Question & AnswerQ&A (BSP MEMORANDUM)
The primary aim is to establish clear customer acceptance policies and procedures, including the verification of customer identity, to mitigate risks such as money laundering and reputational damage to banks.
Banks must consider customers' background, country of origin, public or high profile position, business activities, and other risk indicators when developing customer acceptance policies.
Banks should apply graduated customer acceptance policies requiring more extensive due diligence for high-risk customers, and decisions to engage with such customers should be taken exclusively at senior management level.
The best documents for verifying identity are those difficult to counterfeit, such as passports, driver’s licenses, or alien certificates of registration.
Banks must establish a systematic procedure for verifying new customers' identities and must not enter into business relationships until identity is satisfactorily established.
Special attention is required because the bank should understand the reason a customer chooses to open an account in a foreign jurisdiction, ensuring no identity procedure is bypassed even if the customer cannot present themselves for an interview.
Banks may face significant reputational and legal risks, including media attention, political reactions, costly information requests, seizure orders, and potential charges of money laundering if funds stem from corruption or serious crimes.
No, under Rule 9.1.f of the Implementing Rules and Regulations of R.A. No. 9160 (Anti-Money Laundering Act), as amended, the opening of accounts without face-to-face contact is prohibited.
Banks should develop clear policies, internal guidelines, procedures, and controls, remaining vigilant especially with business relationships involving individuals holding important or prominent positions and their associates.
It is unrealistic to expect banks to investigate every distant connection; the need to pursue suspicion depends on factors such as asset size, transaction patterns, economic background, country reputation, and plausibility of customer explanations.