Source Document
Manual of Regulations for Banks
BSP.MORB.2023.Sec941.b-(2).p37.OBL2
Manual of Regulations for Banks > 941 SANCTIONS AND PENALTIES > Written reprimand; b > (2)
Obligation Summary
Where a covered person misses the plan-submission deadline or fails to carry out its action plan, recommend enforcement action against both the institution and its responsible officers, including monetary penalties accruing daily until the improvements are satisfactorily made.
In the event of non-submission of an acceptable plan within the deadline or failure to implement its action plan, the appropriate department of the Bangko Sentral shall recommend appropriate enforcement action on the covered person and its responsible officers including monetary penalties to be computed on a daily basis until improvements are satisfactorily implemented.
MORB, Sec. 941.b-(2), p. 37 (2023 ed.) · Manual of Regulations for Banks · p. 37
The appropriate department of the Bangko Sentral shall assess the viability of the plan and shall monitor the covered person's performance.
In the event of non-submission of an acceptable plan within the deadline or failure to implement its action plan, the appropriate department of the Bangko Sentral shall recommend appropriate enforcement action on the covered person and its responsible officers including monetary penalties to be computed on a daily basis until improvements are satisfactorily implemented.
c. An AML rating of 1 shall also be considered as an unsafe and unsound banking. For this reason, prompt corrective action shall be initiated on the covered person.
What This Requires.
ProfytAI Regulatory Intelligence
Type: requirementRequires the appropriate BSP department to recommend enforcement action, including daily-accruing monetary penalties, against a covered person and its responsible officers when a required AML action plan is not submitted on time or not implemented.
Relationship
One of the rules introduced by the lead-in stating that the following rules shall apply to implement the enforcement action provision alongside the AML Risk Rating System (ARRS). It follows the sibling rule requiring BSP to assess the plan's viability and monitor performance, and precedes the sibling rule classifying an AML rating of 1 as unsafe and unsound banking, together forming an escalating sequence of ARRS-driven enforcement steps.
Why This Exists
Gives BSP a concrete enforcement trigger so that AML/CFT corrective action plans carry real consequences rather than remaining a paper requirement, protecting the covered institution's safety and soundness and the integrity of the financial system.
Implementation Considerations
Institutions should track internal deadlines for any BSP-required AML action plan and confirm full implementation, since a missed deadline or partial implementation exposes both the institution and named responsible officers to recommended enforcement action and accruing daily penalties.
Interpretation Note · The duty runs to the appropriate department of the Bangko Sentral, not to the covered institution itself; it is triggered by either of two disjunctive failures (missed deadline or failed implementation); covered person is the defined AML/CFT term; the daily penalty computation is open-ended, continuing until improvements are satisfactorily implemented rather than for a fixed period.
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