AMLC: DECLARE TRANSACTIONS

Broker: Hi Juan, are we really required to report real estate deals over Php7.5 million to the AMLC?

JPRE: Let’s break it down from the top.

The Anti-Money Laundering Council (AMLC) now requires all real estate brokers to register with them what they call "covered transactions." One of those is:

"Any single cash transaction exceeding Php7,500,000 (or its equivalent in foreign currency). This includes both cash paid to buy property and cash received from its sale."

Now, what exactly does "cash" mean here?

According to AMLC and BSP officials during a seminar I attended, they're talking literal cash—as in, bundles of physical bills. That suitcase-of-money kind of situation.

What’s not included?

Manager’s checks, even though they’re often treated as “good-as-cash,” fall into a different category. These are issued and cleared through banks, and therefore already pass through banking AML filters.

The logic: Once the funds touch the banking system, they’ve already been screened. But cash? That’s off-the-grid until you declare it.

So yes, brokers do have an obligation—but only for cold, hard cash transactions over Php7.5 Mn. Not every big sale. Just the unbanked ones.