Duration 2 days – 14 hrs
Overview
This fundamentals program equips participants with the core concepts, legal/regulatory foundations, and practical workflows needed to perform Customer Due Diligence (CDD/KYC), apply a risk-based approach, recognize red flags, and execute escalation and reporting obligations expected of covered persons/institutions in the Philippines.
It anchors on the Anti-Money Laundering Act (RA 9160), as amended, and key strengthening updates (e.g., RA 11521), plus AMLC reporting guidance (e.g., GoTRACS) that covered persons use for transaction reporting and compliance submissions.
Objectives
- Explain AML/KYC fundamentals and why AML controls matter to safety, integrity, and regulatory compliance.
- Apply a risk-based approach to customer onboarding and ongoing monitoring (risk rating + EDD triggers).
- Perform practical CDD/KYC: identify/verify customers, understand purpose/nature of relationship, and document sufficiently.
- Identify and document beneficial ownership and control indicators in a defensible way.
- Recognize suspicious indicators and execute proper escalation, including knowing when STR/CTR obligations may apply (workflow-level).
- Strengthen compliance behaviors: record-keeping discipline, audit trail, and control hygiene (screening, monitoring, periodic review).
Audience
- Frontline staff (sales/relationship managers, branch/operations)
- KYC/CDD/EDD analysts and onboarding teams
- AML/compliance support teams
- Back-office operations, customer support, payments teams
- Risk management / internal audit (as participants or observers)
Pre- requisites
- None required (ideal for beginners)
- Helpful: familiarity with your organization’s onboarding forms, internal escalation flow, and customer types
Course Content
Day 1 — Foundations + CDD/KYC Core
Module 1: AML/KYC fundamentals and key concepts
- What money laundering is (placement–layering–integration)
- AML/KYC goals, “covered persons” concept, core obligations overview
Module 2: Philippine AML regulatory landscape
- AMLA (RA 9160) + key amendments and what they strengthened (incl. RA 11521 overview)
- Roles of AMLC and supervisory expectations (high-level)
Module 3: Risk-Based Approach (RBA) in practice
- Risk factors: customer, product/service, channel, geography
- Risk rating basics + calibration and common pitfalls
- EDD vs standard CDD vs simplified (when allowed by policy)
Module 4: Customer Due Diligence (CDD/KYC) workflow
- Customer identification and verification (individual vs juridical entity)
- Purpose and intended nature of relationship; source of funds/source of wealth (practical distinction)
- Documentation and “defensible files” (audit trail mindset)
Workshop A (45 min): KYC file quality drill
- Participants review 2 sample onboarding profiles and spot gaps
Day 2 — Beneficial Ownership, Monitoring, Escalation & Reporting
Module 5: Beneficial Ownership (BO) and control
- BO concepts (ownership + control lens) and documentation habits
- Handling complex structures (layers, nominees, corporate groups)
Module 6: Screening and monitoring fundamentals
- Sanctions/TFS basics and screening expectations (overview-level)
- Ongoing monitoring and event-driven refresh (change triggers)
Module 7: Red flags and suspicious activity escalation
- Common typologies and indicators (behavioral + transactional + documentation)
- Internal escalation: what to write, what evidence to attach, decision logs
Module 8: Transaction reporting essentials (GoTRACS-aligned overview)
- CTR vs STR: what they are and why quality matters
- Submission discipline: data completeness, consistency, and timelines (overview)
Workshop B: Case-to-escalation simulation
- Teams decide: monitor vs EDD vs escalate for STR consideration (with a short narrative)
Wrap-up: Assessment + action planning
- Post-test + key takeaways
- “Next 30 days” compliance improvement checklist
