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TO

SUBJECT

Republic of the PhilippinesDepartment of Finance

INSURANCB COMMISSION1071 United Nations Avenue

1\4anila

Circular No.Date

. 2016-18: 23 Marelt 2O15

CIRCULAR LETTER

All Life lnsurance Companies Authorized to Do BusinessIn the Philippines

Filing of 2015 Annual Statements

ln connection with the filing of the 2015 Annual Statements, the following guidelinesare hereby issued:

1. Submission of three (3) sets blue Annual Statement of life insurancecompanies as of December 31 , 2015 shall be signed and sworn to by thepresident, ch ief operati ng offi cer/general ma nager, secretary, treasu rer,actuary and chief accountant and shall be on legal size bond paper (8 112 x14 inches), using either the Times New Roman font size#12 or Arial fontsize#10 printed at 100 percent normal size;

2. The Annual Statement should be "Soft Cover Binding", permanent adhesive;

3. Annex "A" is the updated list of the required documents and other scheduleswhich shall form part as attachments in the submission of AnnualStatements. THIS MUST BE SUBMITTED lN SEPARATE FOLDER;

4. Annex "B" is the Anti-Money Laundering Compliance Form, which MUST BECOMPLETELY ACCOMPLISHED.

5. The exact formats, columnar headings and footnote instructions found inevery page of the blank forms of the prescribed Annual Statement includingthose required formats attached to Annex "A" shall be STRICTLYOBSERVED;

6. Any Annual Statement not in accordance with the required format and withmissing data/information and incomplete attachments SHALL NOT BEACCEPTED.

Please file your 2015 Annual Statements on or before April 30, 2016 to avoid penalty

EMMANUELlnsurance C

Head OfIice: P.O. Box 3589 Manila FAX No.522-14-34 Tel. Nos. 523-84-61 to 70 Website: www.insurance.gov.ph

ANNEX "A"

Name of Company:

LIST OF DOCUMENTS TO BE SUBMITTED TO FORM PART OF THE ANNUALSTATEMENTS OF LIFE INSURANCE COMPANIES:

For the Year

Irlote: Please check if the life insurance company has microinsurance business before receiving the AnnualStatement (A/S). There is a revised A/S intended for those companies with Ml operation.

l\. TO BE SUBMITTED TO LIFE/MBAs/TRUST DIVISION

1. 2015 Audited Financial Statements with comparative figures for 2014, signed by anexternal auditor accredited by this Commission.

2. Reconciliation Statement of the Audited Financial Statements versus the AnnualStatement figures.

3. Reconciliation of figures/accounts in the Adjusted Trial Balance (breakdown/groupings) to tally with the figures/accounts in the Annual Statement.

4. Adjusted Trial Balance as of December 31,2015 signed by the Chief Accountant.

5. lncome Statement for the year ended December 31,2015.

6. Soft copy of the Annual Statement (in USB).

7 . Computation of Risk Based Capital Ratio of the company.

8. For foreign companies, Annual Statement on Worldwide Business and Statement ofReceipts and Disbursements as of year-end.

L List of current members of board of directors, independent directors, their respectiveaddresses, positions and also the chairman and members of Audit, Remuneration andNom ination comm ittees.

10. 2015 General lnformation Sheet filed with SEG.

1 1 . Minutes of meetings of the board and executive committees, including a copy of boardresolutions made during the year.

12. Amended Articles of lncorporation relative to the increase of authorized capital stock.

13. Certification on the balances of all actuarial accounts and a statement of opinion onPolicy Loans by the Company's Actuary duly accredited by this Commission.

14. Soft copy of detailed schedule of the following actuarial accounts with printed copiesof the 1st and last page showing the total of the said schedules.

_4.

_c._d.

a

_ f.

b.

Seriatim list of all policyholders indicating therein the basic information(i.e. policy number, policy holders, age, issue date, plan, amount of insurance,reserves, cash values etc. using the attached Life Required Format No. 5;

Schedule of policy loans indicating policy number, policyholders,outstanding balance as of December 31 , 2015, interest both earned andunearned;

Schedule of net premiums, due and uncollected;

Schedule of premium deposit fund indicating the policy number, plan, amountof insurance, issue date, maturity date of the plan, annual premium,outstanding premium deposit fund amount of the plan, to be signed by theComptroller with rank of at least Vice President;

Detailed Schedule of amount recoverable from accepting companies; and

Schedule of Claims Payable as of 2015 and schedule of all claims filed for the1"t quarter of 2016.

