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May 23, 2014AMLC RESOLUTION NO. 043-14In the Memorandum dated 20 May 2014, the AMLC Secretariat reported to the Council that:Metropolitan Bank and Trust Company (Metrobank), in its letter dated 22 May 2013, inquired, among other things, about the following:Is the STR filed on a per transaction basis? What if the daily transactions of similar suspicious nature are voluminous?Section 7 (7) of the Anti-Money Laundering Act of 2001, as amended, provides:Sec. 7. Creation of Anti-Money Laundering Council (AMLC). — . . . The AMLC shall act unanimously in the discharge of its functions as defined hereunder:(7) to implement such measures as may be necessary and justified under this Act to counteract money laundering;STRs are filed on a per transaction basis. There are occasions, however, when daily numerous suspicious transactions occur in an account based on a similar suspicious transaction indicator. A case in point is when an investment scam breaks out where it is unreasonable for covered persons to file hundreds of STRs on a daily basis. Thus, a need exists to rationalize the filing of...