REPUBLIC ACT NO.

9160 September 29, 2001 investment companies, common trust

funds, and other similar persons, and
AN ACT DEFINING THE CRIME OF MONEY (iii) other entities administering or
LAUNDERING, PROVIDING PENALTIES otherwise dealing in currency,
THEREFOR AND FOR OTHER PURPOSES commodities or financial derivatives
based thereon, valuable objects, cash
Be it enacted by the Senate and House of substitutes and other similar monetary
Representatives of the Philippines in Congress instruments or property supervised or
assembled: regulated by the Securities and
Exchange Commission (SEC);
Section 1. Short Title. – This Act shall be known as the
"Anti-Money Laundering Act of 2001." "(4) jewelry dealers in precious metals,
who, as a business, trade in precious
metals, for transactions in excess of
Section 2. Declaration of Policy. – It is hereby declared
One million pesos (P1,000,000.00);
the policy of the State to protect and preserve the
integrity and confidentiality of bank accounts and to
ensure that the Philippines shall not be used as a "(5) jewelry dealers in precious stones,
money laundering site for the proceeds of any unlawful who, as a business, trade in precious
activity. Consistent with its foreign policy, the State stones, for transactions in excess of
shall extend cooperation in transnational investigations One million pesos (P1,000,000.00);
and prosecutions of persons involved in money
laundering activities whenever committed. "(6) company service providers which,
as a business, provide any of the
REPUBLIC ACT NO. 10365 following services to third parties: (i)
acting as a formation agent of juridical
persons; (ii) acting as (or arranging for
AN ACT FURTHER STRENGTHENING THE ANTI-
another person to act as) a director or
MONEY LAUNDERING LAW, AMENDING FOR THE
corporate secretary of a company, a
PURPOSE REPUBLIC ACT NO. 9160, OTHERWISE
partner of a partnership, or a similar
KNOWN AS THE "ANTI-MONEY LAUNDERING ACT
position in relation to other juridical
OF 2001″, AS AMENDED
persons; (iii) providing a registered
office, business address or
Section 3(a) of Republic Act No. 9160, as amended, is accommodation, correspondence or
hereby amended to read as follows: administrative address for a company,
a partnership or any other legal person
"(a) ‘Covered persons’, natural or juridical, refer or arrangement; and (iv) acting as (or
to: arranging for another person to act as)
a nominee shareholder for another
"(1) banks, non-banks, quasi-banks, person; and
trust entities, foreign exchange
dealers, pawnshops, money changers, "(7) persons who provide any of the
remittance and transfer companies and following services:
other similar entities and all other
persons and their subsidiaries and (i) managing of client money,
affiliates supervised or regulated by the securities or other assets;
Bangko Sentral ng Pilipinas (BSP);
(ii) management of bank,
"(2) insurance companies, pre-need savings or securities accounts;
companies and all other persons
supervised or regulated by the
(iii) organization of
Insurance Commission (IC);
contributions for the creation,
operation or management of
"(3) (i) securities dealers, brokers, companies; and
salesmen, investment houses and
other similar persons managing
(iv) creation, operation or
securities or rendering services as
management of juridical
investment agent, advisor, or
persons or arrangements, and
consultant, (ii) mutual funds, close-end
 buying and selling business (3) securities or negotiable instruments, bonds,
entities. commercial papers, deposit certificates, trust
certificates, custodial receipts or deposit
"Notwithstanding the foregoing, substitute instruments, trading orders,
the term ‘covered persons’ transaction tickets and confirmations of sale or
shall exclude lawyers and investments and money marked instruments;
accountants acting as and
independent legal
professionals in relation to (4) other similar instruments where title thereto
information concerning their passes to another by endorsement,
clients or where disclosure of assignment or delivery.
information would compromise
client confidences or the (d) "Offender" refers to any person who commits a
attorney-client money laundering offense.
relationship: Provided, That
these lawyers and accountants (e) "Person" refers to any natural or juridical person.
are authorized to practice in the
Philippines and shall continue
(f) "Proceeds" refers to an amount derived or realized
to be subject to the provisions
from an unlawful activity.
of their respective codes of
conduct and/or professional
responsibility or any of its (g) "Supervising Authority" refers to the appropriate
amendments." supervisory or regulatory agency, department or office
supervising or regulating the covered institutions
enumerated in Section 3(a).
“(8) casinos, including internet and ship-based
casinos, with respect to their casino cash (h) "Transaction" refers to any act establishing any
transactiotus related to they gaming operations. (RA right or obligation or giving rise to any contractual or
10927 legal relationship between the parties thereto. It also
includes any movement of funds by any means with a
covered institution.

