Guidelines on the Electronic Submission of the Money Laundering (ML)/Terrorist Financing (TF)/Proliferation Financing (PF) Risk Event Report (RER)

OFFICE OF THE DEPUTY GOVERNOR I FINANCIAL SUPERVISION SECTOR 016 MEMORANDUM NO. 2024-______ To : All BSP-Supervised Financial Institutions (BSFIs) Subject : Guidelines on the Electronic Submission of the Money Laundering (ML)/Terrorist Financing (TF)/Proliferation Financing (PF) Risk Event Report (RER) Pursuant to Circular No. 1193, dated 29 April 2024, all BSFIs shall observe the following guidelines in the electronic submission of the ML/TF/PF RER: 1) BSFIs shall submit the required RER within the prescribed timeline, including the following: a. Banks and quasi banks, including their subsidiaries and affiliates; b. Stand-alone trust corporations; c. Non-stock savings and loan associations; d. Money service businesses (i.e., foreign exchange dealers, money changers, pawnshops, and remittance and transfer companies); e. Non-bank electronic money issuers; and f. Virtual asset service providers. 2) All BSFIs shall use the prescribed RER Data Entry Template (DET) (Annex A) which can be downloaded from https://www.bsp.gov.ph/ses/reporting_templates. Reference on how to accomplish the DET is in the attached User Guide (Annex A-1). 3) The accomplished RER DET together with the duly-signed control prooflist shall be submitted by the BSFI’s Compliance Officer and/or Duly Authorized/Designated Officer within twenty-four (24) hours from the date of knowledge or discovery of occurrence of any significant ML/TF/PF risk event to [email protected] as the official e-mail address for RER submission using the following e-mail subject and filename of the report: <RER>underscore<BSFI Acronym>underscore<Report Status>underscore<Date of Report in DD MMM YYYY > For example: RER_ABCKB_Initial Report_05 Oct 2021 A follow-up report to the same incident, if any, shall be submitted using the following e-mail subject and filename of the report: <RER>underscore<BSFI Acronym>underscore<Report Status>underscore<Date of Report in DD MMM YYYY> For example: RER_ABCKB_Follow-up Report_31 Jan 2022 The RER DET shall be submitted using the prescribed file naming convention and file extension/format, as follows: File File Name File Extension/Format RER Data Entry RER_BSFI Acronym_Date of Report in .XLS Template DD MMM YYYY RER Control Prooflist RER_BSFI Acronym_CP_Reference PDF Period in DD MMM YYYY Classification: GENERAL

4) BSFIs that are unable to transmit electronically can submit the DET and control prooflist in any encrypted portable storage device (e.g., USB flash drive) and transmit the same through messengerial or postal services within the prescribed deadline addressed to: Financial System Integrity Department Bangko Sentral ng Pilipinas 5th Floor, Multi-Storey Building BSP Complex, A. Mabini Street, Malate 1004 Manila 5) Report submission should continue to comply with the existing BSP reporting standards. It likewise follows that only files compliant with the prescribed form by the BSP for the report shall be accepted, and validated, subject to applicable penalties for reporting violations. 6) Queries regarding the ML/TF/PF RER and its related regulations may be coursed through email to [email protected] and submitted using the following e-mail subject: <RER>underscore<Query>underscore<BSFI Acronym > For example: RER_Query_ABCKB 7) In case that the ML/TF/PF risk event is also reportable under the Event-Driven Reporting and Notification (EDRN) pursuant to Sections 148/147-Q/142-P/145-S/126-N (Reporting and Notification Standards), the BSFI shall copy furnish the Financial System Integrity Department (FSID) of the BSP via [email protected] upon submission of the EDRN. 1 Digitally signed by For guidance and implementation. Chuchi G. Fonacier Date: 2024.05.27 10:45:52 +08'00' CHUCHI G. FONACIER Deputy Governor __ 27 May 2024 1 For BSFIs submitting EDRN via Advance Suptech Engine for Risk-Based Compliance (ASTERisC*), kindly select item “Reportable as ML/TF/PF Risk Event Report” when the cyber incident to be reported under EDRN also qualifies for reporting as RER. Classification: GENERAL

