Who Are AMLA Covered Persons?


Under the Anti-Money Laundering Act (AMLA), "Covered Persons" refer to individuals or entities required to follow specific rules aimed at preventing money laundering and terrorist financing.

Covered Persons have several key responsibilities to help combat financial crimes. They must verify and document the identities of clients, especially for large or suspicious transactions, and keep detailed records for at least five years. If they detect any suspicious activity, they are required to report it to the Anti-Money Laundering Council (AMLC). To ensure compliance, Covered Persons must set up internal controls, such as audits and risk assessments, and provide their staff with regular AML training to spot and handle suspicious activities.

To support these efforts, Covered Persons are required to ensure their employees receive proper AML training, such as those provided by AMLC and AML Certified PH.  These programs help employees understand how to identify red flags and report covered and suspicious activities, ensuring that organizations remain compliant with AMLA regulations and contribute to preventing illegal financial practices and crimes.

 Bangko Sentral-Supervised Financial Institutions  Banks
 Other non-bank financial institutions which, under special laws, are subject to BSP supervision and/or regulation.
 Offshore banking units
 Quasi-banks
 Trust entities
 Non-stock savings and loan associations
 Pawnshops
 Foreign exchange dealers
 Money changers
 Remittance and transfer companies
 Electronic Money Issuers (EMI)
 All other persons and their subsidiaries and affiliates supervised or regulated by the Bangko Sentral ng Pilipinas (BSP)
 Virtual Asset Service Providers (VASP)
   
 Insurance Commission-Regulated Entities (ICREs)   Insurance companies
 Insurance agents
 Insurance brokers
 Professional reinsurers
 Reinsurance brokers
 Holding companies
 Holding company systems
 Pre-need companies
 Mutual benefit associations
 All other persons supervised or regulated by the Insurance Commission (IC)
   
 Securities and Exchange Commission (SEC)-Registered Companies
  • Securities dealers
  • Brokers
  • Salesmen
  • Investment houses
  • Other similar persons managing securities or rendering services as investment agent, advisor, or consultant
 Mutual funds or open and close-end investment companies or issuers, and other similar entities
 Other entities administering or otherwise dealing in commodities, or financial derivatives based thereon, valuable objects, cash substitutes, and other similar monetary instruments or properties, supervised or regulated by the SEC
   
 Designated Non-Financial Businesses and Professionals (DNFBPs)   Jewelry dealers in precious metals, who, as a business, trade in precious metals
 Jewelry dealers in precious stones, who, as a business, trade-in precious stones

 Company service providers which, as a business, provide any of the following services to third parties:

  • Acting as a formation agent of juridical persons
  • Acting as (or arranging for another person to act as) a director or corporate secretary of a company, a partner of a partnership, or a similar position in relation to other juridical persons
  • Providing a registered office; business address or accommodation, correspondence or administrative address for a company, a partnership or any other legal person or arrangement
  • Acting as (or arranging for another person to act as) a nominee shareholder for another person.  

 Persons, including lawyers, accountants and other professionals, who provide any of the following services:

  • Managing of client money, securities or other assets
  • Management of bank, savings or other assets
  • Organization of contributions for the creation, operation or management of companies
  • Creation, operation or management of juridical persons or arrangements, and buying and selling business entities

IMPORTANT:
 This means that some lawyers and accountants are not considered "covered persons" under the AMLA if they are working independently and handling client information, if sharing that information would break client confidentiality or the attorney-client relationship.

 For this to apply, the lawyer or accountant must be authorized to practice in the Philippines and must still follow their professional rules and codes of conduct.

 An independent legal professional is a lawyer or accountant who works alone or in a small private practice, providing legal or notarial services to their clients as a business.
Last modified: Tuesday, 22 April 2025, 1:44 PM