(b) "Covered transaction" is a single, series, or Section 3(i) of the same Act is hereby amended to read
combination of transactions involving a total amount in as follows:
excess of Four million Philippine pesos
(Php4,000,000.00) or an equivalent amount in foreign
"(i) ‘Unlawful activity’ refers to any act or
currency based on the prevailing exchange rate within
omission or series or combination thereof
five (5) consecutive banking days except those
involving or having direct relation to the
between a covered institution and a person who, at the
following:
time of the transaction was a properly identified client
and the amount is commensurate with the business or
financial capacity of the client; or those with an "(1) Kidnapping for ransom under
underlying legal or trade obligation, purpose, origin or Article 267 of Act No. 3815, otherwise
economic justification. known as the Revised Penal Code, as
amended;
It likewise refers to a single, series or combination or
pattern of unusually large and complex transactions in "(2) Sections 4, 5, 6, 8, 9, 10, 11, 12,
excess of Four million Philippine pesos 13, 14, 15 and 16 of Republic Act No.
(Php4,000,000.00) especially cash deposits and 9165, otherwise known as the
investments having no credible purpose or origin, Comprehensive Dangerous Drugs Act
underlying trade obligation or contract. of 2002;

(c) "Monetary Instrument" refers to: "(3) Section 3 paragraphs B, C, E, G, H

and I of Republic Act No. 3019, as
amended, otherwise known as the Anti-
(1) coins or currency of legal tender of the
Graft and Corrupt Practices Act;
Philippines, or of any other country;
"(4) Plunder under Republic Act No.
(2) drafts, checks and notes;
7080, as amended;
"(5) Robbery and extortion under "(17) Malversation of Public Funds and
Articles 294, 295, 296, 299, 300, 301 Property under Articles 217 and 222 of
and 302 of the Revised Penal Code, as the Revised Penal Code, as amended;
amended;
"(18) Forgeries and Counterfeiting
"(6) Jueteng and Masiao punished as under Articles 163, 166, 167, 168, 169
illegal gambling under Presidential and 176 of the Revised Penal Code, as
Decree No. 1602; amended;

"(7) Piracy on the high seas under the "(19) Violations of Sections 4 to 6 of
Revised Penal Code, as amended and Republic Act No. 9208, otherwise
Presidential Decree No. 532; known as the Anti-Trafficking in
Persons Act of 2003;
"(8) Qualified theft under Article 310 of
the Revised Penal Code, as amended; "(20) Violations of Sections 78 to 79 of
Chapter IV, of Presidential Decree No.
"(9) Swindling under Article 315 and 705, otherwise known as the Revised
Other Forms of Swindling under Article Forestry Code of the Philippines, as
316 of the Revised Penal Code, as amended;
amended;
"(21) Violations of Sections 86 to 106 of
"(10) Smuggling under Republic Act Chapter VI, of Republic Act No. 8550,
Nos. 455 and 1937; otherwise known as the Philippine
Fisheries Code of 1998;
"(11) Violations of Republic Act No.
8792, otherwise known as the "(22) Violations of Sections 101 to 107,
Electronic Commerce Act of 2000; and 110 of Republic Act No. 7942,
otherwise known as the Philippine
"(12) Hijacking and other violations Mining Act of 1995;
under Republic Act No. 6235;
destructive arson and murder, as "(23) Violations of Section 27(c), (e), (f),
defined under the Revised Penal Code, (g) and (i), of Republic Act No. 9147,
as amended; otherwise known as the Wildlife
Resources Conservation and
"(13) Terrorism and conspiracy to Protection Act;
commit terrorism as defined and
penalized under Sections 3 and 4 of "(24) Violation of Section 7(b) of
Republic Act No. 9372; Republic Act No. 9072, otherwise
known as the National Caves and Cave
"(14) Financing of terrorism under Resources Management Protection
Section 4 and offenses punishable Act;
under Sections 5, 6, 7 and 8 of
Republic Act No. 10168, otherwise "(25) Violation of Republic Act No.
known as the Terrorism Financing 6539, otherwise known as the Anti-
Prevention and Suppression Act of Carnapping Act of 2002, as amended;
2012:
"(26) Violations of Sections 1, 3 and 5
"(15) Bribery under Articles 210, 211 of Presidential Decree No. 1866, as
and 211-A of the Revised Penal Code, amended, otherwise known as the
as amended, and Corruption of Public decree Codifying the Laws on
Officers under Article 212 of the Illegal/Unlawful Possession,
Revised Penal Code, as amended; Manufacture, Dealing In, Acquisition or
Disposition of Firearms, Ammunition or
"(16) Frauds and Illegal Exactions and Explosives;
Transactions under Articles 213, 214,
215 and 216 of the Revised Penal "(27) Violation of Presidential Decree
Code, as amended; No. 1612, otherwise known as the Anti-
Fencing Law;
 "(28) Violation of Section 6 of Republic “x x x
Act No. 8042, otherwise known as the
Migrant Workers and Overseas “(l) For purposes of covered persons under
Filipinos Act of 1995, as amended by
Republic Act No. 10022; Section 3(a)(8), the following terms are hereby
defined as follows:
"(29) Violation of Republic Act No.
8293, otherwise known as the “(1) ‘Casino’ refers to a business authorized by
Intellectual Property Code of the the appropriate goverment agency to engage in
Philippines; gaming operations:

