Practice question
A covered real-estate broker handles a single cash transaction of exactly PHP7.5 million. No suspicious circumstance is present. What is the correct amount-only analysis under RA 11521?
- It exceeds the threshold by definition.
- The casino PHP5 million rule necessarily controls the broker.
- Every broker transaction is excluded from AMLA.
- The threshold applies only after criminal conviction.
- It does not exceed the real-estate-sector threshold.
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
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