anti-money laundering and combating the financing...
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The Philippine ExperienceThe Philippine Experience
Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) for Mobile Phone Financial Services (m-FS)
24-26 June 2008 Bangkok, Thailand
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AGENDA
ú Access to Financial Services
ú BSP Initiatives
ú m-FS in the Philippines
ú Key Areas of Concern
ú Other Issues
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3,000
NCR
Region I
Region I
I
Region I
II
Region I
V-A
Region I
V-B
Region V
Region V
I
Region V
II
Region V
III
Region I
X
Region X
Region X
I
Region X
IICAR
ARMM
CARAGA
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20,000
40,000
60,000
80,000
100,000
120,000
140,000
Bank DensityBank Density
Access to Financial ServicesAccess to Financial Services
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Overseas Filipino Workers (OFW)
About 10% of 89About 10% of 89million Filipinosmillion Filipinoswork abroadwork abroad
Remittance Remittance úú USD14.45 billion USD14.45 billion
(2007)(2007)úú USD16.4 billion USD16.4 billion
(2008 projection)(2008 projection)úú 10.0% of GDP10.0% of GDP
Access to Financial ServicesAccess to Financial Services
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BSP InitiativesBSP Initiatives
§ Proactive role in development of microfinance in the banking sector
§ Promote efficiency in banking services through outsourcing and sharing of service
§ Respond positively to ICT Innovation
§ Liberalization of ID requirements
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•Withdraw from ATMs
•Balance/Change MPin
•Purchase Goods/Services
•Buy Airtime load
•Transfer Funds
•Purchase Goods/Services
•Pay Bills
•Remote Purchase
•Lock/Unlock/Change Pin
mm--Financial ServicesFinancial Services
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Bills Payment
Merchant Payments
Money Transfer
(P2P)
Remittances
ACCREDITED REMCOOUTLET
mm--Financial ServicesFinancial Services
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Smart Money (BankSmart Money (Bank--based Model)based Model)
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GG--Cash (Cash (NonbankNonbank--based Model)based Model)
You have received
P10,000.
You have received
P10,000.
Settlement Bank
GG--Cash Cash Encashment Encashment
CentersCentersMerchantsMerchants
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CrossCross--Border RemittanceBorder Remittance
REMCO
Issuing Issuing
BankBank
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Impact on Money SupplyImpact on Money Supply
Accredited Accredited Local OutletLocal Outlet(Encashment (Encashment
Center)Center)
REMCO You have received P10,000.
You have received P10,000.
MerchantMerchant
Settlement Bank
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Distinct FeaturesDistinct Features
SMART Money G-Cash
Issuer partner banks GXI
Channels mobile phone and debit card mobile phone
Access to Records
SMART and partner banks GXI
Repository partner banks GXI
Float Management partner banks GXI
Settlement partner banks GXI Instruction
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Key Areas of ConcernKey Areas of Concern§ Supervision over non-bank institutions
offering financial products
§ Prevention from money launderers and terrorist financing
§ Consumer protection
§ Risk Management
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Policy & Regulatory EnvironmentPolicy & Regulatory Environment
§ Electronic Commerce Act (R.A. 8792)
§ The General Banking Law of 2000 (R.A. 8791)
§ The Anti-Money Laundering Act (R.A. 9160 and 9194)
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Sec. X621 of Manual of Regulations for Banks (MORB) – Guidelines on Electronic Banking Services;
Sec. X169.2 of MORB – Outsourcing of information technology systems/processes;
Circular 471 – Requires registration of remittance agents
Addressing ConcernsAddressing Concerns
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Registration Process:
Addressing ConcernsAddressing Concerns
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Cash-In and Cash-Out
Addressing ConcernsAddressing Concerns
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§§ Know Your CustomerKnow Your Customerúú Partner AccreditationPartner Accreditation Documentary requirements: business registration,
Secretary’s Certificate, etc. Partner Verification: Checking against OFAC list,
credit review checkingúú CashCash--In/CashIn/Cash--Out DocumentationOut Documentation Subscriber required to fill up registration form for
cash-in and acknowledgment form for cash-out Presentation of valid ID for every cash-in/cash-out
transactions Right to access partner’s records Data retention period of seven (7) years
Addressing ConcernsAddressing Concerns
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Wallet Limits
Daily Limit – Php 40,000
Monthly Aggregate Limit – Php100,000.00
Addressing ConcernsAddressing Concerns
Current Exchange Rate: 45Php:1USD
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• On-site supervision of BSP
• Access to e-money records by BSP and AMLC
• AML Monitoring System
• Reporting of CTR/STR
Addressing ConcernsAddressing Concerns
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Addressing ConcernsAddressing Concerns
§ Safeguard customer information; § Prevent money laundering and terrorist
financing; § Reduce fraud and theft of sensitive
customer information; and § Promote legal enforceability of banks’
electronic agreements and transactions
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Addressing ConcernsAddressing Concerns
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Other Issues:Other Issues:
§ Accreditation of more remittance agents
§ Prudential requirements on e-money issuers and operators
§ Enactment of a Payment Systems Act
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Raymond O. Estioko, CISA, CPA, MBA Manager, Core IT Specialist Group
[email protected]@bsp.gov.ph
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