AMLC Registration and Reporting Guidelines for Casinos

February 21, 2018 AMLC REGULATORY ISSUANCE (C) NO. 01-18 SUBJECT : AMLC Registration and Reporting Guidelines for Casinos By the authority vested to the Anti-Money Laundering Council (AMLC) to implement measures as may be necessary and justified to counteract money laundering, in accordance with Section 7 (7) of Republic Act (RA) No. 9160, also known as the Anti-Money Laundering Act of 2001, as amended (AMLA), the Council, in its Resolution No. 25, dated 19 February 2018, approved the adoption of the AMLC Registration and Reporting Guidelines for Casinos (ARRGC), and issue the same as an AMLC Regulatory Issuance (ARI). SECTION 1. General Provisions . A. Financial Action Task Force (FATF) Standards. The FATF is an inter-governmental policy-making body established in 1989 which sets the standards and promote effective implementation of legal, regulatory and operational measures for combating money laundering, terrorist financing and other related threats to the integrity of the financial system. The FATF has developed a series of Recommendations that are recognised as the international standard for combating of money laundering, terrorist financing, and proliferation of weapons of mass destruction. These Recommendations form the basis for a coordinated response to these threats to the integrity of the financial system and help ensure a level playing field. The FATF monitors the progress of its members in implementing necessary measures, reviews money laundering and terrorist financing techniques and counter-measures, and promotes the adoption and implementation of appropriate measures globally. A key element in the fight against money laundering and terrorist financing is the need for countries' systems to be monitored and evaluated, with respect to these international standards. The mutual evaluations conducted by the FATF and FATF-style regional bodies (such as the Asia Pacific Group on Money Laundering [APG] of which the Philippines is a member-country), as well as the assessments conducted by the International Monetary Fund (IMF) and the World Bank (WB), are vital mechanisms for ensuring that the FATF Recommendations are effectively implemented by all countries. FATF Recommendation No. 24 requires that Designated Non-Financial Businesses and Professions (DNFBPs) shall be subject to regulatory and supervisory measures as set out below: 1. Casinos should be subject to a comprehensive regulatory and supervisory regime that ensures that they have effectively implemented the necessary anti-money laundering and terrorist-financing measures. At a minimum: a. casinos should be licensed; b. competent authorities should take the necessary legal or regulatory measures to prevent criminals or their associates from holding or being the beneficial owner of a significant or controlling interest, holding a management function in, or being an operator of a casino; c. competent authorities should ensure that casinos are effectively supervised for compliance with requirements to combat money laundering and terrorist financing. 2. Casinos should ensure that other categories of DNFBPs are subject to effective systems for monitoring and ensuring their compliance with requirements to combat money laundering and terrorist financing. This should be performed on a risk-sensitive basis. This may be performed by a government authority or by an appropriate self-regulatory organization, provided that such an organization can ensure that its members comply with their obligations can ensure that its members comply with their obligations to combat money laundering and terrorist financing. B. Legal Framework. 1. Anti-Money Laundering Act . RA No. 9160 or the AMLA was signed into law on 29 September 2001, and took effect on 17 October 2001. It was amended by RA Nos. 9194, 10167 and 10365, which took effect on 23 March 2003, 06 July 2012 and 07 March 2013, respectively. The Implementing Rules and Regulations of the AMLA took effect on 02 April 2002. It was amended by the 2016 Revised Implementing Rules and Regulations (2016 RIRR), which took effect on 09 August 2017. On 14 July 2017, RA No. 10927 was signed into law, designating casinos as covered persons under the AMLA. It took effect on 29 July 2017. The "Casino Implementing Rules and Regulations of Republic Act No. 10927" (CIRR) took effect on 04 November 2017. 2. Terrorism Financing Prevention and Suppression Act . RA No. 10168, otherwise known as the Terrorism Financing Prevention and Suppression Act of 2012 (TFPSA) was signed into law on 18 June 2012, and took effect on 05 July 2012. The Implementing Rules and Regulations of TFPSA took effect on 09 August 2017. In relation to RA No. 10168, the AMLC issued Resolution Nos. TF-01 and TF-02, Series of 2012, directing the freezing without delay of property or funds, including related accounts, of designated terrorist individuals and entities named in the Al-Qaida Sanctions List pursuant to United Nations Security Council (UNSC) Resolution Nos. 1267/1989 and Taliban 1988 Sanctions List pursuant to UNSC Resolution No. 1988. C. Covered Persons. The following are the Covered Persons (CPs) under the AMLA: 1. Banks, non-banks, quasi-banks, trust entities, pawnshops, non-stock savings and loan associations, electronic money issuers, foreign exchange dealers, money changers, remittance and transfer companies, and all other persons and their subsidiaries and affiliates, supervised or regulated by the Bangko Sentral ng Pilipinas (BSP). 2. Insurance companies, pre-need companies, insurance agents, insurance brokers, professional reinsurers, reinsurance brokers, holding companies, holding company systems, mutual benefit associations, and all other persons supervised or regulated by the Insurance Commission (IC). 3. Securities dealers, brokers, salesmen, investment houses and other similar persons managing securities or rendering services as investment agent, advisor, or consultant; mutual funds or open-end investment companies, close-end investment companies or issuers, and other similar entities; other entities administering or otherwise dealing in commodities or financial derivatives based thereon, valuable objects, cash substitutes and other similar monetary instruments or properties, supervised or regulated by the Securities and Exchange Commission (SEC). 4. The following Designated Non-Financial Businesses and Professions (DNFBPs): a. Jewelry dealers, dealers in precious metals, and dealers in precious stones. b. Company service providers which, as a business, provide any of the following services to third parties: i. acting as a formation agent of juridical persons; ii. acting as (or arranging for another person to act as) a director or corporate secretary of a company, a partner of a partnership, or a similar position in relation to other juridical persons; iii. providing a registered office, business address or accommodation, correspondence or administrative address for a company, a partnership or any other legal person or arrangement; and iv. acting as (or arranging for another person to act as) a nominee shareholder for another person. c. Persons, including lawyers and accountants, who provide any of the following services: i. managing of client money, securities or other assets; ii. management of bank, savings or securities accounts; iii. organization of contributions for the creation, operation or management of companies; and iv. creation, operation or management of juridical persons or arrangements, and buying and selling business entities. Lawyers and accountants who are: (1) authorized to practice their profession in the Philippines, and (2) engaged as independent legal or accounting professionals, in relation to information concerning their clients, or where disclosure of information would compromise client confidences, or the attorney-client relationship, are not covered persons. 5. Casinos, including internet and ship-based casinos, with respect to their casino cash transactions related to their gaming operations. a. 'Casino' refers to a business authorized by the appropriate government agency to engage in gaming operations: i. 'Internet-based casinos' shall refer to casinos in which persons participate by the use of remote communication facilities such as, but not limited to, internet, telephone, television, radio or any other kind of electronic or other technology for facilitating communication; and ii. 'Ship-based casino' shall refer to casinos, the operation of which is undertaken on board a vessel, ship, boat or any other water-based craft wholly or partly intended for gambling. b. 'Casino cash transaction' refers to transactions involving the receipt of cash by a casino paid by or on behalf of a customer, or transactions involving the payout of cash by a casino to a customer or to any person in his/her behalf; and c. 'Gaming operations' refer to the activities of the casino offering games of chance and any variations thereof approved by the appropriate government authorities. D. Transaction Reporting Obligation. Section 9 (c) of the AMLA requires all CPs to the AMLC all covered transactions and suspicious transactions within five (5) working days from occurrence thereof. E. Covered Transaction Reports (CTRs). 1. "Covered Transaction" refers to a single casino cash transaction involving an amount in excess of Five million pesos (P5,000,000.00) or its equivalent in any other currency. "Casino Cash Transaction" refers to a transaction involving the receipt or payout of cash by and of a casino, paid or received by or on behalf of a customer, or such other cash transactions that may be determined by the AMLC and the AGA. 2. CTRs shall be filed within five (5) working days from occurrence of the transaction. 3. Submission of CTRs beyond 12:01 am of the day following the 5th working day from occurrence of the transaction shall be considered as non-submission of CTRs and may be subject to appropriate administrative sanction, if circumstances so warrant. F. Suspicious Transaction Reports (STRs). 1. "Suspicious Transaction" refers to a transaction, regardless of amount, where any of the following suspicious circumstances or indicators exists: a. There is no underlying legal/trade obligation, purpose or economic justification; b. The client is not properly identified; c. The amount involved is not commensurate with the business or financial capacity of the client; d. Taking into account all known circumstances, it may be perceived that the client's transaction is structured in order to avoid being the subject of reporting requirements under the AMLA; e. Any circumstance relating to the transaction which is observed to deviate from the profile of the client and/or the client's past transactions with the covered person; f. The transaction is in any way related to an unlawful activity or any money laundering activity or offense under the AMLA, that is about to be, is being or has been committed; or g. Any transaction that is similar, analogous or identical to any of the foregoing. 2. Recognizing Suspicious or Unusual Transactions. Customer Identification Process (CIP), Customer Due Diligence (CDD) and Ongoing Monitoring of customers provide the basis for recognizing unusual and suspicious transactions and events. An effective way of recognizing suspicious activity is knowing enough about customers, their circumstances and their normal expected activities to recognize when a transaction or instruction, or a series of transactions or instructions, is unusual warranting the conduct of an internal inquiry, investigation and suspicious transaction reporting. Likewise, it is essential for CPs to sufficiently know and understand the customer's business, to recognize whether a transaction or a series of transactions is unusual and, from an examination of the unusual transaction, whether there is a suspicion of money laundering. Where a transaction is inconsistent in amount, origin, destination, or type with a customer's known, legitimate business or personal activities, among other things, the transaction should be considered unusual and the covered person should be put on alert. Where the inquiries do not provide a satisfactory explanation of the activity or transaction, an internal report should be made and properly escalated to the designated compliance officer and/or review committee to determine if there are grounds for suspicion warranting the filing of the STRs. 3. Alerts and Red Flags. CPs should have systems in place that would alert its responsible officers of any suspicious circumstance or indicator that would give rise to a determination that a suspicious transaction exists. The following is a list of non-exhaustive examples of situations or red flag indicators that may give rise to any of the suspicious circumstances or indicators: a. transactions or instructions which have no apparent legitimate purpose and/or appear not to have a commercial rationale; b. transactions, instructions or activity that involve apparently unnecessary complexity or which do not constitute the most logical, convenient or secure way to do business; c. where the transaction being requested by the customer, without reasonable explanation, is out of the ordinary range of services normally requested, or is outside the experience of the financial services business in relation to the particular customer; d. where, without reasonable explanation, the size or pattern of transactions is out of line with any pattern that has previously emerged; e. where the customer refuses to provide the information requested without reasonable explanation or who otherwise refuses to cooperate with the CDD and/or ongoing monitoring process; f. where a customer who has entered into a business relationship uses the relationship for a single transaction or for only a very short period without a reasonable explanation; g. the extensive use of trusts or offshore structures in circumstances where the customer's needs are inconsistent with the use of such services; h. transfers to and from high risk jurisdictions without reasonable explanation, which are not consistent with the customer's declared business dealings or interests; and i. unnecessary routing of funds or other property from/to third parties or through third party accounts. CPs are encouraged to develop their own list of alerts or red flag indicators taking into account the nature of their business, type of customers and risks involved. 5. n Internal Analysis, Investigations and Escalation. CPs shall formulate a reporting chain under which a possible suspicious transaction will be processed, analyzed and investigated. The reporting chain should include the designation of a Board Level or approval Committee or the Chief Compliance Officer as the ultimate decision maker on whether or not the covered person should file a report to the AMLC. The reporting chain, with reasonable timeframes starting from flagging, analysis, investigation, escalation and until the final decision is made, shall be clearly written in the covered person's Money Laundering and Terrorism Financing Prevention Program (MLPP). CPs should ensure that proper controls are in place to guarantee confidentiality of the process and that no "tipping-off" of customers will happen at all times during the entire proceedings. For this reason, the Compliance Officer shall have access to all customer information files and transactions through the electronic or manual customer monitoring system. 