Filipino Bank adheres to the recommendations of the Federal Financial Institutions Examination Council (FFIEC), Federal Deposit Insurance Corporation Examination Policies (FDIC), Financial Crimes Enforcement Network (FinCEN), Office of Foreign Assets Control (OFAC), Financial Action Task Force on Money Laundering (FATF), International Narcotics Control Strategy Report (INCSR), Transparency International Corruption Perceptions Index and/or other applicable agencies. It is also subject to the regulations administered by the Hong Kong Monetary Authority, United Nations (Anti-Terrorism Measures) Ordinance and other applicable governmental regulations and has policies and procedures designed to comply with the prohibitions and restrictions mandated by laws and regulations applicable in the jurisdictions in which Filipino Bank operates.
Filipino Bank adheres to sanctions compliance programs issued by public bodies such as the Office of Foreign Assets Control, the United Nations or any other local sanctions laws. Filipino Bank carries out real-time monitoring of sanctions lists in order to identify customers and transactions that may be required to be blocked or rejected.
Filipino Bank’s AML Program is designed to ensure that all employees and business units of Filipino Bank are well informed with respect to their customers and the nature of the transactions processed through their accounts. Filipino Bank has a designated AML Compliance Officer and its Risk and Compliance Board committee ultimately has responsibility for overseeing Filipino Bank’s AML Program. All of the policies, procedures and practices relating to anti-money laundering, terrorist financing and sanctions compliance are approved by Filipino Bank’s Board of Directors. There are also audit and compliance reviews to test the adequacy of Filipino Bank’s anti-money laundering policies, procedures and programs. Risk assessments, such as “know your customer” program involving due diligence to confirm the identities of persons seeking to open accounts and to deny accounts to those persons unable to demonstrate their identities, are conducted on Filipino Bank’s customers once every 12 months. AML systems have also been developed to monitor transactions in order to identify and report unusual or potentially suspicious transactions to Financial Crimes Enforcement Network (FinCEN) and the Joint Financial Intelligence Unit (JFIU) to facilitate the filing of currency transaction reports for deposits and withdrawals of large amounts of cash and suspicious activities reports for activity that might signify money laundering, tax evasion, or other criminal activities. Filipino Bank’s AML Program also includes additional precautions for accounts sought and managed for non-U.S. persons, and verification and certification of money laundering risk with respect to private banking and foreign correspondent banking relationships.
Filipino Bank adheres to the following principles in its AML efforts: compliance, confidentiality, lawfulness, prudence and cross region cooperation. Written policies and procedures cover the areas of compliance management, customer identification (including politically exposed persons identification), beneficial ownership, money laundering risk assessment, classification and management (classified as customers, correspondent banks, innovative products and services, and legal persons and institutions), large-volume and suspicious transaction monitoring and reporting, anti-terrorist financing and terrorist assets freezing, and prohibition of anonymous or numbered accounts, or payable-through accounts. There are also record keeping and reporting requirements, including those for cash transactions.
Different business lines are in charge of their own AML management. Responsibilities include constituting AML regulations, making annual AML working plans, collecting and reporting non-on-site AML inspection data, examining the execution of the AML rules of the business line, optimizing business systems in line with AML regulation and related requirements, assisting the Financial Crimes Intelligence Units to collect and report data of suspicious and large-volume transactions, and performing AML self-inspection of the business line etc.
When establishing business relationships with overseas financial institutions, Filipino Bank will collect information regarding their business types, goodwill, internal control and supervision. Assessment will be done on their AML regulation, and the effectiveness of their AML measures. Written documents, such as AML questionnaires are required to be completed to specify the responsible party for identifying customers and retaining ID documents and transaction records. Approval from senior management is required for Filipino Bank to build business relations with overseas banks.
Last but not least, anti-money laundering, anti-terrorist financing, sanctions compliance and other related trainings are provided to Filipino Bank’s employees, including trainings on the identification of clients and suspicious activities.
Compliance with the legal and regulatory requirements that govern the management of client relationships is critical for Filipino Bank to protect itself and the international financial system from illicit finance. Moreover, compliance with Filipino Bank’s AML Program and internal procedures allows Filipino Bank to maintain good standing in the jurisdictions where Filipino Bank transacts business.
Filipino Bank has completed the Wolfsberg Correspondent Banking Due Diligence Questionnaire, for use and review by any financial institution that requires more detailed information about Filipino Bank's AML/CTF and OFAC/Sanctions compliance programs. Please click below to view/print the questionnaire.
Filipino Bank has prepared a global certification for use by any financial institution that requires a Patriot Act Certification (PAC) for a Filipino Bank foreign entity. Please click the below link to view/print our Patriot Act Certification.
If the Filipino Bank business that maintains a correspondent account with your institution is not listed in our PAC or if you have questions regarding any of the above AML information, please contact [email protected].
