Anti-Money Laundering (AML) Policy

Money laundering is defined as the process intended to mask benefits derived from serious criminal offenses or criminal conduct, as described under Anti-Money Laundering Act of 2001, to make it appear that such benefits originated from a legitimate source.


Generally, money laundering is composed of three (3) stages involving several transactions which could alert an intermediary such as the Company to the money laundering activity:

1. Placement – the physical act of disposing of the cash proceeds drawn from illegal activities

2. Layering – the act of separating illicit proceeds from their source by creating complex tiers of financial transactions in order to disguise the audit trail and to provide anonymity

3. Integration – the act of providing an appearance of legitimacy to criminally- derived wealth. If the layering process is successful, the integration step places the laundered proceeds back into the economy in a manner that their re-entry into the financial system has the appearance of being normal business funds

1.2 BASIC PRINCIPLES TO COMBAT MONEY LAUNDERING endeavors to apply the following principles in order to detect, prevent and oppose the use of the Company’s services for money laundering and terrorist financing:

• Established and duly appointed Compliance Office
• Know-Your-Customer (CDD and EDD)
• Reporting to AMLC
• Ongoing Employee Training
• Ongoing monitoring and Compliance Testing
• Record Keeping and Data retention in accordance with AML laws and regulations
• Internal Audit Function

1.2.2 COMPLIANCE WITH LAWS ensures that its business is conducted in conformity with the height of ethical standards, that laws and regulations are respected and complied with whenever possible, and that service is not provided where there is good reason to believe that transactions are associated with money laundering activities.


Within the legal constraints relative to client confidentiality, cooperates with law enforcement agencies. This includes taking appropriate measures within the law if there are reasonable grounds for suspecting money laundering. Any disclosure made in conjunction with the Act shall be made to the Executive Director of the Anti-Money Laundering Council of the Bangko Sentral ng Pilipinas.