6. Timing and Manner of Submission of STRs. CPs shall file STRs that are complete, accurate and timely in accordance with the following guidelines: a. CPs shall report to the AMLC all suspicious transactions within five (5) working days from the occurrence thereof. b. "Occurrence" refers to the date of determination of the suspicious nature of the transaction, which determination shall be made not exceeding ten (10) calendar days from date of transaction. c. Highly unusual or suspicious transactions, activities or circumstances conducted in the presence of, or immediately known or apparent to, the personnel handling the transaction shall be reported to the AMLC within five (5) working days from the date of the transaction. A "highly unusual" or suspicious transaction is one where, at the moment of transaction, the person handling the transaction has knowledge and reason to suspect that the funds being transacted are related to an unlawful activity. Knowledge shall include: i. Actual knowledge; ii. Knowledge of circumstances which would indicate facts to a reasonable person; and iii. Knowledge of circumstances which would put a reasonable person on inquiry. d. For transactions triggered under an existing suspicious transaction monitoring system (TMS) where the suspicious transaction circumstances or indicators have been conclusively incorporated to the system, said transaction shall be reported within five (5) working days from the date of transaction. e. Where the circumstances for filing an STR has no corresponding transaction, or when the TMS-generated alert is only a ground for the covered person to conduct an internal analysis, investigation and escalation, determination of the suspicious nature of the circumstances shall be made within a reasonable period of time. In such case, the covered person shall submit the corresponding STR using the "ZSTR" transaction code within five (5) working days after the said reasonable period, which in no case shall exceed sixty (60) calendar days from the time the circumstances were flagged. The report to be submitted in accordance with this item shall be comprehensive enough to establish the complete circumstances for the filing of the report. f. In cases where the transaction is in any way related to an unlawful activity, or the person transacting is involved in or connected to an unlawful activity or money laundering offense, the ten (10) calendar day determination period shall be reckoned from the date the covered person knew of, or should have known, the suspicious transaction indicator. To determine whether the covered persons knew or should have known the suspicious transaction indicator, they shall be given reasonable period of time, which in no case shall exceed sixty (60) calendar days, to gather facts in order to enable the submission of a meaningful STR. g. The reasonable period shall be indicated in the covered person's MLPP. The MLPP shall be duly approved by the covered person's Board of Directors, as well as the designation of the Board approved Committee or Board Level Committee or duly authorized Senior Officer as the Body or Officer who shall make the final determination of whether or not an STR should be filed. 7. Uploading of KYC Documents is mandatory for transactions related to any of the following Predicate Crimes: PC1 Kidnapping for Ransom PC2 Drug Trafficking PC12 Hijacking; destructive arson; and murder, including those perpetrated by terrorists against non-combatant persons and similar targets PC13 Terrorism and conspiracy to commit terrorism PC14 Financing of Terrorism If the AMLC Secretariat, requests for the KYC Documents for STR previously filed with the AMLC, wherein, subject of the STR has an existing money laundering case, CPs should be able to upload said KYC documents. See Section 4.B.3 of this ARI for the step-by-step procedure in the Uploading of KYC Documents. 8. Should a transaction be determined to be both a covered and a suspicious transaction, the CP shall report the same as a suspicious transaction. G. Guidelines in Reckoning CPs' Compliance with the Prescribed Reporting Period. 1. The following non-working days are excluded from the counting of the prescribed reporting period: a. weekend (Saturday and Sunday); b. official regular national holiday; and c. officially declared national holiday and workday suspensions. 2. A "non-reporting day" may be declared by the AMLC Secretariat when the File Transfer and Reporting Facility (FTRF), used by the CPs in transmitting their electronic reports to AMLC is unavailable to all CPs for at least five (5) consecutive hours during the day. a. AMLC-declared "non-reporting day" is excluded from the counting of the prescribed reporting period. b. The Executive Director or, in his absence, the Officer-in-Charge of the AMLC Secretariat is authorized to declare such day as a "non-reporting day." 3. Officially declared non-working days in localities or regions affected by natural calamities such as flood, typhoon, earthquake, etc. may be excluded from the counting of the prescribed reporting period for CPs located in the affected localities or regions subject to submission of deviation request by the CP. CPs' request for deviation shall be subject to approval of the Executive Director or, in his absence, the Officer-in-Charge of the AMLC Secretariat. H. Ensuring Accuracy and Completeness of CTRs and STRs. The Appropriate Government Agencies (AGAs) shall ensure that casinos, casino operators and licensees, and integrated resorts under their respective regulation shall install an anti-money laundering/counter-terrorism financing (AML/CTF) reportorial system within a reasonable time, not to exceed ninety (90) days from publication of this ARI, upon consultations with the AMLC. Section 29 of the CIRR states that CPs shall ensure the accuracy and completeness of CTRs and STRs, which shall be filed in the forms prescribed by the AMLC and shall be submitted in a secured manner to the AMLC in electronic form. Casinos shall ensure the accuracy and completeness of CTRs and STRs in accordance with the reporting procedures prescribed by the AMLC. I. Applicability of the Rules on the Imposition of Administrative Sanctions. Violations of this ARI shall be subject to administrative sanctions, in accordance with the "Rules on the Imposition of Administrative Sanctions under Republic Act No. 9160, as Amended," which took effect on 09 August 2017. The "Rules on the Imposition of Administrative Sanctions under Republic Act No. 9160, as Amended," applies to casinos, pursuant to Section 37 of the CIRR. Covered persons should note that non-filing, late filing, and filing of incomplete and/or inaccurate CTRs/STRS, among others, constitute violations of the AMLA and the CIRR. J. Implementation. This ARI shall be implemented immediately after its effectivity, except for the provisions of Section 4 (Reporting System) hereof, which shall be implemented ninety (90) days after its effectivity. To enable casinos to test their respective systems, the AMLC Secretariat undertakes to make itself available to accept reports sixty (60) days after publication of this ARI. K. Effectivity. This ARI shall take effect fifteen (15) calendar days after its publication in a newspaper of general circulation, and filing with the Office of the National Administrative Register at the University of the Philippines Law Center. SECTION 2. Online Registration System . One of the many functions of the Anti-Money Laundering Council (AMLC) is "To require and receive covered or suspicious transaction reports (CTRs/STRs) from covered casinos" (Rule IV, Section 7a). In addition, Rule 8, Section 32 of the CIRR of the AMLA states that "All casinos shall register with the AMLC's electronic reporting system within ninety (90) days from the effectivity of this CIRR." In order to transmit CTRs and STRs, CPs need to register with the AMLC in order to be given access to the AMLC Portal. The Online Registration System for CPs will allow Compliance Officers to manage their user accounts as well as that of their alternates. The system will also provide a means of monitoring CP's user accounts by requiring Compliance Officers to update their information every two (2) years. A. Guidelines. 1. Before proceeding with the Online Registration, Compliance Officers (COs)/Associated Persons (APs)/Primary Designated Officers (PDOs) should have document/s showing his/her designation. Documents should be uploaded in PDF format. Notarized Secretary Certificate showing the appointment of the Compliance Officer, Rule V, Section 13 and 14 of the CIRR requires the designation of an AML Compliance Officer, who shall at least, be of senior management level. 2. COs should download the Transaction Security Protocol Manual (Section 2 this ARI) from www.amlc.gov.ph and perform the following steps: a. Download the Gnu Privacy Guard (GPG) software from www.amlc.gov.ph under the Reporting Tools tab. b. Install the GPG Software. c. Generate public key. d. Export public key (file extension is .asc). Be ready with your exported asc file as this will be needed during online registration e. Get and save the AMLC public key (amlc.asc) from www.amlc.gov.ph under the Reporting Tools tab. f. Import the AMLC Public key (amlc.asc). g. Certify and Sign AMLC Public key. h. Back-up of COs Public key. 3. Once Items 1-2 have been performed/accomplished, COs may now proceed with the Online Registration (https://portal.amlc.gov.ph). 4. Registration will be processed daily; cut-off time is 1:00 PM, registration received after 1:00 PM will be processed the following day. 5. The Secretariat will issue a Certificate of Registration, with the facsimile signature of the AMLCS Executive Director or the Officer-in-Charge to successfully-registered Casinos, upon request. The said certification will be sent via email as a PDF file. 6. A two (2)-year mandatory update of the registration via the Online Registration System is required. Failure to update the registration will result in the deactivation of the Casino's user access in the AMLC Portal. Log-on to https://portal.amlc.gov.ph 1. Click on Register 2. Covered Person/Casinos Registration page will appear, please read the instructions first before proceeding to Step 1 of 3. Step 1 of 3: Key in details of the Casinos and Contact Details of the Authorized Officer. Once step 1 of the Registration process is completed, click on Next to go to the 2nd step. Covered Person Registration Step 1 of 3: Covered Person Note: Be sure to have a scanned copy of your document/s stating your appointment as the CO; have generated your public key using Kleopatra and have your exported asc file before proceeding to the next page (Step 2 of 3). 3. Step 2 of 3 are the details of the CO, as well as the key details of their public key. This is also where the CO uploads supporting documents (PDF) of his/her appointment and his exported asc file. If there is no alternate, click "Done," otherwise click "Add Alternate." Step 2 of 3: Authorized Personnel 4. Continue to add details of the alternate (if any). Public key (Key details) of the Alternate is optional. Step 2 of 3: Authorized Personnel Alternate 1 Information If alternate generated a public key, please continue with the key details 5. Step 3 of 3 shows the Summary of Registration, if all details are correct, Click "Save"; to edit details of registration, Click "Previous," to exit page without saving, Click "Exit." Step 3 of 3: Summary of Registration 6. After you click Save, a window will appear, showing that Registration has been successful. Please take note of your Reference No. You will need this to check the status of your Registration. Registration Successful 7. To verify if your Registration has been successful, please check your registered email and click the link to verify your email address. Note: Email verification will be sent to the email address of the CO, as well as the designated alternate (if any). 8. After the CO and alternate have validated their email addresses, this page will appear, just click "Agree." Then click on the "Exit" button. Email Address Verification Status 9. To check the status of your Registration, log-in to https://portal.amlc.gov.ph , and click on Registration Status. Please enter the reference number of your Registration. If you have not received an email from AMLC requesting verification of your account, please check your registration status, it will show if the email address is still unverified , if still unverified, please check if the email address is correct and edit accordingly. Then click the "Resend" button. Registration Status 10. Once AMLC has processed your Registration, you will receive an email from AMLC whether Registration has been approved or disapproved. Below is a sample email of an approved Registration. Please note that AMLC can only approve your Registration when the Compliance Officer and all the registered alternate/s have verified their email addresses. 11. Once registration has been approved, log-in to https://portal.amlc.gov.ph to change your password. Please log in using the first 6-digits of your institution code, email address and system generated password. Change Password Once password has been changed, you can now start to access the AMLC portal. SECTION 3. Transaction Security Protocol Guidelines . A. Guidelines. 1. The File Transfer and Reporting Facility using the Hypertext Transfer Protocol over Secure Socket Layer (FTRF v 2.0) shall be used by the Casinos in transmitting their respective reports. 2. Hypertext Transfer Protocol over Secure Socket Layer (HTTPS) is a private, secure and graphical method of accessing web page information and/or sending information across a web. It is especially useful for encrypting forms-based information as it passes between clients and servers. HTTPS which is implemented under the File Transfer and Reporting Facility (FTRF v 2.0) will address the efficiency, integrity and security concerns of data collection from the Covered Persons. 3. File Transfer and Reporting Facility (FTRF) has the following features: 1. Secure upload provides data encryption, server authentication and message integrity; 2. Self-signed Digital Identification & Certificate allows encrypting and digital signing of messages; and 4. The self-signed digital identification shall be implemented for all Casinos. AMLC and the Casinos shall use the Gnu Privacy Guard (GPG) software for their encryption and authentication and the GPG supported algorithm (MD5) for their signing. Installer of the said software shall be provided by AMLC upon registration. 