Is money laundering a crime in the country where your institution is registered/located?

Name of the law that regulates Anti-Money Laundering (AML) and Terrorist Financing, country in which your institution is located: 

Republic Act (RA) No. 9160, otherwise known as the Anti-Money Laundering Act of 2001, as amended by the following:

R.A 9194 - An Act Amending Republic Act No. 9160

R.A 10167 - An Act to Further Strengthen the Anti-Money Laundering Law; and

R.A 910365 - An Act to Further Strengthen the Anti-Money Laundering Law; 

RA No. 10168, otherwise known as "The Terrorism Financing Prevention and Suppression Act of 2012

Name of official entity/agency that regulates anti-money laundering activities in your Country:
Anti-Money Laundering Council (AMLC)

Does your institution have written guidelines to prevent, detect, and report covered and suspicious transactions that have been approved by senior management?

Does your institution have a legal and regulatory AML compliance program that includes a designated officer responsible for coordinating and overseeing the AML framework, which has been approved by the institution's board, senior management, or a senior committee? If yes, please provide the following details pertaining to such a responsible officer:

Name: AMELIA S. AMPARADO

Position / Title: First Vice President / Head
Compliance Management Group

Telephone Number: (632)405-7396

Fax Number: (632)528-8493

E-mail address: aamparado@mail.landbank.com

In addition to inspections by the government supervisors/regulators, does the institution’s client have an internal audit function or other independent third party that assesses AML policies and practices on a regular basis?
LBP's Internal Audit Group - Annual review

Does your institution maintain any anonymous or numbered accounts? If yes, please explain.

Does your institution allow direct use of a correspondent account by a third party (e.g., a payable-through account)? If yes, please explain.

Does your institution provide services to shell banks/institutions (banks/institutions with no physical presence in any jurisdiction)? If yes, please explain.

Does your institution have policies covering relationships with Politically Exposed Persons (PEPs), consistent with industry best practices?

Do regulations in your country require that your institution report transactions in excess of a given amount and/ or any suspicious transaction to an agency established for such purpose?

Does your institution require that records of your customers' KYC information and transactions be maintained for a period of time? If yes, please indicate the retention period.  
Minimum Retention Period: Five (5) Years per AMLA

Does your institution require that its AML policies and practices be applied to all branches and subsidiaries?

Has any action been brought against your institution for violation of laws or regulations on terrorist financing and/or money laundering? If yes, please explain.

Is your institution fully compliant with the FATF 49 recommendations?

Does your institution have a risk-based assessment of its customer base and their transactions?

Does your institution determine the appropriate level of enhanced due diligence necessary for those categories of customers and transactions that the institution has reason to believe pose a heightened risk of illicit activities at or through the institution?

Does your institution mandate verification of the true identity of all customers at the inception of any business relationship and on an ongoing basis?

Has your institution implemented processes for the identification of those customers on whose behalf it maintains or operates accounts or conducts transactions?

Are reasonable measures taken to obtain information about the legitimacy of the client's activities and sources of funds?

Does your institution have procedures to establish a record for each new customer, noting their respective identification documents and "Know Your Customer" information?

Does your institution assess its financial institution customers’ AML policies and practices?

Does your institution complete a risk-based assessment to understand the normal and expected transactions of its customers?

Does your institution have policies or practices for the identification and reporting of transactions that are required to be reported to the authorities?

Where cash transaction reporting is mandatory, does your institution have procedures to identify transactions structured to avoid such obligations?

Does your system check the list of individuals and entities under financial measures and/or suspected of terrorist activities to ensure that none of the counterparty is on the list (OFAC-SDN/FATF-NCCT)?

Does your institution have policies to reasonably ensure that it only operates with correspondent banks that possess licenses to operate in their countries of origin? 

Does the FI adhere to the Wolfsberg Transparency Principles and the appropriate usage of the SWIFT MT 202/202COV and MT 25/205COV message formats?

Does your institution have a monitoring program for unusual and potentially suspicious activity that covers fund transfers and monetary instruments such as traveler's checks, money orders, etc.?