AMLC Resolution No. 107, s. 2017

November 15, 2017 AMLC RESOLUTION NO. 107, S. 2017 Acting on the Memorandum dated 10 November 2017 of the Anti-Money Laundering Council (AMLC) Secretariat, the Council resolved to approve: 1. The AMLC Registration and Reporting Guidelines (ARRG) and issue the same as an AMLC Regulatory Issuance; 2. Authority for the Secretariat to publish the ARRG in a newspaper of general circulation and to post the same in the AMLC website; 3. Authority for the Executive Director or, in his absence, the Officer-in-Charge, to approve revisions and/or amendments to the ARRG, except those that involve policies, in which case, the AMLC's approval shall be obtained; and 4. Dissemination of this Resolution to covered persons under the respective jurisdictions of the Bangko Sentral ng Pilipinas, the Securities and Exchange Commission and the Insurance Commission. This Resolution supersedes the AMLC Reporting Procedures Manual dated March 2014, and AMLC Resolution No. 408, Series of 2004; AMLC Resolution No. 02, Series of 2005; AMLC Resolution No. 117, Series of 2009; AMLC Resolution Nos. 10, 10-a, 10-b and 10-c, Series of 2013; AMLC Resolution No. 43, Series of 2014; AMLC Resolution No. 05, Series of 2016; AMLC Resolution No. 61, Series of 2016; and AMLC Resolution No. 42, Series of 2017. November 15, 2017, Manila, Philippines. aDSIHc (SGD.) NESTOR A. ESPENILLA, JR. Chairman (Governor, Bangko Sentral ng Pilipinas) (SGD.) TERESITA J. HERBOSA Member (Chairperson, Securities and Exchange Commission) (SGD.) DENNIS B. FUNA Member (Commissioner, Insurance Commission) ATTACHMENT AMLC Registration and Reporting Guidelines General Provisions PART 1 I. Legal Framework The goal of a large number of criminal acts is to generate a profit for the individual or group that carries out the act. Money laundering is the processing of these criminal proceeds to disguise their illegal origin. This process is of critical importance, as it enables the criminal to enjoy these profits without jeopardising their source. 1 Anti-Money Laundering Act (AMLA) In order to establish an effective anti-money laundering regime in the country, the anti-money laundering legislation was enacted under R.A. No. 9160, as amended (AMLA) was signed into law on 29 September 2001 and took effect on 17 October 17 2001. On 07 March 2003, R.A. No. 9194 (An Act Amending R.A. No. 9160) was signed into law and took effect on 23 March 2003. In order to further strengthen the AMLA, R.A. Nos. 10167 and 10365 were enacted and took effect on 06 July 2012 and 07 March 2013, respectively. The Implementing Rules and Regulations took effect on 02 April 2002. Subsequent revisions to the Implementing Rules took effect on 07 September 2003, 15 September 2012 and 09 August 2017, respectively. Section 4 of the AMLA, states that: Money Laundering Offense Money laundering is committed by any person who, knowing that any monetary instrument or property represents, involves, or relates to the proceeds of any unlawful activity: a) transacts said monetary instrument or property; b) converts, transfers, disposes of, moves, acquires, possesses or uses said monetary instrument or property; c) conceals or disguises the true nature, source, location, disposition, movement or ownership of or rights with respect to said monetary instrument or property; d) attempts or conspires to commit money laundering offenses referred to in paragraphs (a), (b) or (c); e) aids, abets, assists in or counsels the commission of money laundering offenses referred to in paragraphs (a), (b) or (c) above; and f) performs or fails to perform any act as a result of which he facilitates the offense of money laundering referred to in paragraphs (a), (b) or (c) above. R.A. No. 10927 which took effect on 29 July 2017 effectively amends Section 1. Section 3 (a) of the AMLA to include casinos as "Covered Persons." Single cash transactions of casinos in excess of five (5) million pesos or its equivalent in any other currency, must be reported to the Anti-Money Laundering Council (AMLC). Terrorism Financing Prevention and Suppression Act On 18 June 2012, R.A. No. 10168, otherwise known as the Terrorism Financing Prevention and Suppression Act of 2012 was signed into law. This law took effect on 05 July 2012. Pursuant to Section 22 of R.A. No. 10168, the AMLC promulgated the Implementing Rules and Regulations (IRRs) of R.A. No. 10168, which was published on 11 August 2012. In relation to R.A. 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. II. Covered Persons Covered Persons (CPs) which are mandated by the AMLA, to submit covered and suspicious transaction reports (CTRs/STRs) to the AMLC are as follows: Banks, non-banks, quasi-banks, trust entities, foreign exchange dealers, pawnshops, remittance and transfer companies and other similar entities and all other persons and their subsidiaries and affiliates, supervised and regulated by the Bangko Sentral ng Pilipinas (BSP). Insurance companies, pre-need companies and all other persons supervised or regulated by the Insurance Commission (IC). Securities dealers, brokers, salesmen, investment houses and other similar persons managing securities or rendering services as investment agent, advisor, or consultant, mutual funds, close-end investment companies, common trust funds, and other similar persons, and other entities administering or otherwise dealing in currency, commodities or financial derivatives based thereon, valuable objects, cash substitutes and other similar monetary instruments or property supervised or regulated by the Securities and Exchange Commission (SEC). ETHIDa The following Designated Non-Financial Businesses and Professions (DNFBPs): o Jewelry dealers, dealers in precious metals, and dealers in precious stones. o Company service providers which, as a business, provide any of the following services to third parties: acting as a formation agent of juridical persons; 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; 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 acting as (or arranging for another person to act as) a nominee shareholder for another person. o Persons, including lawyers and accountants, who provide any of the following services: managing of client money, securities or other assets; management of bank, savings or securities accounts; organization of contributions for the creation, operation or management of companies; and creation, operation or management of juridical persons or arrangements, and buying and selling business entities. Casinos, including internet and ship-based casinos, with respect to their casino cash transactions related to their gaming operations. The term "Covered Persons" shall exclude lawyers and accountants acting as independent legal professionals in relation to information concerning their clients or where disclosure of information would compromise client confidences or the attorney-client relationship, provided, that they are authorized to practice in the Philippines and shall continue to be subject to the provisions of their respective codes of conduct and/or professional responsibility or any of its amendments. III. Covered Transaction Reports (CTRs) A. CPs shall report to the AMLC all covered transactions within five (5) working days from occurrence thereof. B. 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. C. All CPs shall report to the AMLC all covered transactions, regardless of the mode of payment used in the settlement thereof, including transactions in checks, fund transfers, and/or debiting or crediting of accounts, except those transactions covered under the no/low risk transactions (Part 1 General Provisions, Item VII). D. Covered Transaction is a transaction in cash or other equivalent monetary instrument involving a total amount in excess of five hundred thousand pesos (Php500,000.00) within one (1) banking day. For jewelry dealers in precious metals and jewelry dealers in precious stones as defined, covered transaction is a transaction in cash or other equivalent monetary instrument involving a total amount in excess of one million pesos (P1,000,000.00). For casinos, a covered transaction is a transaction in cash or other equivalent monetary instrument involving an amount in excess of five million pesos (Php5,000,000.00) or its equivalent in any other currency. IV. Suspicious Transaction Reports (STRs) A. Under Sec. 3 (b-1) of the AMLA, a Suspicious Transaction is a transaction, regardless of amount, where any of the following circumstances exists: 1. There is no underlying legal/trade obligation, purpose or economic justification; 2. The client is not properly identified; 3. The amount involved is not commensurate with the business or financial capacity of the client; 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 AMLA; 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; 6. 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 cSEDTC 7. Any transaction that is similar, analogous or identical to any of the foregoing. B. Customer Due Diligence (CDD) and Ongoing Monitoring. CDD and ongoing monitoring 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. C. Alerts and Red flags. Covered persons should have systems in place that would alert its responsible officers of any circumstance or situation that would give rise to a suspicion of a money laundering activity or transaction. The following is a list of non-exhaustive examples of situations that might give rise to a suspicion in certain circumstances: 1. transactions or instructions which have no apparent legitimate purpose and/or appear not to have a commercial rationale; 2. transactions, instructions or activity that involve apparently unnecessary complexity or which do not constitute the most logical, convenient or secure way to do business; 3. 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; 4. where, without reasonable explanation, the size or pattern of transactions is out of line with any pattern that has previously emerged; 5. 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; 6. 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; 7. the extensive use of trusts or offshore structures in circumstances where the customer's needs are inconsistent with the use of such services; 8. transfers to and from high risk jurisdictions without reasonable explanation, which are not consistent with the customer's declared business dealings or interests; and 9. unnecessary routing of funds or other property from/to third parties or through third party accounts. Covered persons 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. See Annex D for examples of Examples of Alerts, Red Flags and Suspicious Indicators D. Recognizing Suspicious or Unusual transactions. The key is knowing enough about the customer's business to recognize that a transaction, or a series of transactions is unusual and, from an examination of the unusual, 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, etc., the transaction should be considered unusual and the covered person should be put on alert. Where a responsible officer of the covered person conducts inquiries and obtains what it considers to be a satisfactory explanation of the activity or transaction, it may conclude that there are no grounds for suspicion, and therefore take no further action. However, where the inquiries do not provide a satisfactory explanation of the activity or transaction, an internal report should be made and be properly escalated to the designated compliance officer and/or review committee to determine if there are grounds for suspicion warranting the submission of the STR. E. Internal Analysis, Investigations and Escalation. Covered persons shall formulate a reporting chain under which a suspicious transaction or circumstance will be processed, analyzed and investigated. Said 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 Terrorist Financing Prevention Program (MLPP). Covered persons 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. F. Timing and Manner of Submission of STRs. Covered persons shall file Suspicious Transaction Reports (STRs) that are complete, accurate and timely in accordance with the following guidelines: SDAaTC 1. Covered persons shall report to the AMLC all suspicious transactions within five (5) working days from the occurrence thereof. 2. "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. 3. 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. Generally speaking, knowledge is likely to include: a. Actual knowledge; b. Knowledge of circumstances which would indicate facts to a reasonable person; and c. Knowledge of circumstances which would put a reasonable person on inquiry. 4. For transactions triggered under an existing suspicious transaction monitoring system (TMS) where the suspicious transaction indicators under Section 3 (b-1) of the AMLA have been conclusively incorporated to the system, said transaction shall be reported within five (5) working days from the date of transaction. 5. 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 under paragraph E above, 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. 6. 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, it shall be given a 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. 7. The reasonable period shall be indicated in the covered person's MLPP. Said 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. G. Uploading of KYC Documents is mandatory, if the reason for suspicion will fall under 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 However, 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 Part 4, Chapter 2.3 of the AMLC Registration and Reporting Guidelines for a step-by-step procedure of the Uploading of KYC Documents. H. Should a transaction be determined to be both a covered and a suspicious transaction, the CP shall report the same as a suspicious transaction. V. Guidelines in reckoning CPs compliance with the prescribed reporting period A. The following non-working days are excluded from the counting of the prescribed reporting period: weekend (Saturday and Sunday) official regular national holiday officially declared national holiday and workday suspensions acEHCD B. 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. AMLC-declared "non-reporting day" is excluded from the counting of the prescribed reporting period. The Executive Director, or in his/her absence, the Officer-in-Charge of the AMLC Secretariat is authorized to declare such day as a "non-reporting day." C. 