Clari5 Market Insights
PHILIPPINES
The Anti-money Laundering Council
Regulatory Reporting Guidelines for FIs for Fraud and Money Laundering
Philippines’ AMLC Sets Out Regulatory Reporting Guidelines for Financial Institutions for Fraud and Money Laundering
By when must Financial Institutions (FIs) comply with the mandate?
All FIs must meet these guidelines with immediate effect.
Highlights of the guidelines
The Anti-money Laundering Council (AMLC), the Philippines’ Financial Intelligence Unit had amended the AMLC Registration and Reporting Guidelines (ARRG) in view of the issuance of AMLC Regulatory Issuance (ARI) No. 1, series of 2020, amending certain provisions of the 2018 Implementing Rules and Regulations of Republic Act No. 9160, also known as the Anti-money Laundering Act of 2001, and ARI No. 3, series of 2020, approving the deferment of reporting of specific transactions identified as low risk transactions for money service businesses (MSBs).
Salient Features of the 2021 ARRG Include the Following:
- Comprehensive definition of “covered persons” to include certain types of designated non-financial businesses and professions.
- Definition of “covered transaction” for real estate developers and brokers.
- Delegated authority to the Executive Director of the AMLC to require submission of all covered transactions, including low risk, of persons subject to AMLC investigation.
- Requirement to include specific details of the covered person’s reporting chain / process in its Money Laundering / Terrorism Financing Prevention Program.
- Clarification of rules as regards timing of submission of suspicious transaction reports (STRs) [specifically the identification of applicable reporting and determination periods].
- Clarification on non-working and non-reporting days in terms of the counting of the prescribed reporting period, including automatic suspension thereof.
- Removal of loan payment as a low-risk transaction.
- Provision of a list of low risk covered transactions involving Operators of Payment System.
- Incorporation of previously approved low risk covered transactions involving MSBs.
- Renaming of “no / low risk” covered transactions to “low risk” covered transactions.
- Introduction of new provisions on compliance-checking and administrative sanctions.
- Updated online registration guidelines.
- Inclusion of STR trigger in the reporting of STRs.
- Updating of the reason for suspicion to include two (2) new predicate crimes.
- Guidelines in the reporting of loan availing and sale of real and other properties acquired.
- Addition of new transaction codes.
- Updating of country and currency codes.
- Provision of guidelines in suspicious transaction reporting on a per account basis.
- Provision of a list of “red flags” and transaction codes involving real estate transactions and those concerning virtual asset service providers.
How Clari5 helps Philippines’s FIs quickly comply with AMLC’s guidelines
Highlights
Advantages
Highlights
- Clari5’s Regulatory Reporting Module supports regulatory reporting for timely filing along with integrated role-based reports and dashboards for any investigator or supervisor with Philippines relevant transaction codes, AMLC codes and country codes according to AMLC 2021 guidelines’ header record, detail record and trailer record.
- Supports inclusion of reasons for filing STR for as many datapoints as needed, during the process of filing the Suspicious Transaction Report.
- Subsequent no-risk, low-risk or high-risk parameters identified and included as part of reporting guidelines.
- Clari5 is also available as an end-to-end AML compliance solution that can be easily integrated with Clari5 Fraud Management System along with our pre-packaged AML scenarios, various parameters like Threshold & Time Duration can be configured based on the business policies. These scenarios cover recommendations made by various regulatory agencies for real-time transaction processing.
- Also has a Real-time Customer Due Diligence module and Enhanced Due Diligence module which can be integrated to any type of watchlist, PEP list and has capabilities to screen any parameter or entity.
- Enables profile-based risk assessments and periodic reassessments of onboarded customers and entities with high-risk red flags.
Advantages
- Also available as a Unified FMS at FI Level covering both AML and fraud risk mitigation across digital and physical channels, across all products and services.
- Extensive library of rule-based scenarios covering all products & channels reflecting years of real-life experience across 25+ geographies; authoring tool to modify / add to this library.
- Clari5’s web-based Scenario Authoring Tool configures new scenarios as / when required, without any coding or effort from the IT team.
- Parallel use of AI / ML tools and graph analytics to extract new patterns, deploy them for better detection rates with lower false positives.
- Entity link analysis feature helps expose customer / account associations and organized money laundering and fraud crime rings.
- Case Management System to shrink analyst time on false positive investigation, using AI / ML driven models on past resolution data; workflow-driven investigation in a configurable centralized or decentralized manner.
- Quicker implementation because of prepackaged scenarios and built-in interfaces for integration.
- Low-cost commodity hardware infrastructure leading to reduced TCO.