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September 9, 2004BSP MEMORANDUMTO : All Banks and Non-Bank Financial Institutions under BSP Supervision The Anti-Money Laundering Council (AMLC), in its letter of 13 August 2004, stated that the Financial Action Task Force (FATF) observed inter alia that the obligation to file Suspicious Transaction Reports (STR) needs to be observed by all commercial banks. During the first and second meetings held on 14 May 2004 in Hong Kong and 13 June 2004 in Seoul, Korea, respectively, regarding the Philippines Implementation Plan on Money Laundering, the Chairman of FATF's Asia Pacific Review Group, repeatedly questioned the low number of STRs from banks and all institutions supervised by the Bangko Sentral ng Pilipinas (BSP), Securities and Exchange Commission (SEC) and the Insurance Commission (IC). Mr. Vicente S. Aquino, Executive Director of AMLC, surmised that this may be attributed to the covered institutions' erroneous understanding that they should only file STRs after they have established a link between the unlawful activity under the Anti-Money Laundering Act (AMLA), as amended, and the monetary instruments or property. Thus, for the...