Anti-Money Laundering Compliance

The prevention of financial crimes is a top priority of the bank, not only because these pose a significant threat to our reputation but because such crimes weaken the certitude and destroy the integrity of the global financial system. In this respect, the Compliance Office must extend its focus beyond the bank, its policies, and its employees to ensure that the bank’s clients also act within the law and do not use the bank for illegal activities. Our Anti-Money Laundering Compliance or AML-Compliance Unit develops, administers, and maintains an effective program for compliance with the Anti-Money Laundering Act (AMLA) and all of its implementing rules and regulations and Bangko Sentral Circular 706.

BPI seeks to combat money laundering and counter terrorist financing by applying the following principles:

Risk management system. The bank adopts and implements a sound AML and terrorist financing risk management system that identifies, assesses, monitors and controls risk associated with money laundering and terrorist financing. The risk management system involves adequate and active Board and Senior Management oversight, appropriate policies and procedures, monitoring, MIS, comprehensive internal controls and audit.

Customer identification process. The bank’s customer due diligence and know-your-customer process determines and verifies the true identity of all individuals, including their beneficial owners if applicable, as well as entities seeking to avail of BPI's products and services.

Compliance with laws. The bank ensures that laws and regulations are adhered to in accordance with superior and principled culture of compliance and that service is not provided where there is good reason to suppose that transactions are associated with money laundering and terrorist financing activities.

Cooperation with authorities. BPI takes appropriate measures required by law if there are reasonable grounds for suspecting money laundering or terrorist financing including including maintenance of customer data and transaction documents within prescribed timelines, reporting of covered and suspicious transactions and cooperating with investigations or complying with requirements of an authorized body.

Policies, procedures and training. The Bank designs appropriate policies and procedures for their respective business units, keeping these updated with changes in regulations and AML and CFT typologies. It also ensures that its staff are adequately informed and undergo effective AML-CFT training programs and eLearning courses to adequately comply with said policies and procedures.

Developed under the guidance of the Bangko Sentral's Money Laundering and Terrorist Financing Prevention Program (MLPP), the bank's anti-money laundering program incorporates the following:

• Formation of an Anti-Money Laundering (AML) unit, headed by a senior-level management officer, which, as the “watch dog” in preventing and detecting potential money laundering and suspicious financial activities of clients, monitors customer and counterparty transactions in compliance with the Anti-Money Laundering Law, its implementing rules and regulations, and Bangko Sentral Circular 706;
  
  
• Strict implementation of the bank’s AML program in accordance with local and international standards;
  
  
• Conscientious observance of strict Customer Due Diligence (CDD) and “Know Your Customer” (KYC) as the first line of defense against money laundering and terrorist financing and as an ongoing customer relations concern;
  
  
• Investment in state of the art technology and other automated tools that can help identify and monitor financial transactions and activities that appear to be suspicious;
  
  
• Adequate screening and recruitment process to ensure that only qualified personnel who have no criminal records are employed to assume sensitive banking functions;
  
  
• Reliance on the training, accountabilities and responsibilities of our front-line employees—branch managers, relationship managers and customer service people—in identifying fully the parties with whom BPI is doing business with and in ensuring that all transactions conducted by the customers are proper;
  
  
• Maintenance of customers’ identification and transaction documents in compliance with the existing rules and regulations;
  
  
• Monitoring and ensuring the periodic reviews by an independent unit on AML compliance of all business units and the reporting of violations, if any, to senior management for appropriate action;
  
  
• Regular updating of the bank’s AML program at least once a year to incorporate changes in AML policies and procedures, latest trends in money laundering and terrorist financing typologies, and latest pertinent regulatory issuances; and
  
  
• Recognition that deterrence of money laundering and terrorist financing is an ongoing concern that requires due diligence and vigilance to keep pace with the evolving schemes adopted by money launderers and terrorist organizations.

BPI's anti-money laundering program covers all its subsidiaries and affiliates. In conformity with the standards set by the local banking authority and international organizations, the bank constantly reviews its program to ensure compliance with the latest legislative and regulatory developments.