Small, repeated payments can look ordinary on their own but reveal suspicious patterns when viewed together. That’s why the Philippine AML/CFT framework expects monitoring to assess each customer’s activity over time and across accounts, rather than test individual payments against a threshold. AMLC and BSP red flags include many-to-one transfers, remittances collected from different branches in the same city, and deposits kept just under the PHP 500,000 reporting threshold.
The obligations sit across several instruments: AMLA and its Implementing Rules and Regulations, Part IX of the MORB and MORNBFI, BSP Circular 1230, AMLC’s GoTRACS, and BSP Memorandum M-2023-013. Together they require institutions to aggregate each customer’s activity across accounts, reach a documented decision on every alert within the GoTRACS determination periods, and show BSP that their monitoring rules are tested and effective.
This brief brings these requirements together in one place, with their sources, and maps each one to a practical transaction monitoring setup.
What’s inside
- The Philippine framework in three layers: primary legislation, BSP regulation and supervisory guidance, and AMLC rules
- The thresholds and timelines that matter: PHP 500,000 covered transactions, CTRs within five working days, STR determination periods, and EDD on cash payouts above PHP 1,000,000
- Typologies and red flags from AMLC’s 3rd National Risk Assessment, GoTRACS and AMLC’s anti-trafficking rules, including cyber-enabled fraud indicators
- What BSP expects from a transaction monitoring system, from data controls and rule design to testing, case management and reporting
- How Sumsub AML Transaction Monitoring supports each obligation, one by one
Who it’s for
Compliance, AML and financial crime teams at BSP-supervised banks, digital banks, e-money issuers, and remittance and transfer companies.