15. Schedule showing balance sheet items in foreign currency and their peso equivalent,including a sub-schedule showing the currency breakdown in case an accountconsists of multiple currencies.

16. Confirmation of sales of investments in Bonds and Treasury Bills, together withStatement of Securities Account of BTR-ROSS as of December 31,2015.

17. Certification from the custodian bank for dollar-denominated Bonds as of year-end.

18. Schedule of dollar denominated bonds using the attached Life - Required Format No.1 .

19. Detailed schedules, together with the supporting documents of all investments andother asset accounts.

20. Certification from Phil. Depository & Trust Co. for the scriptless stocks certificates asof December 31,2015.

2l.Breakdown/Computation/Schedule of Fluctuation Reserve-Bonds/Stocks andRevaluation Reserve -Real Estate as reported in the Annual Statement.

22.Breakdown/Computation/Schedule of Unrealized Gain/Loss-Bonds/Stocks thatare closed to Retained Earnings.

23. Documents supporting Mortgage Loans, Guaranteed Loans, Collateral Loans, ChattelMortgage loans, Salary Loans and Other Loans accounts.

24.Bank statements/passbooks of all current, savings and time deposit accounts as ofDecember 31,2015 and January 31,2016, together with the pertinent bankreconciliation statements.

25. Detailed schedule of deposit in transit showing in columns the official receipts number,date, date deposited, name of depository bank and to be supported with OfficialReceipts and Validated Deposit Slips.

26. Detailed schedule of undeposited collections, if any, showing in columns theofficial receipts number, date, date deposited, name of depository bank and tobe supported with Official Receipts and Validated Deposit Slips.

27. Certification of receivables from government agencies/government-owned andcontrolled corporations.

28. Detailed Schedule of EDP for the last five (5) years together with the sales invoicesand official receipts to support purchases of EDP Equipment during the year.

29. Computation of Premium Tax during the year, using the attached Life-RequiredFormat No. 2.

30.Computation of DST in accordance with BIR RA 10001 using the attached Life -Required Format No. 3 (number of policies issued and total sum insured should tallywith the figures in the Annual Statement)

31. Official receipts to support payments of Premium Tax, Documentary Stamps Tax andReal Estate Tax during the year 2015.

32. LOA from BIR Tax Assessment and proof of payments (BlR Form No. 0605).

33. For companies with Variable Contracts:

- a. Separate Annual Statement for each variable account;

- b. Schedule showing balance sheet items in foreign currency and their peso

equivalent, including a sub-schedule showing the currency breakdown in casean account consists of multiple currencies;

- c. Confirmation of sales of investments in Bonds and Treasury Bills, together with

the year-end Statement of Securities Account of BTr-ROSS;

- d. Certification of investments as of year-end from custodian bank for the

company's dollar-denominated Bonds;

- e. Schedule of dollar denominated bonds using the attached Life - Required

Format No. 1;

- f. Statement of Account as of year-end from Philippine Depository & Trust Corp.

for scriptless equity investments;

- g. Bank statements/passbooks of all current, savings and time deposit accounts

as of December 3'l , 2015 and January 2016, together with the pertinent bankreconciliation statements; and

h. Detailed schedule of deposit in transit showing in columns the official receiptsnumber, date, date deposited, name of depository bank and to be supportedwith Official Receipts and Validated Deposit Slips.

34. For companies with Microinsurance business:

- a. Performance Standard (SEGURO); and

b. Soft Copy of the following:

Production

- Collections

- Claims Paid :

35. For companies with OFW business

Computation of legal Reserve; and

Soft Copy of the following:

- Production

- Collections

- Claims Paid :

Schedule showing separately in columns the name of theassured, policy number, certificate number, sum assured,premium, premium tax, DST and othertaxes (per productline)

Schedule showing separately in columns the name of theassured, policy number, certificate number, sum assured,premium, premium tax, DST, other taxes, amountcollected, date and number of official receipt.

Schedule showing separately in columns the name ofassured/claimant, Claim no., date filed, policy number,sum insured, date of loss, amount of loss, nature ofclaim, date paid and voucher number.

a.

b.