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/her absence, the Officer-in-Charge of the AMLC Secretariat. VI. Transaction Reporting Rule 9C (1) of the 2016 RIRRs of the AMLA states that Covered persons shall ensure the accuracy and completeness of covered transaction and suspicious transaction report, 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. VII. No/Low Risk Transactions Defer reporting of the following "no/low risk" covered transactions. A. For CPs under the supervisory authority of the Bangko Sentral ng Pilipinas (BSP): 1. Transactions between BSP-supervised covered institutions and the BSP; 2. Transactions between banks operating in the Philippines; 3. Transactions involving transfer of funds from one deposit account to another deposit account of the same person within the same bank, limited to Checking and Savings Account only; 4. Roll-over of placements of time deposits and/or other client's investments, provided that there is no change in the Account number; 5. Bank-initiated (transactions of the bank) or system generated transactions such as but not limited to: a. Internal operating expenses and capital expenditures of CPs These are necessary expenses of covered institutions for the normal day-to-day running of a business. These are transactions of covered institutions and, therefore, not reportable. Such as, but not limited to payment of salaries, taxes, debt service, SSS premiums, Pag-IBIG contributions and employees' benefits. b. Payments of dividends or interests on investments, provided that the principal investment was previously reported; c. Remittance by a bank, acting as a collecting agent, of taxes and other government fees collected from the public, to the Bureau of Internal Revenue and other government agencies; d. Remittance by a bank, acting as a collecting agent, of customers' bills payment ( e.g. , utilities ); e. Adjusting entries or reclassification of accounts; f. Service fees, proprietary revenue fees, arrangement fees, loan syndication fees and other form of fees incidental to loans granted or investments sold, provided that the loans granted or the sale of investment was reported at gross or at its principal amount; and g. Investments of covered institutions in government securities, or in companies listed in the local or international Stock Exchanges. 6. Payment of loan and/or its corresponding interest regardless of the manner of payment (cash, fund transfer, debit of account, check) , provided that the grant of loan was previously reported as covered transaction; 7. Reclassification of loan security to Real and other Properties Acquired (ROPA); 8. Installment or partial payment in the sale of ROPA, provided that the total selling price of the ROPA in excess of P500,000.00 was reported at the time of the execution of the contract to sell or sales contract receivable, or deed of sale; 9. Loan repricing, loan renewal, loan restructuring, provided that there is no change in borrower's name, otherwise, the loan shall be considered as new loan, hence, reportable; 10. Transactions of the Trust department of a bank: SDHTEC a. Investment/divestment of Unit Investment Trust Fund (UITF) and Trust and Other Fiduciary Activities (TOFA); b. Investment/divestment of Investment Management Account (IMA), such as Special Deposit Account, government securities, equities traded in the Philippine Stock Exchange, real estate properties, and deposits with own bank or other banks, and loans granted; and c. Rollover of Investment of UITF, TOFA, and IMA, provided that the initial contribution or placement was previously reported. Any redemption, termination, or cancellation of investment resulting to closure of the trust account of a client shall be reported. 11. Transaction of government agencies with banks, except the following: a. Disbursements of government agencies that passed through the Modified Disbursement Scheme (MDS), which disbursements are payable to private entities; non-governmental organizations (NGOs); non-profit, charitable or religious foundations; or to individual persons; b. Disbursements of government agencies coursed through other depository banks, other than the MDS accounts, that are payable to private entities; non-governmental organizations (NGOs); non-profit, charitable or religious foundations; or to individual persons; and Government agency refers to any of the various units of the Government, including a department bureau, office, instrumentality, or government-owned or controlled corporation, or a local government or a distinct unit. 12. Agrarian Reform Receivables; and 13. Payment for agricultural lands under the Agrarian Reform Law. B. For CPs under the supervisory authority of the Securities and Exchange Commission (SEC): 1. Transactions between banks and quasi-banks operating in the Philippines; 2. Roll-over of client's investments or deposit substitutes, provided that the principal investment was previously reported; 3. Transactions between parent bank and its subsidiary or associate financing company or affiliates; 4. Payment of loan and/or its corresponding interest regardless of the manner of payment (cash, fund transfer, debit of account, check) , provided that the grant of loan was previously reported as covered transaction; 5. Loan repricing, loan renewal, loan restructuring, provided that there is no change in borrower's name, otherwise, the loan shall be considered as new loan, hence, reportable; 6. Investment or Divestment of Mutual Funds; 7. Internal operating expenses and capital expenditures of covered institutions; These are necessary expenses of covered institutions for the normal day-to-day running of a business. These are transactions of covered institutions and, therefore, not reportable. Such as, but not limited to payment of salaries, taxes, debt service, SSS premiums, Pag-IBIG contributions and employees' benefits. 8. Adjusting entries or reclassification of accounts; and 9. Service fees, proprietary revenue fees, arrangement fees, loan syndication fees and other form of fees incidental to loans granted or investments sold, provided that the loans granted or the sale of investment was reported at gross or at its principal amount. C. For CPs under the supervisory authority of the Insurance Commission (IC): 1. Transactions between domestic insurance companies/professional reinsurers/intermediaries licensed by the Insurance Commission; 2. Renewal of non-life insurance policies under the same terms and conditions provided that a CTR has been previously filed; 3. Automatic premium advance; 4. Collection of premium payments from telemarketing, or direct marketing or through SMS and/or by way of salary deductions, where the bulk settlement exceeds P500,000.00 but the individual transactions are below the reporting threshold amount; 5. Group Life Insurance and Hospitalization Insurance; 6. Transactions of members of Mutual Benefit Associations pertaining to basic benefits; 7. Payment of loan and/or its corresponding interest regardless of the manner of payment, provided that the grant of loan was previously reported as covered transaction; 8. Bulk settlement of claims on death and disability benefits of a policy where individual claim does not exceed P500,000.00; AScHCD 9. Transactions coursed through brokers, agents and other intermediaries, in which case, however, the insurance company (principal) shall report the said transactions; 10. Internal operating expenses and capital expenditures of covered institutions; and These are necessary expenses of covered institutions for the normal day-to-day running of a business. These are transactions of covered institutions and, therefore, not reportable. Such as, but not limited to payment of salaries, taxes, debt service, SSS premiums, Pag-IBIG contributions and employees' benefits. 11. Adjusting entries or reclassification of accounts. VIII. Applicability of the Imposition of Administrative Sanctions Violations of AMLC Registration and Reporting Requirements 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. For reference, please see www.amlc.gov.ph . IX. Effectivity The AMLC Registration and Reporting Guidelines shall take effect thirty (30) days after its publication, except for the Uploading of KYC Documents for Suspicious Transaction Reports, Part 4 Chapter 2.3, and the Uploading of Electronic Return (E-Return) for Freeze Order, Part 4 Chapter 2.6, which shall take effect on the first banking day of January 2018. Online Registration System PART 2 ONLINE REGISTRATION INTRODUCTION 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 institutions" (Section 7.1 of R.A. 9160). Section 1 of RA 10365 amends Section 3 of R.A 9160 to expand the coverage of the law; it changes the definition from covered institutions to covered persons, whether natural or juridical. In addition, Rule 9C (3) of the 2016 RIRRs of the AMLA states that "All covered persons shall register with the AMLC's electronic reporting system within ninety (90) days from the effectivity of this RIRR." 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. 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. a. Secretary Certificate and/or Board Resolution and/or General Information Sheet for COs of Banks, Insurance Companies, Securities Companies, Financing Companies, Lending Companies, Pre-Need Companies and all other Covered Persons registered with the SEC as a Corporation. b. Certificate of Associated Persons for APs of Brokerage Companies. c. DTI Certificate for Pawnshops/Money Service Businesses, registered as Single Proprietorship as well as a Document, notarized and signed by the owner of the MSB/Pawnshop designating him/her as the PDO, if the PDO is not the owner of the MSB/Pawnshop. 2. COs/APs/PDOs should download the Transaction Security Protocol Manual 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. AcICHD 3. Once Items 1-2 have been performed/accomplished, COs/APs/PDOs 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 CPs, 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 CPs user access in the AMLC Portal. 7. List of successfully registered MSBs and Pawnshops will be published in the AMLC website, to be updated monthly. Log-on to https://portal.amlc.gov.ph 1. Click on Register 2. Covered Person 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 Covered Person 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. Note: Be sure to have a scanned copy of your document/s stating your appointment as the CO/AP/PDO; 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/AP/PDO, as well as the key details of their public key. This is also where the CO/AP/PDO uploads supporting documents (PDF) of his/her appointment and his exported asc file. If there is no alternate, click "Done," otherwise click "Add Alternate." 4. Continue to add details of the alternate (if any). Public key (Key details) of the Alternate is optional. 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." 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. 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/AP/PDO, as well as the designated alternate (if any). 8. After the CO/AP/PDO and alternate have validated their email addresses, this page will appear, just click "Agree." Then click on the "Exit" button. 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. 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. ICHDca 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 or first 9-digits of your institution code, email address and system generated password. Transaction Security Protocol PART 3 Transaction Security Protocol GUIDELINES A. The File Transfer and Reporting Facility using the Hypertext Transfer Protocol over Secure Socket Layer (FTRF v 2.0) shall be used by the CPs in transmitting their respective reports. B. 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. C. File Transfer and Reporting Facility (FTRF) has the following features: a. Secure upload provides data encryption, server authentication and message integrity; b. Self-signed Digital Identification & Certificate allows encrypting and digital signing of messages; and D. The self-signed digital identification shall be implemented for all CPs. AMLC and the CPs 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. E. The compliance officer of the CP shall generate his private key as well as public key using GPG which shall be uploaded during the Online Registration. F. The signed public key of the AMLC shall be used by the CPs to: a. Encrypt the electronic files (CTR/STR in csv format) to be submitted to AMLC; and b. Verify the signature of the files they will receive from AMLC. H. The signed private key of the AMLC shall be used by AMLC to: a. Decrypt the encrypted files sent by the CPs which were encrypted using AMLC's signed public key; and b. Sign the electronic files they will send to the CPs. I. The signed public key of the CP shall be used by the AMLC to: a. Encrypt the validation messages that AMLC will send to the CP; and b. Verify the signature of the files AMLC will receive from the CPs. J. The signed private key of the CP 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. K. CPs are required to encrypt and sign the electronic CTR/STR files before transmitting them to AMLC via https (AMLC portal). L. In cases wherein the public key is compromised, superseded or no longer in use, CPs 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. 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. TCAScE 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 company 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 . Pin entry window will be displayed on the screen. Enter Passphrase (gpg password of compliance officer), 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. Re-enter passphrase, then click Ok . 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. cTDaEH 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. cSaATC 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. n Recovery Procedure This is done if the public key is compromised, only if the CPs 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. Reporting Procedures PART 4 CHAPTER 1 Covered/Suspicious Transaction Report 1.1 Data Elements Chart (Format Code 1.0) BSP/SEC 1.2 Electronic Record Format (Format 1.0 BSP/SEC) 1.3 Data Elements Chart (Format Code 1.0) IC 1.4 Electronic Record Format (Format 1.0 IC) 1.5 Electronic Record Format Bulk Reporting 1 (B1) 1.6 Electronic Record Format Bulk Reporting 2 (B2) CHAPTER 2 Transaction Security Process and Transferring of Files 2.1 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 . 2.2 Transferring of Files (File Transfer Reporting Facility version 2.0) 2.2.1 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 Enter password cHDAIS Click LOGIN A successful login will show the CP User Main Page. There are nine (9) options or links available in CP User Main Page: a. Advisory , if the icon is clicked, it will automatically display latest/announcement of AMLC. b. CTR/STR File Upload provides access for the registered CP user to upload the electronic CTRs and STRs. c. CTR/STR File Upload History 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. Logout will log the CP user out of the system and go back to CP User Login Page. e. KYC Docs Upload provides access for the registered CP user to upload KYC Documents for STRs. f. Electronic Returns Upload provides access for the registered CP user to upload E-Returns for Freeze Orders. g. Electronic Returns Template provides a template facility (excel file) for Electronic Returns. h. STR Attachment Upload gives the option for the registered CP user to upload a STR attachment, provided that the STR has been uploaded and processed. i. STR Attachment History gives the option for the registered CP user to check the status of the STR attachment that has been uploaded. 2.2.2 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. 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 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. 2.2.3 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 Click > SEARCH to start the search. When the search is completed, the query result is displayed. 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. 2.2.4 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. 