Ingenique Solutions

The Philippines has made significant strides in combating money laundering and terrorist financing (AML/CTF). However, its inclusion in the Financial Action Task Force’s (FATF) grey list in 2021 underscores the need for continued vigilance. Designated Non-Financial Businesses and Professions (DNFBPs) play a crucial role in this ongoing effort. This article explores the importance of AML/CTF regulations for DNFBPs, their responsibilities, and how they can contribute to removing the Philippines from the grey list. 

Who are the DNFBPs for AML/CTF?

Under the 2018 Implementing Rules and Regulations of Republic Act No. 9160, DNFBPs are covered persons who are: 

  • Jewelry dealers, dealers in precious metals, and dealers 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; and 
    • acting as (or arranging for another person to act as) a nominee shareholder for another person; 

  • Persons, including lawyers and accountants, who provide any of the following services: 
    • managing of client money, securities or other assets; 
    • management of bank, savings, securities or accounts; 
    • organization of contributions for the creation, operation or management of companies; and 
    • creation, operation or management of juridical persons or arrangements, and buying and selling business entities.

  • Real Estate Brokers and Developers; and

  • Offshore Gaming Operators, as well as their service providers, supervised, accredited or regulated by the Philippine Amusement and Gaming Corporation (PAGCOR) or any Appropriate Government Agency (AGA).

Why AML/CTF Regulations Matter for DNFBPs

Money laundering involves disguising the origins of illegally obtained funds. Criminals often exploit vulnerabilities in non-financial sectors to launder money. DNFBPs, by nature of their activities, can be attractive targets. For instance, real estate transactions can be used to hide illicit funds through inflated prices. Similarly, precious metals dealers can be used to convert cash into easily transportable assets. 

AML/CTF regulations safeguard DNFBPs from being unwittingly used for criminal purposes. These regulations provide a framework for identifying suspicious activity and reporting it to the authorities. By complying with these regulations, DNFBPs not only protect their businesses but also contribute to a safer financial system for everyone. 

Understanding Your Obligations: Key AML/CTF Requirements for DNFBPs 

The Anti-Money Laundering Council (AMLC), the Philippines’ primary AML/CTF regulator, lays out specific requirements for DNFBPs. These include:

  1. Registration:
    All DNFBPs, as defined by Republic Act No. 9160 (Anti-Money Laundering Act of 2001, as amended) and its implementing regulations, must register with the AMLC. This process involves submitting information about the business and its ownership structure. 

  2. Customer Due Diligence (CDD) Procedures:
    DNFBPs must implement CDD procedures to identify and verify the identity of their customers. This includes collecting basic information like names, addresses, and identification documents. For higher-risk customers, additional due diligence may be necessary. 

  3. Customer Due Diligence for Politically Exposed Persons (PEPs):
    PEPs are individuals who hold prominent public functions, along with their family members and close associates. DNFBPs are required to conduct enhanced CDD for PEPs due to the heightened risk of money laundering associated with them. 

  4. Risk-Based Approach:
    DNFBPs should adopt a risk-based approach to AML/CTF compliance. This means tailoring their procedures to the specific risks associated with their business type and customer base. 

  5. Suspicious Transaction Reporting (STR):
    DNFBPs are obligated to report suspicious transactions to the AMLC. Transactions that appear inconsistent with a customer’s profile or lack a legitimate economic purpose should be flagged and reported. 

  6. Record-Keeping:
    DNFBPs must maintain records of customer identification information, transactions, and any suspicious activity reports filed. 

How DNFBPs Can Help Remove the Philippines from the FATF Grey List

The FATF identifies several areas for improvement in the Philippines’ AML/CTF regime. DNFBPs can play a crucial role in addressing these concerns and demonstrating the country’s commitment to combating money laundering: 

  • Effective Implementation of AML/CTF Programs:
    DNFBPs should prioritize effective implementation of their AML/CTF programs. This includes having a designated AML compliance officer, conducting regular training for employees, and periodically testing the program’s effectiveness. 

  • Enhanced Cooperation with Authorities:
    Open communication and collaboration with the AMLC and other law enforcement agencies are essential. DNFBPs should actively participate in information-sharing initiatives and promptly respond to requests from the authorities. 

  • Raising Awareness:
    DNFBPs can contribute by educating their customers about AML/CTF. Public awareness campaigns within their industries can help deter criminals from exploiting vulnerabilities in the system. 

  • Advocacy:
    Industry associations representing DNFBPs can play a vital role in advocating for stronger AML/CTF regulations and promoting best practices among their members. 

Beyond these specific actions, DNFBPs should strive for continuous improvement in their anti-money laundering efforts. Regularly reassessing their risk profiles, staying updated on new regulations, and adopting innovative compliance solutions are key to staying ahead of evolving threats. 

Streamlining your Compliance with AML/CTF Software

In today’s digital age, DNFBPs in the Philippines can now leverage the power of AML/CTF software solutions, also known as Regulatory Technology (RegTech), to streamline their anti-money laundering and counter-terrorist financing (AML/CTF) programs and efforts, enhancing their compliance capabilities and contributing to a more robust financial system.

One of the reputable AML/CTF solutions is SentroWeb Anti-Money Laundering and Customer Due Diligence Solutions. SentroWeb provides a comprehensive AML/CTF screening feature for verifying customer identities. With its reliable and up-to-date databases, you can search against over 3.3 million consolidated profiles, including Politically Exposed Persons (PEPs), Sanctions and Watchlists.

Moreover, SentroWeb’s automated ongoing monitoring system can ensure continuous surveillance of customer names, enabling DNFBPs to promptly detect any hits or red flags associated with money laundering or terrorist financing risks.

SentroWeb also offers a customer due diligence (CDD) module, simplifying and streamlining the AML/CTF process. DNFBPs can leverage SentroWeb to digitize customer identity verification and assess the risk level of their customers with ease. By embracing SentroWeb’s CDD module, DNFBPs can not only enhance efficiency but also maintain comprehensive records for audit and compliance purposes.

By embracing these technological advancements, DNFBPs can enhance the effectiveness and efficiency of their AML/CFT measures, aiding the Philippines’ efforts to be removed from the FATF grey list.


The fight against money laundering requires a collective effort. DNFBPs have a critical role to play in ensuring the Philippines’ financial system is robust and resilient to financial crime. By actively participating in AML/CTF efforts, DNFBPs can contribute to a safer financial environment and accelerate the Philippines’ journey out of the FATF grey list.