Anti-Money Laundering Compliance for Foreign Companies in the Philippines: A 2026 Legal Guide

When a foreign company opens a bank account in the Philippines, registers a subsidiary with the SEC, or acquires real estate through a Philippine entity, it enters the regulatory orbit of the country's anti-money laundering framework. That framework — centered on Republic Act No. 9160, the Anti-Money Laundering Act of 2001, as amended — imposes reporting obligations, customer due diligence requirements, record-keeping mandates, and criminal penalties that apply not only to banks and financial institutions, but to a growing list of non-financial businesses and professions that foreign investors commonly operate through.

For foreign companies entering the Philippine market, understanding AMLA compliance is not optional. It is a prerequisite to keeping banking relationships and government licenses in good standing. Non-compliance can result in administrative sanctions from the Bangko Sentral ng Pilipinas (BSP), the Securities and Exchange Commission (SEC), or the AMLC itself, criminal prosecution under the AMLA, court-ordered freezing of corporate accounts, and, for some offenses committed by foreign nationals, deportation. The rules are more expansive than most foreign investors initially assume.

This guide explains how AMLA compliance applies to foreign companies operating in the Philippines in 2026. It covers the statutory framework, the evolving definition of covered persons, transaction reporting thresholds, customer due diligence obligations, penalties, and the practical steps foreign investors should take before and after establishing a Philippine presence.

I. The Statutory Framework: Republic Act No. 9160 and Its Amendments

The Original Act: RA 9160 (2001)

Republic Act No. 9160, signed into law on September 29, 2001, was the Philippines' foundational anti-money laundering statute. Modeled on international standards set by the Financial Action Task Force (FATF), the law created the Anti-Money Laundering Council (AMLC) — composed of the Governor of the BSP (as chair), the Chairperson of the SEC, and the Commissioner of the Insurance Commission — with authority to receive transaction reports, investigate money laundering offenses, pursue forfeiture of illicit proceeds, and coordinate with foreign states.

The original RA 9160 primarily targeted banks and other financial institutions as "covered institutions" — entities subject to the law's reporting and compliance obligations — and set the covered transaction threshold at PHP 4,000,000 within five consecutive banking days. Both the list of covered persons and the reporting rules have since been significantly expanded through five amendments.

The Amendments: RA 9194, RA 10167, RA 10365, RA 10927, and RA 11521

Each amendment widened either the range of entities that must comply or the range of unlawful activities that can give rise to money laundering liability. Understanding each one is essential for foreign investors operating in sectors that may now fall within the AMLA's reach.

Republic Act No. 9194 (2003) — The first amendment lowered the covered transaction threshold to PHP 500,000 within one banking day, introduced the statutory definition of "suspicious transactions" (reportable regardless of amount), and expanded the list of predicate crimes. It also shifted the power to freeze accounts from the AMLC to the Court of Appeals, acting on the AMLC's ex parte application, and allowed the AMLC to examine bank deposits without a court order in cases involving kidnapping for ransom, dangerous drugs offenses, and hijacking, destructive arson, and murder.

Republic Act No. 10167 (2012) — This amendment refined the freeze and bank-inquiry procedures. The Court of Appeals may issue a freeze order, effective immediately, for twenty (20) days unless extended, and must act on the AMLC's petition within twenty-four (24) hours. The AMLC may inquire into deposits and investments — including "related accounts" — upon an ex parte court order, with the court-order requirement still waived for the specific crimes listed above, their foreign equivalents, and terrorism.

Republic Act No. 10365 (2013) — This amendment expanded the definition of covered persons beyond financial institutions to include dealers in precious metals and precious stones (for transactions above PHP 1,000,000), company service providers, and persons who manage client money, securities, or accounts, or who create and manage juridical persons. Lawyers and accountants acting as independent legal professionals are excluded as to privileged client information. RA 10365 also expanded the predicate crimes, restructured the money laundering offense in Section 4 (adding attempt, conspiracy, and aiding and abetting), set a six-month ceiling on freeze orders, and required the Land Registration Authority to report real estate transactions above PHP 500,000 to the AMLC.

Republic Act No. 10927 (2017) — Perhaps the most consequential amendment for foreign investors in the gaming sector, RA 10927 brought casinos, including internet-based and ship-based casinos, within the scope of covered persons. A single casino cash transaction exceeding PHP 5,000,000 is a covered transaction requiring mandatory reporting to the AMLC. This amendment was enacted in part as a response to FATF concerns about the Philippine casino sector's vulnerability to money laundering.

