Published by Anti-Money Laundering Council(AMLCS) on March 15, 2022.
Requested from AMLC by R. Rubio at 05:05 PM on
March 15, 2022.
Purpose: Bank requirements
Date of Coverage: 03/15/2022 - 03/15/2022
Tracking no: #AMLCS-976283202068
I.FAYLONA
March 15, 2022, 5:05 p.m.
Hi AMLC,
I would like to kindly request to have an AMLA Certificate as a new requirement for my BDO Bank account update per request of the bank.
Sincerely,
Ivan Faylona
F.OFFICER
March 17, 2022, 3:34 p.m.
March 17, 2022
Dear Mr. Faylona,
We refer to your request dated Mar 15, 2022 05:05:21 PM about your request under Executive Order No. 2 (s. 2016) on Freedom of Information in the Executive Branch, for the issuance of an AMLA certificate.
In order for us to work further on your request, we need more information from you regarding your query. In particular, please answer yes or no to the following questions:
1. Are you transacting for yourself (personal transaction)?
2. Is the bank account being used for/on behalf of a company?
3. Give a short description for the company’s line of business you are transacting for.
You may use the reply function on the eFOI portal at https://www.foi.gov.ph/requests/aglzfmVmb2ktcGhyHwsSB0NvbnRlbnQiEkFNTENTLTk3NjI4MzIwMjA2OAw, for request with ticket number #AMLCS-976283202068, to respond.
During the period of us awaiting your reply, your request will be put on hold. If we do not receive a reply on or before Jun 09, 2022 07:32:52 AM, your request will be closed.
We hope to hear from you at the soonest possible time.
Thank you.
Respectfully,
FOI Receiving Officer
FOI Officer
I.FAYLONA
March 18, 2022, 7:26 p.m.
To FOI receiving officer,
To whom it may concern,
Here are my answers to the questions you provided.
1. Are you transacting for yourself (personal transaction)? Answer: Yes this is a personal transaction with the bank.
2. Is the bank account being used for/on behalf of a company? Answer: Yes. I am using the bank account for business purposes also.
3. Give a short description for the company’s line of business you are transacting for. Answer: We are into real estate business and we are selling subdivided farm lots.
I.FAYLONA
March 23, 2022, 12:09 a.m.
#AMLCS-976283202068
F.OFFICER
March 23, 2022, 11:09 a.m.
March 23, 2022
Dear Mr. Faylona,
May we know if you are transacting as a licensed real estate broker or developer? If no, can you give us a brief description of your actual role in the real estate business that you just disclosed.
Thank you.
Respectfully,
FOI Receiving Officer
I.FAYLONA
March 23, 2022, 7:54 p.m.
Hi FOI Officer,
Good day! I am working as a real estate agent under a licensed broker. Hope this helps.
Sincerely,
Ivan Faylona
I.FAYLONA
March 23, 2022, 7:55 p.m.
#AMLCS-976283202068
F.OFFICER
March 31, 2022, 2:46 p.m.
March 31, 2022
Dear Mr. Faylona,
We refer to your request dated Mar 15, 2022 05:05:21 PM about your request under Executive Order No. 2 (s. 2016) on Freedom of Information in the Executive Branch, for Amla certificate.
In order for us to work further on your request, we need more information from you regarding your query. May we further clarify whose name the BDO account being updated is under? Whether the account is under your name or the licensed real estate broker?
You may use the reply function on the eFOI portal at https://www.foi.gov.ph/requests/aglzfmVmb2ktcGhyHwsSB0NvbnRlbnQiEkFNTENTLTk3NjI4MzIwMjA2OAw, for request with ticket number #AMLCS-976283202068, to respond.
During the period of us awaiting your reply, your request will be put on hold. If we do not receive a reply on or before Jun 23, 2022 06:45:09 AM, your request will be closed.
We hope to hear from you at the soonest possible time.
Thank you.
Respectfully,
FOI Receiving Officer
I.FAYLONA
March 31, 2022, 11:18 p.m.
Hi Mr/Ms. FOI Officer,
Good day! The BDO Bank Account is under my name. Have a great day and stay safe.
Looking forward,
Ivan Faylona
F.OFFICER
April 5, 2022, 10:37 a.m.
April 5, 2022
Dear Mr. Faylona,
Thank you for your request dated Mar 15, 2022 under Executive Order No. 2 (s. 2016) on Freedom of Information in the Executive Branch, for Amla certificate.
We received your request on Mar 15, 2022 and will respond on or before Apr 05, 2022 05:05:21 PM, in accordance with the Executive Order's implementing rules and regulations.
Should you have any questions regarding your request, kindly contact me using the reply function on the eFOI portal at https://www.foi.gov.ph/requests/aglzfmVmb2ktcGhyHwsSB0NvbnRlbnQiEkFNTENTLTk3NjI4MzIwMjA2OAw, for request with ticket number #AMLCS-976283202068.
Thank you.
Respectfully,
FOI Receiving Officer
A.DECISION MAKER
April 5, 2022, 10:40 a.m.
April 5, 2022
Dear Mr. Faylona,
Thank you for your request dated 15 March 2022 under Executive Order No. 2 (S. 2016) on Freedom of Information in the Executive Branch.
The bank is particularly requesting for a Provisional Certificate of Registration (PCOR) with the Anti-Money Laundering Council (AMLC).
In view of the information you provided, that you are transacting as a real estate agent under a licensed real estate broker, we inform you that pursuant to Section 2.d of the 2021 Anti-Money Laundering/Counter-Terrorism Financing Guidelines for Designated Non-Financial Business and Professions (DNFBP Guidelines) it is the licensed real estate broker or real estate developer who should apply for the PCOR as they are the ones specifically considered under Republic Act No. 9160, otherwise known as the Anti-Money Laundering Act, as amended (AMLA) as a covered person.
Considering that you are neither a licensed real estate broker nor a real estate developer, and that the purpose of your request is for updating your BDO account to be used in the real estate business, you are not required to register with the AMLC. We suggest clarifying with your bank that you are an agent of a real estate broker and that the AMLA requires the PCOR only for the licensed real estate broker to avoid further confusion.
We hope we have been of assistance.
Respectfully,
FOI Decision Maker
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