"(30) Violation of Section 4 of Republic “(i) ‘Internet-based casinos’ shall refer a casinos
Act No. 9995, otherwise known as the in which persons participate by the use of
Anti-Photo and Video Voyeurism Act of
2009;
remote communication facilities such as, but not
limited to, internet, telephone, television, radio
"(31) Violation of Section 4 of Republic or any other kind of electronic or other
Act No. 9775, otherwise known as the technology for facilitating communication; and
Anti-Child Pornography Act of 2009;
“(ii) ‘Ship-based casino’ shall refer to casinos,
"(32) Violations of Sections 5, 7, 8, 9, the operation of which is undertaken on board a
10(c), (d) and (e), 11, 12 and 14 of vessel, ship, boat or any other water-based craft
Republic Act No. 7610, otherwise wholly or partly intended for gambling;
known as the Special Protection of
Children Against Abuse, Exploitation
and Discrimination; “(2) ‘Casino cash transaction’ refers to
transactions involving the receipt of cash by a
"(33) Fraudulent practices and other casino paid by or on behalf of a customer, or
violations under Republic Act No. 8799, transactions involving the payout of cash by a
otherwise known as the Securities casino to a customer or to any person in his/her
Regulation Code of 2000; and behalf; and
"(34) Felonies or offenses of a similar “(3) ‘Gaming operations’ refer to the activities of
nature that are punishable under the
penal laws of other countries."
the casino offering games of chance and any
variations thereof approved by the appropriate
Section 3. Section 3 of the same Act shall have new government authorities.”
paragraphs (j) and (k).
Section 4. Section 4 of the same Act is hereby
"(j) Precious metals’ shall mean gold, silver, amended to read as follows:
platinum, palladium, rhodium, ruthenium,
iridium and osmium. These include alloys of "SEC. 4. Money Laundering Offense. – Money
precious metals, solders and plating chemicals laundering is committed by any person who,
such as rhodium and palladium plating knowing that any monetary instrument or
solutions and potassium gold cyanide and property represents, involves, or relates to the
potassium silver cyanide and silver cyanide in proceeds of any unlawful activity:
salt solution.
"(a) transacts said monetary instrument
"(k) ‘Precious stones’ shall mean diamond, or property;
ruby, emerald, sapphire, opal, amethyst, beryl,
topaz, and garnet that are used in jewelry "(b) converts, transfers, disposes of,
making, including those formerly classified as moves, acquires, possesses or uses
semi-precious stones." said monetary instrument or property;

