Practice question
A company offers, as a business to third parties, a registered office and correspondence address for legal entities. It says AMLA company-service-provider coverage requires physically forming the client company as well. Resolve.
- All listed services must always be performed together.
- The listed address-provision service is itself a covered company-service-provider activity; formation is not a cumulative requirement.
- Only the client's bank can ever be covered.
- Address services are excluded even when provided as a business to third parties.
- The provider becomes exempt merely by using the word consultant.
Legal references
- RA 9160, Section 9(a)-(b), customer identification and recordkeeping: https://lawphil.net/statutes/repacts/ra2001/ra_9160_2001.html
- RA 10365, Sections 1 and 7, covered persons and reporting amendments: https://lawphil.net/statutes/repacts/ra2013/ra_10365_2013.html
- RA 10927, casino coverage and casino covered-transaction threshold: https://lawphil.net/statutes/repacts/ra2017/ra_10927_2017.html
- RA 11521, amended covered-person and covered-transaction provisions: https://lawphil.net/statutes/repacts/ra2021/ra_11521_2021.html
- RA 12312, Sections 8 and 17, Anti-POGO Act AMLA amendment: https://lawphil.net/statutes/repacts/ra2025/ra_12312_2025.html
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