Practice question
A covered, lawfully operating casino receives one PHP 6 million cash transaction related to gaming operations. It argues that casino transactions are never covered because it is not a bank. Which is correct?
- The casino is correct because only banks are covered persons
- The casino is covered with respect to casino cash transactions, and the single transaction exceeds its PHP 5 million threshold
- The transaction is exempt because all gaming receipts are cash
- The transaction is covered only if it reaches PHP 7.5 million
- Casino transactions can be reported only after a money laundering conviction
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.
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