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Philippine Bar review · Question

Practice question: Covered Transactions; Suspicious Transactions

Multiple Choice Medium

Practice question

A licensed covered casino handles one casino cash transaction of exactly PHP5 million. No suspicious indicator or other relevant transaction exists. Does the amount alone exceed RA 10927's special threshold?
  1. Yes; exactly equal always means in excess.
  2. Yes; the real-estate threshold must be substituted.
  3. No; because licensed casinos are never covered persons.
  4. No; the special covered threshold is in excess of PHP5 million.
  5. Yes; every casino transaction is automatically a conviction.

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.