Suspicious Transactions under the Anti-Money Laundering Act | 21 April 2024

Suspicious transactions refer to transactions with covered persons, regardless of the amounts involved

Suspicious Transaction under the Anti-Money Laundering Act

Suspicious transactions refer to transactions with covered persons, regardless of the amounts involved, where any of the following circumstances exist:

1. There is no underlying legal or trade obligation, purpose or economic justification;

2. The client is not properly identified;

3. The amount involved is not commensurate with the business or financial capacity of the client;

4. Taking into account all known circumstances, it may be perceived that the client’s transaction is structured in order to avoid being the subject of reporting requirements under the Anti-Money Laundering Act;

5. Any circumstance relating to the transaction which is observed to deviate from the profile of the client and/or the client’s past transactions with the covered person;

6. The transaction is in any way related to an unlawful activity or offense under the Anti-Money Laundering Act that is about to be, is being, or has been committed; or

7. Any transaction that is similar or analogous to any of the foregoing.

(Source: Section 3, par. b-1, Republic Act No. 9160, as amended by Republic Act No. 11521)

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Alburo Alburo & Associates Law Offices:

• Have labor law and business law as our main fields of practice. For almost a decade now, we have been helping businesses improve their productivity and profitability by helping them comply with relevant laws, rules, and regulations.

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