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ZIGRAM examines AML compliance beyond registration

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ZIGRAM examines AML compliance beyond registration

For organisations operating in the Philippines, registration with the Anti-Money Laundering Council (AMLC) is more than an administrative requirement. It marks the beginning of formal anti-money laundering (AML) obligations, connecting covered entities to the country’s financial intelligence and regulatory reporting framework.

The AMLC, the Philippines’ financial intelligence unit, requires covered persons to register through its online system and designate a Compliance Officer as their primary point of contact with the regulator. Registration provides access to the AMLC Portal, where entities can submit Covered Transaction Reports (CTRs) and Suspicious Transaction Reports (STRs), upload supporting documentation, review filing histories and maintain their registration details. ZIGRAM’s analysis highlights the importance of understanding these requirements as the starting point for a broader, ongoing AML compliance programme.

Determining whether registration is required depends on an organisation’s activities and regulatory status. The 2018 Implementing Rules and Regulations of the Anti-Money Laundering Act cover a broad range of financial institutions, including banks, quasi-banks, trust entities, pawnshops, e-money issuers, foreign exchange dealers, remittance firms, insurers and securities firms.

The scope also extends to designated non-financial businesses and professions (DNFBPs), including real estate brokers and developers. Lawyers handling client funds may also fall within the regulatory framework. Organisations should establish their obligations based on their specific activities rather than relying on generic registration checklists.

Documentation requirements vary according to legal structure and regulatory category. Applicants typically need corporate or professional registration records, details of the organisation and its authorised representative, information about the designated Compliance Officer and any alternates, evidence of their appointment, and relevant sector-specific licences.


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