2.3 Uploading of KYC documents for Suspicious Transaction Reports 2.3.1 Mandatory uploading of KYC Documents Uploading of KYC Documents is mandatory if the Reason of Suspicion falls under any of the following: ISHCcT 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 Persons' User Main Page. Click on KYC Docs upload, to go to the Upload window. In the initial KYC Docs Upload window, two options will be available: Choose New STR, if the KYC Docs to be uploaded corresponds to an STR not previously uploaded otherwise choose Existing STR, if the KYC Docs to be uploaded is for previously uploaded STRs. Click on New STR button to enable the KYC Docs Upload window, enter the Customer Reference Number and attach the corresponding KYC Documents, then Click the Upload Button. The Find Button will only be used for the updating of KYC Documents. * Customer Reference Number (CRN) is a unique number assigned to a customer of a CP; please make sure that the CRN indicated in the KYC Docs upload window will be the same CRN inputted in the STR where the KYC Docs will be attached. Click on Existing STR button to enable the KYC Docs for Existing STR window, click Upload, once fields are filled up and the KYC Docs have been attached. After the Upload button is clicked and upon every successful upload, the "KYC Upload Confirmation Receipt" is displayed. If an STR with the above mention Reason for Suspicion will be filed on the same CRN, three (3) years after the initial uploading of KYC Docs, a mandatory update for the uploaded KYC Documents is required. To Update, go to the KYC Docs Upload Window, type the CRN and 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. 2.4 STR Attachment Upload Please note, that a successfully processed and uploaded STR is required before a Covered Person can upload an STR attachment. CAacTH 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 Enter password Click LOGIN 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. After the Upload button is clicked and upon every successful upload, the "STR Attachment Upload Confirmation Receipt" is displayed. 2.5 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 . To view specific past date or date range, click 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. 2.6 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 9digits of the Inst. Code for CPs with 18-digit Inst. Code Enter the Username or Registered email address Enter password Click LOGIN 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 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, attach the accomplished excel file (as downloaded in the AMLC portal) containing the e-returns and Click Upload. IAETDc CHAPTER 3 General Guidelines I. 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 PHP500,000.00) 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, TRANSACTION CODE, REFERENCE NO. and FLAGS. b. POLICY NO./CERTIFICATE NO./OR NO. (D-5) for IC transactions. c. ACCOUNT NUMBER (D-5) for BSP/SEC when customers reported are Account Holders of the CPs. d. PESO AMOUNT (D-7) for BSP/SEC and PESO AMOUNT OF ANNUAL PREMIUM (D-7) for IC except the transaction codes NFFWV, NLOIP, NPFWV and NPLN where AMOUNT OF CLAIM/POLICY LOAN (D-13) becomes mandatory. e. FX CODE if the FX AMOUNT has a value. f. For rollover of investments, the OLD ACCOUNT NO./PN NO./CLIENT STOCK REF. NO. (D-6), if a new account number is issued. 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.) 4. For STRs a. The PLACE OF BIRTH, NATIONALITY, ID TYPE, ID NO., and NATURE OF BUSINESS for the Account Holder Party (BSP/SEC) and Policy Owner Party (IC) except for ZSTR transaction code wherein only the Subject of Suspicion Name is mandatory, all other parties are optional, only if the Account Holder or Policy Owner is not known. b. The REASON and NARRATIVE fields. c. If the value in the reason field is "SI6," the description of the suspicious activity should always be specified separated by a semicolon. d. SUBJECT OF SUSPICION. (Flag and Subject of Suspicion only) other fields are optional. 5. For BSP/SEC a. For the Account Holder, the NAME, ADDRESS and BIRTHDATE, except for the following transaction codes: for RIRDA and RIRIA only the account name and address are mandatory), for RIRDP, RIRIP, CBPYC, CBPYM and KPAYM (only the account name is mandatory). b. For Outward Remittances, the NAME and ADDRESS of the Beneficiary, except for RORDE where only the Beneficiary Account number is Mandatory; however, the Name flag Y for the Beneficiary name should be present. c. For Inward Remittances, the name and address of the counterparty, except for RIRDP and RIRIP , where only the name of the counterparty is Mandatory and for RIRDA and RIRIA , where only the Beneficiary and Counterparty names are Mandatory and for RIRDE , Counterparty Account number is Mandatory; however, the Name flag Y for the Counterparty name should be present. d. For other transactions requiring information on the Beneficiary, Counterparty, Other Participant and Issuer, only the NAME may be filled up. e. For transactions where settlement is for credit/debit to/from account of the PARTY, the corresponding Party ACCOUNT NO. is mandatory. DcHSEa 6. For IC a. For life insurance, the NAME, ADDRESS and BIRTHDATE of the Policy Owner, Insured and Beneficiary, except for NREC where only the Policy Owner is mandatory (applies to Life and Non-Life Insurance). b. For non-life insurance, the NAME, ADDRESS and BIRTHDATE of the Policy Owner. For the Beneficiary, only the NAME may be filled up; Insured Party is optional. The list of MANDATORY fields per transaction is further discussed in Annex C . For optional fields, wherein data is available, data should also be included in the CTRs/STRs. 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 (BSP/SEC) 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 BSP or SEC) of the reporting covered person. H-3. Institution Code This refers to the 11-digit code or 18-digit code of the reporting CP which came from the BSP codes for BSP-supervised CPs or the 11-digit code for SEC-supervised CPs 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 Date when transaction occurred in year, month, and day format (YYYYMMDD). 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. Account No./PN No./Client Stock Ref. No. Refers to the assigned Account Number of the client or Promissory Note No. for loans, etc. or Client Stock Ref. No. for securities. D-6. Old Account No./PN No./Client Stock Ref. No. Refers to the previously assigned Account Number of the client or Promissory Note No. for loans, time deposit etc. or Client Stock Ref. No. for securities. D-7. 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-8. Transaction Amount (FX) If applicable, amount in original foreign currency involved in the transaction. D-9. FX Currency Code Indicates the currency of the FX transaction following AMLC's currency codes (Use only if applicable Part B.2.). Mandatory if FX Amount is not null. D-10. Nature/purpose of Transaction Explains the nature or purpose of transaction or the risk being insured. D-11. Inception/Effectivity Date Date when stock/bond was issued or start of obligation. It should not be less than 20011017. D-12. Maturity Date/Expiry Date Date when the financial obligation becomes due. It should not be less than the inception date. D-13. Amount of Claim/Dividend/CSV Amount being claimed or amount of the dividend or the cash surrender value. D-14. No. of shares/units Refers to the number of shares purchased/sold. D-15. Net Asset Value Refers to the price per share or an exchange-traded fund's (ETF) price per share. D-16. 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-17. 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-18. Country Code of Correspondent Bank Indicates the country of the correspondent bank following BSP country codes (Part B.3). D-A-1. Party Type Flag Indicates that the person/corporation is an accountholder (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. cHECAS D-A-3. Name Flag "N" if accountholder is an individual, "Y" if accountholder is a corporation. D-A-4. Name of Account Holder Refers to the accountholder/client specifying the last name, first name, middle name of the individual person or the registered name of the corporation or partnership. D-A-5. Address of Account Holder 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-6. Birthdate of Account Holder Date of birth of the account holder or the registration date in case of corporation or partnership. 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. For corporate accounts, registration year must be greater than 1521 but less than the current date. D-A-7. Place of Birth/Registration Birth place of the accountholder/client (City, Municipality, Country). D-A-8. Nationality Nationality of the account holder/client. D-A-9. ID Type Type of ID presented by the accountholder/client (SSS, GSIS, Company, etc.). D-A-10. Identification No. Identification No. of the accountholder/client. D-A-11. Telephone No. Contact number of the accountholder/client. D-A-12. Nature of Business Specifies the occupation of the accountholder/client or nature of the business of the corporation or partnership. D-B-1. Party Type Flag Indicates that the person/corporation is the Beneficiary (B). D-B-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-B-3. Name of Beneficiary/Recipient Flag "N" if beneficiary is an individual, "Y" if beneficiary is a corporation. D-B-4. Name of Beneficiary/Recipient Where applicable, indicates the name of the beneficiary of the transaction, i.e. , recipient of money remittance (outward remittance), payee if transaction involves check, etc. D-B-5. Address of Beneficiary/Recipient Gives the detailed address of the beneficiary specifying the Room No./Office Name, building/house no., street, Barangay, District, Town, City, Province, Country, and ZIP code. D-B-6. Account No. of Beneficiary Refers to the account no. of beneficiary being credited. D-B-7. Birthdate of Beneficiary/Recipient Date of birth of the beneficiary/recipient or the registration date in case of corporation or partnership. 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. For corporate accounts, registration year must be greater than 1521 but less than the current date. D-B-8. Place of Birth/Registration of Beneficiary Birth place of the beneficiary/recipient (City, Municipality, Country). D-B-9. Nationality of Beneficiary Nationality of the beneficiary/recipient. D-B-10. ID Type of Beneficiary Type of ID presented by the beneficiary/recipient (SSS, GSIS, Company, etc.). D-B-11. Identification No. of Beneficiary Identification No. of the beneficiary/recipient. D-B-12. Telephone No. of Beneficiary Contact number of the beneficiary/recipient. D-B-13. Nature of Business of Beneficiary Specifies the occupation of the beneficiary/recipient or nature of the business of the corporation or partnership. D-C-1. Party Type Flag Indicates that the person/corporation is the Counterparty. D-C-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-C-3. Name of Remitter/Counterparty Flag "N" if remitter/counterparty is an individual, "Y" if remitter/counterparty is a corporation. D-C-4. Name of Remitter/Counterparty Where applicable, indicates the name of the counterparty to the transaction, i.e. , name of the remitter (inward remittance transactions), issuer of check if transaction involves check. AHDacC D-C-5. Address of Remitter/Counterparty Gives the detailed address of the remitter/counterparty of the transaction specifying the Room No./Office Name, building/house no., street, Barangay, District, Town, City, Province, Country, and ZIP code. D-C-6. Account No. of Remitter/Counterparty Refers to the account no. of remitter being debited. D-O-1. Party Type Flag Indicates that the person/corporation is the Other Participant (O). D-O-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-O-3. Name of Other Participant Flag "N" if other participant is an individual, "Y" if other participant is a corporation. D-O-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. D-O-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-O-6. Account No. of Other Participant Refers to the account no. of the other participant being credited/debited. D-I-1. Party Type Flag Indicates that the person/corporation is the Issuer (I). D-I-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-I-3. Name of Issuer Flag "N" if issuer is an individual, "Y" if issuer is a corporation. D-I-4. Name of Issuer Identifies the issuer of stocks/bonds specifying the last name, first name, middle name or the registered name of the corporation or partnership. D-I-5. Address of Issuer Gives the detailed address of the issuer specifying the Room No./Office Name, building/house no., street, and Barangay, District, Town, City, Province, Country, and ZIP code. D-I-6. Account No. of Issuer Refers to the account no. of the issuer being credited/debited. D-T-1. Party Type Flag Indicates that the person/corporation is the Transactor (T). D-T-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-T-3. Name of Transactor Flag "N." D-T-4. Name of Transactor Identifies the person who made the transaction on behalf of the account holder, specifying the last name, first name and middle name. D-T-5. Address of Transactor Gives the detailed address of the transactor involved in the transaction, specifying Room No./Office Name, building/house no., street, Barangay, District, Town, City, Province, Country, and ZIP code. D-T-6. Account No. of Transactor Refers to the account no. of the transactor (if transactor is also a client of the reporting institution). 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 Flag "N" if subject is an individual, "Y" if subject is a corporation. D-S-4. 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-5. 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-6. Account No. of Subject of Suspicion Refers to the account no. of the subject. IDSEAH D-S-7. Birthdate of Subject of Suspicion Date of birth of the subject or the registration date in case of corporation or partnership. 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. For corporate accounts, registration year must be greater than 1521 but less than the current date. D-S-8. Place of Birth/Registration of Subject of Suspicion Birth place of the subject (City, Municipality, Country). D-S-9. Nationality of Subject of Suspicion Nationality of the subject. D-S-10. ID Type of Subject of Suspicion Type of ID presented by the subject (SSS, GSIS, Company, etc.). D-S-11. Identification No. of Subject of Suspicion Identification No. of the subject. D-S-12. Telephone No. of Subject of Suspicion Contact number of the subject. D-S-13. 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. G. Definition of Field Names (IC) 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 (IC Supervised) of the reporting covered person. H-3. Institution Code This refers to the 11-digit code of the reporting CP which came from the BSP codes for BSP-supervised CPs or AMLC codes for IC-supervised CPs. 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 Date when transaction occurred in year, month, and day format (YYYYMMDD). 