Anti-money laundering

As a financial institution that caters to millions of customers in the Philippines and abroad for various banking and investment needs, BPI is well-prepared and committed to support the fight against money laundering and terrorist financing. It acknowledges its obligations to unite with the government and with organizations of financial institutions, local and foreign, to close the channels that are being used by money launderers and terrorist organizations for their unlawful objectives. To achieve this commitment, the bank adopted a comprehensive and risk-based Money Laundering/Terrorism and Proliferation Financing Prevention Program (MTPP) geared towards the promotion of high ethical and professional standards and the prevention of BPI being used for money laundering and terrorist financing/Proliferation Financing (ML/TF/PF).

Objectives

This MTPP shall ensure consistent and effective compliance with the Philippine’s Anti-Money Laundering Act (AMLA), as amended, the Terrorism Financing Prevention and Suppression Act (TFPSA), their respective Implementing Rules and Regulations (IRR), and Part 9 of the Manual of Regulations for Banks (MORB) and its amendments as issued by the Bangko Sentral ng Pilipinas or BSP (Central Bank of the Philippines). It also aims to protect the Bank and its employees from being used for the ML/TF/PF activities of criminals.

Policies

To achieve these objectives, BPI adopted a comprehensive and risk-based MTPP which includes policies, controls and procedures to enable the Bank to manage and mitigate the risks that have been identified in the risk assessment, including taking enhanced measures for those classified as high risks. The MTPP is consistent with the AMLA, as amended, the TFPSA, their respective IRR and the provisions set out in Part 9 of BSP’s MORB.

The MTPP is in writing, approved by the Board of Directors, through its Executive Committee and Audit Committee, and well disseminated to all officers and staff to implement the same. For its subsidiaries and offices located outside the Philippines, there is a consolidated ML/TF risk management system to ensure the coordination and implementation of policies and procedures on a group-wide basis, taking into account local business considerations and the requirements of the host jurisdiction.

The MTPP is anchored on the following four (4) pillars:

1. Risk Management System

A sound anti-money laundering and counter-terrorism/proliferation financing (AML/CTPF) risk management system that identifies, assesses, monitors and controls risk associated with ML/TF was adopted and implemented. This aims to avoid being used as channel of these criminal activities through adequate and active Board and Senior Management oversight, appropriate policies and procedures embodied in the MTPP, appropriate monitoring, reporting and comprehensive internal controls and audit.

2. Customer identification Process

The true identity of all customers including their beneficial owners, if applicable, seeking to avail of BPI’s products and services are determined and verified. Customers are risk profiled, which will dictate the level of customer due diligence to be applied during onboarding and periodic revalidation/refresh. Customer profiled as high risk are subjected to enhanced due diligence and senior management approval. All customers are screened against sanctions lists, watchlists and lists of high risk jurisdictions to identify those who should be rejected and those who should be subjected to deeper scrutiny prior to onboarding and during the existence of the business relationship with the bank.

3. Reporting of Covered and Suspicious Transactions

Appropriate measures required by law are taken if there are reasonable grounds for suspecting ML/TF, including investigation and reporting and suspicious transactions, and cooperating with investigations or complying with requirements of authorized body. In addition, all single transactions amounting to more than P500,000 or its equivalent are reported to the AMLC through covered transaction reports.

4. Training

A comprehensive training program was designed to cover all parts of the MTPP to ensure that all employees are well informed and trained to adequately comply with the policies which included customer due diligence, risk profiling, sanctions screening, and ongoing monitoring, among others. All employees are required to complete this training at least once a year and must pass the test given at the end of the training program.

Ongoing thrust

Financial institutions can fight the evil effects of ML/TF/PF following the standards set by government and international organizations. BPI, for its part, has done and is continuously doing the following, in conformity with the standards set by the local banking authority and international organizations:

1. Formation of an adequately manned Anti-Money Laundering (AML) Department, headed by a senior-level management officer, which will be the “watch dog” in preventing and detecting potential money laundering and suspicious financial activities of clients.

2. Strict implementation of the Bank’s MTPP in accordance with local and international standards.

3. Conscientious observance of strict customer due diligence (CDD) and “know-your-customer” (KYC) policy as the first line of defense against ML/TF/PF and as an ongoing customer relations concern.

4. Investment in state of the art technology and other automated tools that can help identify and monitor financial transactions and activities that appear to be suspicious.

5. Adequate screening and recruitment process to ensure that only qualified personnel who have no criminal record/s are employed to assume sensitive banking functions.

6. Reliance on the training, accountabilities and responsibilities of our front-line employees, i.e. branch managers, relationship managers and customer service people, in identifying fully the parties with whom BPI is doing business and in ensuring that all transactions conducted by the customers are proper.

7. Maintenance of customers’ identification and transaction documents in compliance to the existing rules and regulations.

8. AML Department’s monitoring of transactions and periodic compliance test checks of all business units, and the reporting of violations, if any, to senior management for appropriate action.

9. Regular updating of the Bank’s MTPP at least once every 2 years, or when there are changes in regulations, whichever comes first, to incorporate changes in AML policies and procedures, latest trends in ML/TF typologies, and latest pertinent regulatory issuances.

10. Recognition that deterrence of ML/TF/PF is an ongoing concern that requires due diligence and vigilance to keep pace with the evolving schemes adopted by money launderers and terrorist organizations.

Continued Vigilance

Money launderers and terrorist organizations will not be deterred until their ill objectives have been accomplished. They will find new ways and means to continue their illicit activities. In order to put a stop and close the channels of their evil ways, BPI will not rest its guard and will, instead, continue to explore the schemes that these criminals may adopt. BPI fully commits to continue to educate its personnel and evaluate its policies, procedures and systems and update these, as needed. BPI will constantly invest its resources and boost its efforts to prove its dedication in combating ML/TF/PF.