The compliance office must run periodic (non-exhaustive) compliance checks using sample testing and review of audit/examination reports, covering processes/policies/procedures, ongoing staff performance monitoring, reporting channels, and the effectiveness of the ML transaction-monitoring and record-retention systems.

a. Compliance office. Management of the implementation of the covered person’s Money Laundering and Terrorist Financing Prevention Program (MTPP) shall be a primary task of the compliance office. To ensure the independence of the office, it shall have a direct reporting line to the board of directors or any board-level or approved committee on all matters related to AML and CTF compliance and their risk management. It shall be principally responsible for the following functions among other functions that may be delegated by senior management and the board, to wit:

(1) Ensure compliance by all responsible officers and employees with this Part, the AMLA, as amended, the RIRR and its own MTPP. It shall conduct periodic compliance checking which covers, among others, evaluation of existing processes, policies and procedures including ongoing monitoring of performance by staff and officers involved in ML and TF prevention, reporting channels, effectiveness of the electronic money laundering transaction monitoring system and record retention system through sample testing and review of audit or examination reports. It shall also report compliance findings to the board or any board-level committee;

(2) Ensure that infractions, discovered either by internally initiated audits, or by special or regular examination conducted by the Bangko Sentral, or other applicable regulators, are immediately corrected;