Subject: Circular Letter - Anti-Money Laundering Council (AMLC) Resolution No. 30-A dated 13 April 2011

BANEKo SENTRAL No PtLtPINAg OFFICE OF THE DEPUW GOVERNOR Supervision and Examination Sector clRcutAR LETTER NO. Ct-2011- 033 To All Banks and Non-Bank Financial Institutions Under BSp Supervision Subject Circular letter - Anti-Money Laundering Council (AMLC) Resolution No. 30-A dated 13 April 2011 Pursuant to Anti-Money Laundering council Resolution No. 30-A dated 13 April 2011 (copy attached), you are hereby informed that on 10 March 2011, the United Nations Secu- rity council Al-Qaida and Taliban Sanctions (scAaTs) committee approved the addition of DOKU KHAMATOVTCH UMAROV to its Consolidated List of Individuals and Entities subject to the Assets Freeze, Travel Ban and Arms Embargo set out in paragraph l ofSecurity Coun- cil Resolution 1904 (2009) adopted under Chapter Vll of the Charter of the United Nations. Under the same resolution, all covered institutions are likewise directed to submit to the AMLC reports on suspicious transactions, if any, involving DoKll KHAMATIV,CH uMA- f,OV, including all transactions that occurred within the past five (5) years counting from date of receipt of the Resolution. For your guidance and strict implementation. ft4'"65 4Aprit2ort A/s A. I\'labiniSt,, Malate ].004 Maflila, philippine5 . {632} 524-7011 o yyww.bsp.gov.ph . bsp,nait6,bsp.gov.ph

Anti-Money Laundering Council Bangko Sentral ng Pilipinas Complex Manila, PhiliPPines RESOLUTION NO. Series of 2011'O-A In its Memorandum dated 29 March 2011, the AMLC Secretariat (AMLCS) reported to the Council that: On 7O March 2071, the Llnited Notions Security Council Al-Qoido ond Tolibon sanctions committee approved the addition of on individuol to its consolidoted List ("consotidqted List") of individuals ond entities subject to the osset freeze, travel bon and arms embargo set out in parogroph 11 of Security Council Resolution 1'904 (2009) odopted under chopter vll of the chqrter of the lJnited Nations. The details of the individuol odded in the list ore os follows: A. lndividuols ossociated with the Talibon Name 1: DOKU 2: KHAMATOVICH 3: UMAROV 4: no Name (original scriqt) Ynopoa floxy XaMomoou'l Title no Designation no DOB 72 Moy 1964 POB Kharsenoy Villoge, Shatoyskiy (Sovetskiy) District, Chechenskoya Respublika, Russian Federation Good quality a,k.o. no Low quality a.k,o. NQ Notionality a) Russion b) USSR (until 1997) Passport no. no Noitione,l no I 1. Decides that all States shall take the measures as previously imposed by paragraph 4 (b) of Resolution |267(|ggg),paragraphs(c)ofResolution1333(2000),andparagraphsland2of.Resolution1390 -to (2002), witir' i"rp".t Al-Qaida, usama bin Laden and the Taliban, and other individuals, groups, resolutions 1267 una".taklng and intities associated-with them, as referred to in the list created pulsuant to (1999) and 1333 (2000) ("the Consolidated List).

identificotion no. Address no Listed on 10 Mar. 20L7 Other informotion Resides in the Russian Federation as ot Nov. 2010. lnternationol orrest worront issued in the year 2000. Doku Khamotovich lJmorov was included in the consolidoted List os being ossocioted with At-Qoida, usama bin Lqden or the Tolibon for "porticipoting in the financing, planning, facilitating, preparing, or perpetroting octs or octivities by, in coniunction with, under the nome of, on behalf of, or in support of, "recruiting for'', "supplying, selling or tronsferring arms and reloted materiel to" and "otherwise supporting octs or activities of" the tslamic Jihad Group, the Islamic Movement of IJzbekistan, and Riyodus-sqlikhin Reconnaissonce and sabotage Bottalion of Chechen Martyrs (RSRSBCM) (QE.R.100.03). As odditionot information, Doku Khomatovich lJmorov held the position of "secretary of the Security Council" of the self-procloimed "Republic of tchkerio" in 1997. tn August 7999, as commonder of the so- called "south-western front", he helped orgonize ond actively porticipated in on attack by militonts on the Republic of Dageston, the Russian Federotion. tn August 2004, he wos oppointed "M.inister of State Security of lchkerio" ond issued o direct order for the eliminotion of Russion ond foreign citizens. Doku lJmarov wos appointed "Vice-President of lchkerio" on 75 June 20O5, by decree of Abdut Kholim Soduloyev' the self-procloimed "President of the Chechen Republic of lchkeria"' On 77 June 2005, he took over "presidentia!" duties foltowing the death of his predecessor, Abdul Khalim Sadulayev. He appointed Shomil Salmonovich Bosoyev os his deputy. Doku lJmarov was directly involved in orgonizing o number of major terrorist acts: the capture of residential areos ot' the vedenski and Urus-Martonovski districts of the . Chechen Republic the Russian Federation (August 2002); the kidnopping of staff from the Office of the Public Prosecutor of the Chechen Republic (December 2002); and the bombings of the building hausing, the Department of the Russian Federal Security Service for the Republic of tngushetia, in the city of Magos, ond of two roilwoy troins in Kislovodsk (September 20A3). He wos one of the main orgonizers of the raid on lngushetio by militonts on 22 June 2004' the sortie into Grozny dn 27 August 2004, the hostsge-taking in Beslon of