Schedule showing separately in columns the name ofthe assured, policy number, certificate number, sumassured, premium, premium tax, DST and othertaxes(per product line)

Schedule showing separately in columns the name ofthe assured, policy number, certificate number, sumassured, premium, premium tax, DST, other taxes,amount collected, date and number of official receipt.


B. TO BE SUBMITTED TO THE STATISTICS & RESEARCH DIVISION

- 1. 2015 Audited Financial Statements with comparative figures for 2014, signed by an

external auditor accredited by this Commission.

- 2. Reconciliation Statement of the Audited Financial Statements versus the Annual

Statement figures.

- 3. Reconciliation of figures/accounts in the Adjusted Trial Balance (breakdown/

groupings) to tally with the figures/accounts in the Annual Statement.

- 4. Adjusted Trial Balance as of December 31 , 2015 signed by the Chief Accountant.

-- 5. lncome Statement for the year ended December 31,2015.

-- 6. Soft copy of the Annual Statement and attachments (in USB).

- 7 . Computation of Risk Based Capital Ratio of the company.

- 8. Schedule V - Premiums & Claims by Market Segment & Region.

- a. No. of Policyholders should tally with Outstanding at Yearend (Exhibit

15 column 2);

- b. Sum Assured should tatly with Outstanding at Yearend (Exhibit 15

column 4);

- c. Total Premiums should tally to Direct Premiums (Exhibit 1A item 25

column 1); and

- d. Glaims lncurred/Benefit Payments should tally with the Benefit

Payments on SIS (Page 4, Tota! of item 8 to 17 plus item 29-31 column1).

-- 9. Extracopyeachof Pages 1,3,4,7A,78,9A,98,16, 17,20 and46

- a. Figures on Page 7A (Exhibit 1A) Total Premiums shall be gross of

loading; and

- b. Figures on Page 78 (Exhibit 1B) Total Premiums Collected should tally

with Total Premiums and considerations (page 7A column {) and InForce/Active at Yearend should tally with Exhibit 15.

10. Separate Analysis of Operations (Page 4) for Variable Contracts.

1 1. List of current members of board of directors, independent directors, their respectiveaddresses, positions and also the chairman and members of Audit, Remuneration andNomination committees.

12.Certification on the balances of all actuarial accounts and a statement of opinion onPolicy Loans by the Company's Actuary duly accredited by this Commission.

13. Computation of Premium Tax during the year, using the attached Life-RequiredFormat No.2.

14. Computation of DST in accordance with BIR RA 10001 (number of policies issued andtotal sum insured should tally with the figures in the Annual Statement) using theattached Life - Required Format No. 3.

15. For companies with Variable Contracts:

- a. Separate Annual Statement for each variable account; and

b. Exhibit ll - Statement of Changes in Net Assets and Exhibit lll - UnitMovement for the year, using the attached Life -Required Format No. 4.

16. For companies with Microinsurance business:

- a. Performance Standard (SEGURO); and

- b. Soft Copy of the following:

Production :

Collections

Claims Paid :

17.For companies with OFW business

Soft Copy of the following:

Production :

Collections

Claims Paid

Schedule showing separately in columns the name ofthe assured, policy number, certificate number, sumassured, premium, premium tax, DST and other taxes(per product line)

Schedule showing separately in columns the name ofthe assured, policy number, certificate number, sumassured, premium, premium tax, DST, other taxes,amount collected, date and number of official receipt.


Schedule showing separately in columns the name ofthe assured, policy number, certificate number, sumassured, premium, premium tax, DST and othertaxes (per product line)Schedule showing separately in columns the name ofthe assured, policy number, certificate number, sumassured, premium, premium tax, DST, other taxes,amount collected, date and number of official receipt.

Schedule showing separately in columns the name ofassured/claimant, Claim no., date filed, policynumber, sum insured, date of loss, amount of loss,nature of claim, date paid and voucher number.