Republic Act No. 11521 (2021) — The most recent amendment, approved on January 29, 2021, added real estate developers and brokers (for single cash transactions above PHP 7,500,000) and offshore gaming operators (OGOs) and their service providers to the list of covered persons. It made tax crimes a predicate offense where the deficiency basic tax exceeds PHP 25 million per taxable year per tax type, added proliferation financing under the Strategic Trade Management Act as a predicate offense, and gave the AMLC new powers: to apply to the courts for search and seizure orders and subpoenas, and to implement United Nations targeted financial sanctions on proliferation financing, including ex parte freezes. For foreign investors in real estate development or the offshore gaming sector, RA 11521 introduced direct compliance obligations that did not exist before 2021.

II. The AMLC: Structure, Powers, and Jurisdiction

The Anti-Money Laundering Council (AMLC) is the Philippines' financial intelligence unit and the primary enforcement agency under the AMLA. Established under Section 7 of RA 9160, it is composed of the BSP Governor (Chair), the SEC Chairperson, and the Insurance Commissioner, and it acts unanimously. The AMLC has broad powers to:

• Receive covered and suspicious transaction reports, and investigate suspicious transactions, money laundering activities, and other violations of the AMLA
• Inquire into or examine bank deposits and investments, including related accounts, upon an ex parte court order — or without a court order in cases involving kidnapping for ransom, dangerous drugs offenses, hijacking, destructive arson and murder, their foreign equivalents, and terrorism
• Petition the Court of Appeals, ex parte, for freeze orders that take effect immediately for twenty (20) days and may be extended after a summary hearing, up to a total of six (6) months
• File civil forfeiture cases, through the Office of the Solicitor General, to recover proceeds of unlawful activity — without first securing a criminal conviction
• Apply to the courts for search and seizure orders and subpoenas in the course of its investigations
• Implement targeted financial sanctions under United Nations Security Council resolutions on the financing of weapons of mass destruction
• Act on requests for assistance from foreign states and request assistance from them, including tracing, freezing, and forfeiting assets
• Impose administrative sanctions — including warnings, reprimands, and monetary penalties of up to PHP 500,000 per violation — on covered persons and their directors, officers, and employees

For foreign investors, the AMLC's international coordination powers are particularly significant. As a member of the Egmont Group — a global network of financial intelligence units — the AMLC can share financial intelligence with counterpart agencies in other countries. An AML problem in the Philippines can therefore surface in the company's home jurisdiction, and a home-country investigation into funds routed through Philippine accounts can lead to action here.

III. Covered Persons: Who Must Comply

One of the most important questions for foreign investors is whether their Philippine operations qualify as "covered persons" under Section 3(a) of the AMLA — meaning they are directly subject to the law's reporting and compliance obligations. The following categories are relevant to foreign companies:

Banks and Other Financial Institutions

The original and most extensive category of covered persons includes:

• Banks, non-banks, quasi-banks, trust entities, foreign exchange dealers, pawnshops, money changers, remittance and transfer companies, and all other persons supervised or regulated by the BSP
• Insurance companies, pre-need companies, and all other persons supervised or regulated by the Insurance Commission
• Securities dealers, brokers, salesmen, investment houses, mutual funds, close-end investment companies, common trust funds, and other entities dealing in currency, commodities, financial derivatives, or similar instruments supervised or regulated by the SEC

Foreign bank branches operating in the Philippines are fully subject to AMLA obligations as covered persons. Philippine subsidiaries of foreign companies that engage in any financial activity requiring BSP, IC, or SEC registration will fall into this category.

Designated Non-Financial Businesses and Professions

The AMLA, as amended, also covers several non-financial businesses that foreign investors commonly operate or use:

• Dealers in precious metals and precious stones — for transactions above PHP 1,000,000 (RA 10365, 2013)
• Company service providers — businesses that act as formation agents, provide nominee directors, corporate secretaries, or nominee shareholders, or supply a registered office or business address for companies (RA 10365, 2013)
• Persons who manage client money, securities, or accounts, or who create, operate, or manage juridical persons — lawyers and accountants acting as independent legal professionals are excluded as to privileged client information (RA 10365, 2013)
• Casinos, including internet-based and ship-based casinos (RA 10927, 2017)
• Real estate developers and brokers (RA 11521, 2021)
• Offshore gaming operators and their service providers supervised, accredited, or regulated by PAGCOR or any government agency (RA 11521, 2021)

The company service provider category matters to foreign investors on both sides of the relationship. The incorporation agents, nominee directors, and corporate secretarial firms that foreign companies often engage to set up a Philippine entity are themselves covered persons — which is why they will ask for identification and beneficial ownership documents before taking you on.

