Guidelines on the Submission of the Report on Temporarily-Held Funds (THF) through the Advanced Suptech Engine for Risk-based Compliance (ASTERisC*) Platform and the Execution of Annual Notarized Certification

OFFICE OF THE DEPUTY GOVERNOR I FINANCIAL SUPERVISION SECTOR MEMORANDUM NO. M-2026-029 _________ To : ALL BANGKO SENTRAL-SUPERVISED INSTITUTIONS (BSIs) Subject : Guidelines on the Submission of the Report on Temporarily-Held Funds (THF) through the Advanced Suptech Engine for Risk-based Compliance (ASTERisC*) Platform and the Execution of Annual Notarized Certification To implement Republic Act No. 12010, otherwise known as the Anti-Financial Account Scamming Act (AFASA), the BSP issued Circular No. 1215 covering regulations on the temporary holding of funds subject to disputed transactions and the coordinated verification process. Pursuant to the Circular, all Bangko Sentral-Supervised Institutions (BSIs) are required to submit periodic reports on funds subject to temporary holding and an annual notarized certification on compliance with the related requirements of adequate risk management systems and controls to the Bangko Sentral. Accordingly, the following guidelines shall be observed: A. Report on Temporarily-Held Funds (THF) 1. These guidelines on the submission of Report on Temporary Holding of Disputed Funds shall take effect on 09 July 2026, or one (1) year from the effectivity of BSP Circular No. 1215. 2. The following guidelines shall apply to all Banks, Electronic Money Issuers (EMI), Virtual Asset Service Providers (VASP), and all other BSIs enrolled in ASTERisC*. a. The Data Entry Template (DET) for the THF report shall be deployed in ASTERisC* and shall be made available to existing users upon issuance of this memorandum. ASTERisC* is accessible through https://asterisc.bsp.gov.ph. Meanwhile, BSIs may access the system in advance to familiarize themselves with the DET. b. The ASTERisC* user manual, instructional videos, data import template, and Control Prooflist (CP) for the THF report and the ASTERisC* User Account Form (UAF) are accessible in the BSP website (www.bsp.gov.ph/ses/reporting_templates). New and existing ASTERisC* users are required to review the instructional videos and user manual prior to submission of reports on THF through ASTERisC*. c. The scanned CP (see Annex A for the CP Template) in Portable Document Format (PDF) shall be signed by the President/Chief Executive Officer and Chief Compliance Officer or Officers of equivalent rank, duly designated by the BSI’s Board of Directors of the reporting entity and attached to the monthly record in ASTERisC*. d. An email notification will automatically be sent to the ASTERisC* authorized user once the monthly THF report is submitted. 3. The Guidelines on the Submission of Report on Temporary Holding of Disputed Funds (see Annex B) as specified under Annex C of BSP Circular No. 1215 or Appendix

162/Q-106/1105-3 of the MORB/MORNBFI/MORPS1 shall remain applicable to all other BSIs not covered in #2 above. The prescribed DET, CP (see Annex A), and user guide may also be downloaded from the BSP website (www.bsp.gov.ph/ses/reporting_templates). 4. BSIs shall submit the THF report on or before the 15th of the month, covering the data from the previous reference month. A BSI is not required to submit a THF report if no funds were held during the reference month. Non-submission shall be deemed as the BSI’s formal declaration that it held no funds. 5. Initial submission of the THF Report shall be due on 15 September 2026 covering the THF for the month of August 2026. B. Annual Notarized Certification on Compliance 1. Within thirty (30) calendar days from end of year, BSIs that initiated or effected Temporary Holding of Disputed Funds during the immediately preceding year shall execute and submit to the Consumer Account Protection Office (CAPO) a notarized certification that it complied with the related requirements of adequate risk management systems and controls as prescribed by the Bangko Sentral at the time that it initiated or effected the holding of funds. 2. The scanned copy of the notarized certification (see Annex C for the certification template) in PDF shall be transmitted to [email protected], using the following e-mail subject format: ANC<Space><BSI NAME><Space><Date of Approval by the BSI President or Officer of equivalent rank in DD MONTH YYYY format> For example: TO: [email protected] SUBJECT: ANC ABC Bank 29 JANUARY 2027 For inquiries regarding the THF reporting requirements and annual notarized certification on compliance, BSIs may contact the Consumer Account Protection Office at [email protected]. For technical issues related to the ASTERisC* platform, coordinate with the Technology Risk and Innovation Supervision Department (TRISD) at [email protected]. For compliance. Digitally signed by LYN I. JAVIER Lyn I. Javier Deputy Governor __ 24 June 2026 1 Manual of Regulations for Banks (MORB), Manual of Regulations for Non-Bank Financial Institutions (MORNBFI), and Manual of Regulations for Payment Systems (MORPS)