C. TO BE SUBMITTED TO THE MICROINSURANCE DIVISION

Soft copy of the following to be submitted (in USB):

- a. 2015 Annual Statement;

- b. Adjusted Trial Balance as of December 31,2015;

- c. lncome Statement of the year ended December 31,2015;

d. Gomputation of Risk Based Capital Ratio of the company;

e. List of current members of board of directors, independent directors,their respective addresses, positions and also the chairman andmembers of Audit, Remuneration and Nomination committees;

f. Schedute of Claims Payable as of 2015 and all claims for the 1"t quarterof 2016; and

g Schedule of Claims paid/denied during the year (New Format No. 6).

tiubmitted by:Received by:

Date

Life - Required Format No. 1Dollar Denomin ated Bonds

DescriptionFace Value Acquisition Cost Price

(%lDollar Rate at thetime of acquisitionPeso Dollar Peso Dollar

Total

Lffe - Required Format No. 1

Life - Required Format No. 2Computation of Premium Tax

Note: Please refer to your AS on Exhibit 1A lines 4, 11 & 18 of column 1 & 2 to fill up the space providedabove. Alt the adjustments are to be supported and subiect to verification.

Life - Required Format No.2

ParticularsColumn 1

ffraditional)Column 2(Variable)

Column 1 minusColumn 2

Exhibit lA of the Annual StatementLine 4 - Collected during the year - direct business, lstyearLine 11- Single premium & consideration, direct businessLine18- Collected during the year - direct business, renewalTotalAdd/Deduct adiustments:

1. Cost of lnsurance2. Zero Rated Premiums3.45.6.7.

Total - tax baseMultiolv bv the tax rate 2o/o

Premium Tax durinq the year

Bracket RateNo. of Policies

lssued Sumlnsured

DST

lf the amount of insurance does notexceed Php100,000.00

Exempt

lf the amount of insurance exceedsPhp 100,000.00 but does not exceedPho 300,000.00

Php 10.00

lf the amount of insurance exceedsPhp 300,000.00 but does not exceedPhp 500,000.00

Php25.00

lf the amount of insurance exceedsPhp 500,000.00 but does not exceedPhp 750,000.00

Php50.00

lf the amount of insurance exceedsPhp 750,000.00 but does not exceedPhp 1,000,000.00

Php75.00

lf the amount of insurance exceedsPhp1.000.000.00

Php100.00

Total XXXXX XXXXX XXXXX

Life- Required Format No.3CpnpglatioO_ot_DS'L

Note: The totat number of policies issued and sum insured should tally with fhe AS figures.

Life - Required Format No. 3

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ANNEX "B"

Republic of the PhilippinesDepartment of Finance

INSURANCE COMMISSION

ANTI.MONEY LAUNDERING COMPLIANCE FORM

NAME OF COMPANY

PRACTICES AND ACTS REQUIRED UNDER AMLA,ITS IRR AND OPERATING MANUAL YES NO

COMPLIANCE AREAEXPLANATION/REASON FOR

NON/COMPLIANCE

I. ADOPTION OF THE MANUAL

2. Did you submit your AML Operating Manual to thelnsurance Commission?

3. ls your AML Operating Manual being followed by)rour personnel in your dayto-day operations?

Anti-Money Lau Manual1. Do you have an Anti-Money Laundering (AML)

Operating Manual?

II. CUSTOMER DUE DILIGENCE OR KNOW-YOUR.CUSTOMER RULE

A. Questions Applying to All Covered tnstitutions Regulated by the lnsurance CommissionDo you obtain the following information from yourcustomer (i.e., clienUmember)?

4.1 Complete name(s) used?

4.2 Present address or residence in thePhilippines, or abroad, if customer is a non-resident?

4.3 Residence telephone numbers?

4.4 Permanent address for both resident and non-resident?

4.5 Mailing address, if different from 4.2 and 4.4?

4.6 Birth date and birth place?

4.


COMPLIANGE AREAEXPLANATION'REASON FOR

NON/COMPLIANCE

4.7 Nationality?

4.8 Nature of work or occupation of the customere.g. attorney, cashier, physician (do not usenon-descript terms such as businessman,employee, merchant, store owner (unlessname of store is provided)?

4.9 Name of employer, if employed, and thecomplete address and telephone numbers ofthe employer?

4.10 Nature of self-employment or business, orname of the single proprietorship and itscomplete address and telephone numbers?

4.11 Customer's Tax ldentification Number?

4.12 Customer's Social Security Numbers orGovernment Service lnsurance SystemNumbers?

4.13 Sources of funds?

4.14 Complete name, address and contactinformation of beneficial owner?

5. ln addition to No. 4, do you require the followinginformation in cases where the applicants areacting in a representative capacity?

5.1 Legal capacity of the customer?

5.2 ldentity of the principal owner or beneficiary,including information from 4.1 to 4.14?

