MORNBFI Vol. 1 - Planters Development Bank

§§ 4807Q.2 - 4807Q.411.12.31§ 4807Q.2 Electronic monitoringsystem for money laundering. UBs and KBsare required to adopt an electronic moneylaundering transaction monitoring systemwhich at the minimum shall detect and raiseto the bank’s attention, transactions and/oraccounts that qualify either as CTs or STsas herein defined.The system must have at least thefollowing automated functionalities:a. Covered and suspicious transactionmonitoring – performs statistical analysis,profiling and able to detect unusual patternsof account activity;b. Watch list monitoring – checkstransfer parties (originator, beneficiary, andnarrative fields) and the existing customerdatabase for any listed undesirableindividual or corporation;c. Investigation – checks for givennames throughout the history of paymentstored in the system;d. Can generate all the CTRs of thecovered institution accurately andcompletely with all the mandatory fieldproperly filled up;e. Must provide a complete audit trail;f. Capable of aggregating activities ofa customer with multiple accounts on aconsolidated basis for monitoring andreporting purposes; andg. Has the capability to record all STsand support the investigation of alertsgenerated by the system and brought to theattention of Senior Management whether ornot a report was filed with the AMLC.UBs and KBs with existing electronicsystem of flagging and monitoringtransactions already in place shall ensurethat their existing system is updated to befully compliant with functionalities as thoserequired herein. For this purpose, they shallbe given ninety (90) days from 27 January2011 within which to make their systemfully operational and automated with all thefunctionalities stated above.(Circular No. 706 dated 05 January 2011)§ 4807Q.3 Manual monitoring. Forcovered institutions other than UBs andKBs, it need not have an electronic systemof flagging and monitoring transactions butshall ensure that it has the means offlagging and monitoring the transactionsmentioned in Subsec. 4807Q.2. It shallmaintain a register of all STs that have beenbrought to the attention of SeniorManagement whether or not the same wasreported to the AMLC.(Circular No. 706 dated 05 January 2011)§ 4807Q.4 Electronic submission ofreports. The CTR and STR shall besubmitted to the AMLC in a securedmanner, in electronic form and inaccordance with the reporting proceduresprescribed by the AMLC. The coveredinstitutions shall provide complete andaccurate information of all the mandatoryfields required in the report. In order toprovide accurate information, the coveredinstitution shall regularly update customeridentification information at least onceevery three (3) years.For the purpose of reporting in asecured manner, all covered institutionsshall register with the AMLC within ninety(90) days from 27 January 2011 by directlycoordinating with that office for theproper assignment of their institution codeand facilitation of the reporting process.All covered institutions that havepreviously registered need not re-register.Only their respective complianceofficers or duly authorized officers shallelectronically sign their coveredtransaction reports and suspicioustransaction reports.Electronic copies of CTRs and STRsshall be preserved and safely stored for atleast for at least five (5) years from thedates the same were reported to theAMLC.(Circular No. 706 dated 05 January 2011, as amended byCL-2011-078 dated 11 October 2011)Manual of Regulations for Non-Bank Financial InstitutionsQ RegulationsPart VIII - Page 21