The 2021 ARRG was published in BusinessWorld on 09 July 2021.

In general, the effectivity date is 30 days after publication or on 08 August 2021. For other provisions, per the 2021 ARRG (page 163), the effectivity date is six (6) months after publication, which falls on 09 January 2022.

The following are amendments effective on 08 August 2021:

General provisions

1. Comprehensive definition of “covered persons” to include certain types of designated non-financial businesses and professions;
2. Definition of “covered transaction” for real estate developers and brokers;
3. Quality, form, and timing of submission of suspicious transaction reports (STRs);
4. Inclusion of PC34 (Violation of Section 19(A)(3) of Republic Act No. 10697, otherwise known as the Strategic Trade Management Act, in relation to the financing of proliferation of weapons of mass destruction and its financing pursuant to United National Security Council Resolution No. 1718 of 2006 and 2231 of 2015) in the requirement of submission of know-your-customer (KYC) documents prior to the actual submission of STRs;
5. Clarification on non-working and non-reporting days in terms of the counting of the prescribed reporting period, including automatic suspension thereof;
6. Delegated authority to the Executive Director of the AMLC to require submission of all covered transactions, including low-risk, of persons subject of AMLC investigation;
7. Renaming of “no/low risk” covered transactions to “low-risk” covered transactions;
8. Amendment to the low-risk transactions; and
9. Introduction of new provisions on compliance-checking and administrative sanctions.

Reporting procedures/annexes

1. Updating of the online registration guidelines;
2. Updating of the reason for suspicion to include two (2) new predicate crimes;
3. Increase in the number of characters for certain fields;
4. Amendment in the mandatory fields for the Beneficiary Party for Outward Remittance transactions;
5. Guidelines in the suspicious transaction reporting on a per account basis;
6. Guidelines for insurance companies on covered and suspicious transaction reporting;
7. Addition of new transaction codes and updating of the mandatory fields; and
8. List of “red flags” and transaction codes, involving real estate transactions and concerning virtual asset service providers.

The following are amendments effective on 09 January 2022:

General provisions

1. Lifting of loan payment as a low-risk transaction

Reporting procedures/annexes

1. Inclusion of STR trigger in the reporting of STRs;
2. New reporting format for loan availment and sale of real and other properties acquired (ROPA) transactions; and
3. Updating of country and currency codes.

The 2017 ARRG will remain posted on the AMLC website until all provisions of the 2021 ARRG become effective.

Posted 12 August 2021

In view of the announcement of the Office of the President, placing the National Capital Region under enhanced community quarantine (ECQ) from 06 to 20 August 2021, please be advised of the following:

Pursuant to Item V-A of Part 1, General Provisions of the AMLC Registration and Reporting Guidelines (ARRG), the periods 07 to 08 and 14 to 15 August 2021 fall on weekends, thus these non-working days shall be excluded from the counting of the prescribed reporting period.

The period 06 to 20 August 2021 shall be considered workday suspensions in accordance with the ECQ.

The foregoing is without prejudice to the voluntary submissions by covered persons of covered (CTRs) and suspicious transaction reports (STRs) within the reglementary period through the AMLC portal.

Further, all specified deadlines relative to pending requests for submission of know-your-customer (KYC) documents as well as requests during the ECQ period (06 to 20 August 2021) are hereby suspended.

For requests during the ECQ period, the same shall be sent through e-mail to the respective compliance officers or other authorized officers of covered persons registered as such with the AMLC. Please be reminded that compliance with said requests may be made during this ECQ period but shall be submitted through the AMLC portal instead of personal delivery.

 Access details are as follows:

1. Log-in the AMLC portal (Ver. 2.9.9).
2. In the Electronic Documents Upload Facility, click the Electronic Return/KYC Documents Request Upload
3. Select KYC Documents Request in the Document Type dropdown and click Proceed.
4. Enter the reference number as specified in the AMLC request.
5. Click Browse, choose the filename of the document, and click Upload. The filename should contain the name of the account holder.

 The ARRG hotlines will remain open for queries and concerns on registration and transaction reporting.

 Posted 5 August 2021