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Philippine Bar review · Question

Practice question: Covered Transactions; Suspicious Transactions

Multiple Choice Hard

Practice question

A covered remittance provider identifies a P100,000 transfer as related to acts violating the Anti-POGO Act after that Act took effect. The provider argues the small amount and absence of a prior conviction make suspicious reporting impossible. The facts establish the prohibited-activity link. Which is correct?
  1. Every POGO-related transfer is automatically lawful if below P500,000
  2. RA 12312 makes its violations unlawful activity, and suspicious classification is not barred by the small amount or lack of prior conviction
  3. Only transactions above P7.5 million can be suspicious
  4. The provider may disregard current law if the client once had a license
  5. A conviction must always precede any report

Legal references

  • RA 11521 Section 2: https://lawphil.net/statutes/repacts/ra2021/ra_11521_2021.html
  • RA 12312 Sections 4,8 and17: https://lawphil.net/statutes/repacts/ra2025/ra_12312_2025.html

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