Picture a bank branch in Manila (illustrative) that takes a cash deposit of PHP 520,000 from one customer. That is over PHP 500,000 in one banking day, so it is a covered transaction, reported to the AMLC within five working days. Later that week the same customer deposits PHP 480,000 on each of three separate days. No single deposit crosses the line. A transaction structured to avoid reporting is one of the law's suspicious circumstances, though, and that report runs on a shorter clock.
What does AMLA mean?
AMLA is an abbreviation that several AML laws and one supervisor share, so the country decides the meaning. Most readers mean the Philippine act, Republic Act No. 9160.
In Malaysia, AMLA is the Anti-Money Laundering, Anti-Terrorism Financing, Anti-Restricted Activity Financing and Proceeds of Unlawful Activities Act 2001 (Act 613). In the United States, it is the Anti-Money Laundering Act of 2020. In the EU, AMLA is the Authority for Anti-Money Laundering and Countering the Financing of Terrorism, a supervisor rather than a law.
For banks, the meaning follows the regulator: in Makati, AMLA is RA 9160 as amended; in Frankfurt, it is the EU authority. And not every AML statute is an AMLA. India's, for one, is the PMLA.
What is the Anti-Money Laundering Act of 2001, and what are its key components?
Republic Act No. 9160 was approved on 29 September 2001. Its parts are the offense (section 4), the covered persons and their duties to identify customers, keep records and report (sections 3 and 9), the penalties (section 14) and the Anti-Money Laundering Council that receives the reports (section 7). The council is the Governor of the Bangko Sentral ng Pilipinas as chair, with the Insurance Commissioner and the Chairman of the Securities and Exchange Commission.
Five laws have amended it:
- RA 9194, 7 March 2003. Cut the covered transaction line from PHP 4,000,000 over five banking days to PHP 500,000 in one, and added suspicious transactions of any amount.
- RA 10167, dated 6 June 2012. Rewrote the freeze order and bank inquiry sections.
- RA 10365, 15 February 2013. Rewrote the offense, the penalties and the list of covered persons.
- RA 10927, 14 July 2017. Made casinos covered persons.
- RA 11521, 29 January 2021. Added real estate developers and brokers and offshore gaming operators, and let the AMLC investigate and apply for search and seizure orders.
What is money laundering under AMLA, and what are the penalties?
Under section 4 as rewritten in 2013, money laundering is committed by a person who, knowing that property relates to the proceeds of an unlawful activity, transacts, converts, transfers, conceals or disguises it, or attempts or conspires to. Section 14(a) sets 7 to 14 years in prison and a fine from PHP 3,000,000 up to twice the value of the property. Aiding, abetting or facilitating carries 4 to 7 years and PHP 1,500,000 to 3,000,000.
Who must comply with AMLA, and what do they report to the AMLC?
Table 1. Reporting obligations and other duties of a Philippine covered person (RA 9160 as amended; AMLC Regulatory Issuance No. 2, Series of 2024; as of October 2026).
| Duty | What the rule requires | Threshold or deadline | Source |
|---|---|---|---|
| Who is covered | Banks, pawnshops, remittance companies and others the Bangko Sentral supervises; insurance companies under the Insurance Commission; securities dealers and brokers under the SEC; jewelry dealers and company service providers (DNFBPs); casinos; real estate developers and brokers; offshore gaming operators | Jewelry dealers only above PHP 1,000,000; lawyers and accountants acting as independent legal professionals excluded where client confidences are at stake | Section 3(a) |
| Customer due diligence (CDD) | KYC: true identity from official documents; for a company, legal existence, structure and who acts for it | At onboarding | Section 9(a) |
| Records | All transaction records; for closed accounts, identification and account files | Five years from the transaction or the closing | Section 9(b) |
| Covered transaction report (CTR) | Cash or equivalent over PHP 500,000 in one banking day | Five working days; late after 11:59:59 pm on day five | Section 3(b); guidelines 4.2, 4.3 |
| CTR, casinos | A single casino cash transaction over PHP 5,000,000 | Five working days | Section 3(b), as amended by RA 10927 |
| CTR, real estate | A single cash transaction over PHP 7,500,000 | Five working days | Section 3(b), as amended by RA 11521 |
| Suspicious transaction report (STR) | Any amount, where a listed circumstance exists, such as a transaction structured to avoid reporting | Next working day after suspicion is established; 10 calendar days to establish it | Section 3(b-1); guidelines 5.4 |
The statute sets one period for both reports, five working days, unless the AMLC prescribes another of up to 15 (section 9(c)). Its guidelines of 11 December 2024 keep five working days for the CTR and move the suspicious transaction report to the next working day after suspicion is established.