5. The Compliance Officer (CO) of the Casinos shall generate his private key as well as public key using GPG which shall be uploaded during the Online Registration. 6. The signed public key of the AMLC shall be used by the Casinos to: 1. Encrypt the electronic files (CTR/STR in csv format) to be submitted to AMLC; and 2. Verify the signature of the files they will receive from AMLC. 7. The signed private key of the AMLC shall be used by AMLC to: a. Decrypt the encrypted files sent by the Casinos which were encrypted using AMLC's signed public key; and b. Sign the electronic files they will send to the Casinos. 8. The signed public key of the COs shall be used by the AMLC to: a. Encrypt the validation messages that AMLC will send to the Casinos; and b. Verify the signature of the files AMLC will receive from the Casinos. 9. The signed private key of the COs shall be used by them to: a. Decrypt the AMLC validation messages from AMLC; and b. Sign the electronic files they will send to AMLC. 10. COs are required to encrypt and sign the electronic CTR/STR files before transmitting them to AMLC via https (AMLC portal). 11. In cases wherein the public key is compromised, superseded or no longer in use, COs should perform the recovery procedure, only if they have successfully performed the back-up procedure of their existing private and public keys, to be able to continue to encrypt file. Otherwise, a new pair of public and private keys shall be generated and to be uploaded via the Online Registration System. B. Procedures. 1. Installing the GnuPG for Windows Software (Gpg4win 2.1.0) Download the gpg4win 2.1.0 from www.amlc.gov.ph , under Reporting Tools, then save this to your local drive. Double click gpg4win-2.1.0.exe . You will be asked if you want to allow the program to make changes in your computer. Click Yes . The Installer Language window will be displayed on the screen. Select English , then click Ok . The Gpg4win Setup window will be displayed on the screen. Click Next . The License Agreement window will be displayed on the screen. Click Next . Select components to install. Check Kleopatra, GpgEX , and Gpg4win Compendium , then uncheck other components. Click Next . Specify destination folder, then, click Next . For 32 bit machine the default directory is C:\Program Files\GNU\GnuPG . For 64 bit machine the default directory is C:\Program Files (x86)\GNU\GnuPG . Select where Gpg4win shall install links. Check Start Menu and Desktop , then click Next . Choose Start Menu folder for the Gpg4win shortcuts. Enter Gpg4win , then click Install . Please wait while Gpg4win is being installed. Once the setup is completed successfully, click Next . Check Root certificate defined or skip configuration, then click Next . Click Finish . 2. Generation of Key Pairs (One time Procedure) From your desktop, double click Kleopatra . The Kleopatra main window will be displayed on the screen. Click File , then select New Certificate . Certificate Creation Wizard will be displayed on the screen. Click Create a personal OpenPGP key pair . Enter Details, then click Advance Settings . Note : Name Name of Compliance Officer Email Email address of Compliance Officer Comment Name of the Casino The Technical Details window will be displayed on the screen. From Key Material, select DSA: 2,048 bits (default) . Check + Elgamal: 2,048 bits (default) . From Certificate Usage, check Signing, Encryption and Certification . Click Ok . From the Certificate Creation Wizard window, click Next . From Certificate Creation Wizard, check Show all details , review the certificate parameters, then click Create Key . Pinentry window will be displayed on the screen. Enter Passphrase (gpg password of compliance officer), then click Ok . Re-enter passphrase, then click Ok . Please be reminded that once you forget your passphrase, you need to generate a new public key, since AMLC cannot retrieve the said passphrase. Wait until the key pair is successfully created. Click Finish . 3. Exporting Public Key From your desktop, double click Kleopatra . The Kleopatra main window will be displayed on the screen. Click the name of the compliance officer, then click Export Certificates . Select the directory where the public key is to be saved, then click Save . For 32 bit machine : c:\Program Files\GNU\GnuPG\ For 64 bit machine : c:\Program Files (x86)\GNU\GnuPG\ Note : The default filename of the public key is the key fingerprint. Please be ready with the exported asc file as you will need this for ONLINE REGISTRATION. 4. Saving AMLC public key Get a copy of the AMLC public key (amlc.asc) from www.amlc.gov.ph under Reporting Tools then save this to your local drive. For 32 bit machine : c:\Program Files\GNU\GnuPG\ For 64 bit machine : c:\Program Files (x86)\GNU\GnuPG\ 5. Importing of AMLC public key From your desktop, double click Kleopatra . The Kleopatra main window will be displayed on the screen. Click Import Certificates . Select the directory where you have saved the AMLC.asc , then click Open . The Certificate Import Result window will be displayed on the screen. Click Ok . The imported public key will be displayed on Kleopatra Imported Certificates tab. 6. Certifying AMLC Key From your desktop, double click Kleopatra . From Kleopatra main window, click Anti-Money Laundering Council's public key . From the menu bar, click Certificates , then click Certify Certificate . Check Anti-Money Laundering Council , then check I have verified the fingerprint . Click Next . Select Certify only for myself , then click Certify . Enter passphrase of compliance officer, then click Ok . Click Finish . 7. Backup Procedure Make sure to do this procedure to ensure that you will not perform all the steps enumerated above in the event that your public key has been corrupted. Open Kleopatra . From My Certificates tab, click the name of the key owner (Compliance Officer). From the menu bar, click File then select Export Certificates . Select the directory where you want to save the backup of your public key (USB), by default filename is your fingerprint. (You have the option to change the filename) Click Save. On My Certificates tab, click the name of the key owner (Compliance Officer). From the menu bar, click File then select Export Secret Keys . Select the directory where you want to save the backup of your private key (USB) by clicking the diskette icon. Create a filename for your secret key backup and select the directory where you want to save the backup of secret key (USB) then click Save. 8. Recovery Procedure This is done if the public key is compromised, only if the Casinos have performed the back-up procedure for their private and public keys. Follow the procedure in installing the GPG Software. Once installed, Open Kleopatra then click File then Select Import Certificate. Select the directory where the backup of your public key (.asc) is saved then click Open. Certificate Import Result window will appear then click Ok. To import your secret key, click file then select Import Certificate. Select the directory where the backup of your private key (.gpg) is saved then click Open. Certificate Import Result window will appear then click Ok. Repeat Procedures 4-6 of the Transaction Security Protocol. SECTION 4. Reporting Procedures . A. Covered/Suspicious Transaction Report. A.1 Data Elements Chart (Format Code 1.0) CASINOS A.2 Electronic Record Format (Format 1.0 Casinos) HEADER RECORD FIELD NO. FIELD NAME TYPE LENGTH FORMAT VALUE/REMARKS H-1 Header Record Indicator Text 1 H H for Header H-2 Supervising Agency Number 1 9 5 PAGCOR, 6 CEZA, 7 APECO H-3 Institution Code Number 11/18 9(11)/(18) AMLC Library H-4 Report Date Number 8 9(8) yyymmdd ; not greater than current date; not less than 20011017 H-5 Report Type Text 3 X(3) CTR, STR H-6 Format Code Number 2 99 1 H-7 Submission Type Text 1 X(1) A add, E edit/correction, D delete, T test DETAIL RECORD Transaction Data FIELD NO. FIELD NAME TYPE LENGTH FORMAT VALUE/REMARKS D-1 Detail Record Indicator Text 1 D D for Detail D-2 Transaction Date and Time Number 8 9(8) yyymmddhhmmss ; not greater than current date; not less than 20011017 D-3 Transaction Code Text 6 X(6) AMLC Transaction Codes D-4 Transaction Reference No. Text 20 X(20) must be unique per transaction date D-5 Transaction Amount (Php) Number 20 9(18).99 Greater than 0 w/or w/o decimal value D-6 Transaction Amount (FX) Number 17 9(15).99 Optional D-7 FX Currency Code Text 3 X(3) Optional; mandatory if FX amount < > null D-8 Nature/Purpose of Transaction Text 200 X(200) D-9 Name of Correspondent Bank Text 90 X(90) D-10 Address Address 1 50 X(50) Room No./Office Name, Bldg./House No., Street, Subd./Brgy. Address 2 50 X(50) District, Town, City Address 3 30 X(30) Province, Country code, ZIP D-11 Country Code of Correspondent Bank Number 3 9(3) Country Code (Refer to System Code, Annex B.3) Subject Data Detail Record-Party details Customer D-A-1 Party Type Flag Text 1 X A Customer D-A-2 Customer Reference Number Text 30 X(30) D-A-3 Name Text Last Name 100 X(100) Last name of customer First Name 100 X(100) First name of customer Middle Name 50 X(50) Middle name of customer D-A-4 Address Text Address 1 100 X(100) Room No./Office Name, Bldg./House No., Street, Subd./Brgy. Address 2 100 X(100) District, Town, City Address 3 100 X(100) Province, Country, ZIP D-A-5 Date of Birth Number 8 9(8) date < current date and the difference between current date and birthdate must be less than 150 D-A-6 Place of Birth Text 90 X(90) City, Municipality, Country D-A-7 Nationality Text 40 X(40) D-A-8 ID Type Text 4 X(4) ID1 Passport ID2 Driver's License ID3 PRC ID ID4 NBI Clearance ID5 Police Clearance ID6 Postal ID ID7 Voter's ID ID8 TIN ID9 Barangay Certification ID10 GSIS e-Card/UMID ID11 SSS ID12 Senior Citizen Card ID13 Overseas Workers Welfare Administration (OWWA) ID ID14 OFW ID ID15 Seaman's Book ID16 Alien/Immigrant Certification of Registration ID17 Gov't. Office/GOCC ID ID18 Certification from National Council for the Welfare of Disabled Persons (NCWDP) ID19 Department of Social Welfare and Development (DSWD) Certification ID20 Integrated Bar of the Philippines (IBP) ID ID21 Company ID ID22 Student's ID ID23 National ID ID24 SEC Certificate of Registration ID25 Business Registration Certificate ID26 Philhealth ID ID27 Others D-A-9 Identification No. Text 30 X(30) D-A-10 Telephone No. Text 15 X(15) D-A-11 Nature of Business Text 35 X(35) OTHER PARTICIPANT D-P-1 Party Type Flag Text 1 X P Other Participant D-P-2 Customer Reference Number Text 30 X(30) D-P-3 Name Flag Text 1 X Y if Other Participant is a corporation N if Other Participant is an individual D-P-4 Name Text Last Name 100 X(100) Last name of other participant First Name 100 X(100) First name of other participant Middle Name 50 X(50) Middle name of other participant D-P-5 Address Text Address 1 100 X(100) Room No./Office Name, Bldg./House No., Street, Subd./ Brgy. Address 2 100 X(100) District, Town, City Address 3 100 X(100) Province, Country, ZIP SUBJECT OF SUSPICION D-S-1 Party Type Flag Text 1 X S Subject of Suspicion D-S-2 Customer Reference Number Text 30 X(30) D-S-3 Name Text Last Name 100 X(100) Last name of subject of suspicion First Name 100 X(100) First name of subject of suspicion Middle Name 50 X(50) Middle name of subject of suspicion D-S-4 Address Text Address 1 100 X(100) Room No./Office Name, Bldg./House No., Street, Subd./ Brgy. Address 2 100 X(100) District, Town, City Address 3 100 X(100) Province, Country, ZIP D-S-5 Date of Birth Number 8 9(8) date < current date and the difference between current date and birthdate must be less than 150 D-S-6 Place of Birth Text 90 X(90) City, Municipality, Country D-S-7 Nationality Text 40 X(40) D-S-8 ID Type Text 4 X(4) ID1 Passport ID2 Driver's License ID3 PRC ID ID4 NBI Clearance ID5 Police Clearance ID6 Postal ID ID7 Voter's ID ID8 TIN ID9 Barangay Certification ID10 GSIS e-Card/UMID ID11 SSS ID12 Senior Citizen Card ID13 Overseas Workers Welfare Administration (OWWA) ID ID14 OFW ID ID15 Seaman's Book ID16 Alien/Immigrant Certification of Registration ID17 Gov't. Office/GOCC ID ID18 Certification from National Council for the Welfare of Disabled Persons (NCWDP) ID19 Department of Social Welfare and Development (DSWD) Certification ID20 Integrated Bar of the Philippines (IBP) ID ID21 Company ID ID22 Student's ID ID23 National ID ID24 SEC Certificate of Registration ID25 Business Registration Certificate ID26 Philhealth ID ID27 Others D-S-9 Identification No. Text 30 X(30) D-S-10 Telephone No. Text 15 X(15) D-S-11 Nature of Business Text 35 X(35) Details of Suspicion D-D-1 Reason Memo 800 Reason for Suspicion SI1 There is no underlying legal or trade obligation, purpose or economic justification. SI2 The client is not properly identified. SI3 The amount involved is not commensurate with the business or financial capacity of the client. SI4 The transaction is structured to avoid being reported. SI5 There is a deviation from the client's profile/past transactions. SI6 The transaction is similar, analogous or identical to any of the foregoing. (Additional reason is required after a semicolon i.e., SI6; The client is. . .) PC1 Kidnapping for ransom PC2 Drug trafficking and related offenses PC3 Graft and corrupt practices PC4 Plunder PC5 Robbery and Extortion PC6 Jueteng and Masiao PC7 Piracy on the high seas PC8 Qualified Theft PC9 Swindling PC10 Smuggling PC11 Violations under the Electronic Commerce Act of 2000 PC12 Hijacking; destructive arson; and murder, including those perpetrated by terrorists against non-combatant persons and similar targets PC13 Terrorism and conspiracy to commit terrorism PC14 Financing of Terrorism PC15 Bribery PC16 Frauds and Illegal Exactions and Transactions PC17 Malversation of Public Funds and Property PC18 Forgeries and Counterfeiting PC19 Violations of Sections 4 to 6 of the Anti-Trafficking in Persons Act of 2003 PC20 Violations of Sections 78 to 79 of the Revised Forestry Code of the Phils., as amended PC21 Violations of Sections 86 to 106 of the Fisheries Code of 1998 PC22 Violations of Sections 101 to 107 and 110 of the Philippine Mining Act of 1995 PC23 Violations of Section 27 (c), (e), (f), (g) and (i) of the Wildlife Resources Conservation and Protection Act PC24 Violation of Section 7b of the National Caves and Cave Resources Management Protection Act PC25 Violation of the Anti-Carnapping Act of 2002 PC26 Violations of Sections 1, 3 and 5 of the Decree Codifying the Laws on Illegal/Unlawful Possession Manufacture Dealing in, Acquisition or Disposition of Firearms, Ammunition or Explosives PC27 Violation of Anti-Fencing Law PC28 Violation of Section 6 of the Migrant Workers and Overseas Filipinos Act of 1995 PC29 Violation of Intellectual Property Code PC30 Violation of Section 4 of the Anti-Photo and Video Voyeurism Act of 2009 PC31 Violation of Section 4 of the Anti-Child Pornography Act of 2009 PC32 Violations of R.A. No. 7610, Special Protection