Practice question
An ordinary bank client makes cash transactions totaling P600,000 within one banking day. The bank says the general covered definition can never apply because no individual cash movement exceeded P500,000. There are no special-sector facts. Which is best?
- The statutory general definition concerns a total in excess of P500,000 within one banking day, so splitting the total does not establish that exemption
- Only a single physical banknote can count
- Every separate transaction erases the day's total
- A customer may privately amend the threshold
- Only a criminal conviction can make the total relevant
Legal references
- RA 11521 Section 2, amending AMLA Section 3(b)-(b-1): https://lawphil.net/statutes/repacts/ra2021/ra_11521_2021.html
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