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Philippine Bar review · Question

Practice question: Safe Harbor Provision

Multiple Choice Hard

Practice question

An employee validly files a good-faith report in regular duties but is separately charged with previously stealing the customer's funds. He claims the filing immunizes the earlier theft. Resolve the safe-harbor issue.
  1. Protection for making the report does not automatically immunize the independent alleged theft.
  2. A qualifying report permanently immunizes every earlier act.
  3. The report transfers the customer's property to the employee.
  4. Only the customer's nationality controls immunity.
  5. Safe harbor abolishes every property offense committed by a reporter.

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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