5.3 lf customer is a legal entity such as acorporation, the identity of the personauthorized, including information from 4.1 to4.9?

5.4 ls there a designated officer or staffauthorized to obtain from the customers theabovementioned information or documentsrelevant thereto? lf yes, specify below therank, office or designation:



NONICOMPLIANCE

B. Questions on Documentations8.1 lndividuals as Clients

6. For purposes of No. 4, do you require from thecustomer the original copy of any of the followingidentification documents before opening of anaccount?

6.1 Philippine passport or passport issued by aforeign government?

6.2 Driver's license?

6.3 Any official original identity card issued by theNational Government of the Republic of thePhilippines, its political subdivisions orinstrumentalities, or government-owned andcontrolled corporations?

7. Do you obtain from the customer prior to theopening of an account the following:

7.1 Notarized special authorizations, for therepresentatives?

7.2 Trust agreement, if acting as a trustee?

7.3 Other pertinent and reasonable documentsdeemed necessary under the circumstances?Specify below the documents, if applicable.

8.2 Co rporate/Partnersh ip/Single Proprietors as Clients8. Do you obtain from your client copies of the

following documents:

8.1 Certificate of registration issued by theSecurities and Exchange Commission (SEC),for corporation or partnership, or by theDepartment of Trade and lndustry, for singleproprietorship, including the Articles ofI ncorporation or Partnersh i P?

tt.2 Latest General lnformation Sheet (GlS) andother documents such as clearance from theSEC that the company is active and compliantwith reportorial requirements?

PRACTICES AND ACTS REQUIRED UNDER AMLA,ITS lRR AND OPERATING MANUAL YES NO

GOTYIPLIANCE AREAEXPLANATION/REASON FOR

NON/COMPLIANGE

8.3 Appropriate board resolution?

8.4 For customers who are non-residents, do yourequire that the documents under No. 7 beduly authenticated by the Philippine Embassyor Consulate where said companies arelocated?

C. Questions on Prohibited Accounts9. Do you maintain accounts only in the names of the

policyholders?

10. Do you allow the opening, keeping or maintainingany of the following accounts:

10.1 Anonymous accounts?

10.2 Fictitious names accounts?

10.3 lncorrect name accounts?

10.4 Accounts similar to the foregoing

1 1. Have you refused opening of accounts under anyof the following circumstances:

11.1 Those covered under No. 10 hereof?

11.2 lf customer fails to provide the requestedevidence of identity?

11.3 lf contrary to the established policies andprocedures of the covered institution?Specify below said policy or procedure, ifapplicable.

12. Have you closed prohibited accounts after theadoption of the AMLA, as amended, and itslmplementing Rules and Regulations?

13. How many prohibited accounts have beenclosed?


COMPLIANGE AREAEXPLANATION/REASON FOR

NON/COMPLIANCE

D. Questions on Accounts without Face-to-Face Contacts14. Are your prospective clients interviewed

personally?

15. Do you allow the opening of accounts thru any ofthe following circumstances:

15.1 lnternet?

15.2 Post?

15.3 Telephone?

15.4 Other instances such

16. Do you have policies and procedures specifyingreliance on an intermediary or third party for yourKnow-Your-Customer (KYC) or customer dueciiligence requirements?

17. ls the intermediary or third party referred to inNo. 16 a covered institution under the AMLA, asamended, or as defined and identified by foreignjurisdiction in so far as covered institutions in theirrespective jurisdictions are concerned?

18. \A/here reliance is permitted, do you undertake thefollowing:

'18.1 lmmediately take adequate steps to satisfyyourself that copies of identification data andother relevant documentation relating to thecustomer due diligence requirements areavailable from the intermediaries or thirdparties upon request without delay?

'1B.2Satisfy yourself that the intermediaries orthird parties are regulated and supervised,and have measures in place to comply withcustomer due diligence requirements?

18.3 Ensure that the customer identificationprogram of the tntermediaries or third party issimilar to or equivalent to your customeridentification Program?



NON/COMPLIANCE

1B.4That the ultimate responsibility for customerand/or beneficial owner identification andverification remains with you?

E. Questions on New T19. Do you pay special attention to any money

laundering threats that may arise from new ordeveloping technologies that might favoranonymity?