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. Policy No./Certificate No./OR/Provisional Receipt No. Refers to the assigned Insurance Policy No. or Issued OR. D-6. Account No/Credit Card Account No. Refers to the account no. of the policy holder to be credited/debited or the Credit Card No. used for the settlement of the policy. D-7. Php Amount of Annual Premium/Excess/Advance Premium/Advance Payment/Top-ups refers to the Philippine Peso amount of annual premium, excess or advance premiums or payments and top-ups to be paid to the insurance company or its equivalent if transaction is in foreign currency. Amount should be greater than 0. D-8. FX Amount of Annual Premium/Excess/Advance Premium/Top-ups If applicable, amount in original foreign currency of the premium to be paid annually. aCIHcD D-9. FX Currency Code Indicates the currency of the FX transaction following AMLC's Currency codes (Use only if applicable). Mandatory if FX Amount is not null. D-10. Nature/purpose of Transaction Explains the nature or purpose of transaction or the risk being insured. D-11. Policy Effectivity Date The date when the policy contract becomes effective or the date specified on the certificate of insurance as the beginning of coverage. It should not be less than 1900. D-12. Maturity Date/Expiry Date Date when the financial obligation/services/benefits become due or when the policy matures or the contract expires. It should be between the transaction date and the policy date +100 years. D-13. Php Amount of Claim/Dividend/CSV/Policy Loan Amount being claimed against the insurance policy or amount of the dividend or the cash surrender value. D-14. Policy Amount/Face Value/Contract Value/Sum Insured (Php) Amount in Philippine peso for which the policy is purchased from the insurance company or its agents. D-15. Policy/Insurance/Product Type Refers to the policy/insurance/product type. D-16. Policy Amount/Face Value/Contract Value/Sum Insured (FX) If applicable, refers to the amount in the original foreign currency for which the policy is purchased from the insurance company or its agents. D-17. Term of insurance Policy (in years) refers to the coverage (in years) of the insurance policy. D-O-1. Party Type Flag Indicates that the person/corporation is a policy owner (O). D-O-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-O-3. Name of Policy Owner Flag "N" if policy owner is an individual, "Y" if policy owner is a corporation. D-O-4. Name of Policy Owner Refers to the name of the person/corporation who owns the insurance policy specifying the last name, first name, middle name of the individual person or the registered name of the corporation/partnership. D-O-5. Address of Policy Owner Gives the detailed address of the policy owner specifying the Room No./Office Name, building/house no., street, Barangay, District, Town, City, Province, Country, and ZIP code. D-O-6. Birthdate/Registration Date Date of birth of the policy owner if individual or the registration date in case of corporation or partnership. 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. For corporate accounts, registration year must be greater than 1521 but less than the current date. D-O-7. Place of Birth/Registration Birth place of the policy owner (City, Municipality, Country). D-O-8. Nationality Nationality of the policy owner. D-O-9. ID Type Type of ID presented by the policy owner (SSS, GSIS, Company, etc.). D-O-10. Identification No. Identification No. of the policy owner. D-O-11. Telephone No. Contact number of the policy owner. D-O-12. Nature of Business Specifies the occupation of the policy owner or nature of the business of the corporation or partnership. D-I-1. Party Type Flag Indicates that the person/corporation is the Insured (I). D-I-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-I-3. Name of Insured Flag "N" if Insured is an individual, "Y" if Insured is a corporation. D-I-4. Name of Insured refers to the persons or parties who are protected by an insurance policy giving the last name, first name, middle name of the individual person or the registered name of the corporation or partnership. Indicates who directly/indirectly benefited from the transaction. D-I-5. Address of Insured Gives the detailed address of the insured if insured name is given specifying the bldg./house no., street, Barangay, District, Town, City, Province, Country, and ZIP code. D-I-6. Account No. of Insured Refers to the account no. of the insured to be credited/debited. cHaCAS D-I-7. Birthdate/Registration Date Date of birth of the insured if individual or the registration date in case of corporation or partnership. 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. For corporate accounts, registration year must be greater than 1521 but less than the current date. D-I-8. Place of Birth/Registration Birth place of the insured (City, Municipality, Country). D-I-9. Nationality Nationality of the insured. D-I-10. ID Type Type of ID presented by the insured (SSS, GSIS, Company, etc.). D-I-11. Identification No. Identification No. of the insured. D-I-12. Telephone No. Contact number of the insured. D-I-13. Nature of Business Specifies the occupation of the insured or nature of the business of the corporation or partnership. D-B-1. Party Type Flag Indicates that the person/corporation is the Beneficiary (B). D-B-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-B-3. Name of Beneficiary Flag "N" if Beneficiary is an individual, "Y" if Beneficiary is a corporation. D-B-4. Name of Beneficiary/Recipient refers to the person who would receive the proceeds of the life insurance policy specifying the last name, first name, middle name of the individual person or the registered name of the corporation/partnership. D-B-5. Address of Beneficiary/Recipient Gives the detailed address of the beneficiary specifying the Room No./Office Name, building/house no., street, Barangay, District, Town, City, Province, Country, and ZIP code. D-B-6. Account No. of Beneficiary Refers to the account no. of the beneficiary to be credited. D-B-7. Birthdate of Beneficiary/Recipient Date of birth of the beneficiary/recipient or the registration date in case of corporation or partnership. 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. For corporate accounts, registration year must be greater than 1521 but less than the current date. D-B-8. Place of Birth/Registration of Beneficiary Birth place of the beneficiary/recipient (City, Municipality, Country). D-B-9. Nationality of Beneficiary Nationality of the beneficiary/recipient. D-B-10. Relationship of Beneficiary to Insured refers to the relationship of the beneficiary to the insured individual/corporation. D-B-11. Designation of Beneficiary Code "Y" if revocable, "N" if irrevocable. D-U-1. Party Type Flag Indicates that the person/corporation is the Trustee (U). D-U-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-U-3. Name of Trustee Flag "N" if Trustee is an individual, "Y" if Trustee is a corporation. D-U-4. Name of Trustee Identifies the name of the trustee/guardian of a minor beneficiary specifying the last name, first name, middle name of the individual person. D-U-5. Address of Trustee Gives the detailed address of the trustee specifying the Room No./Office Name, building/house no., street, Barangay, District, Town, City, Province, Country, and ZIP code. D-U-6. Account No. of Trustee Refers to the account no. of the trustee. D-R-1. Party Type Flag Indicates that the person/corporation is the Payer/Trustor (R). D-R-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-R-3. Name of Policy Owner Flag "N" if Payor/Trust or is an individual, "Y" if Payer/Trust or is a corporation. D-R-4. Name of Payor/Trustor Identifies the name of the payor/trustor specifying the last name, first name, middle name or the registered name of the corporation or partnership. D-R-5. Address of Payor/Trustor Gives the detailed address of the payor/trustor specifying the Room No./Office Name, building/house no., street, Barangay, District, Town, City, Province, Country and ZIP code. DACcIH D-R-6. Account No. of Payor/Trustor Refers to the account no. of the Payor/trustor. D-T-1. Party Type Flag Indicates that the person/corporation is the Transactor (T). D-T-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-T-3. Name of Transactor Flag "N" if Transactor is an individual, "Y" if Transactor is a corporation. D-T-4. Name of Transactor Identifies the person who made the transaction other than the insured, beneficiary, trustee, etc., specifying the last name, first name, middle name of the individual person or the registered name of the corporation or partnership. D-T-5. Address of Transactor Gives the detailed address of the transactor involved in the transaction other than the insured, beneficiary, trustee, etc., specifying the Room No./Office Name, building/house no., street, Barangay, District, Town, City, Province, Country, and ZIP code. The address of the other participant is divided into 3 fields of 30 characters each (address1, address2, address3). D-T-6. Account No. of Transactor Refers to the account no. of the transactor. 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 Flag "N" if Subject of Suspicion is an individual, "Y" if a corporation. D-S-4. 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-5. 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-6. Account No. of Subject of suspicion Refers to the account no. of the subject being credited/debited. D-S-7. Birthdate of Subject of suspicion Date of birth of the subject or the registration date in case of corporation or partnership. 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. For corporate accounts, registration year must be greater than 1521 but less than the current date. D-S-8. Place of Birth/Registration of Subject of suspicion Birth place of the subject (City, Municipality, Country). D-S-9. Nationality of Subject of suspicion Nationality of the subject. D-S-10. ID Type of Subject of suspicion Type of ID presented by the subject (SSS, GSIS, Company, etc.). D-S-11. Identification No. of Subject of suspicion Identification No. of the subject. D-S-12. Telephone No. of Subject of suspicion Contact number of the subject. D-S-13. 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 Philippine peso transaction amounts in the file. T-3. Records Total refers to the number of transactions included in the file. H. Name and Party flags precede each name respectively. Name Flag A name flag "Y" indicates that the subject is an entity and should use a single name field. HSCATc The name flag "N" indicates that the subject is an individual and should use the 3-field name last name, first name, and middle name. For BSP/SEC Party Flag The party flag value "A" is for the account holder/client of the reporting institution. The party flag "B" is for the beneficiary/recipient of the transaction. The party flag "C" is for the counterparty/remitter/source of the transaction. For transactions involving parties other than the accountholder, beneficiary and counterparty, the party flag "P" for other party shall be used. This may be applicable for securities transactions with 3rd party brokers. The party flag "I" refers to the issuer of securities/product/investment instruments. The party flag "T" is for the transactor. This is the person executing the transaction. The party flag "S" is for the subject of suspicion. For IC Party Flag The party flag value "O" refers to the policy owner. The party flag "B" refers to the beneficiary/recipient. The party flag "I" refers to the insured. The party flag "U" refers to the trustee. The party flag "R" refers to the payor/trustor. The party flag "T" is for the transactor. This is the person executing the transaction. The party flag "S" is for the subject of suspicion. I. The parties do not follow a particular order in the CSV file. J. 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. K. 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,N,DELA CRUZ,JUAN,REYES,123 ABC STREET,MAKATI CITY,MAKATI PHILIPPINES 2000,19700101,MANILA PHILS.,FILIPINO,ID1,XX1234567,7210202,REAL ESTATE, A ,5678,N,DELA CRUZ,MARIA,ALCANTARA,123 ABC STREET,MAKATI CITY,MAKATI PHILIPPINES 2000,19720203,MANILA PHILS.,FILIPINO,ID1,XX7654321,7210202,REAL ESTATE, L. 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). M. 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 Chapter 2.3.) 2. In cases where in the perpetrator is not identified, CPs shall use the Name Flag Y and use the term "Unknown" in the Subject of Suspicion Name. 3. The reporting institution shall choose the applicable Reason for Suspicion as enumerated in Chapter 2 Data Elements. 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 an accountholder of the reporting institution or is an accountholder but has no monetary transaction with the covered person at the time the suspicious activity is determined. IDTSEH 5. In filing an STR, the following questions should be answered: 2 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). i. 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. 7. n Bulk Reporting of STRs allows the reporting of multiple STRs, of at least five (5) STRs. Bulk reporting involves two (2) types: a. B1 transactions included should involve the same suspicious transaction indicator, and refer to the same accountholder and account number. See Chapter 1 of the Reporting Procedures Manual, item 1.5 for the format of reporting. b. B2 involves fraud related transactions, such as use of skimmed, stolen or lost credit/ATM cards, mail-order/telephone orders, unauthorized withdrawals, point of sale Debit and spurious checks. For B2, victims are different account holders and the perpetrator is unknown . See Chapter 1 of the Reporting Procedures Manual, item 1.6 for the format of reporting. SICDAa Note: CPs have the option to file STR on each suspicious transaction or in bulk, pursuant to the guidelines of B1 and B2. N. 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. O. 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. P. Validity of each field values in terms of length and data type must be observed. Q. 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 N,Lastname,Firstname,Middlename or N,Lastname,Firstname, R. 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 Branch 1 D 1st Detail Record of Branch 1 . . D Last Detail Record of Branch 1 H Header Record of Branch 2 D 1st Detail Record of Branch 2 D 2nd Detail Record of Branch 2 . . D Last Detail Record of Branch 2 . . 