BSP sets electronic reporting of money laundering, risk events

The Bangko Sentral ng Pilipinas (BSP) has released the guidelines on the electronic submission of money laundering (ML)/terrorist financing (TF)/proliferation financing (PF) risk event reports (RER) within 24 hours of discovery by both banks and non-banks.

The covered BSP supervised financial institutions (BSFIs) required to submit the RER are banks and quasi banks, including their subsidiaries and affiliates; stand-alone trust corporations; non-stock savings and loan associations; money service businesses (i.e., foreign exchange dealers, money changers, pawnshops, and remittance and transfer companies); non-bank electronic money issuers; and virtual asset service providers. Credit card issuers which were part of the list before has been removed.

In a new memo (Memorandum No. 2024-016) signed by BSP Deputy Governor Chuchi G. Fonacier on May 27, all report submission “should continue to comply with the existing BSP reporting standards.”

Meanwhile, all BSFIs are instructed to use the prescribed RER Data Entry Template (DET) which can be downloaded from

“The accomplished RER DET together with the duly-signed control proof list shall be submitted by the BSFI’s Compliance Officer and/or Duly Authorized or Designated Officer within twenty-four (24) hours from the date of knowledge or discovery of occurrence of any significant ML/TF/PF risk event,” according to the memo.

Last January 2023 the BSP circulated a draft circular proposing stricter rules on the electronic submission of BSFIs’ risk reporting and notification of ML, TF and PF.

The Anti-Money Laundering/Countering the Terrorism and Proliferation Financing Reporting Package (ARP) covered six BSFIs required to submit to the BSP information on current ML/TF/PF risk as well as significant risk events arising from ML/TF/PF-related activities or transactions.

As part of its risk-based Anti-Money Laundering and Countering the Terrorism and Proliferation Financing (AML/CTPF) supervision, the BSP designed the ARP to foster the periodic gathering of relevant and updated data and information related to the ML/TF/PF risks of both banks and non-banks.

The ARP reporting requirement is submitted to the BSP within 30 banking days after the end of the reference year.

For any ML/TF/PF RERs, BSFIs will have to notify the BSP within 24 hours from date of first knowledge. This covers reporting of ML/TF/PF-related incident “that may present material and adverse impact on the BSFI, the financial system’s posture or erode public confidence.”

The BSP said that an ML/TF/PF risk event is reportable it it will affect a significant number of customers or counterparties, with cross-border element, or those covered/may be covered in adverse media reports.

The global anti-money laundering watchdog, the Paris-based Financial Action Task Force (FATF), has taken note of the Philippines' progress in adopting stronger measures against money laundering and terrorist financing, part of efforts to be delisted from its “gray list”.

Being on the list means the Philippines is one of jurisdictions under closed monitoring by the FATF until these strategic flaws have been addressed.

To be taken out of the gray list, the country has committed to comply with 18 action plan items as soon as possible.

The Philippines was gray-listed on June 25, 2021. The last time the country was on the FATF watch list was in 2013.

As of February this year, the country is still on the FATF gray list.