A foreign company investing in Philippine real estate development may also find itself classified as a covered person under RA 11521. The statute defines a real estate developer as a person "engaged in the business of developing real estate development project for the account of the developer and offering them for sale or lease." Pure equity investors in real estate projects who are not engaged in development may not be covered persons, but any entity that actively develops and markets real property should assume it is. For the ownership rules that apply to foreigners in the first place, see our guide to real estate ownership by foreigners in the Philippines.

Virtual Asset Service Providers (VASPs)

Cryptocurrency exchanges, digital wallet providers, and platforms facilitating the transfer, exchange, or custody of virtual assets fall within the AMLA as BSP-supervised entities. BSP Circular No. 1108 (Series of 2021) established the licensing framework for VASPs, including capitalization requirements, consumer protection standards, and AML/CFT obligations such as the FATF "travel rule," and was later updated by BSP Circular No. 1206 (Series of 2024). This is particularly significant for foreign fintech companies establishing operations in the Philippines or serving Philippine customers — see our guide to BSP licensing for foreign fintech companies.

Directors, Officers, and Employees

The AMLA's criminal liability extends beyond the corporate entity. A covered person that knows a covered or suspicious transaction must be reported and fails to report it commits money laundering under the last paragraph of Section 4, and directors, officers, and personnel of a covered person who knowingly participate in money laundering face imprisonment of four (4) to seven (7) years. Officers and employees who disclose that a report has been or will be filed are criminally liable as well. For foreign nationals serving as directors or officers of Philippine companies that are covered persons, this creates a personal compliance exposure.

IV. Covered Transactions and Suspicious Transaction Reporting

The AMLA establishes two distinct categories of reportable transactions — each with its own threshold, reporting deadline, and consequences for failure to report.

Covered Transactions: The PHP 500,000 Threshold

Under Section 3(b) of the AMLA, as amended, a covered transaction is a transaction in cash or other equivalent monetary instrument involving a total amount in excess of PHP 500,000 within one (1) banking day. Higher thresholds apply to two sectors:

• Casinos: a single casino cash transaction exceeding PHP 5,000,000 or its equivalent in any other currency
• Real estate developers and brokers: a single cash transaction exceeding PHP 7,500,000 or its equivalent in any other currency

Covered persons must report covered transactions (CTRs) to the AMLC within five (5) working days from the occurrence of the transaction. The statute allows the AMLC to prescribe a different period of up to fifteen (15) working days. The report must include the identity of the customer, the nature of the transaction, the amount involved, and the date and account numbers used.

Separately, the Land Registration Authority and its Registries of Deeds report real estate transactions above PHP 500,000 to the AMLC — so property acquisitions by a foreign company's Philippine entity are visible to the AMLC even where no covered person files a CTR.

Splitting a large cash movement into smaller transactions does not avoid scrutiny. A transaction that appears structured to avoid the reporting requirements is, by statutory definition, a suspicious transaction that must be reported regardless of amount.

Suspicious Transaction Reports (STRs): No Minimum Threshold

Unlike covered transactions, suspicious transactions have no minimum peso threshold. Under Section 3(b-1) of the AMLA, as amended, a transaction with a covered person is suspicious when any of the following circumstances exists:

• There is no underlying legal or trade obligation, purpose, or economic justification
• The client is not properly identified
• The amount involved is not commensurate with the business or financial capacity of the client
• Taking into account all known circumstances, the transaction appears structured to avoid the reporting requirements
• The transaction deviates from the client's profile or past transactions with the covered person
• The transaction is in any way related to an unlawful activity or offense under the AMLA that is about to be, is being, or has been committed
• The transaction is similar or analogous to any of the foregoing

Covered persons must file Suspicious Transaction Reports (STRs) with the AMLC whenever they identify a transaction meeting these criteria — regardless of the amount. Under the AMLC's current reporting rules, an STR must be filed by the next working day after the suspicion is established. The obligation arises from the covered person's own monitoring and due diligence, not from a triggering threshold: a small transfer that is demonstrably linked to an unlawful activity can require an STR.

