Source Document
Manual of Regulations for Banks
BSP.MORB.2023.Sec923.d.p34.OBL1
Manual of Regulations for Banks > 923 ADDITIONAL PREVENTIVE MEASURES FOR SPECIFIC CUSTOMERS AND ACTIVITIES > Fund/Wire transfer > d
Obligation Summary
Both the issuer and any institution accepting for deposit checks drawn in blank or payable to cash, bearer or numbered account must put whatever measures are necessary in place to stop buyers or depositors from using the instruments to launder money.
A covered person which issues as well as those which accepts as deposits, said cashier’s, manager’s or certified checks or other similar instruments issued in blank or payable to cash, bearer or numbered account shall take such measure(s) as may be necessary to ensure that said instruments are not being used/resorted to by the buyer or depositor in furtherance of an ML activity;
MORB, Sec. 923.d, p. 34 (2023 ed.) · Manual of Regulations for Banks · p. 34
c. A register of said checks indicating all the information required under Sec. 921;
d. A covered person which issues as well as those which accepts as deposits, said cashier’s, manager’s or certified checks or other similar instruments issued in blank or payable to cash, bearer or numbered account shall take such measure(s) as may be necessary to ensure that said instruments are not being used/resorted to by the buyer or depositor in furtherance of an ML activity;
e. The deposit of said instruments shall be subject to the same requirements of scrutiny applicable to cash deposits; and
What This Requires.
ProfytAI Regulatory Intelligence
Type: requirementRequires both the covered person that issues these blank, bearer, cash, or numbered-account cashier's, manager's, or certified checks and any covered person that accepts them as deposits to take whatever measures are necessary to ensure the instruments are not being used by the buyer or depositor to further money-laundering activity.
Relationship
One of the enumerated conditions under the section lead-in governing issuance of cashier's, manager's, or certified checks in blank or payable to cash, bearer, or a numbered account; it is the general anti-abuse duty sitting alongside the amount cap, register-keeping, deposit-scrutiny, and AMLC-reporting conditions in that same list, and it uniquely extends to accepting institutions as well as issuers.
Why This Exists
These checks can move without a named payee, making them attractive vehicles for layering illicit funds; this catch-all duty holds both the issuing and depositing institutions responsible for actively guarding against that misuse, not just observing the specific amount and scrutiny rules elsewhere in the list.
Implementation Considerations
Typically requires risk-based controls calibrated to the covered person's own exposure, such as enhanced monitoring or source-of-funds inquiry, applied by whichever covered person is either issuing or accepting the instrument.
Interpretation Note · The measures-as-necessary standard is open-ended and risk-based rather than a specific prescribed control. The duty binds two distinct roles, the issuing covered person and any covered person accepting the instrument as a deposit, so both must independently comply.
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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.