Terrorism and Money Laundering Regulations

The Philippine Association of Gold Banks (“PAGB“) is required by various regulations to ensure that none of its assets are provided or utilised either “directly or indirectly” for the benefit of an individual or group designated as terrorist under the Office of Foreign Assets Control (“OFAC“) and in particular the various Sanctions Programs which OFAC administers. In addition, PAGB complies with the Money Laundering Regulations in all jurisdictions in which it operates.
 

PAGB recognises that Endemic economic crime (particularly when associated with organised crime and terrorist financing) can threaten laws, democratic processes and basic human freedoms, impoverishing states and distorting free trade and competition.

PAGB is committed to conducting its global activities with integrity and respecting its regulatory, ethical and social responsibilities to:

  • Protect investors, employers, employees and any others with whom PAGB interacts; and,
  • Support governments, regulators, and law enforcement in wider economic crime prevention.

PAGB will not tolerate any deliberate breach of financial crime laws and regulations (e.g. bribery, corruption, and money laundering, sanctions, or tax evasion facilitation) that apply to the transactions we facilitate and undertake.

PAGB has a dedicated global Financial Crime function, which sits within Compliance under the control and oversight of the Chief Executive Officer.

The Financial Crime function facilitates risk-based, effective and efficient financial crime risk management by providing expert support and oversight to the PAGB and our legal entities around the world.

PAGB has adopted a holistic approach to Financial Crime and have one group-wide Financial Crime Policy that sets the minimum control requirements in four key risk areas: –

  • anti-bribery & corruption (ABC)
  • anti-money laundering & counter-terrorist financing (AML)
  • anti-tax evasion facilitation (ATEF); and,
  • sanctions.

This combined approach allows PAGB to effectively identify and efficiently manage the relevant inter-connectivity between the key risk areas.

 
Employees and Consultants are made aware that failure to comply with the Financial Crime Policy and/or associated Standards may give rise to disciplinary action, up to and including dismissal.
 
Where PAGB operates in other jurisdictions, it will comply with the relevant Bribery, Modern Slavery, Terrorism and Money Laundering legislation and regulations. These regulations require PAGB to undertake checks on account holders, suppliers, sub-contractors. In addition, these checks will be reviewed and new checks undertaken on a regular basis in order to confirm compliance with the latest standards, rules and sanctions lists.
 
To meet these obligations PAGB will:
  • check all investor organisations against the relevant lists of “proscribed organisations
  • ensure that all country programmes undertake an annual risk assessment
  • provide guidelines to staff on relevant Terrorism and Money Laundering regulations to reduce the risk of abuse
  • establish internal reporting procedures on actual or suspected incidents involving “proscribed organisations
  • include a requirement in partner and affiliate agreements not to support “proscribed organisations
However, PAGB also acknowledges that many NGOs and civil society organisations around the world, have expressed concern about the process undertaken by governments when designating an organisation as being “terrorist”. Therefore, should any PAGB prospective or active client or affiliate organisation be subject to investigation or “proscription” by the relevant authorities in circumstances where PAGB has reason to doubt the soundness of the decision taken to “proscribe” that organisation, then PAGB may make representations to the relevant authorities to review the designation.
 
NB: this policy was first approved in June 2024, it is reviewed annually and is due for review and renewal in June 2025.