7-3 September 2004 ond the terrorist attacks in Moscow metro stations on 29 Morch 2O10. Doku tJmarov is the leader of the Coucosus Emirate (Emorat Kavkaz). He has approximotely 750 militonts under his commond os wel! os emissaries in foreign countries. ln addition, he has overall command of groups operating in the North Coucasus, organizes mojor terrorist octs and . coordinates the provision of resources to militonts. Doku lJmarov, as the leoder of the Caucasus Emirate, has past connections to severol listed entities, including the lslamic Movement of tJz:bekiston (QE.1.10.01-) ond the tslomic Jihod lJnion (QE.l:779'05). tn o stqtement released in May 2009, Doku Umorov took credit for restoring the Riyodus-Sofikhin Reconnoissonce ond Sobotage Bottolion of Chechen Mortyrs (RSRSBCM) (QE.R.1O0.O3), a group previously ted by Shamil Solmonovich Basayev (Q|.8.107.03) and responsible for a number of high profile attacks in Russia. Since 2009, the RSRSBCM has publicly taken credit for severol terrorist attacks in Russia and hos cloimed to oct under direct orders of Doku Umorov. The Russion outhorities have opened o cose file on Doku lJmorov on the grounds of uimes of gangsterism, attempted murder of o law enforcement officer, kidnopping, robbery, terrorism, murder, and illicit sale of orms, ommunition ond explosives. In 7992, Doku Umarov was chorged with two counts of murder ond was chorged in obsentio for a crime committed under orticle 702 of the Russion Criminol Code. ln 2000, . on internationol warrant wos issued for his orrest. The inclusion of DOKU KHAMATOVICH |MAROV in the Consolidoted List volidotes his being ossociated with the Al Qaido, o known terro rist org a n izoti on. The United Nations Security Council Resolution (UNSCR) 1373, adopted on 28 September 2001., provides that: "The Security Council, Acting under Chapter Vll of the Charter of the United Nations, 1. Decides that all States shall:

{a) Prevent and suppress the financing of terrorist acts; (b) Criminalize the wiltful provision or collection, by any means, directly or indirectly, of funds by their nationals or in their territories with the intention that the funds should be used, or in the knowledge that they are to be used, in order to carry out terrorist acts; (c) Freeze without delay funds and other financial assets or economic resources of persons who commit, or attempt to commit, terrorist acts or participate in or facilitate the commission of terrorist acts; of entities owned or controlled directly or indirectly by such persons; and of persons and entities acting on behalf of, or at the direction of such persons and entities, including funds derived or generated from property owned or controlled directly or indirectly by such persons and associated persons and entities; (d) prohibit their nationals or any persons and entities within their territories from making any funds, financial assets or economic resources or financial or other related services available, directly or indirectly, for the benefit of persons who commit or attempt to commit or facilitate or participate in the commission of terrorist acts, of entities owned or controlled, directly or indirectly, by such persons and of persons and entities acting on behalf of or at the direction of such Persons." Section 7(1) of R.A. 9160, as amended, provides: "SEC.7. Creation of Anti-Money Laundering Council (AMLC) - The Anti-Money Laundering council is hereby created and shall be composed of the Governor of the Bangko Sentral ng Pilipinas as chairman, the commissioner of the Insurance commission and the chairman of the securities and Exchange commission as members. The AMLC shall act unanimously in the discharge of its functions as defioed hereunder: (1) to require and receive covered or suspicious transaction reports f rom covered institutions; x," Moreover, the Revised lmplementing Rules and Regulations of the Anti-Money Laundering Act of 2001, as amended, provide:

"Rule 13.7.2. Authority to Assist the United Nations and other International Organizations and Foreign States. - The AMLC is authorized under Section 7 (8) and 13 (b) and (d) of the AMLA to receive and take action in respect of any request of foreign states for assistance in their own anti-money laundering operations. lt is also authorized under Section 7 (71 of the AMLA to cooperate with the National Government and/or take appropriate action in respect of conventions, resolutions and other directives of the United Nations (UN), the UN Security Council, and other international organizations of which the Philippines is a member. However, the AMLC may refuse to comply with any such request, convention, resolution or directive where the action sought therein contravenes the provision of the Constitution or the execution thereof is likely to prejudice the national interest of the Philippines." As a charter member of the United Nations and as part of the international coalition against terrorism; the Philippines, through the Anti-Money Laundering Council, must actively support the actions required underthe subject UNSC Resolutions. The Council resolved to: (1) Direct all covered institutions to submit to the Anti-Money Laundering Council reports on suspicious transactions, if any, involving DOKU KHAMATOVICH UMAROV, including all transactions that occurred within thg past five (5) years counting from the date of receipt of this Resolution; and (2) Request the Supervising Authorities to disseminate copies of this Resolution to all covered institutions under their respective jurisdictions. 1V npril2011, Manila, Philippines. -- _ \\ /v ESTOR A, EEPENIT (Officer-in-Charge, Bangko Sentral ng Pilipinas) #Jnknn" Member (Chairman, Securities and Exchange Commission) (Commissioner, Insurance Commission)