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January 24, 2013AMLC RESOLUTION NO. 010-A-13On October 24, 2003, the Council issued Resolution No. 292, entitled "Rules on Submission of Covered Transaction Reports and Suspicious Transaction Reports by Covered Institutions".Paragraph 3 of the said Resolution provides that:"Covered institutions, other than banks, shall file covered transaction reports (CTRs) on transactions in cash or foreign currency or other monetary instruments (other than checks) or properties. . . .On 26 April 2011, the Council issued Resolution No. 38 adopting the following policies on the submission of CTRs on transactions settled via fund transfers between existing banks of the brokers/dealers and their customers, to wit: 1. The filing of a Covered Transaction Report (CTR) by a broker is deferred when the mode of payment is by checks inasmuch as these checks will ultimately pass through banks which are mandated to file the required CTR thereon.2. In the same manner, if the settlement between the brokers/dealers and their customers is made through fund transfers or "debiting and crediting" of their respective accounts (in which case there is no physical movements...