Practice question
A compliance employee fabricates transaction details to retaliate against a former friend and knowingly sends completely false information as a supposed suspicious report. The employee invokes immunity solely because the document was delivered to AMLC. Which is best?
- The stipulated malice and bad faith defeat the claimed good-faith safe harbor; malicious-reporting provisions remain relevant
- Delivery to AMLC automatically cures deliberate fabrication
- Every report is immune regardless of motive and truthfulness
- Retaliation is an express statutory condition
- No one may ever examine good faith
Legal references
- AMLA Section 9(c), as amended by RA 9194 Section 6; malicious reporting Section14(c), amended by Section9: https://lawphil.net/statutes/repacts/ra2003/ra_9194_2003.html
- RA 10365 Section 7, reporting confidentiality: https://lawphil.net/statutes/repacts/ra2013/ra_10365_2013.html
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