As covered persons under Republic Act No. 9160 or the Anti-Money Laundering Act of 2001 (AMLA), as amended, designated non-financial businesses and professions (DNFBPs) are reminded to register with the Anti-Money Laundering Council (AMLC).

DNFBPs under the AMLA, as amended

Section 1, Rule 4, of the 2021 Implementing Rules and Regulations of the AMLA, as amended (2018 IRR), enumerates the DNFBPs as follows:

  1. Jewelry dealers;
  2. Dealers in precious metals and dealers in precious stones;
  3. Company service providers, which, as a business, provide any of the following services to third parties:
    1. Acting as a formation agent of juridical person;
    2. 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;
    3. Providing a registered office, business address or accommodation, correspondence or administrative address for a company, a partnership or any other juridical person or legal arrangement; and
    4. Acting as (or arranging for another person to act as) a nominee shareholder for another person;
  4. Person, including lawyers, accountants, and other professionals, who provide any of the following services:
    1. Management of client money, securities, or other assets;
    2. Management of bank, savings, securities, or other assets;
    3. Organization of contributions for the creation, operation, or management of companies; and
    4. Creation, operation, or management of juridical persons or arrangements, and buying and selling of business entities;
  5. Casinos, including Internet- and ship-based casinos, with respect to their casino cash transactions and related to their gaming operations;
  6. Real estate brokers and developers; and
  7. Offshore gaming operators, as well as their service providers, supervised, accredited, or regulated by the Philippine Amusement and Gaming Corporation or any appropriate government agency

Primary duties of covered persons

Section 2 of the 2018 IRR states that covered persons shall comply with all the requirements under the AMLA and the Terrorism Financing Prevention and Suppression Act of 2012 (TFPSA), their respective IRRs, and other AMLC issuances. Covered persons shall have the duty to cooperate with the AMLC in the discharge of the latter’s mandate and execution of its lawful orders and issuances, to protect their businesses or profession from being used in money laundering and terrorism financing activities.

Section 9(c) of the AMLA, as amended, requires covered persons to file covered (CTRs) and suspicious transaction reports (STRs). For this purpose, Section 4, Rule 22 of the 2018 IRR mandates all covered persons to register with the AMLC’s electronic reporting system in accordance with the AMLC Registration and Reporting Guidelines (AMLC Regulatory Issuance No. [ARI] 4, Series of 2021).

Consequences of non-registration

Non-registration with the AMLC may result in the imposition against unregistered DNFBPs of appropriate enforcement actions under the Enforcement Action Guidelines (ARI No. 5, Series of 2020) and/or administrative sanctions as per the Rules of Procedure in Administrative Cases under the AMLA, as amended (AMLC Procedural Issuance A, B, and C No. 1, Series of 2019). Unregistered DNFBPs would not be able to electronically submit CTRS and STRs. Non-submission of CTRs/STRs, knowing that such reports are required to be submitted to the AMLC, is penalized as a money laundering offense under the last paragraph of Section 4 of the AMLA, as amended.


For further concerns, please contact the following:

(+632) 5310 3244

(+632) 5302 3848

(+632) 8708 7067

(+63915) 778 0720

(+63960) 690 8794

(+63968) 772 7045

(+63927) 169 7198

Posted 27 December 2022

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