of Children against Abuse, Exploitation and Discrimination PC33 Fraudulent practices and other violations under the Securities Regulation Code of 2000 PC34 Felonies or offenses of a similar nature that are punishable under the penal laws of other countries. D-D-2 Narrative Memo 4000 Narrative of events leading to Suspicion Trailer Record FIELD NO. FIELD NAME TYPE LENGTH FORMAT VALUE/REMARKS T-1 Trailer Record Indicator Text 1 T T for Trailer T-2 Php Amount Total Number 20 9(18).99 Total Transaction Amount T-3 Records Total of batch to be sent Number 10 9(10) Total number of CTR/STRs B. Transaction Security Process and Transferring of Files. B.1 Encrypting of Files (done after CP has created a CSV file Format 1.0) From your desktop, double click Kleopatra . The Kleopatra main window will be displayed on the screen. Click File, then click Sign/Encrypt Files. . . Select the csv file you want to sign and encrypt, then click Open . Select Sign and Encrypt , then click Next . Select Anti-Money Laundering Council's public key, then click Add . Click Next . A warning message will be displayed on the screen. Click Continue . Select the Compliance Officer's private key, then click Sign & Encrypt . Enter passphrase of the Compliance Officer, then click Ok . Click Finish . B.2 Transferring of Files (File Transfer Reporting Facility version 2.0) B.2.1 Log-in Page Log-on to https://portal.amlc.gov.ph Enter the 1st 6-digits of the Inst. Code for CPs with 11-digit Inst. Code Enter the 1st 9-digits of the Inst. Code for CPs with 18-digit Inst. Code Enter the Username or Registered email address A successful login will show the CP User Main Page. There are nine (9) options or links available in CP User Main Page: a. , if the icon is clicked, it will automatically display latest advisory/announcement of AMLC. b. provides access for the registered CP user to upload the electronic CTRs and STRs. c. gives the option for the registered CP user to inquire and view the files uploaded; only files uploaded by the particular CP can be viewed. d. will log the CP user out of the system and go back to CP User Login Page. e. provides access for the registered CP user to upload KYC Documents for STRs. f. provides access for the registered CP user to upload E-Returns for Freeze Orders. g. provides a template facility (excel file) for Electronic Returns. h. gives the option for the registered CP user to upload a STR attachment, provided that the STR has been uploaded and processed. i. gives the option for the registered CP user to check the status of the STR attachment that has been uploaded. B.2.2 CTR/STR File Upload When the registered CP's Institution Code, user name and its corresponding password are entered correctly, the CP user should be able to use the FTRF to upload the electronic reports. Upon successful login, Click File Upload link or icon The file upload window will be displayed on the screen. Click Browse button to locate the file to be uploaded. CTR/STR File Upload Note : Only files with [.csv.gpg] or [.csv.enc] or [.csv.pgp] as extension at the end of the filename will be accepted for uploading through the FTRF. The filename should follow the file naming convention 123456yyyymmddss of 123456789yyyymmdd where: 123456/123456789 1st six digits/1st 9 digits of the institution code yyyymmdd report date (date the report is sent to AMLC) ss Sequence number (from 01-99) representing no. of files transmitted for the day After locating the file, click UPLOAD to upload the selected file or click BACK TO MENU to cancel the upload and return to the User Main Page. After the Upload button is clicked and upon every successful upload, the "Upload Confirmation Receipt" is displayed. The Upload Confirmation Receipt has the following information: Confirmation Receipt: Date and time of receipt + Username + FileName File Name: Name of the file that was uploaded File Size: Size of the file that was uploaded Date and Time: Receipt date and time of the file at AMLC Secretariat Uploaded by: Name of the CP user who uploaded the file Upload Confirmation Receipt If there are still file for uploading, click . If there are no more file for uploading, click . If a CP user wants to search view files that have been uploaded, click . Note: The Upload Confirmation Receipt does not guarantee that all CTRs/STRs in the CSV file/s have been uploaded. To check the status of the submission, files should be viewed in the File Upload History Page. B.2.3 File Upload History A registered CP User can search/view anytime the files that have been uploaded for the registered CP he is representing. Status of each file uploaded is indicated in the search result. From the User Main Page, click >FILE UPLOAD HISTORY . To view specific past date or date range, click (calendar icon) to specific START DATE and END DATE. Click > SEARCH to start the search. When the search is completed, the query result is displayed. CTR/STR File Upload History Check the result of the file uploaded by comparing the number of transaction count with the number of good transactions. a. If the transaction count is equal to the number of good transactions, the CP can save a copy of the confirmation receipt by clicking on the "SAVE REPORT TO FILE" button, or the "PRINT" button to have a printed copy for filing. b. If the transaction count is not equal to the number of good transactions, the CP should select the report file with Bad Transactions and click on the "Download Validation Message" button. The validation message of the selected uploaded file will be sent via email. Check the validation message for the details of the error/s and make the appropriate correction. To search another date or date range, click > CLEAR button before entering the new search dates. B.2.4 How to Log-out From the User Main Page, click Logout link If CP User closes the browser, a notification message below will be displayed on the screen. Click Ok to logout or click Cancel to stay on the current page. B.3 Uploading of KYC Documents for Suspicious Transaction Reports B.3.1 Mandatory Uploading of KYC Documents Uploading of KYC Documents is mandatory if the Reason of Suspicion falls under any of the following: PC1 Kidnapping for Ransom PC2 Drug Trafficking PC12 Hijacking; destructive arson; and murder, including those perpetrated by terrorists against non-combatant persons and similar targets PC13 Terrorism and conspiracy to commit terrorism PC14 Financing of Terrorism Uploading of KYC documents should be performed prior to the upload of the STR, otherwise the STR will be rejected for processing due to non-submission of KYC documents. The customer reference number (CRN) will be mandatory for the Account Holder Party or Subject of Suspicion Party, whichever is applicable for the above mentioned predicate crimes. Uploading of KYC Documents for a CRN of a subject STR will only be done once, if a subsequent STR is filed on the same CRN, CPs need not re-upload the corresponding KYC Documents. Mandatory update of submitted KYC Documents is required every three (3) years, however this is optional if no STR will be filed under the same CRN. In cases where the CP has no updated KYC documents, reason for which should be indicated in the Remarks portion of the KYC Docs Update window. Below is the Acceptable KYC Documents: Account Opening Forms are the following: Signature Cards Customer Information File/Sheet Scanned copy of the following for ID Documents presented: Government IDs Articles of Incorporation/General Information Sheet for Corporation/Articles of Partnership Authorized Signatory's ID for Corporate accounts DTI Certificate for Sole Proprietor Digital Photo, if available Procedures for Uploading of KYC Documents Log-on to https://portal.amlc.gov.ph A successful log-in will show the Covered Person go to the Upload window. In the initial KYC Docs Upload window, three options will be available: Choose Add/New STR (No STRs filed) , if the KYC Docs to be uploaded corresponds to an STR not previously uploaded; Add/New STR (Existing STRs) , if the KYC Docs to be uploaded is for previously uploaded STRs with no KYC docs on file; and Update , for updating previously filed KYC Docs. Click Add/New (No STRs filed) button to enable the KYC Docs Upload Facility. KYC Documents Upload Facility Enter the Customer Reference Number and attach the corresponding KYC Documents, attach the KYC documents then Click the Save Button. * All fields with asterisk are mandatory * Customer Reference Number (CRN) is a unique number assigned to a customer of a CP; please make sure that the CRN indicate in the KYC Docs uploads window will be the same CRN inputted in the STR where the KYC Docs will be attached. * After the Save button is clicked and upon every successful upload, the "KYC Upload Confirmation Receipt" is displayed. KYC Upload Confirmation Receipt Click Add/New (Existing STRs) to enable Upload KYC Documents (Existing STRs). Fill up the mandatory fields and attach KYC documents, then click the Upload button. * All fields with asterisk are mandatory * After the Upload button is clicked and upon every successful upload, the "KYC Upload Confirmation Receipt" is displayed. Click Update to update a previously uploaded KYC Documents. To update type in the CRN with a previously filed KYC Documents, then click the Find button. KYC Docs Update window will appear After the Update/Upload button is clicked and upon every successful update, the "KYC Update Confirmation Receipt" is displayed. B.4 STR Attachment Upload Please note, that a successfully processed and uploaded STR is required before a Covered Person can upload an STR attachment. Enter the 1st 6-digits of the Inst. Code for CPs with 11-digit Inst. Code Enter the 1st 9-digits of the Inst. Code for CPs with 18-digit Inst. Code Enter the Username or Registered email address From the User Main Page, click > STR Attachment Upload . Enter the 11 or 18-digit Inst. Code of the uploaded STR (Please note that the Inst. Code should be the same as the uploaded STR up to the branch level) Enter the Transaction Date and Transaction Reference No. of the STR where the file will be attached. Enter a brief description of the file to be attached. Locate the file to be attached, then Click the Upload Button. STR Attachment Upload After the Upload button is clicked and upon every successful upload, the "STR Attachment Upload Confirmation Receipt" is displayed. STR Attachment Upload Confirmation Receipt B.5 STR Attachment History A registered CP User can search/view anytime the STR attachment/s uploaded for the registered CP he is representing. Status of each attachment is indicated in the search result. From the User Main Page, click > STR Attachment History . STR Attachment Upload History To view specific past date or date range, click (calendar icon) to specify START DATE and END DATE. Click > SEARCH to start the search. When the search is completed, the query result is displayed. Check the result of the STR Attachment, Status should show "Processed" otherwise, re-upload the attachment. B.6 Uploading of Electronic Returns (E-Return) for Freeze Order Rule 10, E.4 paragraph 2 of the 2016 Revised Implementing Rules and Regulations of Republic Act No. 9160, as amended states that: "The covered person shall also submit to the AMLC, through the internet, an electronic detailed return in a format to be prescribed by the latter." For uniformity of E-Returns Format, CP user should first download the Electronic Return Template. This template is an excel worksheet where CPs must encode their E-Returns. To download the template: Log-on to https://portal.amlc.gov.ph Enter the 1st 6-digits of the Inst. Code for CPs with 11-digit Inst. Code or the 1st 9-digits of the Inst. Code for CPs with 18-digit Inst. Code Enter the Username or Registered email address Enter password A successful log-in will show the Covered Persons' User Main Page. Click on Electronic Returns Template. The excel file contains two sheets, 1st sheet is for the main account and the 2nd sheet is for the related account/s. 1st Sheet is for the Main Account which is the subject of the Freeze Order Electronic Return Template Excel 2nd Sheet is for Related/Materially-linked account which contains two (2) tables: Table 1 is for materially-linked accounts as defined under Rule 3-Definition of Terms, R.1-5 of the 2016 Revised Implementing Rules and Regulations of Republic Act No. 9160, as Amended. Table 2 should include related accounts wherein Account Holder (Subject of Freeze Order) is either the Sender or Recipient of funds to/from another account holder. Once the E-Return Worksheet/s has been accomplished, CP user may again log-in to the AMLC Portal and click on Electronic Returns Upload. In the Electronic Returns Upload Facility, select between CA-GR AMLC Case and AMLC Resolution then click Proceed. Electronic Returns Upload Facility If AMLC Resolution is selected, enter the AMLC Resolution Number, its corresponding year then click Browse to attach the E-Return file. If CA-GR AMLC Case is selected, enter the Case Number then click Browse to attach the E-Return file. C. General Guidelines. 1. REPORTING FORMAT. A. The electronic CTR/STR file is a comma separated variable file or CSV (see Attachment A) where each column/field/variable is separated by a comma. Text/Data fields must not contain commas, single and double quotes . A comma is used to separate the different fields of the record. The CSV file may be created by extracting all the required data (those above PHP5,000,000.00) from the CP's database and building records following the format provided by AMLC or inputting the information in Excel and saving it using CSV as its file type. Header column names or columnar headings should not be included in the file . This file is structured to have several header records for CPs with branches and several detail records for the various transactions under each header record. At the end of the file is a trailer record containing the total number of transactions and the total Php amount of all the detail records. (See Attachment A) B. A single report format (Format 1.0) applicable to all covered persons shall be adopted for both CTRs/STRs in which the following MANDATORY fields shall be strictly filled up. 1. All fields in the HEADER RECORD. 2. In the DETAIL RECORD TRANSACTION DATA a. TRANSACTION DATE AND TIME (D-2), TRANSACTION CODE (D-3), REFERENCE NO. (D-4), and PESO AMOUNT (D-5). b. FX CODE if the FX AMOUNT has a value. c. For wire transactions, Correspondent Bank details are mandatory. 