Reports on covered transactions (CTRs) and suspicious transactions (STRs)

MEMORANDUM TO ALL PAWNSHOPS Series of 2006

Pursuant to the provisions of Republic Act (RA) No. 9160 (The Anti-Money Laundering Act of 2001) as amended by RA No. 9194, as implemented under Circular Nos. 302 and 333 dated 11 October 2001 and 30 May 2002, respectively, all pawnshops are required to submit reports on covered transactions (CTRs) and suspicious transactions (STRs).

A covered transaction is a transaction in cash or other equivalent monetary instrument involving a total amount in excess of five hundred thousand pesos (PHP500,000.00) within one (1) banking day.

Suspicious transactions are transactions, regardless of the amount involved, where any of the following circumstances exist:

1. there is no underlying legal or trade obligation, purpose or economic justification;

2. the client is not properly identified;

3. the amount involved is not commensurate with the business or financial capacity of the client;

4. taking into account all known circumstances, it may be perceived that the client’s transaction is structured in order to avoid being the subject of reporting requirements under the Act;

5. any circumstance relating to the transaction which is observed to deviate from the profile of the client and/or the client’s past transactions with the covered institution;

6. the transaction is in anyway related to an unlawful activity or offense under the Act that is about to be, is being or has been committed; or

7. any transaction that is similar or analogous to any of the foregoing.

Pawnshops shall submit the covered transaction and suspicious transaction reports to the Anti-Money Laundering Council (AMLC) at 5th Floor EDPC Building, Bangko Sentral ng Pilipinas Complex, Manila, Philippines, within five (5) banking days from occurrence of the covered or suspicious transactions. Sanctions/penalties shall be imposed against pawnshops that will fail to comply with the provisions of RA No. 9160, as amended.

For strict and immediate compliance.

LEILANI M. CANULLAS Officer-in-Charge