Under the AMLC, a suspicious transaction report is due the next working day from the moment suspicion is determined, while a covered transaction report is due within five working days. The two clocks start on different events and run for different lengths, and conflating them is the most common AML reporting mistake in the Philippines.
The deadlines come from the AMLC's GoTRACS issuance, Regulatory Issuance No. 2 of 2024. That same issuance phases in a new reporting format and new upload requirements over one to three years, so the mechanics around these filings are changing even though the two deadlines are not.
This guide is written for heads of AML, compliance officers and reporting officers who file both reports and want the two clocks, the ₱500,000 threshold and the penalty myth settled in one place.
What is the difference between an STR and a CTR?
One is triggered by suspicion and has no amount; the other is triggered by an amount and carries no suspicion.
A suspicious transaction report, or STR, is filed when a covered person determines that a transaction is suspicious, whatever its value. A covered transaction report, or CTR, is filed when a cash transaction exceeds the reporting threshold, whether or not anything looks wrong. The Inquirer's explainer sets out both categories. The first is a judgement. The second is a measurement.
| Suspicious transaction report | Covered transaction report | |
|---|---|---|
| Trigger | Determination of suspicion | A cash transaction above the threshold |
| Amount | Any amount | Exceeds ₱500,000 in one banking day |
| Judgement | Required | Not required |
| Deadline | Next working day from occurrence | Five working days from occurrence |
Because a CTR is a mechanical filing, it is the easier of the two to automate. Because an STR rests on a judgement, the part that cannot be automated is the determination itself, which is also the event that starts its clock.
When is a suspicious transaction report due?
By the next working day from occurrence, and occurrence means the moment suspicion is determined, not the date of the transaction.
The ACCRALAW summary of the GoTRACS issuance states that an STR is filed electronically "within the next working day from occurrence thereof," and defines occurrence as "the establishment of suspicion or determination of the suspicious nature of the transaction." The clock does not run from when the money moved. It runs from when a person decided the activity was suspicious, which can be days or weeks later.
That distinction is where teams lose time. A transaction can sit in an alert queue for a week, and the next-working-day window only opens when the analyst completes the determination. So the determination date has to be recorded, because it is both the start of the clock and the fact an examiner will test. We cover the specific trap this creates in our piece on the STR filing window, and what the report itself must contain in our guide to a BSP-ready STR.
When is a covered transaction report due?
Within five working days from occurrence, for any single cash transaction exceeding ₱500,000 in one banking day. These CTR requirements apply whether or not the transaction raises any suspicion.
The same GoTRACS summary states that a CTR is filed "within five (5) working days from the occurrence thereof." BusinessWorld's report confirms the five-working-day window and that reports go through the AMLC's electronic facility. The threshold itself comes from the statute: Republic Act 9194, which amends the AMLA, defines a covered transaction as one "in cash or other equivalent monetary instrument involving a total amount in excess of Five hundred thousand pesos (P500,000.00) within one (1) banking day."
Two details matter for calibration. The threshold aggregates over a banking day, so several smaller cash transactions that together exceed ₱500,000 can still be covered, which is also how structuring is meant to be caught. And the threshold is higher for specific sectors, with separate figures for dealers in jewellery and precious metals, for real estate, and for casinos. A monitoring rule that watches only single transactions above the line will miss the aggregated case.
Is ₱500,000 a fine or a reporting threshold?
It is the reporting threshold for a covered transaction. It is not a fine for missing a report.
This is the most persistent error in AML copy about the Philippines. The ₱500,000 figure is the amount above which a cash transaction becomes reportable as a CTR. A covered person that files its CTR on time has met the obligation, and the threshold has nothing to do with penalties. The confusion has a traceable source. The same ₱500,000 figure appears elsewhere in the AMLA as a penalty amount for separate offences, such as malicious reporting and breach of confidentiality. The number is identical, but the two uses are unrelated. Penalties for reporting failures are set separately in the AMLA and in BSP regulations.
Keep the threshold and the penalty regime in different sentences. A policy that describes ₱500,000 as a fine reads as an error to anyone who knows the statute, and accuracy here is a trust signal with a compliance audience.
Why do the two deadlines get confused?
Because the Philippine terms share letters and numbers with the United States system, and most online material is written for that system.
Three overlaps cause it. The abbreviation CTR means covered transaction report under the AMLC, but currency transaction report in the United States, and the US version has its own threshold and its own form. The abbreviation STR maps to the US suspicious activity report, or SAR, which runs on a different clock, a point our SAR versus STR guide sets out. And the ₱500,000 threshold sits close to the US cash-reporting figure in readers' minds, so the two get merged.
A reporting officer who imports a US template will count the CTR clock correctly by luck and the STR clock wrongly. The US suspicious-report window is measured in calendar days from detection, not the next working day from determination. The safest habit is to treat every imported reference as US-framed until proven otherwise.
What happens if a report is filed late?
A late filing is treated as non-compliance with the submission requirements, and may draw administrative sanctions.
The GoTRACS summary states plainly that "submissions beyond the prescribed periods provided in the GoTRACS shall be considered as non-compliance with submission requirements," and that these may result in administrative sanctions. The issuance also phases in a new reporting format and a requirement to upload KYC documents and a beneficial owner template for STRs on juridical persons, scheduled between one and three years after effectivity. A filing that was complete under the old format can become incomplete under the new one, so check which items have taken effect.
Lateness and incompleteness are the two failure modes an examiner looks for, and both are visible in the record. For how these records feed the wider supervisory picture, see our BSP Circular 950 compliance guide and, for the 2027 assessment, our guide to effectiveness evidence.
How should a lean team protect both clocks?
Record the determination, separate the two workflows, and let a system start and track each deadline.
The two clocks need different handling. The CTR clock is mechanical, so it can be started automatically when a qualifying transaction is identified and tracked to the five-working-day mark. The STR clock depends on a human event, so the determination of suspicion and its date must be captured the moment they happen, because nothing downstream can reconstruct them. A third clock runs alongside both for certain events: BSP Circular 1193 requires a risk event report within 24 hours of knowledge or discovery.
Three habits keep a small team on time. Record the determination date and reasoning in the case, not in a person's memory. Keep the CTR and STR queues separate so the five-day filing is never treated with next-day urgency or the reverse. And open one case per customer, so the full picture supports the determination, which is the idea behind our transaction monitoring guide. For the vendor questions that cover reporting alongside the other modules, see our AML software buyer's guide.
How does Fyscal ARCX support STR and CTR reporting?
Fyscal ARCX Regulatory Reporting works from the case record, so each filing carries the determination and the data behind it. A guided workflow starts the applicable deadline, tracks it, and escalates to the responsible officer before the window closes, with the STR and CTR clocks handled as the separate obligations they are. CTR fields are pre-populated from customer due diligence and transaction data, and the AI layer drafts the STR narrative from the case content for an analyst to edit and approve. Every filing sits in a searchable record by case title, case ID or report ID.
If you want to see both clocks tracked in one workflow, book a walkthrough of Fyscal ARCX and bring a recent STR and a recent CTR to trace end to end.