The Anti-Money Laundering Act (AMLA) in the Philippines: Everything You Need to Know

The Anti-Money Laundering Act (AMLA) is the foundation of the Philippines' efforts to prevent criminals from disguising illicit funds as legitimate transactions.

For banks, fintechs and other covered institutions, AMLA establishes obligations for customer due diligence, transaction monitoring, reporting and record-keeping.

With the Philippines' removal from the Financial Action Task Force (FATF) grey list in February 2025 and regulatory developments continuing through 2026, understanding these requirements remains essential.

This guide explains AMLA's key provisions, amendments, reporting thresholds and recent compliance developments.

What Is the Anti-Money Laundering Act (AMLA)?

The Anti-Money Laundering Act of 2001, officially Republic Act No. 9160, is the Philippines' principal legislation against money laundering.

It aims to protect the financial system, prevent criminals from concealing unlawful proceeds and support financial crime investigations.

The Act established the Anti-Money Laundering Council (AMLC), the country's financial intelligence unit responsible for receiving financial intelligence, investigating suspected money laundering and supporting enforcement.

AMLA has been amended several times to strengthen the country's financial crime prevention framework and align it with international standards.

What Are the Key Provisions of AMLA?

Money Laundering Offences

AMLA criminalises specified activities involving proceeds connected to unlawful acts, including knowingly concealing, transferring or facilitating transactions involving illicit property.

Separate offences and penalties apply to certain reporting failures and other violations of the law.

Covered Persons and Institutions

AMLA applies to banks, certain non-bank financial institutions, insurance companies, securities firms, money service businesses and remittance providers.

Its coverage also extends to designated non-financial businesses and professions, including casinos, real estate developers and brokers, precious-metal and jewellery dealers, and certain professional service providers.

Requirements vary according to business activities and applicable regulations.

Covered Transaction Reporting Thresholds

AMLA establishes different reporting thresholds across sectors.

Generally, transactions involving cash or equivalent monetary instruments exceeding PHP 500,000 within one banking day are covered transactions. For casinos, the threshold applies to qualifying cash transactions exceeding PHP 5 million. Real estate developers and brokers are subject to a threshold exceeding PHP 7.5 million for qualifying single cash transactions, while jewellery and precious-metal or stone dealers have a threshold exceeding PHP 1 million for applicable cash transactions.

Suspicious transactions are reportable regardless of amount.

Warning signs include transactions without apparent lawful purpose, activity inconsistent with a customer's financial capacity, unusual account behaviour and attempts to avoid reporting requirements.

Institutions must apply the relevant sector-specific rules.

What Is the Role of the Anti-Money Laundering Council?

The AMLC receives and analyses financial intelligence, investigates suspicious activities and coordinates with relevant authorities.

It also supports enforcement proceedings and monitors compliance with applicable AML requirements.

For ordinary AMLA freeze orders, the AMLC generally applies to the Court of Appeals. Separate procedures apply to certain targeted financial sanctions involving terrorism and proliferation financing.

The law also establishes mechanisms for bank inquiries, asset preservation and forfeiture, subject to applicable legal conditions.

Major Amendments to the Anti-Money Laundering Act

Several amendments have strengthened AMLA:

• RA 9194 (2003): Strengthened compliance, reporting and enforcement provisions.
• RA 10167 (2012): Expanded investigative powers and access to relevant financial information.
• RA 10365 (2013): Broadened covered sectors, unlawful activities and compliance requirements.
• RA 10927 (2017): Included casinos within the AMLA framework.
• RA 11521 (2021): Expanded coverage and strengthened investigation, asset-freezing and proliferation-financing provisions.

Institutions must consider these amendments alongside applicable implementing rules and AMLC issuances.

AMLA Compliance Requirements for Financial Institutions

Covered institutions must establish controls proportionate to their financial crime exposure.

Customer Due Diligence: Identify and verify customers, assess relevant risks, establish beneficial ownership where required and apply enhanced due diligence in higher-risk circumstances.