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 S. For Remittance transactions: 1. For Inward Remittance transactions, wherein CPs have no control over the name and format of the address, the following guidelines should be followed: a. When CPs cannot identify if the Beneficiary or Counterparty name is an individual or corporation, the Name Flag Y should be used, following the format for a corporate name. This shall be limited to the following transaction codes: DHIcET i. Counterparty all inward remittance transaction codes ii. Beneficiary RIRIA and RIRDA transaction codes b. When CPs have identified the Beneficiary or Counterparty as an individual, the Name Flag N should be used, however, only the Last Name field shall be mandatory. This shall be limited to the following transaction codes: i. Counterparty all inward remittance transaction codes ii. Beneficiary RIRIA and RIRDA transaction codes c. When the Beneficiary or Counterparty Address is in free format, the complete address shall be encoded in the 1st field containing one hundred (100) characters, if the address exceeds one hundred (100) characters; the rest of the address can be inputted in the 2nd field; only Address Field 1 is mandatory. This shall be limited to the following transaction codes: i. Counterparty all inward remittance transaction codes ii. Account Holder/Beneficiary RIRIA and RIRDA transaction codes 2. CTRs for Inward/Outward Remittance transactions, including pass-thru inward remittance, should be reported using Format 1 with the following highlights: (All other mandatory fields must have entries including optional fields, if available). Field Name Value Reporting Institution = Bank Outward Remittance (ORM) transaction Account Number (D-5) - Account Number of Client Account Holder/Client (D-A-4) - Name of CP's client Account Holder Address (D-A-5) - Address of the CPs client Beneficiary Name (D-B-4) - Receiver of Remittance Beneficiary Address (D-B-5) - Address of the Receiver of Remittance Beneficiary Account Number (D-B-6) - Account No. of receiver (Mandatory for RORDC and RORIC transaction codes; optional for other outward remittance transaction codes. FX Amount (D-8)/FX Currency Code (D-9) - FX amount remitted (for International Remittances) Correspondent Bank (D-16) - Name of Beneficiary's Bank Country Code (D-18) - Country code of D-16 Inward Remittance (IRM) transaction Account Number (D-5) - Account Number of Client Account Holder/Client (D-A-4) - Name of CP's client (receiver/beneficiary of the remittance) Account Holder Address (D-A-5) - Address of the CPs client Counterparty Name (D-C-4) - Name of Remitter Counterparty Address (D-C-5) - Address of Remitter FX Amount (D-8)/FX Currency Code (D-9) - FX amount remitted (for International Remittances) Correspondent Bank (D-16) - Name of Remitter's Bank Country Code (D-18) - Country code of D-16 Pass-thru transaction (Inward Remittance) Account Number (D-5) - Account Number of Beneficiary's Bank (if client of the reporting CP) Account Holder/Client (D-A-4) - Name of Beneficiary's Bank (may or may not be a client of the reporting CP) Account Holder Address (D-A-5) - Address of the Beneficiary's Bank Beneficiary Name(D-B-4) - Name of final beneficiary client of another bank Beneficiary Address (D-B-5) - Address of final beneficiary client of another bank (Optional) Beneficiary Account Number (D-B-6) - Account no. of final beneficiary (Optional) Counterparty Name (D-C-4) - Name of Remitter Counterparty Address (D-C-5) - Address of Remitter (Optional) FX Amount (D-8)/FX Currency Code (D-9) - FX amount remitted (for International Remittances) Correspondent Bank (D-16) - Name of Remitter's Bank Country Code (D-18) - Country code of D-16 Reporting Institution Non-Bank Outward Remittance (ORM) transaction Account Number (D-5) - Account Number/Tracking Number assigned to client Account Holder/Client (D-A-4) - Name of Remitter (client of reporting CP) Account Holder Address (D-A-5) - Address of the Remitter/client Beneficiary Name (D-B-4) - Receiver of the Remittance Beneficiary Address (D-B-5) - Address of Receiver FX Amount (D-8)/FX Currency Code (D-9) - FX amount remitted (for International Remittances) Correspondent Bank (D-16) - Remittance Tie-up or bank Country Code (D-18) - Country code of D-16 Inward Remittance (IRM) transaction Account Number (D-5) - Account Number/Tracking Number assigned to client Account Holder/Client (D-A-4) - Receiver of Remittance Account Holder Address (D-A-5) - Address of Receiver Counterparty Name (D-C-4) - Name of Remitter FX Amount (D-8)/FX Currency Code (D-9) - FX amount remitted (for International Remittances) Correspondent Bank (D-16) - Remittance tie up or bank Country Code (D-18) - Country code of D-16 T. For uniformity, CPs should observe the use of the following transfer related transaction codes: Inter-Account Transfer (CTRIA) Transfer of funds from one account to another client's account within the same bank Inward Remittance (Domestic) Credit to Beneficiary's Account (RIRDC) Remittance where the instruction is for the beneficiary's account to be credited (involves 2 banks: bank of the remitter & beneficiary) Inward Remittance (International) Credit to Beneficiary's Account (RIRIC) Outward Remittance/TT (Domestic) Credit to Beneficiary's Account (RORDC) Outward Remittance/TT (International) Credit to Beneficiary's Account (RORIC) Inward Remittance (Domestic) For Further Credit to Another Account (RIRDA) Remittance through credit to accountholder's account maintained with another bank (involves 3 banks: remitter's bank, correspondent (intermediary) bank and the beneficiary's bank) Inward Remittance (International) For Further Credit to another account (RIRIA) Outward Remittance/TT (Domestic) For Further Credit to another account (RORDA) Outward Remittance/TT (International) For Further Credit to another account (RORIA) U. 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. II. 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, except in the following transactions: HcDSaT Inward remittance, which shall be reported at the amount actually received by the client, net of taxes or other charges (or net proceeds). Net proceeds of sale of securities and/or similar instruments by the client. Time Deposit Pay-out, where in the amount to be reported is the amount actually credited/ received by the client. B. The sale of Real and Other Properties Acquired (ROPA) shall be reported at the time of the execution of the Contract to Sell, or any similar contract, at its total contract price. Any installment payments and the subsequent execution of a Deed of Absolute Sale and issuance of a new Transfer Certificate of Title (TCT) to the buyer need not be reported. C. Transactions lodged under Contingent accounts pending settlement or maturity thereof shall be reported only at the time such transactions are actually settled, or have matured, or availed of. D. In cases of Securities Custodianship, the identity of the investor/beneficial owner of the securities shall be indicated in the CTRs and STRs when reporting the receipt of securities from issuing bank. E. For CTRs/STRs involving numbered accounts, the covered person is required to use the real names of the account holders in the submission of CTRs/STRs. F. Time Deposit Placements/Investments Roll-over of time deposits/investments are considered no/low risk transactions, however, reporting as a CTR is required in the following scenarios: o If a new Account Number was issued upon rollover, this should be reported as a new placement, indicating the new and the old account number in the transaction data fields. o If upon roll-over, the client made an additional placement of more than Php500,000.00, a CTR should be filed indicating the new amount of placement. o If upon rollover, the client withdraws an amount of more than Php500,000.00, two (2) CTRs should be reported, 1st the payout and 2nd the rollover of CTR less the pay-out amount (only if the amount of the new placement is more than Php500,000.00.) o If a time deposit placement/investment, which upon initial placement is below the reporting threshold, thus not reported as a CTR; however, upon rollover reaches the reporting threshold, this should now be reported as a CTR. G. 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. H. The Customer Reference Number (CRN) is an optional field for CTRs and STRs, this will be used for future static data submission. However, CRN is mandatory for the Account Holder Party or Subject of Suspicion Party, whichever is applicable for Suspicious Transaction Reports, wherein 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 also be used in the uploading of KYC documents. I. A "spurious check" refers to a document having the appearance of a check or similar document, but is actually a fake or counterfeit document. It may also refer to a genuine check or similar document that is materially altered or falsified. AMLC exempts the presenting bank from filing an STR relative to its receipt of a spurious check from a depository bank that has no clearing facilities . This amends Resolution No. 10, Series of 2007 which states that: "A bank through which a fraudulent or spurious check passes, either as depository, presenting, or drawee bank, shall file the corresponding STR, pursuant to Section 9 (c) of the AMLA." In as much as the presenting bank is not privy to the transaction between the depository bank and its client, it is not required to file an STR relative to the fraudulent issuance of the spurious check. It is upon the depository bank and the drawee bank to report the transaction of their respective clients, i.e., the depository and the drawer respectively . Highlights of STR reporting by banks for spurious checks are as follows: (All other mandatory fields must have entries including optional fields, if available). ASTca Depository Bank Account holder/Client - Name of Depositor/Client Account Number - Account Number of Client/Depositor Peso Amount - Amount in Check Beneficiary - Name of Payee in Check Counterparty - Name of Issuer of Check; if available Correspondent Bank - Name of Drawee Bank Drawee Bank Account holder/Client - Name of Client/Issuer of Check Account Number - Account Number in Check Peso Amount - Amount in Check Beneficiary - Name of Payee in Check Counterparty - Not applicable Correspondent Bank - Name of Presenting Bank J. For the Insurance Industry: When the total amount of the regular annualized premiums for the entire year, regardless of the mode of payment (monthly, quarterly, semi-annually or annually), exceeds Php500,000.00, such amount shall be reported as a covered transaction upon payment of the initial premium, even if the amounts of the amortizations are less than the threshold amount. Premiums for the renewal of the insurance policies under the same terms and conditions need not be reported provided that CTRs are submitted on the initial premium payment. Any disbursement in excess of Php500,000.00 shall be filed as covered transaction. In the case of multiple beneficiaries, CTR shall be filed upon claim of each individual beneficiary exceeding the threshold amount. K. For the Securities Industry: Reporting of CT/ST shall be on a per order basis ( order refers to the executed instructions given for buying or selling of each issue); settlement transactions need not be reported. Ex. Client instructed broker to buy Php1,000,000 worth of Meralco shares. Broker bought P300,000 worth of Meralco shares in the morning and P400,000 worth of Meralco shares in the afternoon. Broker will report the purchase of P700,000 worth of Meralco shares. For bundled transactions, reporting shall still be on a per done order basis. For issues with multiple values within the day, the data for the "NET ASSET VALUE" field shall be averaged . For block sale, the executing brokers shall be indicated in the counterparty field. L. 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. M. 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. N. 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. O. Functional trainings for authorized persons are usually conducted on the last Wednesday of the month or upon announcement by the AMLCS. P. 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. Q. The AMLC Web Services is a facility for CPs to transmit CT/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. R. 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. S. 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. T. Electronic returns for Freeze orders shall be uploaded in the AMLC portal, guidelines please refer to Chapter 2.6. U. 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. cDSAEI ANNEXES ANNEX A Sample CSV File (Format 1.0) Detail Record Transaction Data (Row 2, Columns A-T) Subject Data (Account Holder) Trailer Record Sample Using Notepad: CSV File Layout (Format 1) (Sample CTR for Covered Persons with Branches) ANNEX B System Codes B.1 Revised AMLC Transaction Codes B.2 Currency Codes B.3 Country Codes ANNEX C Mandatory Fields ANNEX D Examples of Alerts and Red Flags: I. Predicate Offense/Unlawful Activity A. Corruption Related 3 1. Client has significant holdings in bank time deposits and other high-yielding products such as shares and investments portfolios in another country. 2. Account shows high-volume account activity involving significant cash transactions. 3. Client conducts transactions through a professional facilitator for no apparent commercial or other reason. 4. Client is associated with, or undertakes transactions involving, large unexplained amounts of money. 5. Client is unable or reluctant to provide details or credible explanations for establishing a business relationship, opening an account or conducting transactions. 6. Client uses legal entity structures to undertake transactions for no apparent commercial or other reason. 7. Client uses multiple bank accounts for no apparent commercial or other reason. 8. Personal and business transactions are difficult to distinguish and are mingled either in personal or payroll accounts. B. Cross Border investment fraud involving boiler room operations, recovery room, and advance fee fraud 4 1. Accountholders or clients are individuals or entities, which have just been registered with SEC or DTI. There may be a common signatory for the accounts opened. Normally, the signatory is not an incorporator. In some instances, the individuals opening the account present themselves as owners of a domestic company, branch head or consultant of a foreign entity. 2. Transactions in the domestic account are mostly inward remittances which are immediately withdrawn in cash or by check issuances to different individuals. Said transactions may also be "wire transferred" to another account in the Philippines or overseas, leaving the account with minimal balance. 3. The remitters are located largely in the United States of America, United Kingdom, Canada, Germany, Singapore, Hong Kong and Indonesia. a. Remitters may be individuals, who are most likely victims of cross border investment fraud. This may be considered as the placement stage of money laundering. b. Beneficiary accounts may be companies/entities, which may be considered perpetrators or their cohorts. Funds remitted could have been received from victims of investment fraud in the foreign jurisdiction and subsequently remitted to the Philippines to layer the funds. 4. An individual or consultancy firm sets-up two or more companies, mainly engaged in trading, retail and call center business. 5. The accounts are usually active for a period of one (1) year. Entities operate within a limited period to avoid detection. Thereafter, a new company with a similar nature of business will emerge. 6. Multiple companies are linked by common addresses and signatories. These companies maintain accounts at different banks to conceal their business activities. 7. Recipients of remittances are individuals or companies having common counterparties or remitters. C. Drug related transactions 1. Account Holders that send and receive funds to person/s or entities subject of F.O. 2. Forex, Remittance with substantial transactions but are not registered with AMLC. EDCcaS 3. Recipient of funds located in an area but received funds from different places in the Philippines where the nature of the business makes the business relationship unlikely; i.e. , X Trading in Binondo engaged in electronics business received funds from towns in Mindanao, Visayas and the remitter has no declared business. 4. Persons using other names/alias/A.K.A. 5. Persons using different IDs with inconsistent information such as: names, birth date, address. 6. The recipient of large amount of funds are students/minors. 7. Transactions of arrested suspects/accused while in prison or after their arrest. 8. Sudden closure of bank accounts after being a subject of an adverse media expose. D. Cash Deposits/Ponzi Scheme/Pyramiding 1. Cash deposits coming from various branches located not within or outside the geographical area of the depository branch where depositor lives or works. 2. Accumulating large cash deposits during a week or a month and withdrawing said aggregated deposits in a day leaving minimal balance, as if the savings account is merely used as a conduit and for long-term savings (siphoning). E. Usage of transit accounts (mule accounts) with large, rapid movement of funds 5 1. Funds were actively transferred in and out of the account on the same day or within a short period of time with no absolute reason. 