Under AMLC's GoTRACS (Regulatory Issuance No. 2, Series of 2024), covered institutions must file a Suspicious Transaction Report (STR) by the next working day following the date a transaction is determined suspicious, not the five-working-day window most SLAs still describe. That five-day figure is the deadline for Covered Transaction Reports (CTRs), a different report triggered by a fixed ₱500,000 cash threshold under a separate provision of the same law.
The distinction sits inside most institutions' case management SLAs, vendor contracts, and analyst training, and a meaningful share of that material still reflects the older number. On InstaPay, which processed 4.7 billion transactions in 2025, carrying the wrong window in your workflow isn't a minor calibration error. It is a standing filing risk that scales with every transaction the rail clears.
What GoTRACS Actually Says
AMLA RA 9160 sets a general reporting baseline: covered persons must report covered and suspicious transactions to the AMLC within five working days of occurrence, unless a shorter period, up to fifteen working days, is separately prescribed. On 11 December 2024, AMLC used that authority to prescribe a shorter period specifically for STRs.
Regulatory Issuance No. 2, Series of 2024, the Guidelines on Transaction Reporting and Compliance Submissions, or GoTRACS, requires covered persons to file STRs, including attempted transactions, within the next working day from the date of occurrence, where occurrence means the date the institution determines with finality that a transaction is suspicious. Submissions filed after 11:59:59 PM of that day are treated as non-compliant. As ACCRALAW and BusinessWorld have both confirmed, CTRs were not shortened; they remain governed by the five-working-day baseline.
| Report | Trigger | Filing window | Legal basis |
|---|---|---|---|
| CTR | Cash transaction (or equivalent) ≥ ₱500,000 in one banking day | 5 working days from occurrence | AMLA RA 9160, as amended |
| STR | Determination of suspicion (any amount) | Next working day from determination | GoTRACS, AMLC RI No. 2, Series of 2024 |
GoTRACS took effect upon publication. The chapters phased in from 1 May 2025 relate specifically to the electronic submission format (Chapter II, Part 1, Sections 1.18 and 1.19), not the next-working-day STR standard itself, which is a base Chapter I provision and has applied since publication. AMLC has since published a further rollout schedule extending into 2026–2028 for the format transition; this doesn't change the STR/CTR windows above, but confirm which technical phase applies to your own systems with AMLC or counsel.
Why the Five-Day Assumption Persists
Three dynamics keep the five-day figure alive inside institutions that should know better.
- The pre-2024 baseline was correct, once: RA 9160's five-working-day baseline governed both CTRs and STRs before GoTRACS carved out a shorter window for STRs specifically. Anyone trained on the law before December 2024 learned a rule that was accurate at the time.
- Documentation lags the regulation: Vendor documentation, SLA templates, and analyst training decks written before GoTRACS's phased rollout still describe the pre-2024 baseline, and many haven't been revisited since.
- CTR repetition crowds out STR nuance: CTR triggers are mechanical (a fixed peso threshold), so they dominate day-to-day compliance training. STR determinations require analyst judgment and get comparatively little airtime, so the old five-day figure gets carried over by association.
None of this reflects institutional intent to under-report. It reflects a systemic lag between a regulatory update and the operational materials meant to reflect it, and it's exactly the kind of gap a BSP examiner is trained to find.
What "Next Working Day" Means Operationally
A transaction occurs. Monitoring flags it. An analyst reviews the flag and determines, with finality, that it's suspicious. That determination, not the original transaction and not the initial alert, starts the clock.
4.7B — transactions processed on InstaPay in 2025, the filing window applies per case, from determination, with almost no slack.
A batch-cycle monitoring process that surfaces alerts once every 24 hours can consume the entire filing window before an analyst even sees the transaction. A manual escalation chain that takes a day to route an alert to the right reviewer can do the same. The window doesn't care how many transactions an institution processes or how many analysts are on shift, it applies per case, regardless of volume. At scale, an SLA built around the wrong number doesn't create an occasional miss. It creates a structural one.
The Four-Point SLA Audit
Four things worth checking this week.
- Internal SLA documents: Confirm the STR clock is documented as next working day from determination, not five working days from transaction date.
- Vendor contract language: SLAs and configuration templates set up before your platform's GoTRACS update may still carry the old window.
- Case management workflow: Is the countdown tracked automatically inside the case record, or reconstructed manually from a spreadsheet or shared log?
- Escalation path: Does the workflow escalate automatically as a determination approaches its filing deadline, or does it depend on an analyst remembering to check?
None of these four items requires new technology to check. They require someone to pull the actual SLA document, the actual vendor contract, and the actual GoTRACS submission log, and compare the dates against the standard GoTRACS has actually set, not the standard most training materials still describe.
How to Close the Gap
A case management system built for this standard needs a few specific things: STR/CTR forms that pre-populate from existing case data, so analysts aren't rebuilding a filing from scratch under time pressure; a determination-to-filing countdown that starts automatically the moment a case is marked suspicious; and an escalation trigger that fires before a deadline is at risk, not after it's missed. This is a reasonable minimum bar for any vendor operating in the Philippine market post-GoTRACS, not a differentiated feature but an operational requirement.
FT AML Solution's Regulatory Reporting module is built around this workflow: STR and CTR forms pre-populate directly from case data, so analysts review rather than rebuild a filing under time pressure. A filing countdown runs automatically inside the case record from the moment a case closes, with escalation alerts firing if a deadline is at risk.
Frequently Asked Questions
What is the STR filing deadline in the Philippines?
Under AMLC's GoTRACS (Regulatory Issuance No. 2, Series of 2024), covered institutions must file a Suspicious Transaction Report by the next working day following the date a transaction is determined suspicious.
Is the STR filing window five working days or one working day?
It depends on the report type. The five-working-day window under AMLA RA 9160 applies to Covered Transaction Reports (CTRs). GoTRACS shortened the window specifically for Suspicious Transaction Reports (STRs) to the next working day following determination.
What is the CTR threshold in the Philippines?
A Covered Transaction Report is required for a single cash transaction, or its equivalent, exceeding ₱500,000, under AMLA RA 9160.
What is AMLC GoTRACS?
GoTRACS (Guidelines on Transaction Reporting and Compliance Submissions) is AMLC Regulatory Issuance No. 2, Series of 2024, the digital framework governing how covered persons submit CTRs and STRs to the AMLC.
When did the next-working-day STR rule take effect?
GoTRACS was issued on 11 December 2024 and took effect upon publication, with specific chapters phased in from 1 May 2025. Confirm the applicable phase-in date for your specific reporting obligations with counsel or AMLC directly.
What happens if an institution misses the STR filing deadline?
Submissions filed after the prescribed period are considered non-compliant under GoTRACS and may be subject to administrative sanctions under AMLA.