20. Do you take measures to prevent money

F. Not to Transact21. Do you inform your clients of your explicit policy

that business transactions will not be conducted ifthey fail to provide sufficient evidence of theiridentity?

G. Rene'wal or ldentification22. Do you regularly update or renew identification of

your clients particularly under any of the followingsituations:

22.1 Changes of the applicable informationrequired under Nos. 4 to 8, except No. 6?

22.2 When there is doubt as to the identity of yourclient, beneficial owner, or the principal itpurports to rePresent?

112.3 Whenever necessary pursuant to yourestablished policies and procedure?

H. Old Accounts23. t{ave you taken actions to clean out old accounts?

24. \A/hat actions have you taken to clean out oldaccounts?

PRACTICES AND AGTS REQUIRED UNDER AMLA,ITS IRR AND OPERATING MANUAL YES NO

COMPLIANCE AREAEXPLANATION'REASON FOR

NON/COMPLIANCE

l. $implified or Reduced Customer Due Diligence25. Do you apply simplified or reduced customer due

diligence to the following customers:

25.1 Financial institutions where they are subjectto requirements to combat moneylaundering and the financing of terrorismconsistent with the Recommendations ofthe FinancialAction Task Force (FATF)andare supervised for compliance with thosecontrols?

25.2 Public companies that are subject toregulatory disclosure requirements?

25.3 Government institutions and itsinstrumentalities?

J. VerificationJ.1 Aceounts Without Face-to-Face Contacts

26. Do you ensure that the customer identificationprocedures for non-face-to-face verification be asstringent as those for faceto-face verification?

27. Do you have the following as risk mitigatingrneasures:

27.1 Certification by appropriate authorities andprofessionals of the documents provided?

27.2 Requisition of additional documentscomplement those which are requiredface-to-face customers?

tofor

27.3 lndependent contact with the customer?

27.4 Tnnd party introduction, e.g. by anintermediary?

27.5 Requiring the first payment to be carried outthrough an account in the customer's namewith a bank subject to similar customer duediligence standards?

28. Do you require that documents under Nos. 7 andB be authenticated by the Philippine Embassy orConsulate for those non-residents opening anaccount without face-to-face contact?



NON/COMPLIANCE

J.2 Corporate Accounts29. Before establishing business relationship, do you

ensure that corporate client or other kind ofbusiness applicant has not been, or is not in theprocess of being dissolved, struck off, wound-upor terminated?

J.3 Trust, Nominee and Fiduciary Accounts30. Do you determine whether your customer is acting

in behalf of another person as trustee, nominee oragent?

31. Do you establish the identities of the agenVs andthe authorized signatories, as well as the natureof their trustees or nominee capacity and duties?

32. ln case you suspect that the trustee, nominee oragent is only a dummy, do you undertake furtherverification to verify the business relationshipbetween the parties?

33. ln case satisfactory evidence of the beneficialowners cannot be obtained, do you proceed to:

33.1 Conduct or continue transacting with theclient?

33.2 Stop transacting with such account?

34. For purposes of 33.1, do you undertake thefollowing:

34.1 Record any misgivings?

34.2 Monitors said account?

35. Do you conduct reasonable inquiries on thetransactions whenever these transactions passthrough accounts opened by a law firm oraccountants that give cause for concern?

36. Do you report to AMLC transactions under Nos.33 and 34, pursuant to the provisions of theAMLA, as amended, and your established policiesand procedures, if you have a basis for reportingunder the provisions of the AMLA, as amended?



NON/COMPL!ANCE

J.4 High Risk Customers37. Do you give special attention to business

reiationships and transactions with persons,including companies and financial institutions,from countries which do not or insufficiently applythe FATF Recommendations?

38. Do you ensure that the principles applicable toyour institution are also applied to your branchesand majority owned subsidiaries located abroad,especially in countries which do not orinsufficiently apply the anti-money launderingmeasures implemented in the Philippines?

39. Do you consider costumers from countries whichdo not have or insufficiently apply anti-moneylaundering measures as high risk customers?

40. Do you establish the source of wealth of higherrisk customers?

41. Are decisions on business relations with higherrisk customers taken by your seniormanagement?

III. MONITORING, RECORDING AND REPORTING

A. Monitoring42. Do you conduct monitoring of the following

business relationships and transactions:

42.1 Transactions involving trust, nominee andfiduciary accounts?

42.2 Transactions involving shell companieswhich have been allowed to transact afteru ndertakin g necessary verifications?

