DNFBP (Designated Non-Financial Businesses and Professions) refers to businesses and professionals outside the traditional financial sector that are required to comply with anti-money laundering (AML) regulations under Republic Act No. 9160 (Anti-Money Laundering Act) as enforced by the Anti-Money Laundering Council (AMLC). In the Philippines, real estate developers and real estate brokers are classified as DNFBPs and must register with the Anti-Money Laundering Council (AMLC).

Definition

DNFBPs are non-financial entities identified by international standards as vulnerable to money laundering and terrorist financing due to the nature of their business activities. The Financial Action Task Force (FATF) established this classification globally, and the Philippines adopted it through amendments to the AMLA.

Under Philippine law, DNFBPs must implement customer due diligence, maintain transaction records, and report suspicious activities to the AMLC.

DNFBP Categories in the Philippines

The AMLA identifies the following as DNFBPs:

Jewelry dealers in precious metals and precious stones
Company service providers that form companies, act as directors/corporate secretaries, or provide registered offices
Accountants and lawyers providing asset management, bank account management, or company creation services
Casinos including internet and ship-based casinos
Real estate developers and individual real estate brokers
Offshore gaming operators and their service providers regulated by PAGCOR

Registration Requirements for Real Estate Professionals

Real estate developers and individual brokers must register with the AMLC. The registration clarifies several important points:

Entity Type	Registration Required?
Real estate developers	Yes
Individual real estate brokers (PRC-licensed)	Yes
Real estate brokerage firms (juridical entities)	No
Real estate salespersons	No
Real estate agents	No

Note: Only individual brokers (natural persons) are required to register—not brokerage firms or salespersons working under brokers.

Documentary Requirements

To register as a DNFBP with the AMLC, you need:

Corporations/Partnerships: Articles of Incorporation/Partnership plus Secretary's Certificate designating a Compliance Officer
Sole Proprietorship: DTI Certificate plus notarized document designating a Compliance Officer (if owner is not the CO)
Real Estate Brokers: Valid PRC ID or PRC license

Registration Process

The AMLC registration follows these steps:

Sign up at portal.amlc.gov.ph
Provide information in mandatory fields with contact details
Upload documents following prescribed filename formats (e.g., PRCID.pdf)
Verify email within 72 hours
Receive PCOR (Provisional Certificate of Registration) valid for 6 months
Await approval and receive final Certificate of Registration via email

You can check registration status at portal.amlc.gov.ph/amlc/web/inquiry.htm.

Compliance Obligations

Once registered, DNFBPs must fulfill these obligations:

Appoint a Compliance Officer to oversee AML/CTF compliance
Conduct Customer Due Diligence (CDD) - verify client identities and source of funds per KYC requirements
Report Covered Transactions involving amounts above PHP 500,000
Report Suspicious Transactions regardless of amount
Maintain records of all transactions for at least 5 years

Reporting Thresholds

Report Type	Threshold
Covered Transaction Report (CTR)	Single transaction above PHP 500,000
Cash Transaction Report	Cash above PHP 500,000 in a single day
Suspicious Transaction Report (STR)	Any amount with suspicious indicators

Penalties for Non-Compliance

Failure to register or comply with DNFBP obligations may result in:

Administrative fines under AMLA
Criminal penalties including imprisonment
Restrictions on conducting real estate transactions
Reputational damage and banking relationship issues

Relevance to Real Estate Business

For real estate brokers operating in the Philippines, DNFBP compliance is mandatory. This affects your brokerage operations in several ways:

Pre-transaction verification: You must verify client identities before facilitating property transactions
Source of funds documentation: Large cash transactions require documentation of fund sources
Record keeping: All transaction records must be maintained for 5 years minimum
Reporting obligations: Suspicious activities must be reported regardless of transaction amount

Real estate platforms with client management and audit trail features help brokers maintain AMLC-compliant records. Features like document management and sales management support your DNFBP compliance requirements.

DNFBP