2. Immediate withdrawals upon receiving large amount of funds. F. Unverified banking accounts/transactions 6 1. Return of customer "Thank You" letter. 2. Abnormal deposits and withdrawals which are deemed inconsistent with the profile of the customer. 3. Large number of transactions conducted near border towns, ports and high risk areas where smuggling activities are rampant. 4. Large amounts of funds transferred into unverified third parties accounts located overseas on a frequent basis. G. Terrorist Financing 7 1. Entities Details match those on sanctions lists Small broker/intermediary; activity does not match business profile Commercial entity acts as money-remittance business 2. Goods: Dual-use or proliferation-sensitive 3. Cash: Used for industrial transactions 4. Consignee: Freight-forwarding company or bank 5. Documents: False or altered (shipping, license, end-user certificate); innocuous descriptions of goods or materials 6. Suspicious Indicators/Circumstances for Terrorist Financing under Rule 3.a.15 of the IRRs of the TF Suppression Act. Remittance in structured amounts to high-risk location for terrorism. II. Examples of Suspicious Indicators 8 Common Indicators: The following are examples of common indicators that may point to a suspicious transaction, whether completed or attempted. This list of examples is provided for guidance only and is neither mandatory nor exhaustive. A. General Areas of Suspicion: Customer admits to or makes statements about involvement in criminal activities. You are aware that a customer is the subject of a criminal investigation. Customer does not want correspondence sent to residential address. Customer appears to have accounts with several financial institutions in one area for no apparent reason. Customer conducts transactions at different physical locations in an apparent attempt to avoid detection. Customer repeatedly uses an address but frequently changes the names involved. Customer is accompanied and watched. Significant and/or frequent transactions in contrast to known or expected business activity(ies). Significant and/or frequent transactions in contrast to known employment status. ISHaCD Ambiguous or inconsistent explanations as to the source and/or purpose of funds. Where relevant, money presented in unusual condition, for example, damp, odorous, or coated with substance. Where relevant, nervous or uncooperative behavior exhibited by employees and/or customers. Customer shows uncommon curiosity about internal systems, controls, and policies. Customer has only vague knowledge of the amount of a deposit. Customer presents confusing details about the transaction or knows few details about its purpose. Customer appears to informally record large-volume transactions, using unconventional bookkeeping methods or "off-the-record" books. Customer over-justifies or -explains the transaction. Customer is secretive and reluctant to meet in person. Customer is nervous, not in keeping with the transaction. Customer is involved in transactions that are suspicious but seems blind to being involved in money-laundering activities. Customer's home or business telephone number has been disconnected, or there is no such number when an attempt is made to contact the customer shortly after opening the account. Normal attempts to verify the background of a new or prospective customer are difficult. Customer appears to be acting on behalf of a third party but does not inform the credit institution staff. Customer is involved in activity(ies) out of keeping for that individual or business. Customer insists that a transaction be done quickly. Inconsistencies appear in the customers' presentation of the transaction. Transaction does not appear to make sense or is out of keeping with usual or expected activity for the customer. Customer appears to have recently established a series of new relationships with different financial entities. Customer attempts to develop close rapport with the staff. Customer uses aliases and a variety of similar but different addresses. Customer spells his or her name differently from one transaction to another. Customer uses a post office box or general delivery address, or other type of mail drop address, instead of a street address when this is not the norm for the area concerned. Customer provides false information or information that the staff of the bank or the financial institution believe is unreliable. Customer offers money, gratuities, or unusual favors to the credit institution staff for the provision of services that may appear unusual or suspicious. Customer pays for services or products via financial instruments, such as money orders or traveler's checks, without relevant entries on the instrument or with unusual symbols, stamps, or notes. The bank or the financial institution is aware that a customer is the subject of a money laundering or terrorist financing investigation. The bank or the financial institution is aware, or becomes aware, from a reliable source (that can include media or other open sources) that a customer is suspected of being involved in illegal activity(ies). A new or prospective customer is known as having a questionable legal reputation or criminal background. Transaction involves a suspected shell entity ( i.e. , a corporation that has no assets, operations, or other reasons to exist). B. Knowledge of reporting or record-keeping requirements Customer attempts to convince employee not to complete any documentation required for the transaction. Customer makes inquiries that would indicate a desire to avoid reporting. Customer has unusual knowledge of the law in relation to suspicious transaction reporting. Customer seems very conversant with money laundering or terrorist activity financing issues. Customer is quick to volunteer that funds are "clean" or are "not being laundered." Customer appears to be structuring amounts to avoid record keeping, customer identification, or reporting thresholds. cDTACE Customer appears to be collaborating with others to avoid record keeping, customer identification, or reporting thresholds. Customer performs two or more cash transactions of less than the thresholds specified seemingly to avoid the reporting requirement. C. Identity Documents Customer provides doubtful or vague information. Customer produces seemingly false identification or identification that appears to be counterfeited, altered, or inaccurate. Customer refuses to produce personal identification documents. Customer only presents copies rather than originals. Customer uses foreign, unverifiable identity documents. Customer wants to establish identity using something other than his or her personal identification documents. Customer's supporting documentation lacks important details, such as a telephone number. Customer inordinately delays presenting corporate documents. All identification presented pertains to foreign countries or cannot be checked for some reason. All identification documents presented appear new or have recent issue dates. Customer presents different identification documents at different times. Customer alters the transaction after being asked for identity documents. Customer presents different identification documents each time a transaction is conducted. D. Cash Transactions Customer starts conducting frequent cash transactions in large amounts when this has not been a normal activity for the customer in the past. Customer frequently exchanges small bills for large ones. Customer uses notes in denominations that are unusual for the customer, when the normal practice in that business is different. Customer presents notes that are packed or wrapped in a way that is uncommon for the customer. Customer deposits musty or extremely dirty bills. Customer consistently makes cash transactions that are significantly below the reporting threshold amount in an apparent attempt to avoid triggering the identification and reporting requirements. Customer presents uncounted funds for a transaction. Upon counting, the customer reduces the transaction to an amount just below that which could trigger reporting requirements. Customer conducts a transaction for an amount that is unusual compared with amounts of past transactions. Customer frequently purchases traveler's checks, foreign currency drafts, or other negotiable instruments with cash when this appears to be outside of normal activity for the customer. Customer asks a clerk at the credit institution to hold or transmit large sums of money or other assets when this type of activity is unusual for the customer. Shared address for individuals involved in cash transactions, particularly when the address is also for a business location, or does not seem to correspond to the stated occupation ( i.e. , student, unemployed, self-employed, etc.). Stated occupation of the customer is not in keeping with the level or type of activity(ies) ( e.g. , a student or an unemployed individual makes daily maximum cash withdrawals at multiple locations over a wide geographic area). Cash is transported by a cash courier. Large transactions using a variety of denominations. E. Economic Purpose Transaction seems to be inconsistent with the customer's apparent financial standing or the usual pattern of activities. Transaction appears to be out of the normal course for industry practice or does not appear to be economically viable for the customer. Transaction is unnecessarily complex for its stated purpose. Activity is inconsistent with what would be expected from declared business. A business customer refuses to provide information to qualify for a business discount. cCHITA No business explanation for size of transactions or cash volumes. Transactions or financial connections between businesses that are not usually connected ( e.g. , a food importer dealing with an automobile parts exporter). Transaction involves nonprofit or charitable organization(s) for which there appears to be no logical economic purpose or where there appears to be no link between the stated activity(ies) of the organization and the other parties in the transaction. F. Transactions involving accounts Opening accounts when the customer's address is outside the local service area. Opening accounts in other people's names. Opening accounts with names very close to other established business entities. Attempting to open or operate accounts under a false name. Account with a large number of small cash deposits and a small number of large cash withdrawals. Funds are being deposited into several accounts, consolidated into one, and transferred outside the country. Customer frequently uses many deposit locations outside of the home branch location. Multiple transactions are carried out on the same day at the same branch but with an apparent attempt to use different tellers. Activity far exceeds activity projected at the time of opening of the account. Establishment of multiple accounts, some of which appear to remain dormant for extended periods. Account that was reactivated from inactive or dormant status suddenly sees significant activity. Reactivated dormant account containing a minimal amount suddenly receives a deposit or series of deposits followed by frequent cash withdrawals until the transferred sum has been removed. Unexplained transfers between the customer's products and accounts. Large transfers from one account to other accounts that appear to be pooling money from different sources. Multiple deposits are made to a customer's account by third parties. Deposits or withdrawals of multiple monetary instruments, particularly if the instruments are sequentially numbered. Frequent deposits of bearer instruments ( e.g. , checks, money orders, or bearer bonds) in amounts just below the threshold amount. Unusually large cash deposits by a customer with personal or business links to an area associated with drug trafficking. Regular return of checks for insufficient funds. Correspondent accounts being used as "pass-through" points from foreign jurisdictions with subsequent outgoing funds to another foreign jurisdiction. Multiple personal and business accounts are used to collect and then funnel funds to a small number of foreign beneficiaries, particularly when they are in locations of concern, such as countries known or suspected to facilitate money-laundering activities. G. Transactions involving areas outside the country Customer and other parties to the transaction have no apparent ties to the country. Transaction crosses many international lines. Use of a credit card issued by a foreign bank that does not operate domestically by a customer who does not live and work in the country of issue. Cash volumes and international remittances in excess of average income for migrant worker customers. Transactions involving high volume international transfers to third-party accounts in countries that are not usual remittance corridors. Transaction involves a country known for highly secretive banking and corporate law(s). Foreign currency exchanges that are associated with subsequent wire transfers to locations of concern, such as countries known or suspected to facilitate money-laundering activities. Deposits followed within a short time by wire transfer of funds to or through locations of concern, such as countries known or suspected to facilitate money-laundering activities. Transaction involves a country where illicit drug production or exporting may be prevalent, or where there is no effective anti-money laundering system. CScaDH Transaction involves a country known or suspected to facilitate money-laundering activities. H. Transactions related to offshore business activity Any bank or financial institution that conducts transactions internationally should consider the following indicators: Accumulation of large balances, inconsistent with the known turnover of the customer's business, and subsequent transfers to overseas account(s). Frequent requests for traveler's checks, foreign currency drafts, or other negotiable instruments. Loans secured by obligations from offshore banks. Loans to or from offshore companies. Offers of multimillion-dollar deposits from a confidential source to be sent from an offshore bank or somehow guaranteed by an offshore bank. Transactions involving an offshore "shell" bank whose name may be very similar to the name of a major legitimate institution. Unexplained electronic funds transfers by customer on an in-and-out basis. Use of letter of credit and other methods of trade financing to move money between countries when such trade is inconsistent with the customer's business. Use of a credit card issued by an offshore bank. I. Personal Transactions Customer appears to have accounts with several financial institutions in one geographic area. Customer has no employment history but makes frequent, large transactions or maintains a large account balance. The flow of income through the account does not match what was expected based on the stated occupation of the account holder or the intended use of the account. Customer makes one or more cash deposits to the general account of a foreign correspondent bank ( i.e. , pass-through account). Customer makes frequent or large payments through online payment services. Customer runs large positive credit card balances. Customer uses cash advances from a credit card account to purchase money orders or drafts or to wire funds to foreign destinations. Customer takes cash