Log In Create Account

Philippine Bar review · Question

Practice question: Covered Transactions; Suspicious Transactions

Multiple Choice Hard

Practice question

A covered casino receives a single casino cash payment in foreign currency. Its properly established equivalent is PHP5.3 million. The casino says only peso-denominated payments can cross its covered-transaction threshold. Resolve.
  1. The foreign-currency equivalent also counts under the statutory casino threshold.
  2. Only physical Philippine banknotes can count.
  3. Foreign currency automatically makes the transaction lawful and unreportable.
  4. The threshold becomes PHP7.5 million whenever dollars are used.
  5. Currency conversion is prohibited for every AML classification.

Legal references

  • RA 9194, Sections 1-2 and 6, AMLA transaction definitions and Section 9(c) safe harbor: https://lawphil.net/statutes/repacts/ra2003/ra_9194_2003.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

Answer this question in flashcards to review your response and continue practicing.