AMLC on Terrorist Lists Compliance

The AMLC is created under Republic Act No. 9160, the Anti-Money Laundering Act of 2001 (AMLA).
The resolution anchors compliance and information-sharing on Sections 2, 7 and 13 of the AMLA and Rule 7.2 (8) of the AMLA Implementing Rules and Regulations (IRRs).
The resolution links terrorist-list requests from foreign states to the AMLC’s authority to receive and act on requests that Philippine authorities must effectively execute and enforce.
The resolution also treats terrorist-list compliance as connected to the AMLA’s covered transaction reporting and suspicious transaction reporting framework under the AMLA IRRs, specifically Rules 5 and 9.3.
The resolution explains that terrorist financing activities are within the AMLA’s predicate framework: it cites unlawful activities under Section 3 and money laundering as an offense under Section 4.

The AMLC resolves to disseminate United States Terrorist Lists for information, guidance, and appropriate action.
The AMLC resolves that supervising authorities must disseminate those lists to covered institutions under their respective jurisdictions.
The AMLC resolves that supervising authorities must direct covered institutions to submit required reports covering listed individuals, groups, organizations, or entities.
The resolution’s operational objective is to ensure covered transaction reporting and suspicious transaction reporting are triggered for any listed person or entity.
The resolution ties the reporting requirement to the AMLA’s handling of proceeds and related concepts under the IRRs, including proceeds tied to the financing and operations of unlawful activities under Rule 3.f.

The AMLC resolves dissemination of the United States Terrorist Lists issued on February 26, 2002 and March 11, 2002.
The BSP compliance direction applies to banks and off-shore banking units “concerned” that must report transactions involving any individual, group, organization, or entity named in the referenced lists.
The resolution’s background references earlier disseminations of United Nations Security Council Resolutions including UNSCR Nos. 1267, 1269, 1333, 1368 and 1373 with dates October 15, 1999, October 19, 1999, December 19, 2000, September 12, 2001, and September 28, 2001.
The resolution’s background also references Executive Order No. 13224 issued on September 24, 2001 and multiple subsequent U.S. terrorist lists, including a Terrorist List dated September 24, 2001 and other lists dated October 12, November 2, November 7, December 4, December 20, 2001, and January 9, 2002.
The operative reporting obligation in the resolution and the BSP memorandum explicitly attaches to the February 26, 2002 and March 11, 2002 lists.

The AMLC directs supervising authorities to disseminate the February 26, 2002 and March 11, 2002 U.S. Terrorist Lists to covered institutions in their jurisdictions.
Supervised covered institutions must submit reports involving any listed individual, group, organization, or entity included in the referenced lists.
The BSP memorandum further specifies that all banks and off-shore banking units concerned must file with the AMLC the necessary reports.
Covered institutions must submit reports for both covered transactions and suspicious transactions involving any named individual or entity on the lists.
The reporting must follow the AMLA IRRs reporting mechanics under Rules 5 and 9.3, as well as other related or applicable rules, regulations, circulars, and operating manuals issued by the supervising authorities.

Covered institutions must file with the AMLC the necessary reports of suspicious transactions involving listed individuals, groups, organizations, or entities.
Covered institutions must also file the necessary reports of covered transactions involving listed individuals, groups, organizations, or entities.
The required reports must be filed in accordance with Rules 5 and 9.3 of the AMLA IRRs.
Covered institutions must comply with additional reporting rules issued by their supervising authorities through related or applicable rules, regulations, circulars, and operating manuals.
Supervising authorities must ensure that their directives to covered institutions operationalize these reporting duties for listed persons and entities.

The resolution identifies hijacking, destructive arson and murder by terrorists against non-combatant persons and similar targets as unlawful activities or predicate crimes under Section 3 of the AMLA.
The resolution states that transacting the proceeds of such terrorist acts is a money laundering offense under Section 4 of the AMLA.
The resolution relies on Rule 3.f of the AMLA IRRs to define “proceeds” as including “all moneys, expenditures, payments, disbursements, costs, outlays, charges, accounts, refunds, and other similar items” for the financing, operations, and maintenance of any unlawful activity.
The resolution therefore treats terrorist-list compliance as integral to capturing transactions linked to money laundering offenses and terrorist predicate activities.
The resolution grounds the authority to execute foreign-request assistance in the AMLC’s statutory powers under Sections 2, 7 and 13 of the AMLA and Rule 7.2 (8) of the IRRs.

The resolution establishes dissemination and reporting duties for covered institutions and supervising authorities but does not itself set separate fines, administrative penalties, or criminal sanctions.
The compliance mechanism is framed through mandatory report submission to the AMLC under the AMLA IRRs reporting rules (Rules 5 and 9.3).
The BSP memorandum implements the resolution by requiring banks and off-shore banking units to file the necessary suspicious and covered transaction reports with the AMLC.
Enforcement consequences for non-compliance are governed through the AMLA and applicable implementing rules and supervisory regulations, as referenced by reporting duties.

The AMLC’s resolution requires dissemination of the February 26, 2002 and March 11, 2002 terrorist lists to supervising authorities for guidance and appropriate action.
The AMLC’s resolution requires supervising authorities to disseminate those lists to covered institutions under their jurisdiction.
The AMLC’s resolution requires supervising authorities to direct covered institutions to submit covered transaction reports and suspicious transaction reports involving listed persons and entities.
The BSP memorandum translates the AMLC resolution into a direct compliance requirement on banks and off-shore banking units to file with the AMLC the necessary reports.
Copies of the U.S. Terrorist Lists dated February 26, 2002 and March 11, 2002 are attached for reference for use in compliance screening and reporting.