3. For DETAIL RECORD SUBJECT DATA a. For Name Fields for foreign nationals with one (1) name only, the following should be observed: 1. there should be five (5) dots (. . . . .) either in first name or last name and 2. Nationality will be mandatory. b. For ID Type 27 Others the ID no. should be preceded by the ID Type. (Please make sure that the ID type indicated does not fall in any one of the ID types before using ID 27.). c. For Customer Party (CTRs only) all fields are mandatory. d. For Subject of Suspicion (STRs only) all fields are mandatory. i. The REASON and NARRATIVE fields. ii. If the value in the reason field is "SI6," the description of the suspicious activity should always be specified separated by a semicolon. e. For Other Participant (Used for Junket Operators) optional; If other participant is present, all fields are mandatory. C. The CTR/STR report file has three (3) parts identified by the Record Indicator located at the first field of every record with values H, D, or T: 1. The Header Record identifies the Covered Person (CP), up to branch level, where the transaction occurred . A file may have several header records, if the reporting CP has several transactions from different branches to report; 2. There is one Detail Record for every transaction to report. Since the file may contain transactions from several branches, each group of Detail Records from one (1) branch is preceded by a Header Record; and 3. Trailer Record (T) is the last record of the file and contains the total peso amount of the transactions and the total number of transactions in the file. D. The CTR/STR may be submitted in four (4) types. 1. The CTR/STR with submission type value "A" refers to a new CTR/STR to be submitted to AMLC. 2. The CTR/STR with submission type "E" edits or amends the previously submitted, uploaded and successfully processed CTR/STR with ERRONEOUS VALUE. Note: The Institution code, Transaction date and reference number of the corrected transaction must be the same as the original transaction. 3. The CTR/STR with submission type "D" is a request to delete the previously submitted, uploaded and successfully processed CTR/STR. This shall be followed by an email request stating the reason for deletion. Email to be sent at [emailprotected] . Note: The deleted transaction must be exactly the same as the original transaction previously submitted to AMLC. 4. The submission type "T" is used by CPs under test mode. Once they are comfortable with the reporting of covered and suspicious transactions, they should shift to submission type "A." E. The list of valid entries for the TRANSACTION TYPE, FX CURRENCY CODE and COUNTRY CODE fields are provided in pages B-1 to B-43. F. Definition of Field Names HEADER RECORD H-1. Header Record Indicator This is the first field of the electronic record and will contain "H" to indicate that it is the beginning of the electronic file being sent by the CP to AMLC. H-2. Supervising Agency This field represents the supervising agency (whether PAGCOR/APECO/CEZA) of the reporting covered person. H-3. Institution Code This refers to the 11-digit code or 18-digit code of the reporting CP as assigned by the AMLC. H-4. Report Date Date of report in year, month, day format (YYYYMMDD). It should not be greater than the current date and not less than 20011017. H-5. Report Type Identifies whether report is CTR or STR. H-6. Format Code This identifies the format of the record. H-7. Submission Type Indicates whether the report being submitted is new, correction of previously submitted report and for deletion. DETAIL RECORD D-1. Detail Record Indicator Contains "D" indicating start of detail record for each and every transaction belonging to the same date and transaction group defined in the header record. D-2. Transaction Date and Time Date and Time when transaction occurred in year, month, and day format (YYYYMMDDHHMMSS). Date should not be greater than the current date but not less than 20011017. D-3. Transaction Code Refers to the type of transaction based on AMLC's table of codes. D-4. Transaction Reference No. Refers to the unique reference number assigned by the reporting covered person to its individual transaction per transaction date. D-5. Transaction Amount (Php) Philippine Peso amount involved in the transaction or its equivalent if transaction is in foreign currency. Amount should be greater than 0. D-6. Transaction Amount (FX) If applicable, amount in original foreign currency involved in the transaction. D-7. FX Currency Code Indicates the currency of the FX transaction following AMLC's currency codes. Mandatory if FX Amount is not null. D-8. Nature/purpose of Transaction Explains the nature or purpose of transaction or the risk being insured. D-9. Correspondent Bank Where applicable, indicates the correspondent bank or remittance partner, i.e. , remitter's bank in case of inward remittance transaction or the beneficiary's bank for outward remittance. D-10. Address of Correspondent Bank Gives the detailed address of the correspondent bank or remittance partner specifying the Room No./Office Name, building/house no., street, District, Town, City, Country, and ZIP code. D-11. Country Code of Correspondent Bank Indicates the country of the correspondent bank following BSP country codes. D-A-1. Party Type Flag Indicates that the person is a customer (A). D-A-2. Customer Reference Number Refers to the CP's reference number of their client. This will serve as reference for the static data to be submitted by the reporting institution. D-A-3. Name of Customer Refers to the customer specifying the last name, first name, middle name of the individual person or the registered name of the corporation or partnership. D-A-4. Address of Customer Gives the detailed address of the account holder specifying the Room No./Office Name, building/house no., street, Barangay, District, Town, City, Province, Country, and ZIP code. D-A-5. Birthdate of Customer Date of birth of the customer. For individual accounts, the difference between the current date and the birthdate must be less than 150 and should also be less than the current date. D-A-6. Place of Birth Birth place of the customer (City, Municipality, Country). D-A-7. Nationality Nationality of the customer. D-A-8. ID Type Type of ID presented by the customer (SSS, GSIS, Company, etc.). D-A-9. Identification No. Identification No. of the customer. D-A-10. Telephone No. Contact number of the customer. D-A-11. Nature of Business Specifies the occupation of the customer or nature of the business of the corporation or partnership. D-P-1. Party Type Flag Indicates that the person is the Other Participant (P). D-P-2. Customer Reference Number Refers to the CP's reference number of their client. This will serve as reference for the static data to be submitted by the reporting institution. D-P-3. Name Flag "N" if Other Participant is an individual, "Y" if Other Participant is a corporation. D-P-4. Name of Other Participant Identifies the other party/person/entity involved in the transaction other than the beneficiary, counterparty, etc., specifying the last name, first name, middle name of the individual person or the registered name of the corporation or partnership. This is usually used for the Junket Operator. D-P-5. Address of Other Participant Gives the detailed address of the other party/person/entity involved in the transaction other than the beneficiary, counterparty, etc., specifying the Room No./Office Name, building/house no., street, Barangay, District, Town, City, Province, Country, and ZIP code. D-S-1. Party Type Flag Indicates that the person/corporation is the Subject of Suspicion (S). D-S-2. Customer Reference Number Refers to the CP's reference number of their client. This will serve as reference for the static data to be submitted by the reporting institution. D-S-3. Name of Subject of Suspicion Identifies the subject of suspicion, specifying the last name, first name, middle name of the individual person or the registered name of the corporation or partnership. D-S-4. Address of Subject of Suspicion Gives the detailed address of the subject of suspicion, specifying the Room No./Office Name, building/house no., street, Barangay, District, Town, City, Province, Country, and ZIP code. D-S-5. Birthdate of Subject of Suspicion Date of birth of the subject of suspicion. For individual accounts, the difference between the current date and the birthdate must be less than 150 and should also be less than the current date. D-S-6. Place of Birth of Subject of Suspicion Birth place of the subject of suspicion (City, Municipality, Country). D-S-7. Nationality of Subject of Suspicion Nationality of the subject. D-S-8. ID Type of Subject of Suspicion Type of ID presented by the subject (SSS, GSIS, Company, etc.). D-S-9. Identification No. of Subject of Suspicion Identification No. of the subject. D-S-10. Telephone No. of Subject of Suspicion Contact number of the subject. D-S-11. Nature of Business of Subject of Suspicion Specifies the occupation of the subject or nature of the business of the corporation or partnership. D-D-1. Reason For STRs, reason field refers to the coded reason for suspicion categorized by suspicious indicator (SI) or predicate crime (PC). D-D-2. Narrative Narrates the events leading to the suspicion including other information which might be of help or importance to the report, i.e. , where the possible violation took place, related litigations, relation to other transactions, description of supporting documents, etc. TRAILER RECORD T-1. Trailer Record Indicator Contains "T" indicating start of trailer record of every file. T-2. Total CTR Amount refers to the total/sum of all peso transaction amounts in the file. T-3. Records Total refers to the number of transactions included in the file. Party Flag The party flag value "A" is for the customer of the reporting institution. For transactions involving parties other than the customer, beneficiary and counterparty, the party flag "P" for other party shall be used. The party flag "S" is for the subject of suspicion. G. The parties do not follow a particular order in the CSV file. H. The parties in the detail record are not mandatory for all transactions. Attached as Annex C, is the summary of the required parties per transaction. Failure to provide the mandatory parties shall cause the rejection of the file. I. For multiple valued name field, such as &/or account holders' names, multiple beneficiaries etc., each name shall be preceded by their corresponding party flags. Example: For Joint Accounts: If Name Flag = N A ,1234,DELA CRUZ,JUAN,REYES,123 ABC STREET,MAKATI CITY,MAKATI PHILIPPINES 2000,19700101,MANILA PHILS.,FILIPINO,ID1, XX1234567,7210202,REAL ESTATE, A ,5678,DELA CRUZ,MARIA,ALCANTARA,123 ABC STREET,MAKATI CITY,MAKATI PHILIPPINES 2000,19720203,MANILA PHILS.,FILIPINO,ID1,XX7654321,7210202,REAL ESTATE, J. The address is divided into address 1 (Room No. /Office Name, building/house no., street, barangay), address 2 (District, Town, City) and address 3 (Province, Country Code, Zip Code). K. For STRs. 1. Uploading of KYC Documents for STRs is mandatory, if an STR filed has no corresponding upload of KYC Documents, such STR will be rejected. (Complete guidelines are discussed in Section 4.B.3) 2. In cases where in the perpetrator is not identified, Cps shall use the term "Unknown" in the Subject of Suspicion Name. 3. The reporting institution shall choose the applicable Reason for Suspicion as enumerated in Section 2.A.2 [Electronic Record Format (Format 1.0 Casinos)]. For reasons other than the specified, the institution shall use the "SI6" followed by a semi-colon and the reason for suspicion. Note: Please make sure that the reason for suspicion indicated in SI6 does not fall in any one of the Suspicious Indicators or Predicate Crimes before using SI6. Example: x x x,SI6;suspected boiler room operations, the client was named in one foreign news article x x x 4. The transaction code "ZSTR" shall be used if the subject is not a customer of the reporting institution or is a customer but has no monetary transaction with the covered person at the time the suspicious activity is determined. 5. In filing an STR, the following questions should be answered: 1 WHO are the individuals/entities involved o People real, false IC o Business or companies, shell companies, legitimate businesses o Non-profit organization/charities WHAT is the activity of concern o Financing of terrorism o Drug Trafficking o People smuggling WHEN is the activity taking place o One-off transaction o Daily o Weekly o Monthly o Patterns within these time frames how many times, number of entities involved WHERE is the activity taking place o Consider all levels o Countries o Cities o Towns o Are these patterns in location or use of same address? WHY is the activity taking place o Providing finance for terrorist activity o Moving proceeds of drug activity or other illegal activity o Purchase of Drugs or other illegal commodity etc. HOW is the activity taking place o Movement of funds, wire transfers, traditional banks, underground banks, cash couriers o Quantity o Currency used o Other commodities diamonds, precious gems, stored value cards, traveler's checks. 6. The narrative should contain all the details and events leading to the suspicion including other information which might be of help or importance to the report, i.e. , where the possible violation took place, related litigations, relation to other transactions, description of supporting documents, etc. a. Additional documents may be attached to the STR through the AMLC Portal. An STR attachment may be any of the recognized file types (.xls, .doc, .docx, .pdf, .bmp, .jpeg, .jpg, .tiff, .tif). A facility in the AMLC portal allows the submission of this attachment. To upload an attachment, please make sure that the STR has been uploaded in the AMLC portal before uploading attachments. Please make sure you enter the complete eleven (11) or eighteen (18) digit institution code for the uploaded STRs; if the institution code used is that of the branch please ensure that you input this in the institution code field, then enter the transaction date and transaction reference number of the STR where the file will be attached. L. Key fields the key fields consist of the institution code, transaction date and transaction reference number . Together, they should be unique at all times. This means that the transaction reference number should be distinct per transaction date per institution. M. All amount values must not contain commas or special characters except the decimal point to indicate centavos, i.e. , P550,120.50 should be encoded as 550120.50. N. Validity of each field values in terms of length and data type must be observed. O. The number of commas must be less than one from the required total number of field values field1,field2, field3, field4 Total Fields = 4 Total Commas = 3 Note: field3 should always be followed by a comma whether or not field4 has data CRN,Lastname,Firstname,Middlename or CRN,Lastname,Firstname, P. CTR/STR reports should reflect where the transaction occurred , i.e. , Head Office or branch. This is identified by the institution code in the Header record which must be 11 or 18 digits (up to branch level). There may be several detail records less than one (1) header record to report several transactions of one branch, and there may be several header records in one (1) file to report transactions of several branches. For Covered Persons with Different Branches, the CTR/STR Format Structure should be as follows: H Header Record of Head Office D 1st Detail Record of Head Office D 2nd Detail Record of Head Office D Last Detail Record of Head Office H Header Record of Branch1 D 1st Detail Record of Branch1 D Last Detail Record of Branch1 H Header Record of Branch2 D 1st Detail Record of Branch2 D 2nd Detail Record of Branch2 D Last Detail Record of Branch2 H Header Record of Branch n D 1st Detail Record of Branch n D 2nd Detail Record of Branch n D Last Detail Record of Branch n T Trailer Record Q. File Name convention for CPs with 11-digit institution code- 999999yyyymmddss.csv where 999999 = first 6 digits of institution code, yyyymmdd = reporting date (year, month, day the report is sent to AMLC), ss = sequence number from 01-99 representing number of files transmitted for the day (batch number or number of transmission). Default sequence no. is 01 . File Name convention for CPs with 18-digit institution code- 999999999yyyymmddss.csv where 999999999 = first 9 digits of institution code, yyyymmdd = reporting date (year, month, day the report is sent to AMLC), ss = sequence number from 01-99 representing number of files transmitted for the day (batch number or number of transmission). Default sequence no. is 01. 