Tipping Off and Confidentiality

Filing an STR or CTR creates a prohibition against tipping off. Under Section 9(c) of the AMLA, covered persons and their officers and employees may not communicate, directly or indirectly, to any person or the media the fact that a covered or suspicious transaction has been or is about to be reported, the contents of the report, or any related information. Breach of this confidentiality is punishable under Section 14(d) by imprisonment of three (3) to eight (8) years and a fine of not less than PHP 500,000 but not more than PHP 1,000,000.

Casino and Offshore Gaming Transactions

Casino operators must identify customers engaged in covered transactions above the PHP 5,000,000 threshold and keep records of those transactions. Offshore gaming operators and their service providers were separately made covered persons by RA 11521 — although, as discussed in Part IX, offshore gaming operations have since been banned. Foreign investors with interests in Philippine casino operations, or who conduct significant financial transactions through Philippine casinos, should understand this separate regime.

V. Customer Due Diligence (CDD) Requirements

Beyond transaction reporting, the AMLA imposes ongoing customer due diligence (CDD) obligations on covered persons. These requirements are set out in Section 9 of the AMLA, the AMLC's 2018 Implementing Rules and Regulations, and the AML rules issued by each supervising authority — the BSP, the SEC, and the Insurance Commission.

Know Your Customer (KYC) Procedures

Covered persons must establish and record the true identity of their clients based on official documents, and anonymous or fictitious-name accounts are prohibited. For individual customers, this includes name, date of birth, nationality, address, and government-issued identification number. For corporate customers, it includes verifying the entity's legal existence and organizational structure, the authority and identity of those acting on its behalf, and its beneficial owners. KYC also requires understanding the purpose and intended nature of the business relationship — the client's business and its expected pattern of transactions — and ongoing monitoring to confirm that transactions remain consistent with that profile.

Beneficial Ownership Identification

Covered persons must look through corporate structures to identify the natural persons who ultimately own or control a client — generally any individual who owns or controls 25% or more of the entity, or who otherwise exercises ultimate effective control over it. Foreign companies operating through Philippine subsidiaries should expect banks and other covered persons to ask for this information at onboarding and whenever the ownership structure changes.

Philippine corporations also have their own disclosure duty. Under SEC Memorandum Circular No. 15 (Series of 2025), the Beneficial Ownership Disclosure Rules of 2026, which replaced the 2019 rules, corporations — domestic and foreign — must disclose their beneficial owners: natural persons owning, directly or through a chain of ownership, at least 20% of the voting rights, voting shares, or capital, or exercising control through other means. Until the SEC declares its Beneficial Ownership Registry operational, this disclosure is made in the General Information Sheet filed with the SEC. For the SEC's newer beneficial ownership platform and the filings expected of foreign corporations, see SEC HARBOR and beneficial ownership for foreign companies.

Risk-Based Approach and Enhanced Due Diligence

Covered persons are required to assess the money laundering and terrorism financing risk associated with each customer relationship and apply enhanced due diligence (EDD) for higher-risk customers. Higher-risk categories include:

• Politically Exposed Persons (PEPs) — individuals holding or having held prominent public positions, and their immediate family members and close associates
• Non-face-to-face customers — those who establish relationships without physical interaction
• Correspondent banking relationships
• Complex or unusually large transactions with no clear economic rationale
• Customers from high-risk jurisdictions — countries identified by the FATF or AMLC as having inadequate AML controls

For foreign companies, the PEP question often arises when a foreign national who is a former government official — or a relative of one — holds a directorship or ownership stake in a Philippine subsidiary. Such individuals trigger enhanced due diligence requirements, including senior management approval for the business relationship and ongoing monitoring of transactions. The AMLA also prohibits using PEP status, religion, race, or ethnic origin as the only basis for denying a customer access to services.

Correspondent Banking and Wire Transfers

Foreign banks maintaining correspondent relationships with Philippine banks should expect enhanced due diligence on the respondent institution and ongoing monitoring of the relationship; Philippine banks may not maintain correspondent relationships with shell banks. For cross-border wire transfers, Philippine rules follow FATF Recommendation 16: transfers must carry originator information (such as name, account number, and address, national identity number, or date and place of birth) and beneficiary information, for both inbound and outbound transfers.

