MORNBFI Vol. 1 - Planters Development Bank

§§ 4806Q.3.a. - 4807Q.111.12.31b. Transacting an amount that is notcommensurate with the business orfinancial capacity of the customer ordeviates from his profile;c. Structuring of transactions in order toavoid being the subject of coveredtransaction reporting; ord. knowing that a customer was or isengaged or engaging in any unlawfulactivity as herein defined.Where additional information cannot beobtained, or any information ordocument provided is false or falsified, orresult of the validation process isunsatisfactory, the covered institution shallimmediately close the account and refrainfrom further conducting businessrelationship with the customer withoutprejudice to the reporting of a suspicioustransaction to the AMLC whencircumstances warrant.(Circular No. 706 dated 05 January 2011)C. Covered and SuspiciousTransaction ReportingSec. 4807Q Covered and SuspiciousTransaction Reporting 1 . Coveredinstitutions shall report to the AMLC allcovered and suspicious transactions withinten (10) working days from occurrencethereof.Should a transaction be determined tobe both a covered and suspicioustransaction, the covered institution shall berequired to report the same as a suspicioustransaction.(Circular No. 706 dated 05 January 2011, as amended byCL -078 dated 11 October 2011)§ 4807Q.1 Deferred reporting ofcertain covered transactions. Pursuant toAMLC Resolution No. 58 dated 25 June2005 as amended by AMLC ResolutionNo. 24 dated 18 March 2009, the followingare considered as “non-cash, no/low riskcovered transactions” the reporting of whichto the AMLC are deferred:1. Transactions between banks and theBSP;2. Transactions between banksoperating in the Philippines;3. Internal operating expenses ofbanks;4. Transactions involving transfer offunds from one deposit account to anotherdeposit account of the same person withinthe same bank;5. Roll-overs of placements of timedeposit; and6. Loan/Interest principal paymentdebited against borrower’s deposit accountmaintained with the lending bank.In addition, pursuant to AMLCResolution No. 292 dated 24 October2003, covered institutions, other thanbanks, shall file CTRs on transactions incash or foreign currency or othermonetary instruments (other than checks)or properties. Due to the nature of thetransactions in the stock exchange, onlythe brokers-dealers shall be required tofile CTRs and STRs 2 .The Philippine Stock Exchange,Philippine Central Depository (PCD),Securities Clearing Corporation of thePhilippines (SCCP) and transfer agents areexempt from filing CTRs. They arehowever required to file STRs when thetransactions that pass through them aredeemed suspicious.The BSP may consider other transactionsas “no/low risk covered transactions” andpropose to the AMLC that they be likewisesubject to deferred reporting by coveredinstitutions.(Circular No. 706 dated 05 January 2011, as amended byCL-2011-035 dated 25 May 2011)1Submission of the hard copies of the STRs to the AMLC is deferred until further advice.2The filing of a CTR by a broker is deferred when the mode of payment is by checks or if the settlement betweenbrokers/dealers and their customers is made through fund transfers or “debiting and crediting” of theirrespective accounts.Q RegulationsManual of Regulations for Non-Bank Financial InstitutionsPart VIII - Page 20