Sanctions screening is the process of checking customers, counterparties and payments against sanctions lists and acting on what the check finds. Under targeted financial sanctions, an institution that holds the funds of a designated person must freeze them without delay and report to the AMLC. This playbook sets out the steps, the clocks and the evidence.
The timings below come from AMLC's 2021 sanctions guidelines and its Regulatory Issuance No. 4 of 2020, which the guidelines describe as amended in 2021. Neither sets a screening procedure or a re-screening schedule, so those parts of the programme are the institution's own design. Whether to screen against additional lists is a policy decision, and nothing here says Philippine law requires it.
The playbook is written for heads of AML and screening leads who need to turn these obligations into a workflow that a lean team can run and an examiner can read.
What is sanctions screening, and what is a targeted financial sanction?
Screening finds designated persons among your customers and counterparties, and a targeted financial sanction is the freeze and the ban on dealing that follows.
AMLC's Regulatory Issuance No. 4 defines targeted financial sanctions as both asset freezing and the prohibition on making funds or other assets available, directly or indirectly, for the benefit of designated persons. The international standard sits in the FATF Recommendations. Recommendation 6 requires countries to implement targeted financial sanctions that comply with UN Security Council resolutions on terrorism and terrorist financing. Recommendation 7 does the same for proliferation financing.
Many institutions also screen against other lists for their own policy reasons. That is a separate decision from the legal duty described here, which carries a freeze and a report to the AMLC.
Which lists and legal bases create the duty?
In the Philippines the duty covers UN Security Council designations and Anti-Terrorism Council designations on terrorism, plus UN designations on proliferation financing.
The AMLC's 2021 sanctions guidelines cover designations under UN Security Council Resolutions 1267, 1989, 2253 and 1988, designations by the Anti-Terrorism Council, and proscriptions by the Court of Appeals. For proliferation financing they cover Resolutions 1718 (2006) and 2231 (2015). The legal basis is the Anti-Terrorism Act of 2020, the Anti-Money Laundering Act as amended by Republic Act 11521, and the Terrorism Financing Prevention and Suppression Act with its implementing rules.
The AMLC issues freeze orders by resolution, and supervisors pass them on. BSP Circular Letter CL-2021-018 notified banks of AMLC Resolution TF-35, directed them to freeze without delay funds owned or controlled by persons on the UN Consolidated List, and warned that dealing with a designated person's property can lead to criminal charges under Section 8 of the Terrorism Financing Prevention and Suppression Act.
Lists move in both directions. An Insurance Commission advisory of February 2025 passed on AMLC Resolution TF-104, which lifted freezes on individuals delisted by the Anti-Terrorism Council and kept them in place for others.
What must you do when a screening alert hits?
The action depends on how closely the customer's identity matches the list entry, and the guidelines separate three outcomes, and proliferation financing carries its own timing.
| Outcome | What it means | What to do | Clock |
|---|---|---|---|
| Name match only | The name matches but the other identifiers do not | Record why it is a different person and take no further action. Contact the AMLC if unsure | None stated |
| Potential target match | The identity matches most, but not all, identifiers | Freeze funds in your possession, file an STR, and inform the AMLC the same day with the account details, list entry and freeze time | The AMLC confirms within 36 hours, or the freeze lifts automatically |
| Target match | The identity matches all identifiers | Freeze and preserve, then file a detailed electronic return | Within 24 hours from effecting the freeze |
| Proliferation financing designation | A person designated under Resolution 1718 or 2231 | Freeze | Within a matter of hours from publication on the AMLC website |
Two further points sit outside the table. Where you know or suspect that a designated person is transacting, the guidelines call for an STR on the next working day from occurrence. The return for a freeze lists the account numbers, owners, freeze time, balances, related accounts and the basis for linking them, as set out in Regulatory Issuance No. 4.
Freezing on a potential match is expected, and the guidelines cite Rule 11.b of the implementing rules, under which no proceedings lie for a mistaken freeze made without bad faith, gross negligence or malice. A person frozen by mistake can apply to the AMLC for lifting with government identification.
