WILL BANKS ALLOW IT?

Question: A Filipino-American buyer who lives in the United States is purchasing a property in the Philippines.

To avoid timing issues in remitting funds, the buyer sends the purchase money to a sibling in the Philippines. The sibling then purchases a Manager's Check payable to the seller.

Would a bank allow this arrangement, considering its AMLA compliance requirements, even though the Manager's Check is being purchased by someone other than the buyer?

A: Yes, the bank will allow it.

B: No, the bank will not allow it.

*****

80% voted yes.

20% voted no.

The correct answer is:

Yes—but subject to the banks’ approval and compliance review.

How do I know this can be done?

Because I personally witnessed this exact arrangement in an actual property transaction.

The buyer’s funds were divided between two major Philippine banks. After completing their respective compliance reviews, both banks credited the remittances and issued the Manager’s Checks required for the purchase.

As expected, the transactions were flagged for further verification. That did not mean the funds were illegal or that the transaction was automatically prohibited. It meant the banks needed to establish the source, purpose, and parties behind the transfers.

Among the documents requested were:

1. The contract showing that the funds would be used to purchase a specific property;

2. The birth certificates of the buyer and the Philippine-based sibling, confirming their identities and relationship; and

3. An apostilled Special Power of Attorney authorizing the sibling to act for the buyer in connection with the property purchase.

The important lesson is that a large or unusual remittance may be delayed and investigated—but it can still be approved when the parties can properly document the source of the money, the purpose of the transfer, and the authority of the person acting for the buyer.

However, approval is never automatic. Each bank conducts its own assessment based on its internal policies and the circumstances of the transaction.

But what if the recipient is merely a friend rather than a sibling?

That arrangement may receive greater scrutiny because the bank will need to understand why a substantial amount is being transferred to an unrelated third party and why that person is purchasing Manager’s Checks on behalf of the buyer.

If the bank is not satisfied, it may decline to credit the remittance or arrange for the funds to be returned through the sending bank.

So, yes, banks may allow it—provided the parties can fully explain and document the transaction.