Question & AnswerQ&A (BSP CIRCULAR LETTER)
Covered institutions must report all covered transactions and suspicious transactions to the AMLC within five (5) working days from the occurrence thereof, subject to specified exceptions.
Non-working days excluded are weekends (Saturday and Sunday), official regular national holidays, officially declared national holidays (special non-working days nationwide), and officially declared holidays in the locality where the AMLC Secretariat Office is located.
A 'non-reporting day' is a day declared by the AMLC Secretariat when the File Transfer and Reporting Facility (FTRF) used for electronic reports is unavailable to all covered institutions for at least five consecutive hours during that day.
The Executive Director of the AMLC Secretariat or the Officer-in-Charge is authorized to declare a 'non-reporting day' upon notification and justification by the Deputy Director of IMAS AMLC Secretariat.
Local holidays, except those officially declared in the AMLC Secretariat's locality, are treated as working days and included in the counting of the reporting period. CIs located in such localities may request a deviation subject to approval.
Yes, covered institutions may file a deviation request if affected by local holidays or natural calamities. Approval is subject to the Executive Director of the AMLC Secretariat based on the recommendation of the Deputy Director of IMAS AMLC Secretariat.
Officially declared non-working days due to calamities such as floods, typhoons, earthquakes, etc., affecting certain localities or regions may be excluded for covered institutions in the affected areas upon approved deviation request.
AMLC uses the Transaction Monitoring and Analysis System (TMAS), which automatically computes penalties for delayed reports based on the prescribed reporting period and approved deviations.
The resolution approves the policies and guidelines for reckoning compliance with the prescribed reporting period under RA 9160 (Anti-Money Laundering Act of 2001), ensuring standardized interpretation and enforcement of report submissions by covered institutions.
Non-compliance may result in penalties automatically computed by the AMLC's TMAS system. Manual recomputation may occur if deviation requests are approved to adjust penalties accordingly.