42.3 Complex, unusual large transactions, orunusual patterns of transactions?

42.4 Business relationships and transactionswith persons, whether natural or juridical,from countries which do not or insufficientlyapply the FATF Recommendations?

T'RACTICES AND ACTS REQUIRED UNDER AMLA,ITS IRR AND OPERATING MANUAL YES NO


NONICOMPLIANCE

42.5 Transactions which are suspected to bemade by a person included in the list ofsuspected terrorists, or terroristorganizations that may be furnished by theAMLC or by any other law enforcementagency or pursuant to internal policies andprocedures?

42.6 Transactions made by persons, whetherindividuals or corporate, who had beensubjected to further verifications butnonetheless required to be monitored by thecovered institution as part of its enhancedKYC application or AMLA complianceprocedure?

42.7 Any other transaction which you may deemnecessary to be monitored based onsurrounding facts or circumstances andyour established policies and procedure?

43. ls there a designated specific officer or staffauthorized to monitor any of the transactionsreferred to above? Specify the rank, office ordesignation:

44. Do you keep and maintain documentations on thefollowing:

44.1 Customer relationships, identification andother pertinent data?

44.2 fransactions?

45. ls there documentation sufficient to permitreconstruction of individual transaction which willenable the AMLC to compile an audit trail shouldthere be a report made pursuant thereto?

46. Does the documentation include information onthe customer/beneficiary's name, address, natureand date of transaction, type and amount ofcurrency involved, the type and identifyingnumber of account, and information on whether aparticular person is a customer or beneficial ownerof the transactions?

10

PRACTICES AND ACTS REQUIRED UNDER AIULA,ITS IRR AND OPERATING MANUAL YES NO


NON/COMPLIANCE

47. Are the documents referred to under Nos. 44 and45 including recordings made under No. 34.1 andany analysis made to detect unusual or suspicioustransactions available to the Commission and tothe AMLC for its inspection?

48. ln case the company's recordkeeping is fullycomputerized, do you have an automatic back-upsystem which is maintained within the prescribedperiod?

49. Do you apply the five (5) year retention period forpurposes of recordkeeping?

50. Do you maintain a complete file on alltransactionsthat have been brought to the attention of yourCompliance Officer, including transactions thatare not reported to the AMLC?

51. Do you require the production of the originaldocuments referred to herein and do you retaincertified copies of said documents, with the nameof your employee certifying the documents clearlyrecorded?

52. lf the original copies of the documents cannot beprcduced or certified copies cannot be retained,do you record the reasons therefor?

53. ls there a designated officer or staff authorized tokeep or maintain the records referred to herein?Specify below the rank, office or designation:

C. Reporting to the AMLCC.{ General Provisions

54. Do you have a system of mandatory reporting ofboth covered transactions and suspicioustransactions?

55.

56.

Have you appointed a senior officer atmanagement level with relevant qualifications andexperience as Compliance Officer?

Do you report to the AMLC all covered andsuspicious transactions within ten (10) workingdays from occurrence thereof?

L'.l.



NON/COMPLIANCE

57. Do you inform your customers when informationrelating to them or whenever their transaction isbeing reported to the AMLC?

58. Do you have a system of ensuring confidentialityof the reports made to the AMLC?

59. Whenever any of your officer or employee knowsthat the client has engaged in any of the predicatecrimes under the AMLA, do you promptly make areport to the AMLC?

C.2 Govered Transaction60. Do you report to the AMLC transactions in cash or

other equivalent monetary instrument involving atctal amount in excess of the threshold of FiveHundred Thousand Pesos (PHP500,000.00)within one (1) banking day?

C.2 General Provisions61. Do you report to the AMLC transactions,

regardless of the amounts involved, where any ofthe following circumstances exists:

61 .1 There is no underlying legal or tradeobligation, purpose or economicjurisdiction?

61.2 The client is not properly identified;

61.3 The amount involved is not commensuratewith the business or financial capacity oryour client?

61.4 Taking into account all knowncircumstances, it may be perceived that theclient's transaction is structured in order toavoid being the subject of reportingrequirements under the AMLA, asamended?

61.5 Any circumstances relating to thetransaction which is observed to deviatefrom the profile of the clients and/or pasttransactions with you?

