BSP Memorandum No. M-2015-007

: The main objective is to require covered institutions to establish policies and procedures to prevent the use of fund/wire transfers for transmitting proceeds of unlawful activities.
: Subsection X806.2.i of the Manual of Regulations for Banks mandates this requirement.
: Covered institutions must have a system that enables them to understand the normal and reasonable account activity of customers and detect unusual or suspicious account activity patterns.
: The beneficiary institution must conduct the necessary customer due diligence to establish the true and full identity and existence of the non-customer beneficiary before accepting instructions to pay-out fund transfers.
: The beneficiary institution must conduct enhanced due diligence on both the beneficiary and the originator in such cases.
: The institution must refuse to effect the fund/wire transfer or the pay-out of funds and, if warranted, report the suspicious transaction to the Anti-Money Laundering Council.
: Transfers amounting to P50,000 or more, or its equivalent, must include accurate and meaningful originator information.
: Ongoing monitoring is important to detect and prevent the use of fund/wire transfers for unlawful activities by understanding normal customer behavior and identifying suspicious transactions.
: They receive reports of suspicious transactions from covered institutions when circumstances warrant such reporting.