Internal AML Compliance Programs

Covered persons must adopt a written money laundering and terrorism financing prevention program. Under the AMLC's rules, that program should include:

• A compliance officer designated at the management level
• Written internal policies, procedures, and controls for AML/CFT compliance
• Ongoing employee training on AML/CFT obligations and red flags
• An independent audit function that tests the adequacy and effectiveness of the program
• A risk assessment methodology to identify, assess, and mitigate ML/TF risks

Where a foreign company's Philippine branch or subsidiary is itself a covered person, the Philippine entity must meet these requirements in its own right. It may draw on group-wide resources and systems, but the program must satisfy Philippine rules.

Record Keeping

Under Section 9(b) of the AMLA, covered persons must keep records of all transactions for at least five (5) years from the date of the transaction. For closed accounts, customer identification records, account files, and business correspondence must be kept for at least five (5) years from the date of closure. The records must be sufficient to permit reconstruction of individual transactions, enabling the AMLC or law enforcement to trace the flow of funds.

Failure to keep records as required carries imprisonment of six (6) months to one (1) year, a fine of not less than PHP 100,000 but not more than PHP 500,000, or both.

VI. The Philippines' FATF Journey: From Grey List to Clean Status

For foreign investors, the Philippines' experience with the FATF grey list is directly relevant to the current compliance environment. Understanding what drove the grey listing — and what compliance improvements allowed delisting — shows the government's enforcement priorities and the areas where regulatory scrutiny is highest.

The Grey List Period

The Philippines was placed on the FATF's "Jurisdictions Under Increased Monitoring" list (commonly known as the grey list) in June 2021, after an evaluation identified strategic deficiencies in the country's anti-money laundering and counter-terrorism financing (AML/CFT) framework. Key concerns included:

• Inadequate coverage of non-financial businesses and professions
• Insufficient beneficial ownership transparency
• Inadequate enforcement of sanctions for AML violations
• Weaknesses in the casino sector's AML controls

Delisting and Current Status

The Philippines was removed from the FATF grey list in February 2025, after addressing the items in its FATF action plan — including the amendments made by RA 11521 (covering real estate developers and offshore gaming operators), stronger AML controls over casinos and the shutdown of offshore gaming operations, more money laundering investigations and prosecutions, stronger targeted financial sanctions, and improvements in beneficial ownership transparency.

For foreign investors, the delisting cuts two ways. Foreign banks that applied enhanced due diligence to Philippine counterparties during the grey list period may ease those measures, which can make cross-border payments and correspondent relationships smoother. But the exit was contingent on demonstrated enforcement, so the BSP, SEC, and AMLC remain under pressure to sustain it. The Philippines is also a member of the Asia/Pacific Group on Money Laundering (APG), the FATF-style regional body that continues to monitor compliance through its mutual evaluation process. Companies should not expect any relaxation of domestic compliance standards.

VII. Penalties for Non-Compliance

The AMLA imposes a tiered system of penalties depending on the nature of the violation. Liability extends to both the corporate entity and to individual directors, officers, and employees.

The Money Laundering Offense

Under Section 4 of the AMLA, as amended, money laundering is committed by any person who, knowing that any monetary instrument or property represents, involves, or relates to the proceeds of any unlawful activity:

• Transacts that monetary instrument or property
• Converts, transfers, disposes of, moves, acquires, possesses, or uses it
• Conceals or disguises its true nature, source, location, disposition, movement, or ownership
• Attempts or conspires to commit any of the above
• Aids, abets, assists in, or counsels the commission of any of the above
• Performs or fails to perform any act that facilitates any of the above

Money laundering is also committed by any covered person who, knowing that a covered or suspicious transaction must be reported to the AMLC, fails to report it. Because Section 4 applies to "any person," a foreign company that is not a covered person can still be charged if it knowingly deals in proceeds of unlawful activity.