How fast is "without delay"?
The guidelines put a number on it only for proliferation financing, which is a matter of hours from publication.
For terrorism financing the guidelines say freeze "without prior notice and preserve without delay" and then set the same-day, 24-hour and 36-hour steps above. They do not give an hour count for the freeze itself. A sensible design target is therefore hours, not days: from the moment a designation is published to the moment every customer record has been run against it.
That target depends on seeing the list change promptly and rescreening the whole customer base quickly. Automated sanctions screening that checks existing customers against only the new list entries makes that practical, and a weekly batch run does not.
How should sanctions screening be designed to meet the clock?
Screen at onboarding, at the payment and whenever a list changes, using the identifiers the AMLC names.
Use more than the name. Regulatory Issuance No. 4 lists the identifiers to use: aliases, date of birth, nationality, passport details, last known address, and employment or government role. A name alone cannot separate a name match from a potential target match, which is the distinction the clocks turn on. Our pieces on common Filipino surnames and on fuzzy matching and transliteration cover how multi-field matching reduces noise.
Screen at the right moments. Real-time sanctions screening at onboarding closes the window in which a designated person opens an account before the first batch run. Payment screening covers the parties to individual transfers, and our comparison of payment screening and transaction monitoring explains why it is a separate control. Existing customers need screening each time a list changes, and the schedule is a documented programme decision, since the guidelines set none.
Plan the lookback. The February 2025 advisory to insurers asked for STRs on the named individuals' previous transactions within five days from the effectivity of the freeze order, together with proof of screening. A given notice may carry its own wording for banks, so check the BSP circular that passes it on.
Keep politically exposed persons separate. PEP screening runs on different logic and carries no freeze, as we explain in our PEP screening guide.
What evidence should the screening file hold?
It should show what was screened, against which list version, how the match was decided and when each step happened.
- 01The list and the time. The list version and the date and time of the screening run.
- 02The identifiers compared. The fields used and the result for each.
- 03The decision. Name match, potential target match or target match, with the reasoning and the approver.
- 04The freeze record. The freeze time, the same-day notice to the AMLC, the detailed return, and the outcome of the 36-hour confirmation.
- 05The STR link. The determination date and filing reference, where an STR was filed. Our guides to the STR filing window and to a BSP-ready STR cover the filing side.
The advisory's request for proof of screening is a reminder that the proof is what an examiner asks for, and it is hard to rebuild after the fact.
What changes with delisting, humanitarian exemptions and mistaken identity?
Applications to lift a freeze or to use frozen funds go through the AMLC, so the institution's job is to keep the freeze in place and record the AMLC's instruction.
The 2021 guidelines describe separate routes. Persons on the UN lists apply for delisting through the relevant UN committee or Ombudsperson, with forms submitted to the AMLC. A person designated by the Anti-Terrorism Council may file a verified request within 15 days from publication of the designation. Basic and extraordinary expenses can be released from frozen funds through an application via the AMLC. The AMLC posts a notice when the UN delists someone.
FATF updated Recommendation 6 in June 2026 to add humanitarian exemption provisions, tied to UN Security Council Resolutions 2664, 2761 and 2615. How the AMLC reflects that change in its procedures should be checked against its current issuances. For the case file, record who instructed each lifting, and when.
How does Fyscal ARCX support this workflow?
Fyscal ARCX Name Screening matches customers across configurable fields against the AMLC and UN sanctions lists in parallel. The fields include name, date of birth, nationality and country, and each potential match shows field-level scores beside a side-by-side identity comparison. The analyst can see which identifiers support the match and which contradict it. Delta screening checks existing customers against new list entries, and changes to match weightings are logged. A confirmed match moves into a case, so the decision, the timestamps and the STR sit in one record.
If you want to see how a list change flows from screening alert to case record, book a walkthrough of Fyscal ARCX and bring your last list-update run to test it against.