The AMLA is the law that:

• Criminalizes money laundering
• Creates a financial intelligence unit – known as the Anti-Money Laundering Council
• Imposes requirements on customer identification, record keeping, and reporting of covered and suspicious transactions

The Anti-Money Laundering Act (AMLA) plays a crucial role in ensuring AML compliance across financial institutions and businesses in the Philippines, as mandated by the AMLC.

The Anti-Money Laundering Council (AMLC) was created pursuant to RA9160, otherwise known as the AMLA, to protect the integrity and confidentiality of bank accounts and to ensure that the Philippines shall not be used as a money laundering site for the proceeds of any unlawful activity. As the central AML compliance authority in the Philippines, the AMLC ensures that all registered institutions follow strict guidelines to mitigate money laundering risks.

It is the Philippines' central AML authority and financial intelligence unit, which is the government instrumentality mandated to implement the AMLA and TFPSA.

“Covered Persons” are required to register with and report to the AMLC. These are the financial institutions and designated non-financial businesses and professions, which include:

• Banks
• Quasi-Banks
• Trust entities
• Pawnshops
• Money changers
• Money remittance or transfer companies
• Casinos
• Full list found here

Registering with the AMLC Philippines is an essential step for institutions to ensure AML compliance as required under the AMLA.

No! Only Covered Transactions and Suspicious Transactions are required to be reported.

A Covered Person shall report to the AMLC the following covered transactions:

• For cash transactions: A transaction in cash or other equivalent monetary instrument involving a total amount in excess of P500,000 within 1 banking day
• For casino transactions: A single casino cash transaction involving an amount in excess of P5,000,000.000 or its equivalent in any other currency
• For transactions by real estate developers and brokers: A single cash transaction involving an amount in excess of P7,500,000.00 or its equivalent in any other currency.

This means that those transactions below the respective threshold amounts need not be reported – unless they’re Suspicious Transactions! For businesses to maintain AML compliance in the Philippines, it is essential to report covered transactions exceeding these thresholds to the AMLC.

A Covered Person shall report to the AMLC suspicious transactions – regardless of the amount involved – if the following circumstances are involved:

• There is no underlying legal or trade obligation, purpose, or economic justification for the transaction
• The client is not properly identified
• The amount involved is not commensurate with the business or financial capacity of the client
• The client’s transaction is structured in order to avoid being the subject of reporting requirements
• The transaction is in any way related to an unlawful activity or offense that is about to be, is being, or has been committed
• Any transaction that is similar or analogous to any of the foregoing

Reporting suspicious transactions is critical to upholding AML compliance and preventing illegal financial activities in the Philippines under the guidance of the AMLC.

UCheck is a global database AMLA check with automated regulatory compliance reporting. UCheck allows users to instantly search databases and repositories based on identity particulars, aliases, and other important details. The users can then generate reports on the searched entity, which they can use for compliance with the AMLC’s documentary requirements. UCheck helps institutions streamline their AML compliance processes by offering easy access to essential databases, ensuring adherence to AMLC Philippines standards.

No! Currently, the AMLC only requires that Covered Persons collect records about their clients. Such records may include any information after conducting the required Know-Your-Client (KYC) procedure – not necessarily gathered through any tools, such as UCheck.

UCheck can help in your KYC procedure by searching publicly available databases and generating a report for it. The report can then form part of your records and can be made easily available to authorities when needed. While not mandatory, using UCheck can enhance your institution’s AML compliance efforts by providing comprehensive and quick reporting options in line with AMLC Philippines requirements.

The following are the databases and repositories being constantly searched by UCheck:

• United Nations Security Council (UNSC) Consolidated List
• UN Al-Qaida Sanctions List
• Office of Foreign Assets Control
• Anti-Terrorism Council (ATC) Resolutions
• Politically Exposed Persons (PEP) Public Inf
• Adverse Media

The following may be searched through UCheck:

• Full Name (Romanized and/or Scripted)
• Aliases
• Affiliations
• Address
• ****

Yes, UCheck can generate two (2) types of reports:

• Positive Hit: When a client’s name appear in any of the searched databases, then a report containing all details about the client is generated.
• Negative Hit: A report stating that the client’s name does not appear in any of the available databases is generated.

All reports contain a scannable QR code which shall redirect the user to an electronic copy of the report in UCheck. This can be used to verify the information in report.

The AMLC requires that KYC documents are uploaded to AMLC Portal. UCheck’s generated report may form part of your KYC documents. Uploading the UCheck report to the AMLC portal ensures that your institution meets all AML compliance standards set forth by AMLC Philippines.

You may still upload UCheck’s generated report to show that you have done your part in knowing your client! Even with a negative hit, uploading the report can demonstrate your commitment to AML compliance in the Philippines, ensuring that your records meet AMLC guidelines.

Currently, we offer three (3) tiers for our introductory promos:

• Basic Package (PHP 1,500): Includes 5,000 Sanctions List Searches
• Complete Package (PHP 3,000): Includes 5,000 Sanctions List Searches, 100 PEP Searches, and 1,000 Adverse Media Searches
• Enterprise (Customizable): Customizable

UCheck is a search tool designed to help you ease your compliance with AMLA regulations. The tool is closely monitored by IT and law professionals to make sure that the AMLA and other related laws (such as the Data Privacy Act) are fully complied with! UCheck is meticulously designed to align with AMLC Philippines standards, ensuring your organization meets all AML compliance obligations under the AMLA.

You can view PJS Law’s legal compliance memorandum on UCheck here.