Annex A (1) BSFI Name (2) BSFI Code (3) Branch Code (if Branch reporting) MONEY LAUNDERING/TERRORIST FINANCING/PROLIFERATION FINANCING RISK EVENT REPORT (4) Date of report: (DD MMM YYYY) (5) Reference No: - (6) Report Status: (7) Risk Event : (8) Date of Knowledge or Discovery of Occurrence : (9) Type of Customer/Client Individual : (DD MMM YYYY) Juridical : (10) Brief Description of the Risk Event (11) Nature or Type of Transaction/Product : (12) Amount of Transaction (PhP) : (13) Mode of Transaction/Delivery Channel Used : (14) Initial Root Cause/s of the occurrence or possible occurrence of risk (15) Action/s Taken (16) Impact on the BSFI's operations (in terms of financial/operational/reputational losses) $$$$$

[BSFI NAME] (BSFI Code) MONEY LAUNDERING/TERRORIST FINANCING/PROLIFERATION FINANCING RISK EVENT REPORT CONTROL PROOFLIST I hereby certify that the contents of this risk event report which general information is described below are true and correct to the best of my knowledge. Reference No.: Report Status: Date of Occurrence/Discovery: ML/TF/PF Risk Event: Type of Customer Involved: Nature of Incident: Amount Involved: Mode of Transaction: Name and Signature of the Compliance Officer or the Designated Officer by the BSFI Date:

Annex A-1 User Guide for the Money Laundering (ML)/Terrorist Financing (TF)/Proliferation Financing (PF) Risk Event Report Data/ Format Valid Values Information Reference No. RER - BSFI Code as provided by Indicate unique assigned reference number for each BSP - Year Month Date of reported incident. Submission – Four (4) Digit assigned by the BSFI Only numeric values shall be accepted in the following format: RER-BSFI Code as provided by BSP-Year Month Date of Submission-Four (4) Digit assigned by the BSFI, which, shall be in a continuing series until the end of the year (starting at 0001). Example: RER-001234-20231103-0001 The reference number for the follow up report for the same incident shall be the same as the initially submitted report. Report Status Dropdown Indicate status of the report being submitted. Valid values are: 1 – Initial Report – initial report to be submitted. 2 – Follow up Report – in the event additional information was required from the BSFI concerned or a follow-up report is needed to be submitted. Date of DD MMM YYYY Indicate the date of knowledge or date of discovery of Knowledge or occurrence which shall pertain to the time the BSFI Discovery of been known or should have known the ML/TF/PF risk Occurrence event ML/TF/PF Risk Free form Indicate the ML/TF/PF risk event that occurred which Event may present material and adverse impact to the BSFI, the financial system’s posture or erode public confidence therein. Example: Qualified theft, Swindling, Financing of Terrorism, Fraudulent Practices and other violations under the Securities Regulations Code of 2000; Violations under Electronic Commerce Act of 2000 Brief Free form Provide short narrative of the ML/TF/PF incident that Description/ occurred. Details of the Risk Event Type of Free form For individual customer/s, indicate if accountholder, Customer/Client beneficial owner, agent, or transactor. For juridical (a) Individual customer/s, indicate the nature of its business. (b) Juridical Example: For Individuals - Accountholder, Beneficial Owner, or it’s agent, Transactor, etc. Classification: GENERAL

Annex A-1 User Guide for the Money Laundering (ML)/Terrorist Financing (TF)/Proliferation Financing (PF) Risk Event Report Data/ Format Valid Values Information For Juridical - Trading company, mining company, grocery, jewelry dealer, foundation, etc. Nature or Type Dropdown and Free Form Select the type or nature of transaction/product from of Transaction/ the dropdown list, i.e. deposit, incoming/outgoing Product remittance, e-money transaction, trade finance, wealth management, trust; or Specify the particular type of transaction/product if not included in the dropdown list. Amount of Numeric format Indicate the Philippine Peso equivalent at the time of Transaction transaction. (PhP) Mode of Dropdown and Free Form Select the mode of transaction/ delivery channel, i.e., Transaction/ internet banking, Over-the-Counter, mobile banking; Delivery or Channel Used Specify the particular type of transaction/product if not included in the dropdown list. Initial Root Free form Enumerate the initial root cause/s of the occurrence Cause/s of the or possible occurrence of risk. occurrence or possible (Example: issues on controls, system upgrading, etc.) occurrence of risk Use semi colons to separate each root cause or possible risk (if multiple). Action/s Taken Free form Enumerate the action/s taken by the BSFI relative to the risk event (Example: reported to AMLC, freeze the account, etc.) Use semi-colon to separate each action. Impact on the Free form Cite impact on BSFI’s operations in terms of financial, BSFI's operational, or reputational losses. operations (in terms of (Example: losses incurred; number of financial/ customers/accounts affected; number of complaints operational/ received; disrupted operations, etc.) reputational losses) Use semi-colon to separate each impact (if multiple). Classification: GENERAL