advance to deposit into savings or checking account. Large cash payments for outstanding credit card balances. Customer makes credit card overpayment and then requests a cash advance. Customer visits the safety deposit box area immediately before making cash deposits. Customer wishes to have credit and debit cards sent to international or to domestic destinations other than his or her address. Customer has numerous accounts and deposits cash into each of them with the total credits being a large amount. Customer deposits large endorsed checks in the name of a third party. Customer frequently makes deposits to the account of another individual who is not an employee or family member. Customer frequently exchanges currencies. Customer frequently makes automatic banking machine deposits just below the reporting threshold. Customer's access of the safety deposit facilities increases substantially or is unusual in light of their past usage. Many unrelated individuals make payments to one account without any rational explanation. Third parties make cash payments or deposit checks to a customer's credit card. Customer gives power of attorney to a nonrelative to conduct large transactions. Customer has frequent deposits identified as proceeds of asset sales, but the assets cannot be substantiated. Customer acquires significant assets and liquidates them quickly with no explanation. Customer acquires significant assets and encumbers them with security interests that do not make economic sense. Customer requests movement of funds that are uneconomical. High volume of wire transfers are made or received through the account. aHSTID J. Corporate and business transactions Some businesses may be susceptible to the mixing of illicit funds with legitimate income. This is a very common method of money laundering. These businesses include those that conduct a significant part of their business in cash, such as restaurants, bars, parking lots, convenience stores, and vending machine companies. On opening accounts with the various businesses in its area, a financial institution would likely be aware of those that are mainly cash based. Unusual or unexplained increases in cash deposits made by those entities may be indicative of suspicious activity(ies). Accounts are used to receive or disburse large sums but show virtually no normal business-related activities such as the payment of payrolls, invoices, etc. Accounts have a large volume of deposits in bank drafts, cashier's checks, money orders, or electronic funds transfers, which is inconsistent with the customer's business. Accounts have deposits in combinations of monetary instruments that are atypical of legitimate business activity(ies) ( e.g. , deposits that include a mix of business, payroll, and social security checks). Accounts have deposits in combinations of cash and monetary instruments not normally associated with business activity(ies). Business does not want to provide complete information regarding its activities. Financial statements of the business differ noticeably from those of similar businesses. Representatives of the business avoid contact with the branch as much as possible, even when it would be more convenient for them. Deposits to or withdrawals from a corporate account are primarily in cash rather than in the form of debit and credit normally associated with commercial operations. Customer maintains a number of trustee or customer accounts that are not consistent with that type of business or not in keeping with normal industry practices. Customer operates a retail business providing check-cashing services but does not make large withdrawals of cash against checks deposited. Customer pays in cash or deposits cash to cover bank drafts, money transfers, or other negotiable and marketable money instruments. Customer purchases cashier's checks and money orders with large amounts of cash. Customer deposits large amounts of currency wrapped in currency straps. Customer makes a large volume of seemingly unrelated deposits to several accounts and frequently transfers a major portion of the balances to a single account at the same bank or elsewhere. Customer makes a large volume of cash deposits from a business that is not normally cash-intensive. Customer makes large cash withdrawals from a business account not normally associated with cash transactions. Customer consistently makes immediate large withdrawals from an account that has just received a large and unexpected credit from abroad. Customer makes a single and substantial cash deposit composed of many large bills. Small, single location business makes deposits on the same day at different branches across a broad geographic area that does not appear practical for the business. There is a substantial increase in deposits of cash or negotiable instruments by a company offering professional advisory services, especially if the deposits are promptly transferred. There is a sudden change in cash transactions or patterns. Customer wishes to have credit and debit cards sent to international or domestic destinations other than his or her place of business. There is a marked increase in transaction volume in an account with significant changes in an account balance that is inconsistent with or not in keeping with normal business practices of the customer's account. Asset acquisition is accompanied by security arrangements that are not consistent with normal practice. Unexplained transactions are repeated between personal and commercial accounts. Activity is inconsistent with stated business. Account has close connections with other business accounts without any apparent reason for the connection. CDHaET Activity suggests that transactions may offend securities regulations or the business prospectus is not in tune with the requirements. A large number of incoming and outgoing wire transfers take place for which there appears to be no logical business or other economic purpose, particularly when this is through or from locations of concern, such as countries known or suspected to facilitate money laundering activities. K. Transactions for nonprofit organizations (including registered charities) Inconsistencies between apparent modest sources of funds of the organization ( e.g. , communities with modest standard of living) and large amounts of funds raised. Inconsistencies between the pattern or size of financial transactions and the stated purpose and activity of the organization. Sudden increase in the frequency and amounts of financial transactions for the organization, or the inverse, that is, the organization seems to hold funds in its account for a very long period. Large and unexplained cash transactions by the organization. Absence of contributions from donors located in the country. Organization's directors are outside the country, particularly if large outgoing transactions are made to the country of origin of the directors and especially if that country is a high-risk jurisdiction. Large number of nonprofit organizations with unexplained links. Nonprofit organization appears to have little or no staff, no suitable offices, or no telephone number, which is incompatible with their stated purpose and financial flows. Nonprofit organization has operations in, or conducts transactions to or from, high-risk jurisdictions. L. Wire and funds transfer activities Customer is reluctant to give an explanation for the remittance. Customer orders wire transfers in small amounts in an apparent effort to avoid triggering identification or reporting requirements. Customer receives large sums of money from an overseas location and the transfers include regulations for payment in cash. Customer makes frequent or large funds transfers for individuals or entities who have no account relationship with the institution. Customer receives frequent funds transfers from individuals or entities who have no account relationship with the institution. Customer receives funds transfers and immediately purchases monetary instruments prepared for payment to a third party, which is inconsistent with or is outside the normal course of business of the customer. Customer requests payment in cash immediately upon receipt of a large funds transfer. Customer instructs the bank or the financial institution to transfer funds abroad and to expect an equal incoming transfer. Immediately after transferred funds have cleared, the customer moves the funds to another account or to another individual or entity. Customer shows unusual interest in funds transfer systems and questions the limit of what amount can be transferred. Customer transfers funds to another country without changing the currency. Large incoming wire transfers from foreign jurisdictions are removed immediately by company principals. Customer sends frequent wire transfers to foreign countries but does not seem to have connection to such countries. Wire transfers are received from entities having no apparent business connection with the customer. Size of funds transfers is inconsistent with normal business transactions for that customer. Rising volume of remittances exceeds what was expected from the customer when the relationship was established. Several customers request transfers either on the same day or over a period of 2-3 days to the same recipient. Different customers request transfers that are all paid for by the same customer. Several customers requesting transfers share common identifiers, such as family name, address, or telephone number. Several different customers send transfers that are similar in amounts, sender names, test questions, free message text, and destination country. TaCEHA Customer sends or receives multiple transfers to or from the same individual. Stated occupation of the customer or the customer's financial standing is not in keeping with the level or type of activity(ies) ( e.g. , a student or an unemployed individual who receives or sends large numbers of wire transfers). Migrant remittances made outside the usual remittance corridors. Personal funds sent at a time not associated with salary payments. Country of destination for a wire transfer is not consistent with the nationality of the individual customer. Customer requests transfers to a large number of recipients outside the country who do not appear to be family members. Customer does not appear to know the recipient to whom he or she is sending the transfer. Customer does not appear to know the sender of the transfer from whom the transfer was received. Beneficiaries of wire transfers involve a large group of nationals of countries associated with terrorist activity. Customer makes funds transfers to other businesses abroad that are not in line with the customers business. Customer conducts transactions involving countries known as narcotic source countries or as transshipment points for narcotics, or that are known for highly secretive banking and corporate law practices. M. Suspicious indicators related to lending Customer suddenly repays a problem loan unexpectedly. Customer makes a large, unexpected loan payment with unknown source of funds, or a source of funds that does not match the credit institution's knowledge about the customer. Customer repays a long-term loan, such as a mortgage, within a relatively short time period. Source of down payment is inconsistent with borrower's background and income. Down payment appears to be from an unrelated third party. Down payment uses a series of money orders or bank drafts from different financial institutions. Customer shows income from "foreign sources" on loan application without providing further details. Customer's employment documentation lacks important details that would make it difficult for the credit institution to contact or locate the employer. Customer's documentation to ascertain identification, support income, or verify employment is provided by an intermediary who has no apparent reason to be involved. Customer has loans with offshore institutions or companies that are outside the ordinary course of business of the customer. Customer offers the credit institution large dollar deposits or some other form of incentive in return for favorable treatment of loan request. Customer asks to borrow against assets held by another financial institution or a third party, when the origin of the assets is not known. Loan transaction does not make economic sense ( e.g. , the customer has significant assets, and there does not appear to be a sound business reason for the transaction). Customer seems unconcerned with terms of creditor costs associated with completion of a loan transaction. Customer applies for loans on the strength of a financial statement reflecting major investments in or income from businesses incorporated in countries known for highly secretive banking and corporate law(s) and the application is outside the ordinary course of business of the customer. Down payment or other loan payments are made by a party who is not a relative of the customer. Reluctance to use favorable facilities, for example, avoiding high interest rate facilities for large balances. Substantial increases in deposits of cash or negotiable instruments by a professional firm or company, using customer accounts, in-house company, or trust accounts, especially if the deposits are promptly transferred between other customer companies and trust accounts. Frequent and/or unscheduled cash deposits to loan accounts. Frequent deposits of winning gambling checks followed by immediate withdrawal or transfer of funds. acHTIC Children's accounts being used for the benefit of parents and/or guardians. N. Life insurance companies, brokers, and agents Client wants to use cash for a large transaction. Client proposes to purchase an insurance product using a check drawn on an account other than his or her personal account. Client requests an insurance product that has no discernible purpose and is reluctant to divulge the reason for the investment. Client who has other small policies or transactions based on a regular payment structure makes a sudden request to purchase a substantial policy with a lump-sum payment. Client conducts a transaction that results in a conspicuous increase in investment contributions. Scale of investment in insurance products is inconsistent with the client's economic profile. Unanticipated and inconsistent modification of client's contractual conditions, including significant or regular premium top-ups. Unforeseen deposit of funds or abrupt withdrawal of funds. Involvement of one or more third parties in paying the premiums or in any other matters involving the policy. Overpayment of a policy premium with a subsequent request to refund the surplus to a third party. Funds used to pay policy premiums or deposits originate from different sources. Use of life insurance product in a way that resembles the use of a bank account, such as making additional premium payments and frequent partial redemptions. Client cancels investment or insurance soon after purchase. Early redemption takes place in the absence of a reasonable explanation or in a significantly uneconomic manner. Client shows more interest in the cancellation or surrender of an insurance contract than in the long-term results of investments or the costs associated with termination of the contract. Client makes payments with small denomination notes, uncommonly wrapped, with postal money orders or with similar means of payment. Duration of the life insurance contract is less than 3 years. First (or single) premium is paid from a bank account