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Philippine Bar review · Question

Practice question: Safe Harbor Provision

Multiple Choice Medium

Practice question

An administrative complaint challenges only a good-faith suspicious report made in regular compliance duties. The complainant says safe harbor protects against civil suits alone. Which is correct?
  1. Only civil proceedings are listed.
  2. Only proceedings brought by foreign customers are listed.
  3. Only criminal proceedings after conviction are listed.
  4. The protection depends on the customer's consent.
  5. The statutory protection also addresses administrative and criminal proceedings for making a qualifying report.

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 10365, Sections 1 and 7, covered persons and reporting amendments: https://lawphil.net/statutes/repacts/ra2013/ra_10365_2013.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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