2. Additional Guideline in CT/ST Reporting. A. The amount indicated in the CTRs or STRs shall include all taxes, or other fees incidental to the execution of the transaction. B. The AMLC supports the use of "multi-legged transactions" (series of transactions initiated by one (1) action within a covered person). Only the main transaction is required to be reported as CTR and the transactions inherent to the main transaction need not be reported. E.g. , Purchase of Manager's Check wherein amount will be paid by debiting the account of the client, instead of reporting two (2) CTRs for this, which is the debiting of the account and the actual purchase of MC; transaction code to be reported under Format 1.0 will be Purchase of MC via debit to account wherein the accountholder's account details (client who purchased the MC) will be reported. C. The Customer Reference Number (CRN) is mandatory for the Customer Party or Subject of Suspicion Party, whichever is applicable for Suspicious Transaction Reports, especially if the reason of Suspicion will fall in any of the following predicate crimes: Kidnapping for Ransom; Drug Trafficking; Hijacking; destructive arson; and murder, including those perpetrated by terrorists against non-combatant persons and similar targets; Terrorism and conspiracy to commit terrorism; and Financing of Terrorism. CRN will be used in the uploading of KYC documents. D. Deferred reporting shall be applicable to covered transactions only. The responsibility of CPs to report suspicious transactions, where applicable, remains. Should there be further adjustments/modifications in the application thereof; the foregoing policy shall be prospective. E. Digital certificate shall be implemented to ensure integrity, efficiency and security of the report files. The Gnu Privacy Guard (GPG) shall be provided to all the CPs to be used for encrypting and digital signing. F. To ensure that only authorized officials will be allowed to send reports to AMLC electronically, there shall be a registration and continuous data updating of business units, and their authorized compliance officers. G. Functional trainings for authorized persons are usually conducted on the last Wednesday of the month or upon announcement by the AMLCS. H. Rejected transaction due to invalid codes (transaction, currency and country) should be sent again using submission type A. Please take note that the reference number of the original transaction should be used for the resent transaction. I. The AMLC Web Services is a facility for CPs to transmit CTR/STRs automatically. To avail of the service, CPs should send an email to the Secretariat ([emailprotected]) requesting enrolment to the facility. Thereafter, an email shall be sent by the Secretariat with the attached Registration Form and Web Services specifications. J. For COs handling multiple CPs under the same company umbrella, a single User Account may be arranged to be able to log-on and submit CTRs/STRs of the different subsidiaries/affiliates. To apply for this arrangement, an email request specifying the list of subsidiaries/affiliates to be grouped should be sent. K. The advisory icon in the AMLC portal which contains advisories, resolutions and guidelines shall be the main process of communication with the CPs. The "New Advisory" icon will flash whenever a new advisory is published, and will continue to do so until such time the user opens or reads the advisory. L. Electronic returns for Freeze orders shall be uploaded in the AMLC portal, guidelines please refer to Section 4.B.6 (Uploading of Electronic Returns (E-Return) for Freeze Order. M. Updates on the UNSC Designated list (include both the Taliban 1988 Sanctions List and the Al-Qaida Sanctions List) shall be posted in both the AMLC website and AMLC portal for reference and guidance. SECTION 5. Annexes . The attached Annexes shall form part and parcel of this ARI: A. Annex A Sample CSV File (Format 1.0) B. Annex B System Codes C. Annex C Examples of Alerts and Red Flag Indicators D. Annex D Typologies of Money Laundering for Casinos FOR THE AMLC: MEL GEORGIE B. RACELA Executive Director ANNEX A Sample CSV File (Format 1.0) Detail Record Transaction Data (Row 2, Columns A-M) Subject Data (Customer) Trailer Record Sample using Notepad: CASINOS Cash to Chips Transaction (CTR) ANNEX B System Codes B.1 Transaction Codes for Casinos GROUP REVISED CODE TRANSACTION TITLE TRANSACTION DEFINITION A ACTCH Cash to Chips The purchase of chips using Cash. A ACCCH Purchase of Chips Credit Card The purchase of chips using Credit Cards. A ATITOP Ticket-in-ticket-out (TITO) Ticket Purchase Players purchase TITO tickets from the teller's cage to be used in the slot machine. A AFCCH Foreign Currency to Chips Exchange of Foreign Currency to tokens or peso bills to used in the slot machines with the option to redeem foreign currency at the same rate it originally used. A AFCCH Foreign Currency to Tokens/Bills Exchange of Foreign Currency to chips with the option to redeem foreign currency at the same rate it originally used. A AIRCH Purchase of Chips via telegraphic transfer/wire Players remit funds to the Treasury Fund Capital accounts of casino branches maintained with Land Bank of the Philippines. Chips are released after confirmation of the credit of funds. A ADDCH Purchase of Chips via Demand Draft Player deposits demand drafts issued by foreign banks to Land Bank of the Philippines. Chips are released once demand drafts are cleared. A ACHTC Chips to Cash The payment in cash in exchange for the players' chips holdings A ATITOR Ticket-in-ticket-out (TITO) Ticket Redemption Payment of TITO tickets presented for redemption to the teller's cage. A APAYW Payment of winnings via telegraphic transfer/wire Players' winning will be sent via wire to any bank in the country, subject to bank requirements and issuance of Certificate of Winnings. A APAYK Payment of winnings via Demand Draft/Manager's Check Players' winning shall be released via issuance of Demand Draft/Manager's Check, subject to bank requirements and issuance of Certificate of Winnings. A ATFC Payment of winnings via TFC Players' winning shall be released via issuance of Treasury Fund Capital Check (TFC) drawn against the branch's TFC account with Land Bank of the Philippines duly supported with a Certificate of Winnings from the Gaming Division, Slot Machine Division or Bingo Section. A ACCKC Chip check (cash) Issuance of chip check in exchange of players' cash. Chip checks are negotiable only at PAGCOR casinos. A ACCKCH Chip check (Chips) Issuance of chip check in exchange of players' chips. Chip checks are negotiable only at PAGCOR casinos. A ACCKE Chip Check Encashment Encashment of Chip Checks in casinos A AFTCH Fund transfer to chips Transfer of players' personal funds deposited to the Branch Treasury, wherein withdrawal of chips will be done in another branch. A ACHSF Safekeeping Players deposit playing chips for safekeeping with the Casino Treasury Division. A ACAPC Capital Infusion Cash Infusion of funds by a shareholder of the reporting covered Person via cash A ACAPK Capital Infusion Check Infusion of funds by a shareholder of the reporting covered person via check A ACAPD Capital Infusion Debit Infusion of funds by a shareholder of the reporting covered person via debit to account A ACAPW Capital Infusion Wire Infusion of funds by a shareholder of the reporting covered person via wire Z ZSTR STR transactions STR filed on the basis of suspicious trigger (ex. subject of news report, qualified theft, etc.) even if the subject has no monetary transaction with the covered institution at the time the suspicious activity was determined. GROUP LEGEND: A Casinos B.2 Currency Codes Description Code AFGHANISTAN AFGHANI AFN ALBANIAN LEK ALL ALGERIAN DINAR DZD ANDORRAN PESETA ADP ANGOLAN KWANZA AOA ARGENTINE PESO ARS ARMENIAN DRAM AMD ARUBAN GUILDER AWG AUSTRALIAN DOLLAR AUD AUSTRIAN SCHILLINGS ATS AZERBAIJANIAN MANAT AZM BAHAMIAN DOLLAR BSD BAHRAINI DINAR BHD BANGLADESHI TAKA BDT BARBADOS DOLLAR BBD BELARUSSIAN RUBLE BYR BELGIAN FRANC BEF BELIZE DOLLAR BZD BERMUDIAN DOLLAR BMD BHUTAN NGULTRUM BTN BOLIVIAN BOLIVIANO BOB BOTSWANAPULA BWP BRAZILIAN REAL BRL BRUNEI DOLLAR BND BULGARIAN LEV BGL BULGARIAN LEV BGN BURUNDI FRANC BIF CANADIAN DOLLAR CAD CAPE VERDE ESCUDO CVE CAYMAN ISLANDS DOLLAR KYD CFA FRANC BCEAO XOF CFA FRANC BEAC XAF CFP FRANC XPF CHILEAN PESO CLP CHINESE RENMINBI RMB COLOMBIAN PESO COP COMORO FRANC KMF CONVERTIBLE MARKS BAM COSTA RICAN COLON CRC CROATIAN KUNA HRK CUBAN PESO CUP CYPRUS POUND CYP CZECH KORUNA CZK DANISH KRONE DKK DEUTSCHE MARK DEM DJIBOUTI FRANC DJF DOBRA STD DOMINICAN PESO DOP EAST CARRIBEAN DOLLAR XCD EGYPTIAN POUND EGP EL SALVADORCOLON SVC ERITREA NAKFA ERN ESTONIAN KROON EEK ETHIOPIAN BIRR ETB EURO CURRENCY EUR EURO CURRENCY UNIT ECU FALKLAND ISLANDS POUND FKP FIJI DOLLAR FJD FINLAND MARKKA FIM FRANC CONGOLAIS CDF FRENCH FRANC FRF GAMBIAN DALASI GMD GEORGIAN LARI GEL GHANAIAN CEDI GHC GIBRALTAR POUND GIP GREECE DRACHMA GRD GUATEMALAN QUETZAL GTQ GUINEA FRANC GNF GUINEA-BISSAU PESO GWP GUYANA DOLLAR GYD HAITIAN GOURDE HTG HONDURAN LEMPIRA HNL HONGKONG DOLLAR HKD HUNGARIAN FORINT HUF ICELAND KRONA ISK INDIAN RUPEE INR INDONESIAN RUPIAH IDR IRANIAN RIAL IRR IRAQI DINAR IQD IRISH ILE IRISH POUND (PUNT) IEP ITALIAN LIRA ITL JAMAICAN DOLLAR JMD JAPANESE YEN JPY JORDANIAN DINAR JOD KAMPUCHEAN RIEL KHR KAZAKHSTAN TENGE KZT KENYAN SHILLING KES KUWAITI DINAR KWD KYRGYZSTANIAN SOM KGS LAO KIP LAK LATVIAN LATS LVL LEBANESE POUND LBP LEONE SLL LIBERIAN DOLLAR LRD LITHUANIAN LITAS LTL LUXEMBOURG FRANC LUF LYBIAN DINAR LYD MACAU PATACA MOP MACEDONIAN DENAR MKD MALAGASY FRANC MGF MALAWI KWACHA MWK MALAYSIAN RINGGIT MYR MALDIVE RUFIYAA MVR MALTESE LIRA MTL MAURITANIAN OUGUIYA MRO MAURITIUS RUPEE MUR MEXICAN PESO MXN MEXICAN UNIDAD DE INVERSION (UDI) MXV MOLDOVAN LEU MDL MONGOLIAN TUGRIK (TUGRUG) MNT MOROCCAN DIRHAM MAD MOZAMBIQUE METICAL MZM MVDOL BOV MYANMAR KYAT MMK NAMIBIA DOLLAR NAD NAMIBIAN DOLLAR NAM NEPALESE RUPEE NPR NETHERLAND GUILDER NLG NETHERLANDS ANTILLAN GUILDER ANG NEW ISRAELI SHEQEL ILS NEW TAIWAN DOLLAR TWD NEW ZEALAND DOLLAR NZD NICARAGUAN CORDOBA ORO NIO NIGERIAN NAIRA NGN NORTH KOREAN WON KPW NORWEGIAN KRONE NOK PAKISTAN RUPEE PKR PANAMANIAN BALBOA PAB PAPUA NEW GUINEA KINA PG PARAGUAY GUARANI PYG PERUVIAN NUEVO SOL PEN PESO URUGUAYO UYU PHILIPPINE PESO PHP POLISH SLOTY PLN PORTUGUESE ESCUDO PTE POUND STERLING GBP QATARI RIAL QAR RIAL OMANI OMR ROMANIAN LEU ROL RUSSIAN RUBLE RUR RUSSIAN RUBLE RUB RWANDA FRANC RWF SAINT HELENA POUND SHP SAMOAN TALA WST SAUDI RIAL SAR SERBIAN DINAR CSD SEYCHELLES RUPEE SCR SINGAPORE DOLLAR SGD SLOVAK KORUNA SKK SLOVENIAN TOLAR SIT SOLOMON ISLANDS DOLLAR SBD SOMALI SHILLING SOS SOUTH AFRICAN RAND ZAR SOUTH KOREAN WON KRW SPANISH PESETA ESP SRI LANKA RUPEE LKR SUDANESE DINAR SDD SUDANESE POUND SDG SURINAME GUILDER SRG SWAZILAND LILANGENI SZL SWEDISH KRONA SEK SWISS FRANC CHF SYRIAN POUND SYP TAJIKISTANI SOMONI TJS TANZANIAN SHILLING TZS THAILAND BAHT THB TONGAN PA'ANGA TOP TRINIDAD & TOBAGO DOLLAR TTD TUNISIAN DINAR TND TURKISH LIRA TKL TURKMENISTAN MANAT TMM U.S. DOLLAR USD UAE DIRHAM AED UGANDA SHILLING UGX UKRAINE HRYVNIA UAH UNIDADES DE FOMENTO CLF UZBEKISTAN SUM UZS VANUATU VATU VUV VENEZUELAN BOLIVAR VEB VIETNAMESE DONG VND YEMENI RIAL YER YENI TURK LIRAS (YTL) TRY YUAN RENMINBI CNY ZAMBIAN KWACHA ZMK B.3 Country Codes Description Code ABU DHABI U.A.E. 248 AFGHANISTAN 102 AFRICA N.E.S. 997 ALBANIA 081 ALGERIA 103 AMERICAN PACIFIC ISLAND 021 AMERICAN SAMOA 034 AMERICAN VIRGIN ISLANDS 027 ANDORRA 104 ANGOLA 105 ARGENTINA 106 ARMENIA 270 ARUBA 030 AUSTRALIA 107 AUSTRIA 051 AZERBAIJANI REPUBLIC 271 AZORES 036 BAHAMAS COMM OF 108 BAHRAIN 109 BANGLADESH 247 BARBADOS 110 BELARUS REPUBLIC OF 280 BELGIUM 052 BELIZE 118 BENIN 139 BERMUDA 113 BHUTAN 114 BOLIVIA 115 BOSNIA 277 BOTSWANA 112 BRAZIL 116 BRITISH ARAB STATES 121 BRITISH IND. OCEAN T. 119 BRITISH OCEANIA N.E. 120 BRITISH VIRGIN ISLAND 029 BRITISH WEST INDIES 122 BRUNEI 123 BULGARIA 082 BURKINA FASO 239 BURMA/MYANMAR 124 BURUNDI 125 CAMEROUN UNITED REP 127 CANADA 022 CANARY ISLANDS 039 CAPE VERDE ISLANDS 040 CAROLINE ISLANDS 041 CAYMAN ISLANDS 028 CENTRAL AFRICAN REP. 128 CHAD 130 CHANNEL ISLANDS 031 CHILE 131 CHINA 083 CHRISTMAS ISLANDS 042 COLUMBIA 133 COMORES ARCHIPELAGO 043 CONGO REP OF 134 COOK ISLANDS 260 COSTA RICA 136 CROATIA 094 CUBA 137 CURACAO 032 CYPRUS 138 CZECHOSLOVAKIA 084 CZECH REPUBLIC 288 DENMARK 053 DJIBOUTI (REP OF) 261 DOMINICAN REPUBLIC 140 DUBAI U.A.E. 249 ECUADOR 141 EGYPT 238 EL SALVADOR 142 ESTONIA 096 ETHIOPIA 143 EUROPE N.E.S. 998 FAEROE ISLANDS 145 FALKLAND ISLAND & DEP 144 FIJI 146 FINLAND 147 FRANCE 054 FRENCH GUINA 148 FRENCH OCEANIA N.E.S. 149 FRENCH SOMALILAND 150 FRENCH WEST AFRICA 151 FRENCH WEST INDIES 152 GABON 153 GAMBIA THE 154 GERMANY DEM REP OF 085 GERMANY FEDERAL REP 055 GHANA 155 GIBRALTAR 156 GREECE 056 GREENLAND 157 GUADALOUPE 158 GUAM (MARIANAS ISLAND) 023 GUATEMALA 159 GUINEA 160 GUINE-BISSAU REP OF 206 GUYANA 117 HAITI 161 HONDURAS 162 HONGKONG 163 HUNGARY 086 ICELAND 057 INDIA 164 INDONESIA 165 IRAN 166 IRAQ 167 IRELAND REP OF 058 IRIAN (WEST/BARAT) 168 ISLE OF MAN 046 ISRAEL 169 ITALY 059 IVORY COAST 170 JAMAICA 171 JAPAN 060 JORDAN 172 KAMPUCHEA 126 KAZAKHSTAN 089 KENYA 173 KIRGHIZIA REPUBLIC OF 273 KIRIBATI REPUBLIC 262 KOREA REPUBLIC OF 221 KUWAIT 174 LAOS 175 LATVIA 284 LEBANON 176 LEEWARD & WINDWARD 035 LESOTHO 111 LIBERIA 177 LIBYA 178 LIECHTENSTEIN 061 LITHUANIA 097 LUXEMBOURG 062 MACAO 983 MACAU 047 MACEDONIA REPUBLIC OF 268 MADAGASCAR DEM REP 179 MADEIRA 048 MALAWI REP OF 180 MALAYSIA 245 MALDIVE ISLANDS 049 MALI REPUBLIC OF 181 MALTA 182 MARSHALL ISLANDS 050 MARTINIQUE 183 MAURITANIA 184 MAURITIUS 