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BSP Memorandum No. 29 (2026)

Guidelines on the Submission of the Report on Temporarily-Held Funds (THF) through the Advanced Suptech Engine for Risk-based Compliance (ASTERisC*) Platform and the Execution of Annual Notarized Certification

BSP Memorandum · June 24, 2026


To

Subject

BANGKO SENTRAL NG PILIPINAS

OFFICE OF THE DEPUTY GOVERNOR | FINANCIAL SUPERVISION SECTOR

MEMORANDUM NO. M-2026-029

ALL BANGKO SENTRAL-SUPERVISED INSTITUTIONS (BSIs)

Guidelines on the Submission of the Report on Temporarily-Held Funds (THF) through the Advanced Suptech Engine for Risk-based Compliance (ASTERisC*) Platform and the Execution of Annual Notarized Certification

To implement Republic Act No. 12010, otherwise known as the Anti-Financial Account Scamming Act (AFASA), the BSP issued Circular No. 1215 covering regulations on the temporary holding of funds subject to disputed transactions and the coordinated verification process. Pursuant to the Circular, all Bangko Sentral-Supervised Institutions (BSIs) are required to submit periodic reports on funds subject to temporary holding and an annual notarized certification on compliance with the related requirements of adequate risk management systems and controls to the Bangko Sentral.

Accordingly, the following guidelines shall be observed:

A. Report on Temporarily-Held Funds (THF)

1.

These guidelines on the submission of Report on Temporary Holding of Disputed Funds shall take effect on O9 July 2026, or one (1) year from the effectivity of BSP —- Tee Circular No. 1215.

The following guidelines shall apply to all Banks, Electronic Money Issuers (EMI), Virtual Asset Service Providers (VASP), and all other BSIs enrolled in ASTERisC*.

a.

c.

d.

The Data Entry Template (DET) for the THF report shall be deployed in ASTERisC* and shall be made available to existing users upon issuance of this memorandum. ASTERisC* is accessible through https://asterisc.bsp.gov.ph. Meanwhile, BSIs may access the system in advance to familiarize themselves with the DET.

The ASTERisC* user manual, instructional videos, data import template, and Control Prooflist (CP) for the THF report and the ASTERisC* User Account Form (UAF) are accessible in the BSP website (www.bsp.gov.ph/ses/reporting templates). New and existing ASTERisC* users are required to review the instructional videos and user manual prior to submission of reports on THF through ASTERisC*.

The scanned CP (see Annex A for the CP Template) in Portable Document Format (PDF) shall be signed by the President/Chief Executive Officer and Chief Compliance Officer or Officers of equivalent rank, duly designated by the BSI’s Board of Directors of the reporting entity and attached to the monthly record in ASTERisC*.

An email notification will automatically be sent to the ASTERisC* authorized user once the monthly THF report is submitted.

3. The Guidelines on the Submission of Report on Temporary Holding of Disputed Fund's (see Annex B) as specified under Annex C of BSP Circular No. 1215 or Appendix

Page 1 of 2

Page 2 of 2 162/Q-106/1105-3 of the MORB/MORNBFI/MORPS1 shall remain applicable to all other BSIs not covered in #2 above. The prescribed DET, CP (see Annex A), and user guide may also be downloaded from the BSP website (www.bsp.gov.ph/ses/reporting_templates).

4. BSIs shall submit the THF report on or before the 15th of the month, covering the data from the previous reference month. A BSI is not required to submit a THF report if no funds were held during the reference month. Non-submission shall be deemed as the BSI’s formal declaration that it held no funds.

5. Initial submission of the THF Report shall be due on 15 September 2026 covering the THF for the month of August 2026.

B. Annual Notarized Certification on Compliance

1. Within thirty (30) calendar days from end of year, BSIs that initiated or effected Temporary Holding of Disputed Funds during the immediately preceding year shall execute and submit to the Consumer Account Protection Office (CAPO) a notarized certification that it complied with the related requirements of adequate risk management systems and controls as prescribed by the Bangko Sentral at the time that it initiated or effected the holding of funds.

2. The scanned copy of the notarized certification (see Annex C for the certification template) in PDF shall be transmitted to [email protected], using the following e-mail subject format:

ANC<Space><BSI NAME><Space><Date of Approval by the BSI President or Officer of equivalent rank in DD MONTH YYYY format>

For example:

TO: [email protected] SUBJECT: ANC ABC Bank 29 JANUARY 2027

For inquiries regarding the THF reporting requirements and annual notarized certification on compliance, BSIs may contact the Consumer Account Protection Office at [email protected].

For technical issues related to the ASTERisC* platform, coordinate with the Technology Risk and Innovation Supervision Department (TRISD) at [email protected].

For compliance.

LYN I. JAVIER

Deputy Governor

__ June 2026

1 Manual of Regulations for Banks (MORB), Manual of Regulations for Non-Bank Financial Institutions (MORNBFI), and Manual of Regulations for Payment Systems (MORPS) LYN I. JAVIER Deputy Gov ov ov ov over e nor 24 Digitally signed by Lyn I. Javier

Annex A Page 1 of 2 (Name of BSP-Supervised Institution)(BSI Code) Report on Temporarily-Held Funds (THF) Monthly Report

CONTROL PROOFLIST

I hereby certify that the contents of this monthly report which includes details of Temporarily-Held Funds (THF) are true and correct to the best of my knowledge.

Report Cutoff Month-Year

Part 1: Volume of Temporarily-Held Funds Trigger to Hold Funds Number of Disputed

Transactions reported as 'Ongoing - Funds remain on hold' under Status of Held Funds at the Time of Reporting Number of Disputed Transactions reported as 'Released to Source Account Owner - Amount on hold was released to the Source Account Owner' under Status of Held Funds at the Time of Reporting Number of Disputed Transactions reported as 'Released to Beneficiary Account Owner - Amount on hold was released to the Beneficiary Account Owner ' under Status of Held Funds at the Time of Reporting Complaint filed by Source Account Owner

BSI’s own Fraud Management System (Outgoing Transactions) – flagged by Originating Financial Institution

BSI’s own Fraud Management System (Incoming Transactions) – flagged by Receiving Financial Institution

Information from another BSP Supervised Institution (Based on Complaint or FMS Finding) – Initial Holding Request based on complaint or FMS

Information from another BSP Supervised Institution (Based on Other Grounds) – Initial Holding Request not based on complaint or FMS

TOTAL

Page 2 of 2

Part 2: Amount (in Philippine Pesos*) of Temporarily-Held Funds Trigger to Hold Funds Total Amount of Disputed Transactions

reported as 'Ongoing - Funds remain on hold' under Status of Held Funds at the Time of Reporting Total Amount of Disputed Transactions reported as 'Released to Source Account Owner - Amount on hold was released to the Source Account Owner' under Status of Held Funds at the Time of Reporting Total Amount of Disputed Transactions reported as 'Released to Beneficiary Account Owner - Amount on hold was released to the Beneficiary Account Owner ' under Status of Held Funds at the Time of Reporting Complaint filed by Source Account Owner

BSI’s own Fraud Management System (Outgoing Transactions) – flagged by Originating Financial Institution

BSI’s own Fraud Management System (Incoming Transactions) – flagged by Receiving Financial Institution

Information from another BSP Supervised Institution (Based on Complaint or FMS Finding) – Initial Holding Request based on complaint or FMS

Information from another BSP Supervised Institution (Based on Other Grounds) – Initial Holding Request not based on complaint or FMS

TOTAL

*For the PHP equivalent of foreign currency amounts that are subject to hold, use the updated BSP Reference Rate Exchange Bulletin at the time of reporting

Chief Compliance Officer (or duly-authorized officer of equivalent rank) (Signature over Printed Name)

President/Chief Executive Officer (or duly-authorized officer of equivalent rank) (Signature over Printed Name)

Annex B

APPENDIX 162/Q-106/1105-3

(Annex C of Circular)

Guidelines on the Submission of Report on Temporary Holding of Disputed Funds (Appendix to Section 1006/1006-Q/1105 on Report to Bangko Sentral on the Temporary Holding of Disputed Funds)

Scope. These Guidelines shall apply to all Bangko Sentral-Supervised Institutions (BSIs) that temporarily hold funds subject of disputed transactions, in accordance with Section 7 of R.A. No. 12010, or the Anti- Financial Account Scamming Act (AFASA), and its implementing rules and regulations.

Report Content. A BSI shall promptly notify the Bangko Sentral whenever it temporarily holds funds that are the subject of a disputed transaction.

The report shall be called Report on Temporarily-Held Funds (THF). The required information, definitions, formats, values, and field requirements are provided below. These details are arranged according to their order on the Data Entry Template (DET). All information tagged as “Conditional” may be left blank only if the information is unavailable in the reporting BSI.

