5 Ways Fintech Companies Can Comply with the Anti-Money Laundering Act

4 mins

The COVID-19 pandemic became a great catalyst that propelled digital payments in the Philippines to new heights, as the country’s young population and broad mobile network penetration have boosted the country’s internet-based businesses.  

In response to this need, the Bangko Sentral ng Pilipinas (BSP) continues to provide an enabling environment that promotes financial innovation while safeguarding the integrity and stability of the financial system. The central bank created its Digital Payments Transformation Roadmap 2020-2023, which aims at creating an “efficient, inclusive, safe and secure digital payments ecosystem that supports the diverse needs and capabilities of individuals and firms”

Aligning with the roadmap, the BSP launched an Open Finance Framework in June 2021 to enable portability, interoperability, and collaborative partnerships between BSP-supervised financial institutions and fintech players.

Along with the rise of digital payments comes the threat of sophisticated financial crimes. While the country works hard to move out of the FATF grey list, players in the digital payments space are also facing intense regulatory scrutiny. The BSP is conscious of the financial crime risks within the country and is working with the Anti-Money Laundering Council (AMLC) to create strategies for concrete anti-money laundering policies for new-age payments. Fintech companies in the Philippines now require efficient and effective Anti-money Laundering/Counter Terrorist Financing (AML/CTF) measures, apart from other corporate governance requirements.

In order to dive deep into the anti-money laundering (AML) and other compliance requirements for fintech firms in the Philippines, Tookitaki conducted a webinar on September 28 as part of our Compliant Conversations webinar series

Our eminent panellists from Divina Law – Enrique V. Dela Cruz, Jr. and Juan D. De Zuniga, Jr – covered a range of topics including the Anti-Money Laundering Act (AMLA) and its key provisions and processes that fintech companies need to comply with. Meanwhile, our AML expert Akshara Karanjekar shared how technology can ensure compliance amidst heightened risks. 


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The Key Topics of Discussion

All About the AMLA

Our panellist Juan explained the ill effects of money laundering and the reason why the Philippines enacted the AMLA. He also discussed the features of the AMLA, the Anti-Money Laundering Council and its powers, the predicate offences enumerated in the AMLA and the covered institutions under the AMLA and their reporting requirements. He also mentioned that the AMLA has been amended five times to broaden the scope and relisting of corporate transactions and predicate offenses. 

The Need for AML Programmes

Juan further elaborated on the need for fintech companies to have AML programmes. The AML programmes should have various processes including customer identification, monitoring, screening, record keeping and regulatory reporting. He also mentioned that fintech companies should comply with all applicable AML laws and explained the consequences of non-compliance. 

Compliance with the AMLA

Our AML expert Akshara touched upon how perpetrators are abusing the payment systems in the Philippines for money laundering. She explained about the covered institutions under the AMLA and the various AML requirements they need to fulfill such as suspicious transaction reporting, record keeping and maintaining an audit trail to support investigations. She also mentioned the situation in which the AMLA underwent an amendment in February 2021 and elaborated on the key provisions in the amendment. 

The Need for Ongoing Monitoring

Akshara noted that ongoing monitoring is definitely a key AML control measure that every financial institution should have in place. AML risk might also manifest at a later stage of the customer lifecycle; therefore fintech companies should monitor the risk associated with the customer throughout the business relationship with the customer, she said.  

Staying Compliant with Changing Regulations

Our panellist Enrique explained the need for compliance officers of fintech companies to review the policies of the financial regulators periodically and train themselves to be adept with the knowledge necessary to comply with these regulations. He added that fintech companies should leverage modern technology such as artificial intelligence to monitor transactions as manually checking millions of daily transactions is cumbersome. He cited the example of the Bangladesh Central Bank money laundering case where criminals smartly circumvent reporting thresholds, adding that financial institutions should have systems to detect irregularities in transaction patterns. Enrique noted that there needs to a central database so that screening of customers can be more dynamic.    

Uniting to Fight Financial Crime

Akshara shared Tookitaki’s point of view that financial crime cannot be fought in silos. She also presented Tookitaki’s innovative AML Ecosystem  comprising of the Typology Repository and our network of experts. The AML Ecosystem removes the information vacuum created by siloed AML operations. It also lays the foundation of a  democratised detection approach where money laundering scenarios are shared across an ecosystem through a privacy-protected framework. 


The webinar touched upon unique thoughts on how fintech companies can ensure compliance under the AMLA of the Philippines. At Tookitaki, we share the same thought as the Philippine regulators to have a risk-based approach to building comprehensive AML compliance programs and we help our customers to be future-proof with our proven technology solutions. 

Hear from our experts about what it takes for fintech companies to adhere to the compliance obligations prescribed in the AMLA in the Philippines.


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