Source Document
Manual of Regulations for Banks
BSP.MORB.2023.Sec921.f(1).p23.OBL1
Manual of Regulations for Banks > 921 CUSTOMER DUE DILIGENCE > Third party reliance > (1)
Obligation Summary
When relying on a third party that is itself a covered person under this Part and the AMLA, obtain a written sworn certification from it covering two points: that it completed the prescribed customer identification (including face-to-face contact) and holds the required customer records, and that it will release identification documents on request without delay.
Where the third party is a covered person specifically defined by this Part and as generally defined by AMLA, as amended, and its RIRR — The covered person shall obtain from the third party a written sworn certification containing the following:
MORB, Sec. 921.f(1), p. 23 (2023 ed.) · Manual of Regulations for Banks · p. 23
f. Third party reliance. A covered person may rely on third parties to perform the CDD procedures under Item “(a) 1 to 3” of Sec. 921 (Customer due diligence) subject to the following rules:
(1) Where the third party is a covered person specifically defined by this Part and as generally defined by AMLA, as amended, and its RIRR — The covered person shall obtain from the third party a written sworn certification containing the following:
(a) The third party has conducted the prescribed customer identification procedures in accordance with this Part and its own MTPP, including the face-to-face contact requirement, to establish the existence of the ultimate customer and has in its custody all the minimum information and/or documents required to be obtained from the customer; and
What This Requires.
ProfytAI Regulatory Intelligence
Type: requirementRequires a covered person, when the third party it relies on for customer due diligence is itself a covered person under the AMLA, to obtain from that third party a written sworn certification containing specified content.
Relationship
Is the governing stem for the branch of the Third party reliance list item applying when the third party is itself an AMLA covered person, as opposed to a sibling branch applying to foreign financial institutions; it governs two conjunctive leaf items that specify exactly what the required certification must contain.
Why This Exists
It creates a documented, sworn attestation trail whenever a bank relies on another covered person for customer due diligence, so the bank and its supervisors can verify that identification procedures were actually performed and that reliance is not being used to bypass due diligence obligations.
Implementation Considerations
A bank entering a third-party reliance arrangement for customer due diligence should first confirm the third party meets the covered person definition, then obtain and retain a written sworn certification addressing both required content points before relying on that third party's work.
Interpretation Note · "RIRR" refers to the AMLA's Revised Implementing Rules and Regulations, referenced but not defined here. The opening "Where..." clause scopes this stem's duty to third parties meeting the covered person definition; a separate item covers foreign financial institutions that are not covered persons. "The following" refers forward to the two conjunctive content items that must both be satisfied.
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Reproduced from the Bangko Sentral ng Pilipinas Manual of Regulations for Banks, retrieved from bsp.gov.ph. Highlighting and the verification stamp were added by ProfytAI; the underlying text is unaltered. This document is freely available from the BSP website.