Practice question
A bank observes repeated small transactions structured, on the known circumstances, to avoid reporting requirements. Each amount is below PHP 500,000. Does that fact alone remove them from suspicious-transaction reporting?
- Yes, because every suspicious transaction must exceed PHP 500,000
- Yes, because only one large deposit may be reported
- No, because suspicious transactions are defined regardless of amount and include the specified structuring circumstance
- Yes, unless the client first confesses to an offense
- No, because every small deposit is automatically criminal
Legal references
- https://lawphil.net/statutes/repacts/ra2001/ra_9160_2001.html — RA 9160, the Anti-Money Laundering Act, read with the subsequent amendments cited below.
- https://lawphil.net/statutes/repacts/ra2003/ra_9194_2003.html — sections 1–2, covered and suspicious transactions.
- https://lawphil.net/statutes/repacts/ra2013/ra_10365_2013.html — sections 4–5 and 7, current money laundering offense, independent prosecution and reporting confidentiality.
- https://lawphil.net/statutes/repacts/ra2017/ra_10927_2017.html — sections 1–3, casino coverage and cash transactions.
- https://lawphil.net/statutes/repacts/ra2021/ra_11521_2021.html — section 2, current covered and suspicious transaction definitions and real-estate cash threshold.
- https://lawphil.net/statutes/repacts/ra2022/ra_11930_2022.html — section 9(c), sections 4–5 violations as AMLA unlawful activity.
- https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/2/100174 — RA 12312, sections 8, 16–17 and 20; October 29, 2025 newspaper publication recorded by the Supreme Court E-Library; statutory predicate rule operative before June 30, 2026.
Answer this question in flashcards to review your response and continue practicing.