Duration 2 days – 14 hrs
Overview
This refresher equips institutional / corporate lending teams (relationship managers, credit/underwriting, KYC ops, AML/compliance) with the latest Philippine AML/KYC regulatory expectations and practical workflows across the institutional loan lifecycle—from onboarding and beneficial ownership (BO) identification to adverse media screening, monitoring of drawdowns/repayments, and escalation/reporting.
The program is aligned to:
- The Anti-Money Laundering Act (RA 9160) baseline obligations for covered institutions (banks/BSFIs).
- Key strengthening amendments under RA 11521, including stronger AMLC powers and explicit focus on targeted financial sanctions / proliferation financing.
- Recent BSP supervisory expectations on beneficial ownership due diligence (best practices and common typologies).
- Recent BSP guidance on negative/adverse media screening as part of CDD/EDD and monitoring—covering UBOs and signatories too.
- Newer BSP controls on large value cash transactions / payouts (₱500,000 threshold, traceable channels + EDD, STR considerations if EDD can’t be completed).
- Market context after the Philippines was removed from FATF increased monitoring (Feb 21, 2025)—i.e., sustaining stronger compliance practices
Objectives
- Explain the latest regulatory expectations impacting institutional/corporate lending KYC in the Philippines (AMLA, BSP supervisory guidance, reporting expectations).
- Apply a risk-based approach to institutional borrowers (risk rating, EDD triggers, periodic reviews, event-driven refresh).
- Perform beneficial ownership identification + verification using both ownership and control lenses, and document BO rationale defensibly for audit/exam.
- Operationalize adverse/negative media screening for onboarding + ongoing monitoring, including coverage of UBOs, signatories, and counterparties.
- Implement controls for large value cash payouts/transactions and apply EDD/documentation requirements at the ₱500,000 threshold.
- Improve STR/CTR decisioning quality using realistic institutional lending scenarios and clear escalation narratives
Audience
- Institutional / Corporate Banking Relationship Managers
- Credit Officers / Underwriters / Loan Operations
- KYC/CDD/EDD Analysts and Onboarding Teams
- AML Compliance, MLRO/AMLO support teams
- Risk Management, Internal Audit (as observers or participants)
Pre- requisites
- Prior AML/KYC onboarding experience or completion of AML/KYC fundamentals training
- Familiarity with your bank’s KYC forms, risk rating model, and escalation/STR workflow (helpful but not required)
Course Content
Module 1 — AML/KYC refresher: what changed & why it matters in institutional lending
- AML/KYC responsibilities across 1st/2nd/3rd lines
- AMLA baseline duties for covered institutions and why institutional loans are higher-risk in practice
- Post-FATF increased monitoring: sustaining controls (what examiners look for)
Quick activity: “What’s new since your last refresher?” risk/control gap board
Module 2 — Key regulatory updates affecting corporate/institutional clients
- Strengthening amendments and enforcement direction (incl. sanctions/PF emphasis)
- Reporting/registration expectations and common supervisory findings (timeliness, completeness, narratives)
- Practical implications for institutional loan onboarding + periodic review cycles
Module 3 — Beneficial Ownership due diligence for institutional borrowers
- BO risks/typologies in complex corporate structures; why “dummies/nominees/layers” matter
- BO identification approaches:
- Ownership threshold approach
- Control lens / “ultimate effective control” approach (board, governance, signatory powers)
- Verification: multi-pronged evidence, documentation, and exception handling
- File defensibility: what auditors/examiners expect in the BO section
Workshop: BO mapping exercise for a multi-layer corporate borrower (group case)
Module 4 — Adverse/Negative media screening as CDD/EDD control
- BSP expectations: integrate NMR screening into CDD + complement transaction monitoring
- Building a credible NMR process: sources, validation, false positives
- Extending screening coverage to UBOs and authorized signatories + relevant counterparties
- What triggers: lookback, EDD, escalation, and enhanced monitoring
Mini-drill: turning a negative media hit into a defensible “so what?” assessment
Module 5 — Institutional loan lifecycle monitoring: red flags, scenarios, and controls
- Loan-specific AML risks:
- Unusual drawdowns / third-party disbursement requests
- Early repayment patterns, circular fund flows, “loan proceeds as layering”
- Related party indicators and unusual collateral arrangements
- Aligning credit + AML without over-collecting or under-documenting
- Event-driven refresh: change in ownership/control, adverse news, sanctions hits
Case study: decide if it’s “monitor”, “EDD + restrict”, or “file STR” (with rationale)
Module 6 — Large value cash transactions (₱500,000) and EDD requirements
- BSP Circular 1218 essentials:
- Cash payouts > ₱500,000 should go through traceable channels (checks/fund transfer/direct credit/digital payments)
- Threshold applies to single or multiple transactions within one banking day
- EDD required for transactions exceeding threshold; STR considerations if EDD can’t be completed
- Lending context: disbursements, proceeds handling, borrower cash requests—control options and documentation
Module 7 — Reporting quality & escalation (GoTRACS-ready practices)
- Writing better escalation narratives: who/what/why/why now
- Watchlist + negative news as STR input (good documentation habits)
- CTR/STR workflow checkpoints and common mistakes (timing, completeness, supporting docs)
- Practical “GoTRACS-ready” discipline: consistent data fields, BO data quality, decision logs (overview-level)
Module 8 — Assessment, action planning, and take-home tools
- Post-test + debrief
- Team action plan: 3 improvements to implement in the next 30 days
- Take-home toolkit (templates you can include in your training pack):
- Institutional borrower KYC checklist (incl. BO + control lens prompts)
- Adverse media handling guide (triage + documentation)
- Loan monitoring red flags list (drawdown/repayment/third party)
- STR decision tree + sample narrative structure