Requirement

Reporting The Bank Code of the | Numeric Assigned BSI per | Mandatory BSI BSP Supervised Reporting Entity

Institution (BSI) who

is submitting the

Report Branch of | The Branch Code of the |} Numeric >=0, Positive | Mandatory Account specific Branch of the integers

Reporting BSI where

the account subjected

to holding of funds is

maintained Reference Unique Reference Mandatory No. Number per Case

(Should be unique per case)

Convention:

THF YYYYMMDD Bank

Code_0000001 Trigger to | The main trigger for Mandatory Hold Funds the Reporting BSI to

initiate holding of

funds

Choose only One from these options: e Complaint filed by Source Account Owner

BSI’s own Fraud Management System (Outgoing Transactions)

- flagged by Originating

Page 1 of 10

Status of Held Funds at the Time of Reporting

Financial Institution

e BSI’s own Fraud Management System (Incoming Transactions) - flagged by Receiving Financial Institution

Information from another BSP Supervised Institution (Based on Complaint or

FMS Finding) —- Initial Holding Request based on complaint or FMS

Information from another BSP Supervised Institution (Based on Other Grounds) = Initial Holding Request based complaint FMS The Status of the temporarily held funds at the time of reporting:

Choose only One from these options: e Ongoing - Funds remain on hold

e Released to Source Account Owner - Amount

on hold was released to the Source Account Owner

e Released to Beneficiary Account Owner - Amount on hold was released to the Beneficiary Account Owner

Field

Requirement

Mandatory

Page 2 of 10

Requirement

Date of | Date when the trigger | Numeric Date Convention: | Mandatory Receipt/ to initiate the YYYYMMDD Transmission | holding of funds was of Trigger | received by, or to Hold | transmitted to, the Funds Reporting BSI “Date of Receipt/ Transmission” can be any of the following, whichever Trigger to Hold Funds came first: e Date of receipt of information or Initial Holding Request from another BSI Date of transmission of finding/ notification/ alert through BSI’s own FMS Date of receipt of complaint from Source Account Owner Time of | Exact Time when the | Numeric Time Convention: | Mandatory Receipt/ trigger to initiate HH:MM:SS Transmission | the holding of funds of Trigger | was received by, or to Hold | transmitted to, the Funds Reporting BSI “Time of Receipt/ Transmission” can be any of the following whichever Trigger to Hold Funds came first: e Time of receipt of information or Initial Holding Request from another BSI Time of transmission of finding/ notification/ alert through BSI’s own EMS Time of receipt of complaint from Source Account Owner

Date of | Date when the | Numeric Date Convention: | Mandatory Initiation Reporting BSI YYYYMMDD of Hold initiated the holding

of funds Time of Exact Time when the Numeric Time Convention: Mandatory Initiation Reporting BSI HH:MM:SS of Hold initiated the holding

of funds

Page 3 of 10

Requirement

Date of Date when the Numeric Date Convention: Conditional Release of Reporting BSI YYYYMMDD Held Funds released the held

funds to the

Source/Beneficiary

Account Owner

Time of Exact Time when the Numeric Time Convention: Conditional Release of Reporting BSI HH:MM:SS Held Funds released the held funds to the Source/Beneficiary Account Owner Amount on Amount that is Numeric >=0, Positive Mandatory Hold in temporarily on hold integers Original in Original Currency Currency

Original Original Currency of Text Text Mandatory Currency of the amount that is Amount on temporarily on hold Hold Choose Currency Code from the list below: Code Unit Philippine i Fae JPY Japanese GBP British aa Ea HKD Hongkong eerie CAD Canadian a Ee Dollar Dollar a Fa Dinar SAR Arabian Riyal BND Bruneian Dollar IDR Indonesian Rupiah Emirati aa Eee

| EUR |

South Korean Won Page 4 of 10

Yuan If the Original Currency is not included in the defined Currency Codes, input CCC; [original currency unit in full].