Sector 3 of Republic Act No. 9160, as amended, "(c) conceals or disguises the true
is hereby further amended by inserting a new nature, source, location, disposition,
paragraph (l) to read as follows: movement or ownership of or rights
 with respect to said monetary organizational structure, as well as the
instrument or property; authority and identification of all persons
purporting to act on their behalf.
"(d) attempts or conspires to commit
money laundering offenses referred to The provisions of existing laws to the contrary
in paragraphs (a), (b) or (c); notwithstanding, anonymous accounts,
accounts under fictitious names, and all other
"(e) aids, abets, assists in or counsels similar accounts shall be absolutely prohibited.
the commission of the money Peso and foreign currency non-checking
laundering offenses referred to in numbered accounts shall be allowed. The BSP
paragraphs (a), (b) or (c) above; and may conduct annual testing solely limited to the
determination of the existence and true identity
"(f) performs or fails to perform any act of the owners of such accounts.
as a result of which he facilitates the
offense of money laundering referred to (b) Record Keeping – All records of all
in paragraphs (a), (b) or (c) above. transactions of covered institutions shall be
maintained and safely stored for five (5) years
"Money laundering is also committed by any from the date of transactions. With respect to
covered person who, knowing that a covered or closed accounts, the records on customer
suspicious transaction is required under this identification, account files and business
Act to be reported to the Anti-Money correspondence, shall be preserved and safety
Laundering Council (AMLC), fails to do so." stored for at least five (5) years from the dates
when they were closed.

(c) Reporting of Covered and Suspicious Transactions.

– Covered persons shall report to the AMLC all covered
Section 5. Section 6(a) of the same Act is hereby
transactions and suspicious transactions within five (5)
amended to read as follows:
working days from occurrence thereof, unless the
AMLC prescribes a different period not exceeding
"SEC. 6. Prosecution of Money Laundering. – fifteen (15) working days.

"(a) Any person may be charged with "Lawyers and accountants acting as independent legal
and convicted of both the offense of professionals are not required to report covered and
money laundering and the unlawful suspicious transactions if the relevant information was
activity as herein defined. obtained in circumstances where they are subject to
professional secrecy or legal professional privilege.
"(b) The prosecution of any offense or
violation under this Act shall proceed When reporting covered transactions to the AMLC,
independently of any proceeding
covered institutions and their officers, employees,
relating to the unlawful activity."
representatives, agents, advisors, consultants or
associates shall not be deemed to have violated
Republic Act No. 1405, as amended; Republic Act No.
(b) Any proceeding relating to the unlawful activity shall 6426, as amended; Republic Act No. 8791 and other
be given precedence over the prosecution of any similar laws, but are prohibited from communicating,
offense or violation under this Act without prejudice to directly or indirectly, in any manner or by any means,
the freezing and other remedies provided. to any person the fact that a covered transaction report
was made, the contents thereof, or any other
Section 9. Prevention of Money Laundering; Customer information in relation thereto. In case of violation
Identification Requirements and Record Keeping. – thereof, the concerned officer, employee,
representative, agent, advisor, consultant or associate
(a) Customer Identification, - Covered of the covered institution, shall be criminally liable.
institutions shall establish and record the true However, no administrative, criminal or civil
identity of its clients based on official proceedings, shall lie against any person for having
documents. They shall maintain a system of made a covered transaction report in the regular
verifying the true identity of their clients and, in performance of his duties and in good faith, whether or
case of corporate clients, require a system of not such reporting results in any criminal prosecution
verifying their legal existence and under this Act or any other Philippine law.
"When reporting covered or suspicious transactions to twenty-four (24)-hour period shall exclude the
the AMLC, covered persons and their officers and nonworking days.
employees are prohibited from communicating, directly
or indirectly, in any manner or by any means, to any “The freeze order or asset preservation order
person or entity, the media, the fact that a covered or issued under this Act shall be limited only to the
suspicious transaction has been reported or is about to
amount of cash or monetary instrument or value
be reported, the contents of the report, or any other
of property that the court finds there is probable
information in relation thereto. Neither may such
cause to be considered as proceeds of a
reporting be published or aired in any manner or form
by the mass media", electronic mail, or other similar predicate offense, and the freeze order or asset
devices. In case of violation thereof, the concerned preservation order shall not apply to amounts in
officer and employee of the covered person and media the same account in excess of the amount or
shall be held criminally liable." value of the proceeds of the predicate offense.

