Under the Anti-Money Laundering Act (AMLA), entities classified as covered persons are legally required to report specific financial transactions to the Anti-Money Laundering Council (AMLC). These include both covered transactions and suspicious transactions, which must be reported within five working days unless a longer period (up to 15 working days) is specifically allowed.
To streamline and clarify the reporting process, the AMLC issued Regulatory Issuance No. 2, Series of 2024, on December 11, 2024. This issuance, known as the Guidelines on Transaction Reporting and Compliance Submissions (GoTRACS), outlines the procedures and requirements for submitting electronic reports of covered and suspicious transactions.
Covered Transactions
Covered transactions are defined as:
Cash or equivalent transactions exceeding PHP 500,000;
Transactions involving jewelry or precious metals/stones dealers in cash or equivalent exceeding PHP 1 million;
Real estate transactions exceeding PHP 7.5 million in cash or equivalent;
Casino cash transactions exceeding PHP 5 million.
Reports for these transactions must be complete, accurate, and submitted electronically through the AMLC’s File Transfer and Reporting Facility (FTRF) within five working days. Non-casino and non-real estate entities must report all covered transactions, regardless of payment mode. However, casinos and real estate businesses are only required to report cash-based transactions.
Suspicious Transactions
Suspicious transactions refer to those that deviate from a customer’s known financial behavior — such as unexpected amounts, sources, or destinations. These may involve potential money laundering or terrorist financing.
GoTRACS requires covered persons to implement a reporting chain that details how suspicious activity is identified, assessed, and escalated. Entities must develop a Money Laundering/Terrorism Financing Prevention Program that:
Outlines internal procedures from identifying a suspicious transaction to deciding on report filing;
Identifies who is responsible for each step in the review process;
Specifies timeframes for each action to ensure timely reporting;
Describes mechanisms to monitor and document all stages of assessment;
Includes decision-making policies and assigns authority to compliance officers or committees;
Ensures confidentiality to prevent “tipping off” customers.
Suspicious Transaction Reports (STRs) must be filed by the next working day following the determination of suspicion. These reports, including attempted transactions, must be submitted electronically through the AMLC’s FTRF.
Late or incomplete submissions will be deemed non-compliant under the AMLA and may result in administrative penalties.
Implementation Timeline
GoTRACS takes effect upon publication but will be enforced in stages:
May 1, 2025 – Implementation of specific provisions in Chapter II, Part 1;
One year from effectivity – Enforcement of rules on low-risk transactions and non-reporting days;
One to three years from effectivity – Implementation of new reporting formats, KYC document uploads, and beneficial ownership templates for corporate accounts.
Read the full guideline below
By FCCT Editorial Team freeslots dinogame telegram营销