Transaction Monitoring and Reporting: Identify reportable covered transactions and investigate suspicious activity. Submit Covered Transaction Reports (CTRs) and Suspicious Transaction Reports (STRs) according to applicable AMLC requirements.

Record-Keeping: Maintain transaction records for at least five years, with additional retention requirements in certain circumstances.

Internal Controls: Establish appropriate governance, risk assessments, investigation procedures, employee training and safeguards against unauthorised disclosure of suspicious transaction reports.

GoTRACS: AMLC Reporting Requirements in 2026

The AMLC's Guidelines on Transaction Reporting and Compliance Submissions (GoTRACS) establish requirements for CTRs, STRs and related compliance submissions.

They address reporting formats, documentation, low-risk transactions and the treatment of non-working and non-reporting days.

Implementation is phased. Certain provisions began applying in 2025, while others have later implementation schedules.

In September 2026, the AMLC applied GoTRACS when declaring 25 September a non-reporting day, excluding it from the prescribed reporting period.

Financial institutions should verify their applicable reporting deadlines, submission formats and implementation requirements against current AMLC guidance.

Philippines' FATF Grey-List Exit

On 21 February 2025, FATF removed the Philippines from its list of jurisdictions under increased monitoring, commonly called the grey list.

The decision recognised progress in risk-based supervision, financial intelligence, beneficial ownership transparency, investigations and targeted financial sanctions.

However, the country's removal does not eliminate financial crime risks or reduce existing AMLA obligations.

Institutions must continue maintaining effective monitoring, reporting and investigation controls.

The Philippines' Third National Risk Assessment

The Philippines' Third National Risk Assessment evaluates money laundering, terrorism financing and proliferation financing risks.

Its money laundering and terrorism financing assessment covers 2021–2024, while the findings inform the country's National AML/CTF/CPF Strategy for 2026–2030.

The assessment highlights evolving financial crime vulnerabilities and the importance of risk-based controls across financial sectors.

Institutions should consider relevant findings when reviewing customer risk profiles, monitoring scenarios and investigation priorities.

Best Practices for AMLA Compliance

Financial institutions face challenges including complex laundering patterns, excessive alerts, legacy systems and evolving regulatory requirements.

Effective compliance requires continuously improving controls rather than relying solely on static detection rules.

Key practices include:

• Applying risk-based customer monitoring and enhanced due diligence.
• Reviewing transaction monitoring scenarios and thresholds.
• Using behavioural and network analytics to identify suspicious activity.
• Maintaining reliable reporting and investigation workflows.
• Training teams on emerging money laundering typologies.
• Incorporating relevant intelligence from the financial crime community.

An October 2026 AMLC advisory also reinforced the importance of verifying the registration status of designated non-financial businesses and professions (DNFBPs) when conducting relevant customer due diligence.

These measures help institutions strengthen detection effectiveness while maintaining regulatory accountability.

How Tookitaki Turns Intelligence Into AML Controls

Financial crime is a network problem. Criminals operate across institutions and markets, while individual financial institutions often see only suspicious activity within their own environments.

Tookitaki is the intelligence ecosystem, helping institutions prevent, detect, adapt and stay ahead of emerging financial crime threats.

Its Anti-Financial Crime (AFC) Ecosystem brings together collective typology intelligence, risk patterns and emerging threat insights from the financial crime community.

FinCense is the platform that turns intelligence into control.

By combining AI with intelligence from the AFC Ecosystem, FinCense helps institutions test detection scenarios, obtain threshold recommendations, simulate potential impact and adapt operational controls.

For Philippine banks and fintechs, this supports a more adaptive approach to financial crime monitoring and investigation.

Discover how FinCense helps institutions translate collective intelligence into deployable financial crime controls. Talk to our team.

Conclusion

The Anti-Money Laundering Act remains central to protecting the Philippine financial system.

Understanding its provisions, amendments, reporting requirements and evolving regulatory guidance is essential for covered institutions.

As criminal methods change, effective AMLA compliance depends on risk-based monitoring, relevant intelligence and adaptable financial crime controls.