2. Covered Transactions; Suspicious Transactions

4. Suspicious Transactions

Suspicious Transactions are transactions with covered persons, regardless of the amount involved, where any of the following circumstances exist:

• 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, it may be perceived that the client’s transaction is structured to avoid being the subject of reporting requirements under this Act
• Any circumstance relating to the transaction which is observed to deviate from the profile of the client and/or the client’s past transactions with the covered person;
• The transaction is in any way related to an unlawful activity or offense under this Act that is about to be, is being or has been committed [Sec. 3(b-1)]³.
• Any transaction that is similar, analogous, or identical to any of the foregoing.

Covered Transactions

General Rule: 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 banking day [Sec. 3(b)¹].

Exceptions: For casinos or “covered persons under Section 3(a)(8)²,” the threshold applies to a single casino cash transaction involving an amount in excess of Php 5,000,000 or its equivalent in any other currency. For dealers in precious metals or precious stones, it applies to a transaction exceeding Php 1,000,000. For real estate developers and brokers, it applies to a single cash transaction exceeding Php 7,500,000 or its equivalent in any other currency [Sec. 3(b), RA 9160, as amended].