Field Name Definition Format Value eiet9 Requirement

Amount on >= Hold in PHP

Account Number Subject to Hold

Last Name of Account Owner Subject to Hold

First Name of Account Owner Subject to Hold

Amount that is temporarily on hold in PHP equivalent at the time of reporting, based on BSP Reference Exchange Rates Bulletin published in BSP website

Account Number subject to the temporary hold of funds

Last Name of Account Owner subject to the temporary hold of funds

For Corporate Accounts, use registered Corporate Account Name recorded in the BSI

First Name of Account Owner subject to the temporary hold of funds

For Joint Accounts, Names should be separated by commas

May be left blank only if the Account Subject to Hold is a Corporate Account

Mandatory

Mandatory

Mandatory

Conditional

Middle Name of Account Owner Subject to Hold

Address of Account Owner Subject to Hold

Middle Name of Account Owner subject to the temporary hold of funds

For Joint Accounts, Names should be separated by commas

Mandatory if information is available in the Reporting BSI Address of Account Owner subject to the temporary hold of funds

Format: House Number, Street/Block, Barangay, Town, City/Municipality

For Joint Accounts with different addresses, addresses should be separated by commas

Text Text Text Text

Conditional

Mandatory

Page 5 of 10

Requirement

Contact Number of Account Owner Subject to Hold

Email Address of Account Owner Subject to Hold

Name of Originating Financial Institution

Amount Under Dispute in Original Currenc Original Currency of Amount Under Dispute

Contact Number of Account Owner subject to the temporary hold of funds

For Joint Accounts and those that have multiple contact numbers, contact numbers should be separated by commas

Mandatory if information is available in the Reporting BSI

Email Address of Account Owner subject to the temporary hold of funds

For Joint Accounts and those that have multiple e-mail addresses, e-mail addresses should be separated by commas

Mandatory if information is available in the Reporting BSI Complete Legal/Registered Name of the Originating Financial Institution (Do Not Abbreviate)

Mandatory if “Trigger to Hold Funds” field shows:

e “Information from another Bangko Sentral Supervised Institution (BSI)” or “Complaint filed by Source Account Owner”

Full amount of funds

under dispute in its

Original Currency

Original Currency of the amount under dispute

Choose Currency Code from the list below:

Currency Currency Code Unit

Peso

U.S. Dollar

an

integers

Conditional Conditional

Conditional

Mandatory

Mandatory

Page 6 of 10

Account Number of Source Account

Last Name of Account Owner of the Source Account

Arabian Riyal Bruneian

Indonesian

Thai Baht Emirati

If the Original Currency is not included in the defined Currency Codes, input CCC; [original currency unit in full].

Account Number from which the disputed funds originated

Mandatory if “Trigger to Hold Funds” field shows:

e “Information from another Bangko Sentral Supervised Institution (BSI)” or “Complaint filed by Source Account Owner”

Last Name of Account

Owner from which the

disputed funds

originated

For Corporate Accounts, use registered Corporate

Page 7 of 10

Account Name recorded in the BSI

Mandatory if “Trigger to Hold Funds” field shows:

e “Information from another Bangko Sentral Supervised Institution (BSI) ‘or “Complaint filed by Source Account Owner”

First Name First Name of Account | Text Text Conditional of Account Owner from which the Owner of the | disputed funds Source originated Account For Joint Accounts, Names should be separated by commas Mandatory if “Trigger to Hold Funds” field shows: e “Information from another Bangko Sentral Supervised Institution (BSI)” or “Complaint filed by Source Account Owner” May be left blank only if the Account is a Corporate Account

Middle Name Middle Name of Text Text Conditional of Account Account Owner from Owner of the | which the disputed Source funds originated Account For Joint Accounts, Names should be separated by commas Mandatory if “Trigger to Hold Funds” field shows: e “Information from another Bangko Sentral Supervised Institution (BS2L)" ‘or “Complaint filed by Source Account Owner”

Page 8 of 10

Definition

Mandatory if

information is available in the Reporting BSI

Reporting Frequency. The BSI shall submit the THF Report every 15% of the month, covering the data from the previous reference month.

A BSI is not required to submit a THF Report if no funds were held during the reference month. Non-submission shall be deemed as the BSI’s formal declaration that it held no funds.

Reporting Template. The BSI shall use the prescribed DET and Control Prooflist (CP) when reporting to the Bangko Sentral. The prescribed DET, CP, and User Guide can be downloaded from www.

Submission Procedures. The DET shall be certified correct through the CP and shall be signed by the BSI’s President/Chief Executive Officer and Chief Compliance Officer or officers of equivalent rank, duly designated by the BSI’s Board of Directors.

The DET and CP files shall be electronically transmitted on or before the prescribed deadline to [email protected] using the subject line [THFR]_[BSI NAME] [DATE OF REPORT format: YYYYMMDD] [Series format: XXXX].