185 MEXICO 186 MOLDOVA REPUBLIC OF 282 MONACO 033 MONGOLIA 087 MONTENEGRO 285 MOROCCO 187 MOZAMBIQUE 188 NAMIBIA 266 NAURU 189 NEPAL 190 NETHERLANDS 063 NETHERLANDS ANTILLES 191 NEW CALEDONIA 192 NEW ZEALAND 194 NICARAGUA 195 NIGER 196 NIGERIA REP OF 197 NORFOLK ISLAND 263 NORTH KOREA 088 NORWAY 064 OCENIA N.E.S. 990 OMAN SULTANATE OF 246 OTHER COUNTRIES 999 PAKISTAN 199 PALAU REPUBLIC OF 269 PALESTINIAN TERRITORIES 301 PANAMA 200 PANAMA CANAL ZONE 024 PAPUA NEW GUINEA 201 PARAGUAY 202 PERU 203 PHILIPPINES 204 POLAND 090 PORTUGAL 065 PORTUGUESE AFRICA 244 PORTUGUESE ASIA 205 PORTUGUESE TIMOR DEP 207 PUERTO RICO 025 QATAR 208 REPUBLIC OF SERBIA 287 REUNION ISLAND 209 RODRIGUEZ ISLAND 045 ROMANIA 091 RUSSIAN FEDERATION 281 RWANDA 210 RYUKYU ISLANDS 198 SABAH 211 SAIPAN 098 SAO TOME & PRINCIPE 283 SARAWAK 212 SAUDI ARABIA 213 SENEGAL 214 SEYCHELLES 215 SIERRA LEONE 216 SINGAPORE 217 SLOVAK REPUBLIC 286 SLOVENIA 278 SOCIETY ISLANDS 038 SOLOMON ISLANDS 264 SOMALI REPUBLIC 218 SOUTH AFRICA REP OF 219 SOUTH WEST AFRICA TE 220 SOUTHERN RHODESIA 223 SPAIN 066 SPANISH AFRICA (ORO/M) 224 SRI LANKA 129 ST. HELENA & DEP 225 ST. PIERRE ET MIGUELON 226 SUDAN DEP REP OF 227 SURINAM 228 SWAZILAND 229 SWEDEN 067 SWITZERLAND 068 SYRIA 251 TAHITI 252 TAIWAN 132 TAJIKISTAN REPUBLIC OF 275 TANZANIA 230 THAILAND 231 TOGO 232 TONGA 233 TRIESTE 236 TRINIDAD & TOBAGO 234 TUNISIA 235 TURKEY 069 TURKMENISTAN REPUBLIC OF 276 TURKS & CAICOS ISLAND 044 U.S.S.R. 092 UGANDA 237 UKRAINE 267 UNITED KINGDOM 070 UNITED STATES 026 URUGUAY 240 UZBEKISTAN 095 VANUATU 193 VENEZUELA 241 VIET-NAM SOC REP OF 222 WEST INDIES N.E.S. 991 WESTERN SAMOA 265 YEMEN ARAB REPUBLIC 242 YEMEN PEOPLE'S DEM 101 YUGOSLAVIA 093 ZAIRE REPUBLIC 135 ZAMBIA 243 ZIMBABWE 037 ANNEX C Examples of Alerts and Red Flag Indicators 1. There is no underlying legal or trade obligation, purpose or economic justification Offsetting bets. Acquaintances betting against each other in even-money games and appearing that they are intentionally losing to one of the parties. Customer requesting for fund transfer to charity that is unfamiliar to the casino or appears to have links to countries that have lack AML/CFT controls. Buying casino chips and cashing them in, without gambling, by way of a casino cheque, bank draft of money transfer. Putting money into slot machines and claiming the accumulated credits as a jackpot win. Customers asking to combine winnings and his and her own cash not played in the casino into casino cheques. Customers frequently inserting substantial amounts of banknotes in gaming machines that have high payout percentages and do not play "max bet" to limit chances of significant losses or wins, thereby accumulating gaming credits with minimal play. Frequent even-money wagering when conducted by a pair of betters covering both sides of an even bet ( e.g. , in roulette, baccarat/mini-baccarat, or craps). Customer's intention to win is absent or secondary. Two or more customers frequently wagering against one another on even money games. Customer in possession of large amounts of coinage or bills. Customer befriending/attempting to befriend casino employees. Purchasing and cashing out casino chips with little or no gaming activity. Customer requests to add cash to casino winnings and then exchanging the combined cash and winnings for a single cheque. Multiple cheques being requested or drawn on account. Chip cash out is same/similar to chip purchase. Requests for credit transfers to other casinos. Use of multiple names to conduct similar activity. Use of third parties to purchase casino chips. Customer purchases chips and leaves casino shortly after. CPV, TITO, ticket or voucher dated prior to date of redemption. Large chip purchases. Frequent purchase of casino gift certificates. Detection of chips brought into the casino. Deliberation on losing a bet to other party(ies) on o peers to peers games; or o opposite bets with similar odds in banker hosted games Exchange of cash/casino currencies without commensurate gambling activities. Structuring transactions to stay below reporting threshold. Chip walk. Customer conducting small changing of chips or deposit or withdrawal of funds without gambling. Customer requesting for multiple payments of winnings and capital to the same account of a third party. Frequent access to safety box without commensurate gambling activities. A patron provides a wire transfer, cashier's check or other form of payment and such instrument reflects that the transaction is being made for a purpose other than related to gaming. Fund transfer to a customer or from a customer that is through multiple financial institutions or jurisdictions in an attempt to disguise their origin. Transfer of funds between customers through means such as hand to hand, wire transfer, safety box deposit, front money, or online casino accounts etc. Inserting funds into gaming machines and immediately claiming those funds as credits. Customers claiming gaming machine credits/payouts with no jackpot. Customers claiming a high level of gaming machine payouts. 2. The client is not properly identified Client refused to provide details/provide fake details Proxy betting Bettor employed by other parties to place bets Client receives money/casino currencies from 3rd parties through means such as hand to hand, wire transfer, safety box deposit, front money, or online casino accounts etc. Customer due diligence challenges, e.g. , refusals, false documents, one-offs, tourists passing trade. 3. The amount involved is not commensurate with the business or financial capacity of the client Unexplained income inconsistent with financial situation/customer profile Client's gaming/cage activity dramatically increases with no known substantiation for the source of those funds Client's gaming/cage activity or wagers incommensurate to the profile originally established by the covered person Customers with unclear source of wealth/funds betting in large amount A negotiable instrument or wire transfer is presented for the benefit of multiple patrons, or multiple patrons engage in play on a single patron account A patron presents funds which the casino has a basis for suspecting to be the proceeds of illegal activity A patron presents funds in any form that derive from a high risk jurisdiction 4. Taking into account all known circumstances, it may be perceived that the client's transaction is "structured" in order to avoid being the subject of reporting requirements under the law Structuring transactions to stay below reporting threshold. A patron requests information about how to avoid AMLC reporting requirements. A patron refuses to provide information for the completion of a CTR, or identifying information more broadly. Multiple players requesting for payments to the same beneficiary (except for customers of junket operators). Structuring the purchase of chips below the mandatory cash transaction reporting threshold. Regularly depositing or transacting similar amounts of cash, which are below a country's reporting disclosure limit. The use of third parties to undertake transactions using single or multiple accounts. Using cheques from multiple financial institutions or branches of a financial institution to "buy in" while the amount of each cheque is below the reporting threshold. Utilizing shift changes to systematically "cash in" chips or other value instruments to avoid threshold reporting. Regularly switching gaming tables, gaming rooms, junkets or casinos within a chain when the wagering amounts are approaching the reporting threshold. Requesting the division of winnings or prize money, which exceeds the reporting threshold, to be broken down into cash and chips below the reporting threshold in order to exchange it at the cashier's desk. High volume of transactions within a short period. Multiple chip cash outs on the same day. Structuring of chip/cheque transactions. 5. Any circumstance relating to the transaction which is observed to deviate from the profile of the client and/or the client's past transactions with the covered person Dramatic or rapid increase in size and frequency of transactions for a regular card holder. Noticeable spending/betting pattern changes. Dramatic or rapid increase in size and frequency of transactions for regular account holder. o Client's gaming activity dramatically increases with no known substantiation for the source of those funds o Client's gaming activity or wagers incommensurate to the profile originally established by the covered person o Cage perform wire transfer/remittance to customer(s) or a different beneficiary without apparent reason/supporting gaming activity records o Client request for winner cheques without commensurate gaming activities/winnings 6. The transaction is in any way related to an unlawful activity or offense under this Act that is about to be, is being or has been committed; or Use of fraudulent identity/credit cards/payment cards to perform any form of cage transactions Withdraw money using fraudulent credit cards/payment cards in the casino Use of counterfeit casino currencies Booking of fictitious gaming activities/transactions by junkets ( e.g. , for the purpose of bypassing table limit/facilitation of cross border transfer etc.) Client(s) who perform the transactions are found to be known or related associates of criminal/wanted persons Funds involved in the transaction/activity originates from casino cheat/scam or another other offenses as described under the AMLA 7. Any transaction that is similar or analogous to any of the foregoing. Supposed winnings do not correspond with recorded winnings. Use of credit cards to purchase casino chips. ANNEX D Typologies of Money Laundering in Casinos Typology 1: Use of Junkets A Syndicate Member in Country A wants to send (beneficiary) drug proceeds to Syndicate Head in Country B. With the help of a junket promoter, Syndicate Member caused the transfer of said proceeds to a casino in Country A. The junket operator then informed an underground remitter in Country B about the amount and beneficiary of the funds. The remitter would then arrange payment of the fund to the beneficiary. When the beneficiary arrives at the casino in Country B, he immediately obtains the amount transferred by the Syndicate Member in Country A through gambling. Both the casino and the remitter would perform reconciliation for net settlement, and thus, basically no transfer of monies between two sides was required. Typology 2: Use of Junkets A casino in Las Vegas, operated a marketing team ("junket") catering to Korean customers. The junket representative lent gambling money to Koreans in the form of cards (coupons), not cash, so that the corresponding loan would be spent only for gambling at the Las Vegas Casino. Representatives of this junket visited Korea to collect debts or make the customer's relatives in Korea do so on their behalf. The collected money was paid to trading companies in Korea for the goods that these companies sold to importing companies in the United States. The importing companies paid the amount to the Las Vegas Casino. Typology 3: Hedging a) A customer routinely bets both sides of the same line and thus the amount of overall loss to the customer is minimal (known as hedging). b) A pair of bettors frequently cover between them both sides of an even bet, such as: (1) betting both "red and black" or "odd and even" on roulette; (2) betting both with and against the bank in baccarat/mini-baccarat; or (3) betting the "pass line" or "come line" and the "don't pass line" or "don't come line" in craps; and, the aggregate amount of both bettors' total wagering is in excess of USD5,000.00. Typology 4: Use of Junkets Mr. A contacted junket operator AA in Jurisdiction X to facilitate a junket game for him and his friends at Casino 1 and Casino 2. Junket operator AA, through an officer in Bank B, caused the opening of four (4) bank accounts in Bank B. The accounts would be used as a depository account to receive money from Mr. A for his casino gaming activity. A total of USD81 million was wired to the four (4) accounts opened in bank B by Junket operator AA. Junket AA instructed the bank officer of Bank B to transfer USD65.8 million to another fictitious account, and to transfer USD15.2 million to the bank account of remittance agent C. Thereafter, junket operator AA and bank officer B instructed remittance agent C to perform the following: (a) Transfer Php1 billion to the account of junket operator AA; (b) Deliver cash to junket operator AA; and (c) Transfer funds to the account of Casino 1. Junket operator AA facilitated the gaming activity of Mr. A and his friends at the VIP gaming program of Casino 1 and junket program of Casino 2. Mr. A and his friends requested Casino 1 to transfer most of their gaming funds to an account with another junket operator, BB, also located inside Casino 1. Mr. A and company played in Casino 2 briefly, then played for several days in the VIP program of Casino 1 and junket operator BB. In the course of their gaming activities, they withdrew a substantial amount of winnings. When Casino 1 found out that the money being played by Mr. A and his friends were proceeds of a bank hacking incident in jurisdiction Z, its officers immediately stopped the gaming activities and seized all chips and money in the gaming tables, gaming accounts and those that were found inside their hotel rooms. Investigation by the Financial Intelligence Unit (FIU) into the casino transactions of Mr. A and his friends revealed that some of them do not have previous gaming activities, while the gaming transactions of others substantially deviated from their gaming profiles. The large transactions, deviation from transaction profiles, and unusual gaming patterns displayed by Mr. A's group would have been reportable as Suspicious Transactions under the anti-money laundering laws of Jurisdiction X. However, casinos are not required to file said reports there because casinos were not covered by the country's anti-money laundering/counter-financing of terrorism (AML/CFT) regime. Thus, the FIU in jurisdiction X and the law enforcement agencies there were unable to conduct a timely investigation. Cases of money laundering were filed against junket operator AA, officers of bank B, and officers of remittance agent C. Typology 5: Casino to bank transactions A law enforcement investigation identified a professional money laundering syndicate operating between Australia, Jurisdiction X and Jurisdiction Y. The investigation revealed that the offender flew to Australia from Jurisdiction X, and two (2) days upon arrival, played at a casino. There she received USD473,000.00 in cash stashed in a backpack from an associate (suspect A), at the casino car park, then deposited it into her casino account. After unsuccessfully attempting to transfer a portion of the funds from her casino account to the bank account of another associate (Ms. X), the offender withdrew USD227,000.00 in cash. Then she attempted