Anti-Money Laundering (AML) Policy
Money laundering refers to the process of disguising the proceeds of serious criminal offenses or criminal conduct, as outlined in the Anti-Money Laundering Act of 2001, to make it appear as if those funds originated from a legitimate source.
1.1 THE THREE STAGES OF MONEY LAUNDERING
Money laundering typically involves three (3) stages, with multiple transactions that may raise suspicion for intermediaries like ROC.PH:
Placement – This stage involves physically disposing of the cash obtained from illegal activities.
Layering – In this stage, illicit funds are separated from their source through complex financial transactions, aiming to conceal the trail and provide anonymity.
Integration – The integration stage seeks to give a façade of legitimacy to the illicit wealth. If the layering process succeeds, the laundered proceeds are reintroduced into the financial system to appear as normal business funds.
1.2 BASIC PRINCIPLES TO COMBAT MONEY LAUNDERING
ROC.PH is committed to applying the following principles to detect, prevent, and counter the use of its services for money laundering and terrorist financing:
• Appointment of a dedicated Compliance Office
• Implementation of Know-Your-Customer (CDD and EDD) procedures
• Reporting suspicious activities to the Anti-Money Laundering Council (AMLC)
• Regular training for employees on AML and CFT measures
• Continuous monitoring and Compliance Testing
• Maintaining records and data in accordance with AML laws and regulations
• Establishing an Internal Audit Function
1.2.2 COMPLIANCE WITH LAWS
ROC.PH ensures that it conducts its business with the utmost ethical standards, adhering to all applicable laws and regulations. The company abstains from providing services when there is reasonable cause to suspect involvement in money laundering activities.
1.2.3 COOPERATION WITH LAW ENFORCEMENT AGENCIES
ROC.PH cooperates with law enforcement agencies while respecting client confidentiality within legal boundaries. The company will take necessary actions, as per the law, if there are valid grounds to suspect money laundering. Any disclosures required under the Act will be promptly made to the Executive Director of the Anti-Money Laundering Council of the Bangko Sentral ng Pilipinas.