61.6 The transaction is in any way related to anunlawful activity or offense under the AMLA,as emended, that is about to be, is being orhas been committed.

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NON/COMPLIANCE

61.7 Do you inform your customers wheninformation relating to them or whenevertheir transaction is being reported to theAMLC?

IV. INTERNAL CONTROL AND PROCEDURES, COMPLIANCE AND TRAINING

A. lnternal Controland Procedure62. Do you have internal control and procedures

aimed at preventing and impending moneylaundering?

63. Are your internal policies and procedures ondealing with money laundering clearly set out andreflected in your Operating Manual?

64. Does your internal written internal reportingprocedure include the following?

64.1 lnformation to all key staff as to whom theyshould report any knowledge or suspicion ormoney laundering activity?

64.2 Clear reporting chain under whichsuspicions of money laundering activity willbe passed to the Compliance Officer?

64.3 Access of the Compliance Officer to anyother information which may be necessaryin determining whether or not a suspicioustransaction report is to be filed?

64.4 A provision that, upon determination of thesuspicious nature of the report, theinformation contained therein is promptlydisclosed to AMLC?

64.5 Maintenance of a register of all reports,including reports of suspicious transactionsto the Compliance Officer but not reportedto the AMLC, covered transactions whichare not reported to the AMLC, details of thedate on which the report is made, the personwho made to the report to the ComplianceOfficer and information sufficient to identifythe relevant papers related to the reports?

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NON/COMPLIANCE

65. Have you instituted an audit function or procedureto test the system to ensure adequate compliancewith the program?

66. Do you have an adequate screening procedure toensure high standards in hiring employees?

67. Have you appointed one or more senior officers oran appropriate unit to advise the management andstaff on the issuance and enforcement of in-houseinstructions relative to the implementation of theAMLA, as amended, your Operating Manual,personnel training, reporting of covered andsuspicious transactions?

68. Does your Compliance Officer have the followingduties?

68.1 Maintenance of a manual of complianceprocedures?

68.2 Ensure compliance by the staff with theAMLC, its lmplementing Rules andRegulations and your Operating Manual?

68.3 Act as liaison officer between you as acovered institution and the AMLC relative toyour compliance with the AMLA?

68.4 Dissemination to the Board, officers and allemployees, memoranda circulars,resolutions, instructions and policies issuedby the AMLC or by the Commission inrelation to money laundering prevention?

68.5 Prepare and submit to the AMLC writtenreports of the covered institution'scompliance with the AMLA and itslmplementing Rules and Regulations?

69. lf you are a branch, subsidiary or affiliate of aforeign company which is a covered institution inits home country, do you observe anti-moneylaundering measures consistent with homejurisdiction requirements to the extent allowed bythe local laws?

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NON'COMPLIANCE

C. Traininq70. Do you provide education and training for all your

staff and personnel, including directors andofficers? lf you have conducted such trainingspecify below topics presented, dates of thetraining and the names of the resource persons:

70.1

70.2

70.3

70.4

71. Do you provide trainings to all new employees,regardless of level of seniority?

72. Do you provide continuous trainings to yourcashiers/dealers' representatives or investmentrepresentatives/advisory staff or "front-line" staffon matters such as, but not limited to,identification of suspicious transactions, theprocedure to be adopted when a transaction isdeemed suspicious, and your policy for dealingnon-regular customers particularly where largecase transactions or complex and unusualtr;ansactions are involved?

73. Do you provide trainings to your supervisors andmanagers on matters such as, but not limited to,offenses and penalties under the AMLA, theprocedures relating to service of production andrestraint orders, internal reporting procedures,and the requirement for verification of identity andretention of records?

74. Do you provide, at least once a year, refreshertrainings, or do you conduct on-going training foryour key staff on matters such as, but not limitedtc, updates or developments on money launderingtechniques, methods and trends of moneylaundering and prevention, aspects of the AMLAand obligations thereunder, the requirements oncustomer identification and due diligence, coveredtransactions and suspicious transactionsreporting?

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NON/COMPLTANCE

Assistance of the lnsurance Commission75. Do you need assistance of the Commission in

effectively implementing or complying with theAMLA, its lmplementing Rules and Regulations,and Circulars issued by the AMLC and thelnsurance Commission relative to the AMLA?

76. lf you need the assistance of the Commission,please specify below the kind or type ofassistance you need:

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