outside the country. Client accepts very unfavorable conditions unrelated to his or her health or age. Transaction involves use and payment of a performance bond resulting in a cross-border payment. Repeated and unexplained changes in beneficiary. Relationship between the policy holder and the beneficiary is not clearly established. O. Securities Firm Accounts that have been inactive suddenly receive large deposits that are inconsistent with the normal investment practice of the client or their financial ability. Any dealing with a third party when the identity of the beneficiary or counterparty is undisclosed. Client attempts to purchase investments with cash. Client wishes to purchase a number of investments with money orders, traveler's checks, cashier's checks, bank drafts, or other bank instruments, where the transaction is inconsistent with the normal investment practice of the client or their financial ability. Client uses securities or futures brokerage firm as a place to hold funds that are not being used in trading of securities or futures for an extended period of time, and such activity is inconsistent with the normal investment practice of the client or their financial ability. Client wishes monies received through the sale of shares to be deposited into a bank account rather than a trading or brokerage account, which is inconsistent with the normal practice of the client. Client frequently makes large investments in stocks, bonds, investment trusts, or other securities in cash or by check within a short time period, inconsistent with the normal practice of the client. Client makes large or unusual settlements of securities in cash. The entry of matching buying and selling of particular securities or futures contracts (called match trading), creating the illusion of trading. Transfers of funds or securities between accounts not known to be related to the client. ScaCEH Several clients open accounts within a short period of time to trade the same stock. Unrelated clients redirect funds toward the same account. Trades conducted by entities that you know have been named or sanctioned by regulators in the past for irregular or inappropriate trading activity(ies). Client is willing to deposit or invest at rates that are not advantageous or competitive. Client attempts to purchase investments with instruments in the name of a third party. Third-party purchases of shares in other names ( i.e. , nominee accounts). Transactions in which clients make settlements with checks drawn by third parties or remittances from third parties. Proposed transactions are to be funded by international wire payments, particularly if from countries where there is no effective anti-money laundering system. ANNEX E Typologies A. Cross-Border Investment Fraud 1. Individuals representing themselves as investment advisors contacted Mr. Cy Toil, an Australian citizen and owner of Eyes Arc Ltd., enticing him to open a trading account with Weasle and Weasle Co., an Australian entity posing as a legitimate investing firm that provides advice and brokerage services for US securities. Mr. Toil acceded and engaged in several non-existent purchase and sale of stocks. In a span of six months, he lost approximately USD1.8 million. Mr. Toil remitted his payments to King Bottom Ltd., an entity based in Hong Kong, which allegedly conducts securities clearing services for Weasle and Weasle Co. Portions of the remittances of Mr. Toil to King Bottom Ltd. were also traced to have been sent to a Philippine SEC-registered entity named Diamond Ring Realty. The funds remitted to Diamond Ring Realty were immediately withdrawn after receipt of the wired funds. Diamond Ring Realty also received funds from various overseas entities tagged in several online forums as involved in boiler room scam. These remittance senders are Galaxy Advisory Co. (Hong Kong); Counter Barter Paint (Macau); Agtra Group (USA); and Southern Money Brokerage (USA). Mr. Toil, through investigations done by his legal counsels, discovered that a significant number of Internet Protocol (IP) addresses used by individuals associated with Weasle and Weasle Co. to open tracked emails from him were traced in a major city in the Philippines. 2. The National Bureau of Investigation (NBI) reported that certain Filipino individuals are creating fictitious web domains and soliciting investments online using fraudulent US Internal Revenue Service (USIRS) and Philippine Government seals and documents. Victims have been advised to transfer purported advance fees and charges to bank account 1 and bank account 2. Bank account 1 is under the account name of ABCD Trading System with address in Cebu City. Transactions in this account are characterized by international remittances (from individuals in the United Kingdom, Australia, Norway and Sweden and an entity in Indonesia) which are immediately withdrawn. One remitter also remitted funds to CD and Associates, USR Trading, XYZ Trading Services which are all based in Cebu; another remitter transferred funds to NL Distribution and Logistics located in Pangasinan. AMLC database showed the same pattern of transactions in the accounts of CD and Associates, USR Trading, XYZ Trading Services and NL Distribution and Logistics as those found in the account of ABCD Trading. A bank has filed an STR on USR because of a complaint from a remitter in China. It was narrated that the complainant remitted money upon advice allegedly by the Department of Treasury Internal Revenue Service for payment of his tax to the account of USR Trading (in connection with the recovery of an earlier investment). B. Use of the Internet and Dummy Corporations for Swindling/Estafa The scheme involves the use of call centers operating in the Philippines for large-scale investment fraud with operations in Country X and the Philippines under various names, such as Birthright Brokers, AA Financial Group Incorporated and LB Corporation (collectively referred to as "Birthright"). Sales calls were made to elderly victims residing in Country X to sell fraudulent certificates of deposits (CDs) and describe these CDs as investment vehicles insured by the government of Country X. Victims are convinced to invest in the CDs and make payments through the issuance of personal checks. Thereafter, the victims receive fraudulent monthly account statements concerning their investments by mail. None of the funds invested nor any of the promised interests have ever been returned or paid to the victims. TIEHDC The operators of the call centers allegedly used false names and business addresses in brochures, business cards and marketing materials sent to the victims. The operators also disguised their true location and names when making telephone calls to the victims by using "Enchanted Drive" devices. These devices are plugged into a USB port of a personal computer enabling the user to place calls over the internet. The devices are assigned a specific area code and telephone number in Country X which will always be displayed as the calling number to the person receiving the phone call, no matter where the "Enchanted Drive" device and the caller are actually located. According to investigation, the "Enchanted Drive" devices used in this particular scam were assigned area codes corresponding to major cities in Country X but the logs of the "Internet Protocol" (IP) addresses used by the said devices showed that the calls were actually made from the Philippines. After the victims had been convinced to invest in the fraudulent CDs, they were advised to write a personal check in the amount of the investment, and Birthright would arrange for a courier to retrieve the checks at the victims' residences. These checks were then sent to four (4) separate "virtual offices" and subsequently forwarded to an address in Muntinlupa City, Philippines. It was noted that sometime in December 2011, Birthright opened a new front company known as "AA Financial Group incorporated" with a new virtual office in Country X to receive the victims' checks. All mails for AA Financial Group Incorporated were forwarded to an address in Bian, Laguna, Philippines. Based on the examination of the victims' cancelled checks, prior to September 2011, the vast majority of the funds collected by Birthright under the front company name "Birthright Brokers" were deposited into an account in Universal Bank A in the Philippines. It was also revealed that between approximately September 2011 and January 2012, cancelled checks issued by the victims to AA Financial Group Incorporated, totaling approximately US $ 615,000.00, were deposited into two (2) accounts in Universal Bank B in the Philippines. Using the front company name "LB Corporation," Birthright allegedly collected more than US $ 1.2 million from several elderly victims from May to June 2012. These funds were deposited by Birthright to Bank Z in Country X, and subsequently wire transferred to two (2) accounts in Universal Bank C in the Philippines. C. Insurance Policy A case involving life insurance, tax fraud and suspected undeclared gifts. In year N-3, Ms Y took out a life insurance policy with an initial payment of 30,000 (~USD34,000). Additional payments of 60,000 (~USD68,000) were made in year N-2 and N-1, and 50,000 (~USD56,500) was paid in year N. The following year, Ms Y fully redeemed the policy. She stated that she needed money for a real estate purchase. Additional enquiries and requests for documentation by the insurance firm revealed that the payments had not been made by Ms Y but rather by her parents. Actions such as these may be used to circumvent gift taxes. 9 D. Proceeds of Drug Trafficking Case of casino gambling debt payment used to conceal laundering of proceeds from drug trafficking. In 2013, operatives of the jurisdiction X's National Police arrested person AC and five other individuals in the Philippines and confiscated/seized 433.236 kilograms methamphetamine hydrochloride estimated to be worth USD43.3 million. In October 2013, the AMLC (Philippines FIU) received a letter requesting a financial investigation on the arrested persons together with a list of bank accounts that were allegedly used in the drug transactions of the group. A STR was also filed by Universal Bank against one of the accounts of person AC. The narrative portion of the STR cited AC's arrest for drug trafficking as the cause for reporting, adding that AC is also known to be actively engaged in casino gambling. Verification with the Department of Trade & Industry (DTI) showed that person AC had two registered businesses, namely: A Trading and G Center. Certifications from the Business Permit and License Office showed that A Trading had gross receipts of only ~USD3,800 and that it had been closed since January 2011 while G Center was registered as a new business only in March 2013 with a capital of only ~USD1,085 and only one employee. Further verification showed that person AC did not appear as stockholder, incorporator or board member of any corporation registered in the Philippines. In spite of the small capitalization and meagre declared income of person AC's businesses, the AMLC Secretariat's financial investigation revealed that AC's bank transactions involved more than USD8.6 million. One bank account was found to have made more than 200 fund transfers amounting to more than USD2.16 million to several individuals. The fund transfers were all made under the guise that they were AC's payment for gambling debts owed to the recipients of the transfer. However, no documents were presented to prove that person AC owed large sums of money by virtue of his gambling activities. ACcaET Financial investigations also showed that AC's bank accounts received funds from persons MST and CW who have also been charged with drug trafficking. Apart from his bank accounts, person AC also owned several prime real estate properties, a foreign currency trust account and money placement worth a significant amount. In August 2014, the Court of Appeals granted the Petition filed by the AMLC for the Issuance of a Freeze Order against the bank accounts, investments, real properties and motor vehicles of Mr. AC and his cohorts. 10 E. Structuring Bank A reported several accounts maintained by individuals who were connected by ways of employment in company B. Company B attracted people by offering attractive profits as a return on their investment and secondly also offered jobs. Around 525 individuals filed applications against the company for depriving them of their hard-earned money. It was suspected that the scam involved a fraud of PKR1.88 billion (~USD 18 million). 399 n It was noted in company B's account that large amounts of funds came through online transfers and cash from different individuals. The accumulated funds flowed from the company's account in a structured manner through online cash/ATM transfers to the personal accounts run by individuals who were either employees of the company or were involved in other businesses. The funds were then taken out from the personal accounts through online cash withdrawal. The matter was referred for investigation. 11 F. Use of False Identification A complaint was lodged against the suspect who was believed to be involved in fraud. The suspect 'JKL' opened an account at the branch of Bank X. At the time of account opening the information provided by the suspect stated that he was working as an Associate and dealing in property business. The account was opened for saving purpose. Two officials of the government department lodged a complaint against the individual and stated that their two cheques were stolen and issued with forged signature amounting to PKR3,000,000 (~USD28,600) and Rs.2,500,000 (~USD23,800). The proceeds of both the cheques were credited to JKL account through clearing. Some of the funds were immediately withdrawn in cash while the remaining funds were returned to the issuing bank after receipt of complaint. 423 n The suspect admitted using a different signature. Both signatures were very different and therefore, a possibility of an unknown beneficial owner was suspected. From the trail of transactions it was observed that the account was primarily used to conduct transactions related to the stolen cheques and that no other significant transactions took place in the account. The case was forwarded to LEA for necessary action. 12 Footnotes 1. http://www.fatf-gafi.org. 2. Presentation materials on Intelligence Analysis & Intelligence Reports: A Workshop for FIUs held on 11 July 2008. 3. http://www.austrac.gov.au/sa-brief-peps-indicators. 4. //www.amlc.gov.ph/images/NewsAnnouncements/crossborderinvestmentfraud.pdf. 5. APG Yearly Typologies Report 2016, page 19. 6. APG Yearly Typologies Report 2016, page 19. 7. Items A-E, taken from the Training Materials on Countering the Financing of Terrorism and Proliferation of Weapons of Mass Destruction through Effective Asset Freezing held on 18-19 October 2017 in Manila, Philippines. 8. ADB's hand book on Anti-Money Laundering and Combating the financing of Terrorism for Nonbank Financial Institutions. 9. APG Yearly Typologies Report 2016, page 52. 10. APG Yearly Typologies Report 2016, pages 65-66. 11. APG Yearly Typologies Report 2016, page 80. 12. APG Yearly Typologies Report 2016, page 83. n Note from the Publisher: Written as "7" in the official document. n Note from the Publisher: Written as "6" in the official document. n Note from the Publisher: Copied verbatim from the official document. n Note from the Publisher: Copied verbatim from the official document.