Predicate Offenses: The "Unlawful Activities"

Section 3(i) of the AMLA lists thirty-six (36) categories of unlawful activity whose proceeds can be laundered — from kidnapping for ransom, drug trafficking, and graft and corruption to malversation of public funds, fraud under the Securities Regulation Code, and intellectual property violations. Two categories deserve particular attention from foreign companies:

• Tax crimes (Section 3(i)(35)) — added by RA 11521, covering tax evasion under Section 254 of the National Internal Revenue Code where the deficiency basic tax in the final assessment exceeds PHP 25 million per taxable year, for each tax type, with a finding of probable cause and of fraud, willful misrepresentation, or malicious intent. For foreign companies with substantial Philippine tax obligations, serious tax non-compliance can now lead to money laundering investigations and freeze orders.
• Foreign crimes (Section 3(i)(36)) — felonies and offenses of a similar nature punishable under the penal laws of other countries. Proceeds of criminal activity committed abroad can therefore support Philippine money laundering charges once they enter the Philippine financial system.

Criminal Penalties Under Section 14

• Money laundering under Section 4(a) to (d) (transacting, converting, concealing, attempt or conspiracy): imprisonment of seven (7) to fourteen (14) years and a fine of not less than PHP 3,000,000 but not more than twice the value of the monetary instrument or property involved
• Money laundering under Section 4(e) and (f) (aiding and abetting, or facilitating): imprisonment of four (4) to seven (7) years and a fine of not less than PHP 1,500,000 but not more than PHP 3,000,000
• Directors, officers, or personnel of a covered person who knowingly participate in money laundering: imprisonment of four (4) to seven (7) years and a fine of up to 200% of the value laundered
• Failure by a covered person to report a covered or suspicious transaction: imprisonment of six (6) months to four (4) years, a fine of not less than PHP 100,000 but not more than PHP 500,000, or both
• Failure to keep records: imprisonment of six (6) months to one (1) year, a fine of not less than PHP 100,000 but not more than PHP 500,000, or both
• Malicious reporting (filing completely unwarranted or false information): imprisonment of six (6) months to four (4) years and a fine of not less than PHP 100,000 but not more than PHP 500,000; an offender who is a foreign national is deported after serving the sentence
• Breach of confidentiality (tipping off): imprisonment of three (3) to eight (8) years and a fine of not less than PHP 500,000 but not more than PHP 1,000,000

Freeze Orders and Civil Forfeiture

Freeze orders issued by the Court of Appeals on the AMLC's ex parte petition take effect immediately for twenty (20) days and may be extended after a summary hearing, up to six (6) months in total. The freeze is limited to the amount the court finds to be proceeds of a predicate offense, and it is lifted automatically if no case is filed within the period the court sets. Separately, the AMLC may pursue civil forfeiture of monetary instruments or property related to unlawful activity or money laundering, and forfeiture can proceed independently of any criminal prosecution. A freeze can immobilize a business's accounts for months.

Administrative Sanctions

Beyond criminal penalties, covered persons and their directors, officers, and employees may face administrative sanctions from the AMLC — warnings, reprimands, and monetary penalties of up to PHP 500,000 per violation — as well as sanctions from their supervising authority (the BSP, SEC, or IC), including fines, suspension of operations, and revocation of license or registration. For a foreign company's Philippine subsidiary or branch, administrative sanctions from the BSP or SEC can effectively shut down the entity's ability to operate.

VIII. Practical Compliance Steps for Foreign Companies

Given the breadth of AMLA obligations and the severity of penalties, foreign companies with Philippine operations should treat AMLA compliance as a foundational governance matter, not a peripheral legal formality. The following steps represent a baseline for any foreign company operating a covered person in the Philippines:

1. Determine Whether Your Philippine Operations Qualify as a Covered Person

This is the threshold question for every other obligation. Not every foreign company in the Philippines is a covered person. A pure holding company with no financial operations, no real estate development activities, and no engagement in gaming may have limited direct AMLA obligations. However, once that company opens a bank account and transacts above the PHP 500,000 threshold, it becomes part of the financial system's reporting chain — even if not itself a covered person. Philippine counsel should be consulted to make this determination.

2. Appoint a Compliance Officer and Adopt a Written AML/CFT Program

If your Philippine entity is a covered person, designate a compliance officer at the management level and adopt a written program covering KYC/CDD policies, transaction monitoring, reporting procedures, record keeping, and training. The law requires documented customer due diligence not just at account opening but on an ongoing basis — periodic reviews of customer files and records that can be produced to the AMLC on request. Covered persons must also register with the AMLC before they can file reports.

3. Train Your Philippine Team on AMLA Obligations

Foreign companies frequently underestimate the extent to which Philippine-based employees — particularly those handling finance, accounting, and compliance — are personally exposed under the AMLA. For covered persons, training for relevant staff on covered transaction identification, suspicious transaction recognition, STR filing procedures, and the tipping-off prohibition is not optional, and compliance staff need more specialized training.