For example:

TS: [email protected] Subject: THFR_ABC BANK 20250106 0001

The DET file shall be in Excel format while the CP file shall be in Portable Document Format, submitted using the prescribed file naming convention, as illustrated below:

File Naming Convention for CP: [CP]_[BSI NAME] [DATE OF REPORT format: YYYYMMDD] [Series format: XXXX]

File Naming Convention for DET: [DET] [BSI NAME] [DATE OF REPORT format: YYYYMMDD] [Series format: XXXX]

For example:

CP_ABC BANK 20250106 0001.pdf DET_ABC BANK 20250106 0001.xls

The BSI may attach one or more DET files with the corresponding CP files in a single submission, provided that the total combined size does not exceed 25 megabytes. The file size limit refers to the total size of all elements in the email, including text, headers, and attachments. Submissions that exceed the prescribed size limit will be automatically rejected by the system.

If the submission exceeds the maximum allowable file size, the BSI may

send multiple submissions, provided that submissions for the reference period must be emailed no later than the prescribed reporting deadline.

Page 9 of 10

BSIs shall use only the email addresses officially registered with the Bangko Sentral Department of Supervisory Analytics (DSA) when electronically submitting the DET and CP files. Email submissions shall be automatically acknowledged by the system.

Submissions that do not receive an automatic acknowledgement shall be considered unsubmitted. It shall be deemed as non-submission of the THF Report for the reference month.

The DET and CP files must be encrypted and transmitted using Transport Layer Security to ensure the confidentiality and integrity of the information contained within.

Updating of Status of Held Funds. Reporting BSIs shall submit an updated THF Report (DET and CP) not later than the deadline for the next reporting period to update the status Of funds placed on temporary hold and previously reported as “Ongoing” in the “Status of Held Funds at the Time of Reporting” column.

As appropriate, the “Status of Held Funds at the Time of Reporting” column must be updated from “Ongoing” to “Released”, and the “Date of Release of Held Funds” and “Time of Release of Held Funds” column should be populated. To ensure that the update is accurately reflected, the Reference Number used in the previous report must be retained in the updated report.

Compliance with Reporting Standards. The THF Report shall be considered as a Category B report in accordance with Sections 171 and 173/171-Q and 172-Q. For stand-alone operators of payment systems, non-submission, erroneous submission, and delayed submission shall be subject to applicable penalties under the MORPS.

Inquiries. Queries regarding the THF Report, its related regulations and guidelines may be sent to the Bangko Sentral’s Consumer Account Protection Office via email to [email protected] following the prescribed subject line: [INQUIRY] THF REPORT [BSI Name).

Page 10 of 10

Annex C

Page 1 of 1

<Name of BSI>

CERTIFICATION ON COMPLIANCE WITH ADEQUATE RISK MANAGEMENT SYSTEMS AND CONTROLS PRESCRIBED BY THE BANGKO SENTRAL NG PILIPINAS

We, <Name of Officer>, President (or Officer of Equivalent Rank) and <Name of Officer>, Chief Compliance Officer, on behalf of the <Name of BSI>, with head/principal office address at <complete address of Head/Principal Office>, after having been duly sworn in accordance with law. Hereby certify to the best of our knowledge, that <Name of BSI>:

1. Temporary Holding of Disputed Funds was initiated or effected during the immediately preceding year, <Insert year>, in accordance with the Anti-Financial Account Scamming Act (AFASA), its implementing rules and regulations, and other regulations issued by the Bangko Sentral;

2. Adequate risk management systems and controls are in place to secure digital channels and customer accounts and;

3. Appropriate policies and procedures have been adopted to address all security risks and concerns affecting the digital channels and customer accounts;

4. Vulnerability assessment and penetration testing, and other relevant security test and evaluation are conducted regularly, in compliance with the regulations of the Bangko Sentral; and

5. Policies and procedures for coordinated verification and temporary holding of funds is in place.

We also certify that all relevant documents in support of the foregoing statements are kept on file and are readily available for verification by examiners of the Bangko Sentral during onsite verification/examination or when a written request is made to verify compliance.

This certification executed on <date of execution> is being submitted in compliance with the requirements of the Bangko Sentral.

Signed:

Signed: <Name> President (or Officer of Equivalent Rank)

<Name> Chief Compliance Officer

SUBSCRIBED AND SWORN to before me, this _____ day of _____ at __________, with affiant exhibiting their valid identifications indicated below:

Name Government ID/Passport No. Date/Place Issued

Notary Public

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