Section 4. Section 10 of Republic Act. No. SEC. 2. Section 11 of the same Act is hereby
9160, as amended, is hereby further amended amended to read as follows:
to read as follows:
“SEC. 11. Authority to Inquire into Bank
“Sec. 10. Freezing of Monetary Instrument or Deposits. – Notwithstanding the provisions of
Property.— Upon a verified ex parte petition by Republic Act No. 1405, as amended; Republic
the AMLC and after determination that probable Act No. 6426, as amended; Republic Act No.
cause exists that any monetary instrument or 8791; and other laws, the AMLC may inquire
property is in any way related to an unlawful into or examine any particular deposit or
activity as defined in Section 3(i) hereof, the investment, including related accounts, with any
Court of Appeals may issue a freeze order which banking institution or non-bank financial
shall be effective immediately, for a period of institution upon order of any competent court
twenty (20) days. Within the twenty (20)-day based on an ex parte application in cases of
period, the Court of Appeals shall conduct a violations of this Act, when it has been
summary hearing, with notice to the parties, to established that there is probable cause that the
determine whether or not to modify or lift the deposits or investments, including related
freeze order, or extend its effectivity. The total accounts involved, are related to an unlawful
period of the freeze order issued by the Cout of activity as defined in Section 3(i) hereof or a
Appeals under this provision shall not exceed money laundering offense under Section 4
six (6) months. This is without prejudice to an hereof; except that no court order shall be
asset preservation order that the Regional Trial required in cases involving activities defined in
Court having jurisdiction over the appropriate Section 3(i)(1), (2), and (12) hereof, and felonies
anti-money laundering case or civil forfeiture or offenses of a nature similar to those
case may issue on the same account depending mentioned in Section 3(i)(1), (2), and (12), which
upon the circumstances of the case, where the are Punishable under the penal laws of other
Court of Appeals will remand the case and its countries, and terrorism and conspiracy to
records: Provided, That if there is no case filed commit terrorism as defined and penalized
against a person whose account has been under Republic Act No. 9372.”
frozen within the period determined by the Court
of Appeals, not exceeding six (6) months, the “The Court of Appeals shall act on the
freeze order shall be seemed ipso application to inquire into or examine any
facto lifted: Provided, further, That this new rule deposit or investment with any banking
shall not apply to pending cases in the courts. In institution or non-bank financial institution within
any case, the court should act on the petition to twenty-four (24) hours from filing of the
freeze within twenty-four (24) hours from filing of application.”
the petition. If the application is filed a day
before a no working day, the computation of the “To ensure compliance with this Act, the Bangko
Sentral ng Pilipinas may, in the course of a
periodic or special examination, check the
compliance of a Covered institution with the same difficult to identify or be segregated for
requirements of the AMLA and its implementing purposes of forfeiture.
rules and regulations.”
"(b) Claim on Forfeited Assets. – Where the
court has issued an order of forfeiture of the
“For purposes of this section, ‘related accounts’ monetary instrument or property in a criminal
shall refer to accounts, the funds and sources of prosecution for any money laundering offense
which originated from and/or are materially defined under Section 4 of this Act, the offender
linked to the monetary instrument(s) or or any other person claiming an interest therein
property(ies) subject of the freeze order(s).” may apply, by verified petition, for a declaration
that the same legitimately belongs to him and
“A court order ex parte must first be obtained for segregation or exclusion of the monetary
instrument or property corresponding thereto.
before the AMLC can inquire into these related The verified petition shall be filed with the court
Accounts: Provided, That the procedure for the which rendered the judgment of forfeiture,
ex parte application of the ex parte court order within fifteen (15) days from the date of the
for the principal account shall be the same with finality of the order of forfeiture, in default of
that of the related accounts.” which the said order shall become final and
executor. This provision shall apply in both civil
and criminal forfeiture.
“The authority to inquire into or examine the
main account and the related accounts shall
"(c) Payment in Lieu of Forfeiture. – Where the
comply with the requirements of Article III, court has issued an order of forfeiture of the
Sections 2 and 3 of the 1987 Constitution, which monetary instrument or property subject of a
are hereby incorporated by reference.” money laundering offense defined under
Section 4, and said order cannot be enforced
Section 9. Section 12 of the same Act is hereby because any particular monetary instrument or
amended to read as follows: property cannot, with due diligence, be located,
or it has been substantially altered, destroyed,
"(a) Civil Forfeiture. – Upon determination by diminished in value or otherwise rendered
the AMLC that probable cause exists that any worthless by any act or omission, directly or
monetary instrument or property is in any way indirectly, attributable to the offender, or it has
related to an unlawful activity as defined in been concealed, removed, converted, or
Section 3(i) or a money laundering offense otherwise transferred to prevent the same from
under Section 4 hereof, the AMLC shall file with being found or to avoid forfeiture thereof, or it
the appropriate court through the Office of the is located outside the Philippines or has been
Solicitor General, a verified ex parte petition for placed or brought outside the jurisdiction of the
forfeiture, and the Rules of Court on Civil court, or it has been commingled with other
Forfeiture shall apply. monetary instruments or property belonging to
either the offender himself or a third person or
"The forfeiture shall include those other entity, thereby rendering the same difficult to
monetary instrument or property having an identify or be segregated for purposes of
equivalent value to that of the monetary forfeiture, the court may, instead of enforcing
instrument or property found to be related in the order of forfeiture of the monetary
any way to an unlawful activity or a money instrument or property or part thereof or interest
laundering offense, when with due diligence, therein, accordingly order the convicted
the former cannot be located, or it has been offender to pay an amount equal to the value of
substantially altered, destroyed, diminished in said monetary instrument or property. This
value or otherwise rendered worthless by any provision shall apply in both civil and criminal
act or omission, or it has been concealed, forfeiture."
removed, converted, or otherwise transferred,
or it is located outside the Philippines or has
been placed or brought outside the jurisdiction
IRR
of the court, or it has been commingled with
other monetary instrument or property G. “Covered transaction” refers to:
belonging to either the offender himself or a
third person or entity, thereby rendering the
1. A transaction in cash or other equivalent
monetary instrument exceeding Five Hundred
Thousand pesos (Php500,000.00) covered person knew or should have known the
suspicious transaction indicator.
2. A transaction exceeding One Million pesos
(Php1,000,000.00) in cases of jewelry dealers, Should a transaction be determined to be both a
dealers in precious metals and dealers in precious covered and a suspicious transaction, the same
stones. shall be reported as a suspicious transaction.

