Title
BSP Fund/Wire Transfer Policies Memo
Law
Bsp Memorandum No. M-2015-007
Decision Date
Jan 26, 2015
BSP Memorandum No. M-2015-007 mandates covered institutions to implement stringent policies and procedures for fund and wire transfers to prevent the transmission of proceeds from unlawful activities, emphasizing enhanced due diligence for high-risk customers and accurate originator information for transactions of P50,000 or more.
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Risk-Based Monitoring and Detection Systems

  • Covered institutions must establish systems to understand customers' normal and reasonable account activities.
  • Systems should detect unusual or suspicious transaction patterns.
  • Monitoring must be risk- and materiality-based and ongoing as part of customer due diligence.

Customer Due Diligence for Beneficiaries

  • Beneficiary institutions shall not pay-out fund transfers to non-customer beneficiaries without conducting full and true identity verification.
  • Verification includes establishment of existence and identity of the beneficiary.

Enhanced Due Diligence for High-Risk Customers

  • For cross-border transfers, if the originator is considered a high-risk customer, the beneficiary institution must conduct enhanced due diligence on both the originator and beneficiary.

Refusal of Transaction and Reporting Obligations

  • Beneficiary institutions shall refuse to process fund/wire transfers or pay-out if:
    • Additional information cannot be obtained.
    • Provided information or documents are false or falsified.
    • Validation process results are unsatisfactory.
  • Such refusal shall not prejudice the reporting of suspicious transactions to the Anti-Money Laundering Council.

Information Requirements for Fund/Wire Transfers

  • Cross-border and domestic transfers and related messaging must include accurate and meaningful originator information.
  • This applies to transfers amounting to P50,000 or its equivalent and above.

Compliance and Enforcement

  • Covered institutions are reminded to observe relevant prudential safeguards in processing fund/wire transfers.
  • Compliance is overseen by Bangko Sentral ng Pilipinas as represented by the Deputy Governor.

This comprehensive regulatory framework serves as a preventive measure against money laundering and unlawful fund transfers through banking channels in the Philippines.


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