Annex A (Name of BSP-Supervised Institution)(BSI Code) Report on Temporarily-Held Funds (THF) Monthly Report CONTROL PROOFLIST I hereby certify that the contents of this monthly report which includes details of Temporarily-Held Funds (THF) are true and correct to the best of my knowledge. Report Cutoff Month-Year Part 1: Volume of Temporarily-Held Funds Number of Disputed Number of Disputed Transactions reported as Transactions reported as Number of Disputed 'Released to Beneficiary 'Released to Source Transactions reported Account Owner - Account Owner - as 'Ongoing - Funds Amount on hold was Trigger to Hold Funds Amount on hold was remain on hold' under released to the released to the Source Status of Held Funds at Beneficiary Account Account Owner' under the Time of Reporting Owner ' under Status of Status of Held Funds at Held Funds at the Time the Time of Reporting of Reporting Complaint filed by Source Account Owner BSI’s own Fraud Management System (Outgoing Transactions) – flagged by Originating Financial Institution BSI’s own Fraud Management System (Incoming Transactions) – flagged by Receiving Financial Institution Information from another BSP Supervised Institution (Based on Complaint or FMS Finding) – Initial Holding Request based on complaint or FMS Information from another BSP Supervised Institution (Based on Other Grounds) – Initial Holding Request not based on complaint or FMS TOTAL

Part 2: Amount (in Philippine Pesos*) of Temporarily-Held Funds Total Amount of Total Amount of Total Amount of Disputed Disputed Disputed Transactions Transactions reported as Transactions reported as 'Released to 'Released to Beneficiary reported as Source Account Owner - Account Owner - Amount Trigger to Hold Funds 'Ongoing - Funds Amount on hold was on hold was released to remain on hold' released to the Source the Beneficiary Account under Status of Account Owner' under Owner ' under Status of Held Funds at the Status of Held Funds at Held Funds at the Time of Time of Reporting the Time of Reporting Reporting Complaint filed by Source Account Owner BSI’s own Fraud Management System (Outgoing Transactions) – flagged by Originating Financial Institution BSI’s own Fraud Management System (Incoming Transactions) – flagged by Receiving Financial Institution Information from another BSP Supervised Institution (Based on Complaint or FMS Finding) – Initial Holding Request based on complaint or FMS Information from another BSP Supervised Institution (Based on Other Grounds) – Initial Holding Request not based on complaint or FMS TOTAL *For the PHP equivalent of foreign currency amounts that are subject to hold, use the updated BSP Reference Rate Exchange Bulletin at the time of reporting Chief Compliance Officer (or duly-authorized officer of equivalent rank) (Signature over Printed Name) President/Chief Executive Officer (or duly-authorized officer of equivalent rank) (Signature over Printed Name)

Annex B

Annex C <Name of BSI> CERTIFICATION ON COMPLIANCE WITH ADEQUATE RISK MANAGEMENT SYSTEMS AND CONTROLS PRESCRIBED BY THE BANGKO SENTRAL NG PILIPINAS We, <Name of Officer>, President (or Officer of Equivalent Rank) and <Name of Officer>, Chief Compliance Officer, on behalf of the <Name of BSI>, with head/principal office address at <complete address of Head/Principal Office>, after having been duly sworn in accordance with law. Hereby certify to the best of our knowledge, that <Name of BSI>: 1. Temporary Holding of Disputed Funds was initiated or effected during the immediately preceding year, <Insert year>, in accordance with the Anti-Financial Account Scamming Act (AFASA), its implementing rules and regulations, and other regulations issued by the Bangko Sentral; 2. Adequate risk management systems and controls are in place to secure digital channels and customer accounts and; 3. Appropriate policies and procedures have been adopted to address all security risks and concerns affecting the digital channels and customer accounts; 4. Vulnerability assessment and penetration testing, and other relevant security test and evaluation are conducted regularly, in compliance with the regulations of the Bangko Sentral; and 5. Policies and procedures for coordinated verification and temporary holding of funds is in place. We also certify that all relevant documents in support of the foregoing statements are kept on file and are readily available for verification by examiners of the Bangko Sentral during onsite verification/examination or when a written request is made to verify compliance. This certification executed on <date of execution> is being submitted in compliance with the requirements of the Bangko Sentral. Signed: Signed: <Name> <Name> President (or Officer of Equivalent Rank) Chief Compliance Officer SUBSCRIBED AND SWORN to before me, this _____ day of _____ at __________, with affiant exhibiting their valid identifications indicated below: Name Government ID/Passport No. Date/Place Issued Notary Public