H. “Suspicious Transaction” refers to a transaction, 1. Substance and Form of Reports. - Covered

regardless of amount, where any of the following persons shall ensure the accuracy and
circumstances exists: completeness of covered transaction report and
suspicious transaction report, which shall be filed in
1. there is no underlying legal or trade obligation, the forms prescribed by the AMLC and shall be
purpose or economic justification; submitted in a secured manner to the AMLC in
electronic form.
2. the client is not properly identified;
2. Confidentiality of Reporting. - When reporting
3. the amount involved is not commensurate with covered or suspicious transactions, covered
the business or financial capacity of the client; persons, and their officers and employees, are
prohibited from communicating, directly or indirectly,
4. taking into account all known circumstances, it in any manner or by any means, to any person or
may be perceived that the client’s transaction is entity, or the media, the fact that a covered or
structured in order to avoid being the subject of suspicious transaction has been or is about to be
reporting requirements under the AMLA; reported, the contents of the report, or any other
information in relation thereto.
5. any circumstance relating to the transaction
which is observed to deviate from the profile of the Any information about such reporting shall not be
client and/or the client’s past transactions with the published or aired, in any manner or form, by the
covered person; mass media, or through electronic mail, or other
similar devices.
6. the transaction is in any way related to an
unlawful activity or any money laundering activity or In case of violation thereof, the concerned officer,
offense that is about to be committed, is being or has and employee, of the covered person and media
been committed; or shall be held criminally liable.

7. any transaction that is similar, analogous or 3. Safe Harbor Provision. - No administrative,

identical to any of the foregoing. criminal or civil proceedings shall lie against any
person for having made a covered transaction or
C. Transaction Reporting. - Covered persons shall suspicious transactaction report in the regular
report to the AMLC all covered transactions and performance of his duties and in good faith,
suspicious transactions within five (5) working days, whether or not such reporting results in any
unless the AMLC prescribes a different period not criminal prosecution under the AMLA or any
exceeding fifteen (15) working days, from the other Philippine law.
occurrence thereof.
4. Enrollment with the AMLC’s Reporting System.
For suspicious transactions, “occurrence” refers to
- All covered persons shall register with the AMLC’s
the date of determination of the suspicious nature of
electronic reporting system within ninety (90) days
the transaction, which determination should be
from the effectivity of this RIRR.
made not exceeding ten (10) calendar days from the
date of transaction. However, if the transaction is in
any way related to, or the person transacting is
involved in or connected to, an unlawful activity or
money laundering offense, the 10-day period for
determination shall be reckoned from the date the