MORNBFI Vol. 1 - Planters Development Bank

§§ 4805Q.211.12.31terrorism financing. The MLPP shall beconsistent with the AMLA, as amended, andthe provisions set out in this Part anddesigned according to the coveredinstitution’s corporate structure and riskprofile. It shall be in writing, approved bythe board of directors or by the country/regional head or its equivalent for localbranches of foreign banks, and welldisseminated to all officers and staff whoare obligated by law and by their programto implement the same. Where a coveredinstitution has branches, subsidiaries,affiliates or offices located within and/oroutside the Philippines, it shall adopt aninstitution-wide MLPP that shall beimplemented on a consolidated basis.The MLPP shall also be readily availablein user-friendly form, whether in hard or softcopy. The covered institution must put up aprocedure to ensure an audit trailevidencing dissemination process for newand amended policies and procedures. Theprogram shall embody the following at aminimum:1) Detailed procedures of the coveredinstitution's compliance and implementationof the following major requirements of theAMLA, as amended, its RIRR, and this Part,to wit:a) Customer identification processincluding acceptance policies and on-goingmonitoring processes;b) Record keeping and retention;c) Covered transaction reporting; andd) Suspicious transaction reportingincluding the adoption of a system,electronic or manual, of flagging,monitoring and reporting of transactions thatqualify as suspicious transactions,regardless of amount or that will raise a “redflag” for purposes of conducting furtherverification or investigation, or transactionsinvolving amounts below the threshold tofacilitate the process of aggregating them forpurposes of future reporting of suchtransactions to the AMLC when theiraggregated amounts breach the threshold.The ST reporting shall include a reportingchain under which a suspicious transactionwill be processed and the designation of aboard level or approved committee who willultimately decide whether or not thecovered institution should file a report tothe AMLC. If the resources of the coveredinstitution do not permit the designation ofa committee, it may designate thecompliance officer to perform this functioninstead: Provided, That the board of directorsis informed of his decision.2) An effective and continuousanti-money laundering and counteringof terrorist financing training program forall directors, and responsible officers andemployees, to enable them to fully complywith their obligations and responsibilitiesunder this part, the AMLA, as amended, itsRIRR and their internal policies andprocedures as embodied in the MLPP. Thetraining program shall also include refreshertrainings to remind these individuals of theirobligations and responsibilities as well asupdate them of any changes in AML laws,rules and internal policies and procedures.3) An adequate screening andrecruitment process to ensure that onlyqualified personnel who have no criminalrecord/s are employed to assume sensitivebanking functions;4) An internal audit system inaccordance with Subsec. 4805Q.4;5) An independent audit program withwritten scope of audit that will ensure thecompleteness and accuracy of theinformation and identification documentsobtained from clients, the covered andsuspicious transactions reports submitted tothe AMLC, and the records retained incompliance with this Part as well asadequacy and effectiveness of the trainingprogram on the prevention of moneylaundering and terrorism financing;Q RegulationsPart VIII - Page 6Manual of Regulations for Non-Bank Financial Institutions