The Anti-Money Laundering Council (AMLC) is the Philippines' financial intelligence unit and AML authority, created in 2001 under the Anti-Money Laundering Act. It receives covered and suspicious transaction reports, freezes and forfeits illicit proceeds, and registers covered persons. Every covered person names an AML compliance officer as its accountable contact with the Council.
The Council's powers have been widened several times since 2001, and its 2024 issuances changed how covered persons register and report. The summary below follows the statute, the implementing rules and the 2024 issuances; confirm sector-specific requirements, such as compliance-officer rank and reporting lines, against the rules of the supervisor that applies to your institution.
This guide is written for CCOs, newly appointed AMLCOs and compliance heads at banks, e-money issuers, money service businesses and other covered persons who need the structure in one place.
What is the Anti-Money Laundering Council?
It is the body created by the Anti-Money Laundering Act to receive reports, investigate, freeze and forfeit illicit proceeds, and lead the country's AML and counter-terrorist financing effort.
Section 7 of Republic Act No. 9160, the Anti-Money Laundering Act of 2001, created the Council. Its functions under that section include receiving covered transaction reports, investigating, instituting civil forfeiture, filing complaints for prosecution, freezing property linked to unlawful activity and acting on requests for assistance from foreign states. The AMLC also serves as the country's financial intelligence unit and implements the Terrorism Financing Prevention and Suppression Act. In practice, that makes the Council the destination for every suspicious transaction report a covered person files, whatever its sector.
Who sits on the AMLC?
The Governor of the Bangko Sentral ng Pilipinas chairs the Council, with the Insurance Commissioner and the Chairperson of the Securities and Exchange Commission as members.
The statute requires the three to act unanimously in discharging the Council's functions, and the structure mirrors the three main financial supervisors, which is why sector supervisors and the AMLC work closely. The BSP, the SEC and the Insurance Commission examine the institutions they regulate, while the AMLC receives the reports and acts on them. A compliance officer at a BSP-supervised institution therefore manages two relationships, with the BSP examining the programme and the AMLC receiving the filings and registration.
Banks, e-money issuers, money service businesses and other covered persons
Primary authorised representative on the AMLC Portal
Financial intelligence unit; receives the reports
Governor of the Bangko Sentral ng Pilipinas
Insurance Commissioner
Chairperson of the Securities and Exchange Commission
Which laws has the AMLC's mandate grown under?
The 2001 Act as amended, most recently by Republic Act No. 11521 in 2021, which widened covered persons and the Council's powers.
Republic Act No. 11521, approved on 29 January 2021, added real estate developers and brokers and offshore gaming operators and their service providers as covered persons. It made certain serious tax crimes predicate offences where the deficiency exceeds ₱25 million per taxable year. It also allowed the AMLC to apply for search and seizure orders and subpoenas, and to issue an ex parte freeze without delay to implement targeted financial sanctions on proliferation financing. These were part of the reforms that preceded the country's exit from the FATF grey list on 21 February 2025, a story our grey-list exit explainer covers.
Who counts as a covered person?
Financial institutions supervised by the BSP, the SEC and the Insurance Commission, and designated non-financial businesses and professions.
Rule 4 of the 2018 implementing rules lists the covered persons. BSP-supervised institutions include banks, quasi-banks, trust entities, pawnshops, electronic money issuers and remittance companies. Insurance companies, pre-need firms and insurance intermediaries fall under the Insurance Commission, and securities dealers, brokers and investment companies under the SEC. The designated non-financial businesses and professions include jewellery and precious-metal dealers, company service providers, casinos, and lawyers and accountants when they handle specified transactions for clients. The same rule makes the board of directors, partners or sole proprietor ultimately responsible for compliance. That clause is why an AML failure is a board matter and not only a matter for the compliance desk.
What did the AMLC's 2024 regulatory issuances change?
Issuance No. 1 rebuilt registration through the Compliance Optimization and Registration System, and Issuance No. 2 set the transaction reporting rules known as GoTRACS.
AMLC Regulatory Issuance No. 1 of 2024, approved by Council Resolution No. 76 on 8 April 2024, sets out the Compliance Optimization and Registration System. Covered persons register through the AMLC Portal and designate a compliance officer and alternates, supported by a board resolution or secretary's certificate. A provisional certificate is valid for six months while the AMLC reviews the registration, which must then be updated every two years, and changes to compliance-officer details must be updated immediately. Regulatory Issuance No. 2 of 2024, approved on 11 December 2024, sets the reporting clocks. A suspicious transaction report is due by the next working day from the determination of suspicion, and a covered transaction report within five working days. Our STR versus CTR guide sets out how each clock starts.
What is an AML compliance officer, and what does the role own?
The AML compliance officer, or AMLCO, is the officer accountable for running the institution's AML programme and its relationship with the AMLC.
Under the registration guidelines, the compliance officer is the covered person's official primary authorised representative on the AMLC Portal. The FATF standard behind the role, the interpretive note to Recommendation 18, calls for compliance management arrangements that include a compliance officer at the management level. In practice an AML compliance officer owns five things. They are the written money laundering and terrorism financing prevention programme, the institutional risk assessment that drives it, the quality and timeliness of every filing, staff training, and the evidence trail an examiner will test. For a BSP-supervised institution, that includes reporting significant ML/TF/PF risk events within 24 hours under Circular 1193. Rank, independence and reporting-line requirements vary by supervisor, so confirm the ones that apply in your manual of regulations.
What do examiners expect an AMLCO to show?
Evidence that the programme works: a current risk assessment, filings made on time, decisions that can be traced, and an independent test of the whole.
The AMLC's December 2025 national risk assessment, reported by BusinessWorld, rated the country's money laundering threat high and its vulnerability medium. It named fraud and cyber-enabled scams among the main threats. That context shapes supervisory questions ahead of the 2027 mutual evaluation, which our 2027 evaluation guide covers. An examiner will ask for the institutional risk assessment and its link to monitoring, a sample of reports with their timestamps, and the reasoning behind closed alerts. They will also ask for the independent audit of the programme, which our guide to independent testing treats in detail. A lean team rarely fails on policy wording, but it does fail when the record behind a decision cannot be produced.
How does Fyscal ARCX support an AMLCO?
Fyscal ARCX gives the compliance officer one record of screening, monitoring, investigation and reporting, so the evidence an examiner asks for already exists. Every alert, review and approval sits in a single case per customer with a timestamped trail. Regulatory Reporting prepares STR and CTR filings and tracks each deadline from the moment suspicion is determined, as our note on regulatory reporting automation describes. Named parties are screened against sanctions, PEP and watchlists, with the outcome recorded in the same case.