4. Implement Transaction Monitoring and Meet Reporting Deadlines

Covered persons are expected to monitor transactions on an ongoing basis — not simply file reports after the fact. The AMLC expects systems (or at minimum, procedures) that flag transactions above the applicable threshold and identify suspicious patterns promptly, so that CTRs are filed within five (5) working days and STRs by the next working day after suspicion is established. For smaller foreign companies without dedicated compliance staff, engaging an external compliance consultant or legal counsel to conduct periodic transaction reviews is a practical approach.

5. Review Beneficial Ownership Structures

Following the FATF's focus on beneficial ownership transparency as a condition for grey list delisting, regulators are scrutinizing whether companies maintain accurate and current beneficial ownership information. Foreign companies with complex multi-tier ownership structures should ensure their Philippine subsidiaries maintain an accurate organizational chart showing the ultimate beneficial owners — individuals owning at least 20% of the entity's voting rights, voting shares, or capital (the SEC's threshold), or otherwise exercising effective control — and that their SEC beneficial ownership disclosures stay current.

6. Assess Risk and Audit the Program Regularly

Conduct a periodic risk assessment of your money laundering and terrorism financing exposure, update the program when your business, products, or customer base changes, and have an independent function test whether the program works in practice.

7. Keep Records for at Least Five Years

Retain transaction records and KYC files for at least five (5) years from the transaction date, or from account closure for closed accounts, in a form that allows individual transactions to be reconstructed.

8. Coordinate with BSP or SEC Compliance Teams

Foreign companies operating through BSP-supervised entities (banks, fintechs, money service businesses) or SEC-supervised entities (securities dealers, investment houses, registered companies) should maintain active engagement with their regulatory compliance teams. BSP and SEC examiners audit AMLA compliance as part of their supervisory examinations, and entities with poor AMLA compliance records face heightened scrutiny in later examinations.

9. Maintain Strong Controls Even If You Are Not a Covered Person

Any person — covered or not — can be charged with money laundering under Section 4 for knowingly dealing in proceeds of unlawful activity, and serious tax non-compliance is itself a predicate offense. Sound internal controls over payments, counterparties, and tax compliance protect companies outside the covered-person regime as well.

IX. Looking Ahead: Emerging AML Challenges for Foreign Investors

As of 2026, several developments in the Philippine AML landscape warrant continued attention from foreign investors:

Virtual asset regulation is evolving quickly. The BSP licenses and supervises VASPs under Circular No. 1108 (Series of 2021), as updated by Circular No. 1206 (Series of 2024). The SEC has separately issued rules for crypto-asset service providers (SEC Memorandum Circular Nos. 4 and 5, Series of 2025), which took effect on July 5, 2025. Foreign companies considering blockchain or crypto-related operations in the Philippines should determine early which regulator — or both — will supervise them. Regulatory sandbox arrangements may be available for some innovative fintech services, but AML obligations apply in full.

Beneficial ownership transparency remains a FATF priority. The Philippines' commitment to beneficial ownership transparency — identified as a key condition for grey list exit — is now enforced through both SEC and BSP channels. Foreign companies with Philippine operations should anticipate increasing regulatory requests for beneficial ownership information and should maintain accurate records of ultimate beneficial owners at all times.

Offshore gaming is now prohibited. The Philippine Offshore Gaming Operator (POGO) sector — and its service providers — was the subject of intense AML scrutiny following the 2023–2024 raids, including in Bamban, Tarlac, that uncovered alleged human trafficking, fraud, and money laundering operations. Executive Order No. 74 (November 2024) ordered all POGO and internet gaming licensees to cease operations by December 31, 2024, and the Anti-POGO Act of 2025 (Republic Act No. 12312), signed on October 23, 2025, made the ban statutory. Foreign investors with any residual exposure to the sector — as landlords, service providers, or counterparties — should expect close regulatory scrutiny and take legal advice on their position.

AML compliance in the Philippines is not a one-time legal exercise — it is an ongoing operational obligation that requires active management, regular review, and coordination with legal counsel. Foreign investors who treat it that way are better placed to avoid AML-related disruption. Those who ignore it risk criminal prosecution, frozen accounts, civil forfeiture, and reputational damage that can outlast any business relationship in the Philippines.