Source Document
Manual of Regulations for Banks
BSP.MORB.2023.Sec922.p29.OBL7
Manual of Regulations for Banks > 922 COVERED AND SUSPICIOUS TRANSACTION REPORTING > Electronic monitoring systems for AML/CFT > 922
Obligation Summary
Work towards connecting the electronic monitoring system to the systems of any branches, subsidiaries, and affiliates so AML/CFT monitoring runs across the whole group.
The covered person shall endeavor to interface the electronic monitoring system with the systems of its branches, subsidiaries and affiliates, if any, for group-wide AML/CFT monitoring.
MORB, Sec. 922, p. 29 (2023 ed.) · Manual of Regulations for Banks · p. 29
The Bangko Sentral may consider other transactions as “no/low risk covered transactions” and propose to the AMLC that they be likewise subject to deferred reporting by covered persons.
Electronic monitoring systems for AML/CFT. Covered persons required under Sec. 911 (Monitoring and reporting tools) to have an electronic monitoring system for AML/CFT should ensure that the system, at a minimum, shall detect and raise to the covered person’s attention, transaction and/or accounts that qualify either as CT or ST as herein defined. The covered person shall endeavor to interface the electronic monitoring system with the systems of its branches, subsidiaries and affiliates, if any, for group-wide AML/CFT monitoring.
The system must have at least the following automated functionalities:
What This Requires.
ProfytAI Regulatory Intelligence
Type: requirementDirects a covered person to make reasonable efforts to interface its electronic AML/CFT monitoring system with the systems of its branches, subsidiaries, and affiliates for group-wide monitoring.
Relationship
Second sentence of the same opening paragraph as OBL6; extends that baseline detection duty from the covered person's own system to the group level, immediately before the following paragraph's itemized functionalities list (OBL1).
Why This Exists
Supports a consolidated, group-wide view of AML/CFT risk so that money-laundering activity cannot exploit gaps between the separate monitoring systems of related entities.
Implementation Considerations
Typically involves technical or data-sharing integration between the monitoring system and the systems of group entities, subject to applicable confidentiality and data-sharing constraints.
Interpretation Note · 'Shall endeavor to' sets a best-efforts standard rather than an absolute guarantee of successful interfacing; the duty engages only 'if any' branches, subsidiaries, or affiliates exist.
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