to deposit the cash with the intention of transferring it to Ms. X, who worked for an Australian money remittance business based in a different state. The offender was unable to provide satisfactory information when questioned by bank staff as to the origins of the cash and purpose of the transaction. The results of the law enforcement investigation led to the offender's arrest at the bank as she was attempting to deposit the cash. The offender was charged with one count of dealing with more than AUD100,000.00 based on a reasonable suspicion that the funds represented the proceeds of crime; she was sentenced to sixteen (16) months' imprisonment. Typology 6: Use of gambling coupons Person M, a well-known entrepreneur, is the suspect of money laundering and dealing with the proceeds of crime. Person M sells coupons used for gambling in District "T" supplied by person P, who lives in district "B." Person M has two (2) accounts used to carry out the gambling transactions, account "1," used for placement, transfer and receipt of proceeds from gambling, and account "2," used to place profits from the sale of gambling coupons supplied by person P. The profit represented up to 17% of all coupon transactions. Typology 7: Use of licensed casinos Mr. X, an employee of a point of sale business for two (2) casinos (FDJ and PMU), located in the greater Paris region, and run by Mr. Y. Tracfin (France FIU) was alerted to an unusually large number of cheques and wire transfers of winnings credited to the bank accounts of these two casinos. Over a fifteen (15)-month period, Mr. X deposited more than 4,000 separate winnings totaling about 1.5million (USD1.69 million). Mr. Y deposited nearly 700 separate winnings for more than 200,000.00 (USD225,600.00). The winning tickets, nearly all of them sports and horseracing betting products, were validated in Mr. Y's outlet, whose turnover in gaming products increased exponentially over the same period. However, the origin of the money bet by Messrs. X and Y was not clear. Upon investigation it was determined that although payments by cheque, wire transfer or credit card were registered with their bank accounts, they did not sufficiently account for the recurrence and the extremely high amount of the winnings. Mr. X and Y must have been injecting additional money into gaming, whose origin was unknown and therefore raised red flags. Finally, Mr. X, whose official sources of income were quite modest, lived a quite comfortable lifestyle and also acquired real estate. Typology 8: Use of Casino Gaming Account AUSTRAC (Australian FIU) disseminated an intelligence assessment report to law enforcement agencies regarding the financial activities of a suspect attempting to launder the proceeds of crime raised through drug related activity. The suspect used bank and casino accounts to launder the funds. The suspect was the subject of five (5) suspicious matter reports (SMRs) submitted to AUSTRAC. Over a four (4)-day period the suspect made five (5) structured cash deposits of between AUD8,000.00 and AUD9,000.00 into his personal bank account. The structured cash deposits totaled AUD41,500.00. Bank staff reported in the SMRs that the deposited cash smelled of mothballs. After the deposits, the suspect undertook a domestic electronic transfer to move AUD40,000.00 from his bank account into an account with an Australian casino. The suspect deposited another AUD40,000.00 cash directly into the casino account. An additional SMR submitted by the bank reported that the suspect received a deposit via domestic electronic transfer of AUD131,000.00 from the casino. Following this deposit into his bank account, the suspect withdrew AUD9,000.00 in cash. The casino submitted an SMR, indicating that the suspect was known by two (2) aliases and that he would become aggressive when casino staff requested identification as part of the casino's normal identification procedures for customers cashing out gaming chips. The casino also reported that the suspect was known to cash out chips in amounts under the AUD10,000.00 cash reporting threshold, presumably to avoid the requirement to present identification to staff. The suspect was arrested at a domestic Australian airport after a drug detector dog reacted to his suitcase. The suitcase contained ten (10) vacuum-sealed plastic bags containing a total of 4.5 kilograms of cannabis. The suspect was charged with attempting to traffic a controlled drug, contrary to Sections 11.1 and 302.4 of the Criminal Code Act 1995 and was sentenced to two-and-half years' imprisonment. Typology 9: Significantly large wire transfer to a casino gaming account AUSTRAC contributed to a joint international investigation sparked by the suspicious behavior of a prominent Asian businessman. The investigation exposed a multi-million-dollar global fraud committed by an Asian finance manager, who was known as a habitual gambler and international casino 'high roller.' Authorities in Asia suspected that the suspect had defrauded a number of international banks. AUSTRAC received an international request for information from counterparts in Asia, seeking assistance with their enquiries with regard to the financial activity of the target while he was in Australia. AUSTRAC data identified that the suspect had conducted significant international funds transfers to Australian casinos, had visited Australia to gamble at the casinos, and had left Australia with substantial amounts of money, presumed to be the proceeds of his gambling. This information proved the initial suspicions of AUSTRAC's Asian counterparts that the suspect had transferred funds to casinos in Australia. The suspect was arrested and subsequently admitted to Asian authorities that he had embezzled approximately AUD78 million (USD72,003,360.00) from four (4) international banks by forging signatures of his company's executives and opening accounts in the name of his employer. Over a four (4)-year period the suspect transferred approximately AUD190 million (USD175 million) into an Australian casino account via international funds transfer instructions (IFTIs). In addition, the suspect had visited a number of casinos in London, Macau and Malaysia, in some instances placing bets worth up to AUD400,000.00 (USD369,248.00). Asian authorities requested further assistance from Australian law enforcement to trace additional proceeds of the suspect's fraud. In conjunction with AUSTRAC, Australian law enforcement discovered an additional AUD30 million (USD28 million) in accounts with various Australian casinos, held in the name of the suspect. Of this amount, AUD7 million (USD6.5 million) was restrained by Australian law enforcement under the Proceeds of Crime Act 2002, and a portion of this was repatriated back to the investigating authorities in Asia. The suspect pleaded guilty in Asia to six (6) counts of forgery and eight (8) counts of cheating and was subsequently sentenced to forty-two (42) years' imprisonment. Typology 10: Cashing out without record of chips purchase Suspect A was arrested by law enforcement upon arrival in Australia, where he was found to be in possession of card skimming technology. This included computer disks, a laptop, a card encoder, an ATM feeder 'face unit' and thirty-one (31) blank ATM cards. The suspect was an international student residing in Australia. Upon his arrest, law enforcement commenced an investigation into his activity and discovered a card skimming syndicate operating in Australia which laundered the proceeds of its crimes through casinos. Analysis of AUSTRAC financial transaction data associated with suspect A identified three additional members of the syndicate and their activities. Members of the syndicate regularly visited casinos. Over a five (5)-month period, AUSTRAC received threshold transaction reports (TTRs) indicating that suspect A had cashed in more than AUD180,000.00 (USD166,612.00) worth of gaming chips at an Australian casino. However, transaction records showed that the suspect had not previously purchased a corresponding amount of gaming chips at the casino. This suggested that the suspect may have purchased the chips directly from another player before cashing them out, while claiming they were actually his 'winnings.' AUSTRAC information was also used to identify the irregular gaming activity of suspect B. Information on AUSTRAC's database indicated that, over a twelve (12)-month period, suspect B had purchased AUD50,000.00 (USD46,156.00) worth of gaming chips at a casino. However, records indicated that the suspect had cashed out more than AUD610,000.00 (USD563,103.00) worth of gaming chips at the casino. Suspect B also made regular cash deposits and withdrawals, often in amounts over the reporting threshold of AUD10,000.00 (USD9,231.00), into bank accounts in Australia in the days following the casino transactions. A suspect transaction report (SUSTR) was submitted by an Australian casino, noting that: (a) suspect B presented AUD28,000.00 (USD25,847.00) worth of casino chips to a cashier to be cashed out, before handing the cash proceeds to another person, believed to be suspect A; and (b) The value of gaming chips cashed out by suspect B did not correspond with the suspect's observed game play at the casino due to the high volumes of winnings compared to funds withdrawn for gambling purposes, nor did it correspond with the expected financial activity of a young university student. A second SUSTR was also submitted by an Australian financial institution detailing suspicious transactions conducted by suspect B. Over a (3) three-month period suspect B deposited more than AUD155,000.00 (USD143,084.00) in cash into an account, indicating to bank staff that these funds were casino winnings. The majority of these funds were then withdrawn in cash at the bank and via ATMs at the casino. Suspect A was charged under Section 480.6 of the Criminal Code Act 1995 for the importation of a thing to dishonestly obtain or deal in personal information. Typology 11: Use of casino accounts, third party placement, infiltration of junket management CYK, a Hong Kong tycoon and owner of British soccer club in Birmingham (UK), was convicted of laundering HKD93 million through, inter alia , junket operators and casinos in Macau. The prosecution charged that since 2001 various parties made deposits to their accounts, many for no apparent reason. Some were made by securities firms and a Macau casino company, while others were made by unknown parties. Some 437 deposits totaling more than HKD97 million were made in cash. Throughout the trial, CYK said he accumulated hundreds of millions of dollars through stock trading, business ventures in main land China, winnings from gambling and even hair dressing. The Court showed that CYK moved funds for Neptune VIP Club, a junket operator in Macau. One of Neptune's owners, CCT, is alleged to be the head of a powerful Hong Kong Triad gang. According to the evidence at trial, more than HKD18 million was washed by Mr. Yeung for Mr. Cheung. Typology 12: Use of third parties, triggering transaction reports to legitimize suspicious transactions A number of persons purchased chips with illicit cash in amounts below the CTR threshold, but then passed the chips to one individual who cashed out, receiving a casino cheque and triggering the filing or a CTRC that gave the appearance of further authenticating the transaction. Over a twelve (12)-month period, one individual was named in casino CTRCs reporting USD1.1 million paid out, but was not named in a single CTRC for cash taken in. Typology 13: Use of third parties to move illicit funds John in Macau could not perform a large remittance to China due to its foreign exchange control. Susan in China wished to gamble in this casino of Macau, but had difficulty in bringing in the cash. Junket and remitter (aka "M") performed matchmaking and reconciliation/settlement to solve the demand. John paid M's Macau account the desired remittance amount. Susan paid M's China account the desired gaming funds amount. As Susan arrives in Macau, M provide gaming capital to Susan via Macau account using the funds from John. M also pays John's beneficiary in China via China account using the funds from Susan. M would perform reconciliation for net settlement (insofar John and Susan has paid their ends in advance), and basically no transfer of monies between two sides was required. Typology 14: Use of third parties and false identities to structure gambling transactions A Person of Interest (POI) of a drug trafficking organization, utilizing both the money he was paid for his services and the large sums of money put into his possession to be laundered, recruit third parties at the casino to purchase, or cash in, chips for him, paying them a nominal fee to do so. He then gambles. After gambling, he would cash some of these third-party purchased chips back out again, claiming they were his gambling winnings. According to the CTRs a USD 313,000.00 discrepancy was found to exist between chip purchases and cash out. Twenty-four of the CTRCs recording his activities revealed the use of aliases and multiple social security numbers. On numerous other CTRCs he had refused to provide a social security number. Typology 15: Use of debit cards to conduct money laundering transactions An existing member of a casino introduced a number of people over a period of time. Suspicious was raised as the new members were completing debit card transactions to the maximum limit and receiving gaming plaques in exchange, which in turn were passed to the existing member. Most of the new members never returned to the casino after the initial visit. The nationalities of the new members varied widely, but all are believed to have recently arrived from foreign jurisdictions. The transactions varied from GBP1,000.00 to 7,000.00. Typology 16: Proxy betting Gamblers in China obtain credit lines from Macau junket operators, who are repaid using funds derived from unlawful activities by the players ("beneficial owners") inside China. The gaming credit stays outside China, away from scrutiny by the Chinese government and its currency controls and where it can be cashed out in Macau as gambling proceeds. To launder funds, these gamblers use Macau's junket operators as fronts, especially for high-rollers, to bet on their behalf. Hired hands of these junket operators often use wireless headsets to receive instructions from the "beneficial owners" in China. Some proxy players hide their phones inside their elaborate coiffure. While Macanese law prohibited phone betting in 2001, there was no enforcement as long as operators reported the bets and the identities of the gamblers to the regulator. Proxy betting, therefore, represents high risks for money laundering. Footnotes 1. Presentation materials on Intelligence Analysis & Intelligence Reports: A Workshop for FIUs held on 11 July 2008. n Note from the Publisher: Copied verbatim from the official document. Irregular numerical sequence.