So one customer can run on two clocks. The PHP 520,000 deposit is a CTR due within five working days of the transaction. The three PHP 480,000 deposits need no CTR, but structuring is a listed circumstance, so an STR is due the next working day after the designated officer decides, and that decision may take at most 10 calendar days from the transaction.
The decision date is the one to record. A decision not to file goes on record too, since the guidelines have the approving officer either file the STR or "document the non-filing thereof". complead, formerly Sanction Scanner, drafts the SAR or STR from the case trail in its regulatory compliance and reporting workflow, handles each entity's formats and deadlines, and leaves the approval and the filing with a named person on the team.
Which other laws and bodies are called AMLA?
| Name | Country or bloc | Number and date | What it is | Who enforces |
|---|---|---|---|---|
| Anti-Money Laundering Act of 2001 | Philippines | Republic Act No. 9160, approved 29 September 2001, amended five times | A statute: offense, covered persons, reports, penalties | The AMLC |
| Anti-Money Laundering, Anti-Terrorism Financing, Anti-Restricted Activity Financing and Proceeds of Unlawful Activities Act 2001 | Malaysia | Malaysia's Act 613, in force 15 January 2002 | A statute: offenses, reporting institutions (financial institutions, non bank financial institutions, DNFBPs), forfeiture | Bank Negara Malaysia as competent authority |
| Anti-Money Laundering Act of 2020 | United States | Division F of Public Law 116-283, approved 1 January 2021 | Amendments to the Bank Secrecy Act | Treasury and FinCEN |
| Authority for Anti-Money Laundering and Countering the Financing of Terrorism | European Union | Regulation (EU) 2024/1620 of 31 May 2024, applies from 1 July 2025 (some articles earlier) | A supervisor, seated in Frankfurt am Main | Is itself the supervisor |
| Prevention of Money Laundering Act, 2002 (PMLA) | India | Act 15 of 2003 | Often listed as India's AMLA, but not called one | The Enforcement Directorate |
The Philippine and Malaysian acts share a shape: an offense, a list of who must report and an authority that receives the reports. The US act of 2020 works differently. It rode as Division F in the FY2021 National Defense Authorization Act, the same law that carried the Corporate Transparency Act, and it amends the Bank Secrecy Act instead of standing alone.
The EU's AMLA is a body. A supervisory letter in Frankfurt that says "AMLA" means the authority, and no statute by that name exists in EU law.
What changed for AMLA in 2025 and 2026?
- 21 February 2025. The FATF took the Philippines off its grey list of jurisdictions under increased monitoring after a successful on site visit (FATF statement).
- 1 May 2025. Strict implementation of the first parts of the AMLC's 2024 guidelines began.
- 1 March 2026. Malaysia's amending Act A1761, gazetted on 14 May 2025, came into force.
- 10 April 2026. FinCEN proposed a new AML/CFT program rule to carry out the US act of 2020 (91 FR 18704); the Federal Register shows no final rule by 29 October 2026.
Before the next AMLC filing cycle, businesses with Philippine customers can test three things:
- The group manual cites RA 9160 as amended by number, not "AMLA" alone.
- The case system runs CTR and STR deadlines on separate clocks and records the decision date.
- The casino and real estate thresholds sit in the rule set beside PHP 500,000.
Related terms
- Money laundering. Passing the proceeds of crime off as clean money.
- Suspicious activity report. The Philippine form is the STR.
- Currency transaction report. The Philippine form is the CTR, filed above PHP 500,000.
- PMLA. India's Prevention of Money Laundering Act, 2002.
- NDAA. The US defense law that carried the 2020 act.
- Bank Secrecy Act. The US law the 2020 act amended.
How this entry was checked. Emirhan Akgün, Software Engineer at complead, worked from the statute itself: Republic Act No. 9160 and the five acts that amend it (9194, 10167, 10365, 10927 and 11521), as printed on lawphil.net. Deadlines come from the AMLC's Regulatory Issuance No. 2, Series of 2024 (Resolution No. 234 of 11 December 2024), the grey list exit from the FATF statement of 21 February 2025, and the other AMLAs from Public Law 116-283, Regulation (EU) 2024/1620, Bank Negara Malaysia's legislation page and 91 FR 18704. The Manila deposits are illustrative. Before publication Ufuk Gürdaş, Compliance Specialist, matches every peso amount and date in Table 1 to its section or paragraph. Last reviewed: 30 October 2026.
