A Guide to Anti-Money Laundering (AML) Registration in the Philippines

Financial crime represents a global challenge, yet the efforts to combat it frequently occur at a localized level. In the Philippines, addressing money laundering necessitates adherence to a distinct set of regulations, oversight by specific government agencies, and compliance with registration requirements that businesses must carefully navigate.

For entrepreneurs and corporations alike, Anti-Money Laundering (AML) registration is not merely a regulatory formality; it is an essential aspect of conducting business both legally and ethically.

Moreover, the Philippines’ commitment to strengthening its AML framework has yielded significant progress, such as its removal from Europe’s high-risk watchlist. This milestone underscores the importance of compliance in maintaining the country’s global standing.

For those entering the financial sector, real estate industry, or engaging in transactions involving high-value goods, a thorough understanding of AML obligations is imperative.

• What is Anti-Money Laundering (AML)?
• The Legal Framework in the Philippines
• Why Registration Matters
• Step-by-Step Process for AML Registration
• Frequently Asked Questions

What is Anti-Money Laundering (AML)?

Addressing financial crime is a global priority, yet the most significant efforts often take place at the local level. In the Philippines, combating money laundering requires businesses to comply with specific regulations, engage with designated government agencies, and fulfill mandatory registration requirements.

For organizations and entrepreneurs, Anti-Money Laundering (AML) registration is more than a procedural obligation; it is a fundamental step in ensuring both legal and ethical business practices.

A key component of this process is implementing Client Due Diligence (CDD) measures, which help businesses verify the identities of their clients, assess risks, and detect suspicious activities.

Whether entering the financial sector, the real estate market, or engaging in the trade of high-value goods, a clear understanding of AML requirements is essential. This guide provides an overview of the legal framework, details the registration process, and offers guidance on maintaining compliance.

The Legal Framework in the Philippines

The cornerstone of the Philippines’ Anti-Money Laundering (AML) framework is the Anti-Money Laundering Act of 2001 (Republic Act No. 9160), as amended. This legislation established the Anti-Money Laundering Council (AMLC), which serves as the country’s financial intelligence unit tasked with enforcing AML laws.

The law designates “Covered Persons” who are required to register under its provisions. Over time, this list has expanded and now includes the following:

• Financial Institutions. Banks, insurance companies, and securities dealers.
• Designated Non-Financial Businesses and Professions (DNFBPs). This category often surprises many, as it encompasses jewelry dealers, company service providers, lawyers and accountants (when managing client assets), and notably, real estate brokers and developers.
• Casinos. Including internet-based and ship-based gaming operations.

Why Registration Matters

Registering for AML compliance serves as the first line of defense against financial crime. By mandating business registration, authorities are able to monitor financial flows, track high-risk transactions, and identify suspicious activities before they escalate into serious criminal acts.

This system is designed to close the loopholes that criminals often exploit to move illicit funds through the financial system. Below are the key reasons why AML registration is essential:

• Facilitates monitoring of financial flows and high-risk transactions
  Registration enables authorities to track suspicious activities, making it significantly more difficult for criminals to launder money.
• Demonstrates legitimacy and professionalism
  Registered businesses showcase transparency and a commitment to ethical practices, earning trust from clients, partners, financial institutions, and regulators.
• Supports international cooperation
  Compliance with global standards ensures the Philippines maintains good standing with organizations such as the Financial Action Task Force (FATF), facilitating smoother and more cost-effective international transactions.
• Prevents severe penalties and legal repercussions
  Non-compliance can result in substantial fines, suspension of licenses, or even criminal charges for business owners and executives.
• Strengthens the financial system’s integrity
  Registration safeguards businesses from unwitting involvement in criminal schemes and contributes to a safer, more trustworthy financial environment in the country.

Step-by-Step Process for AML Registration

Registering for AML compliance is a crucial step in ensuring your business operates legally and ethically while contributing to the fight against financial crime. The process is now primarily handled online through the AMLC portal, making it more accessible and efficient.

Whether you are a financial institution, a real estate broker, or part of a designated non-financial business, completing this registration is essential for compliance and transparency.

Here is the general roadmap for getting registered:

1. Determine if You are a “Covered Person”
   Before initiating the registration process, confirm whether your business falls under the category of “Covered Persons.” Review the latest AMLC guidelines or consult a legal expert. For instance, real estate brokers are considered Covered Persons if they engage in transactions exceeding PHP 500,000 in a single operation.
2. Prepare Documentary Requirements
   The AMLC requires specific documents to verify your identity and the legitimacy of your business. Commonly required documents include:
   • Articles of Incorporation or DTI Registration: Proof of business registration.
   • Business Permit: A current mayor’s permit.
   • Authorization Letter: If appointing a Compliance Officer to handle the registration.
   • Valid IDs: For business owners and the designated Compliance Officer.
3. Online Registration
   Access the AMLC website and navigate to their online registration portal.
   • Create an account and upload your digital documents.
   • Ensure all information fields are filled out accurately.
   • Upload clear, readable scans of your documents.
   • Designate your Compliance Officer during this stage.
4. Verification and Approval
   Once your application is submitted, the AMLC will review it. This process may take some time, and additional documents or clarifications may be requested. Be sure to monitor your email or the portal for updates on your application status.
5. Issuance of Certificate of Registration (COR)
   Upon approval, you will receive a Certificate of Registration (COR). This document serves as proof that your business is officially registered with the AMLC. Keep a copy readily available at your place of business for compliance purposes.