BSP Memorandum No. M-2026-017

BSP Memorandum No. M-2026-017
May 8, 2026

Overview

The Bangko Sentral ng Pilipinas (“BSP”) issued Memorandum No. M-2026-017 to reiterate existing guidelines on ensuring the integrity of payment activities among BSP-Supervised Institutions (“BSIs”), emphasizing the need for effective anti-money laundering and countering terrorism and proliferation financing (“AML/CTPF”) controls.

Key Regulatory Reminders

BSIs are directed to comply with relevant provisions under:

• Part Nine of the Manual of Regulations for Banks (MORB) and applicable AML/CTPF requirements under the Manual of Regulations for Non-Bank Financial Institutions (MORNBFI); and
• Subsection 503.7 of the Manual of Regulations for Payment Systems (MORPS) on merchant due diligence, including identification, risk assessment, and ongoing monitoring

Key Highlights

Strengthening AML Controls Across Payment Activities

BSIs are directed to maintain robust controls covering, account opening, onboarding, ongoing account and transaction monitoring, to enable timely prevention, detection, and response to potential misuse of accounts.

Accountability of BSP-Supervised Institutions

BSIs retain primary AML/CTPF responsibility for merchant payment activities, whether conducted as the originating financial institution (OFI) or the receiving financial institution (RFI), through payment aggregators or similar intermediaries, participation of such entities does not transfer, diminish, or substitute the AML/CTPF obligations of the BSI providing accounts, access to payment rails, or settlement services.

Oversight of Merchant Arrangements

BSIs are expected to ensure visibility over sub-merchants, apply risk-based onboarding and monitoring, and conduct periodic reviews with appropriate actions on high-risk or non-compliant accounts.

Who is Affected

• BSP-Supervised Institutions
• Payment service providers and payment aggregators
• Entities involved in merchant payment acceptance activities

Our Perspective

The memorandum reinforces BSP’s continued focus on safeguarding the integrity of the payment ecosystem, particularly amid growing digital payment activities. BSIs are expected to sustain strong AML/CTPF frameworks and exercise effective oversight over merchant and intermediary arrangements.

Read the full BSP Memorandum M-2026-017 here: