PHILIPPINE LAWS, RULES, AND REGULATIONS 
ON SECRECY OF BANK DEPOSITS
Introduction
	
This primer is a consolidation of the basic laws on the secrecy of bank 
deposits, as well as the exceptions. It aims to give awareness and guidance to the 
banking and legal community, and the public, on the existing laws, rules, and 
regulations on the secrecy of bank deposits.
	
Republic Act No. 1405,1  also known as the Law on Secrecy of Bank Deposits, 
was enacted in September 1955, primarily to encourage the public to invest their 
money in government securities and deposit them in bank, discourage private 
hoarding,2  and enhance protection of privacy rights.3  During those times, the 
country needed enough capital and credit facilities to boost the economy after the 
ravage of World War II.4 
 
More than half a century after the enactment of the law, the financial sector 
landscape has evolved, such that the financial innovations and ease of transactions 
enabled, necessitated, and encouraged the public to place their money in the 
banks, and spurred the economy.5  The factual milieu then prevailing is no longer 
existing, and the objectives of the law to deter private hoarding and to boost the 
economy are deemed achieved.6  
	
On the other hand, Republic Act No. 6426, also known as the Foreign 
Currency Deposit Act of the Philippines,7  was enacted on April 4, 1972. Prior to this 
law, one of the main economic challenges of the country was its unstable financial 
condition, which was greatly caused by, among other factors, heavy dollar spending.8 
This, in turn, caused a dollar deficit in the country, which dollars were necessary 
to finance foreign currency liabilities and dollar-denominated transactions. To 
address this deficit, Filipinos working overseas were targeted as potential sources 
of foreign currencies.9  The repatriation of dollars by Filipinos abroad was envisioned 
to boost the economy.10  Foreign currencies were also considered to be part of 
the country’s international reserves.11  Thus, it is imperative to attract and invite 
deposits of foreign currencies in duly authorized banks in order that they may 
1       An Act Prohibiting Disclosure of or Inquiry into, Deposits with any Banking Institution and Providing 	
        Penalty Therefor.
2      Rep. Act No. 1405, § 1 (1955).
3      See Republic v. Eugenio, Jr., G.R. No. 174629, Feb. 14, 2008 (545 S.C.R.A. 384). 
4      H.R. No. 3977, 3rd Cong., Congressional Rec. 3886 (July 27, 1995) (enacted).
5      S. No. 1802 (Sept. 1, 2020), 18th Cong., Explanatory Note & H.R. No. 8634 (Feb. 7, 2021), 18th Cong.,     	
   	
        Explanatory Note.
6      Id.
7      Rep. Act No. 6426 (1974) (last amended in 1978).
8      H.R. No. 2475, 7th Cong., Explanatory Note & S. No. 541, 7th Cong., Explanatory Note.
9      Id.
10    Id.
11     H.R. No. 2475, 7th Cong., Congressional Rec. 77 (Feb. 11, 1971).
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 The Laws on Secrecy of Bank Deposits
A Legal Primer
be put into the stream of the banking system.12  This law put in place the primary 
incentives of protection and stability of the foreign currency deposit system. This 
law and its subsequent amendments introduced more incentives by guaranteeing 
confidentiality of deposits, granting tax exemptions, allowing withrawability and 
transferability of deposits, and affirming the vested rights of depositors.13 These 
incentives were intended to encourage residents and non-residents to deposit their 
foreign currencies in the Philippine banking system.14 
	
As early as 2011, the Group of Twenty or G2015  declared that the “era of bank 
secrecy is over” after it endorsed the standards on transparency and exchange 
of information.16  In 2014, the Organisation for Economic Co-operation and 
Development (OECD) released the standard for automatic exchange of information 
as the new global standard of obtaining detailed account information from financial 
institutions, and exchanging that information automatically with other jurisdictions 
for the purpose of combatting tax evasion, money laundering, and commission of 
other crimes.17  This global regulatory watch means lifting the cloak of bank secrecy.
	
The language of existing laws on bank secrecy makes the Philippines the 
only country18  to still have restrictive bank secrecy policy making it hard for the 
government to go after tax evaders and money launderers.19  This, notwithstanding 
the global trend to shift from secrecy towards transparency. 
	
According to the International Monetary Fund (IMF), the existing secrecy 
of bank deposits laws of the Philippines restrict the ability of Bangko Sentral to 
undertake effective supervision.20  The IMF noted that our secrecy laws undermine 
financial stability, financial integrity, and development of the banking sector, and 
expose the banking system to reputational risk.21  The IMF recommended that 
legislative amendments be promptly approved to give Bangko Sentral direct and 
full access to individual depositor information covered by bank secrecy laws.22  Thus, 
a multisector collaboration, spearheaded by Bangko Sentral, and composed of, 
12     Cancio v. Court of Tax Appeals, G.R. No. 73882, Oct. 22, 1987 (154 S.C.R.A. 731).
13     Rep. Act No. 6426 (1974), §§ 5, 6, 7, 8, & 12-A (last amended in 1978).
14     H.R. No. 2475, 7th Cong., Congressional Rec. 77 ( Feb. 11, 1971). 
15     The Group of Twenty (G20) is the premier forum for international economic cooperation. It plays an 	
         important role in shaping and strengthening global architecture and governance on all major   	
   	
         international economic issues. See About G20, https://www.g20.org/en/about-g20/ (last visited
         Jan. 2023).
16     OECD, The Era of Bank Secrecy is Over, Oct. 26, 2011, https://www.oecd.org/ctp/exchange-of-tax-  
      
         information/48996146.pdf (last visited Jan. 2023).
17     OECD, Automatic Exchange of Information, https://www.oecd.org/tax/automaticexchange.htm (last 	
         visited Jan. 2023).
18     Lebanon recently passed a law amending its law on bank secrecy. See https://english.alarabiya.net/ 	
         News/middle-east/2022/10/29/Outgoing-Lebanon-leader-signs-amended-banking-secrecy-law-in-
         step-towards-IMF-reform (last visited Jan. 2023).
19     See National Tax Research Center, Lifting of the Philippine Bank Secrecy Law for Tax Fraud Cases,       	
         National Tax Research Center Research Journal (July-Aug. 2016), https://ntrc.gov.ph/images/journal
         /2016/j20160708a.pdf (last visited Jan. 2023).
20    IMF Country Report No. 20/296, Financial Sector Assessment Program, Philippines, Oct. 2020.
21     IMF Country Report No. 21/74, Financial System Stability Assessment, Philippines, Feb. 11, 2021.
22     Id.
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among others, the Bankers Association of the Philippines, Management Association 
of the Philippines, Chamber of Thrift Banks, and Makati Business Club, is currently 
in place to propose the repeal of bank secrecy laws.
	
Currently, although there are pending legislative proposals aimed at 
amending the existing bank deposit secrecy laws in the Philippines, no such 
amendments have been enacted.
	
Nonetheless, on 20 July 2024, Republic Act No. 12010,23  also known as the 
Anti-Financial Account Scamming Act (AFASA), was signed into law. The law seeks to 
combat financial cybercrimes, safeguard the interests of financial consumers, and 
uphold the integrity of the financial system.24  Under the AFASA, the Bangko Sentral 
is given the authority to investigate and inquire into financial accounts,25  and to 
share the said information with law enforcement and other competent authorities 
subject to the limitations imposed under the said law.26  For this purpose, the 
relevant provisions of laws containing  prohibitions against inquiry into or disclosure 
of deposits, that is, the Law on Secrecy of Bank Deposits, Foreign Currency Deposits 
Act of the Philippines, and Republic Act No. 8367, also known as the Revised Non-
Stock Savings and Loan Association Act of 1997, shall not apply to financial accounts 
subject of Bangko Sentral’s investigation.27  This development effectively eases 
the strict application of the laws on secrecy of deposits, thereby, providing a more 
conducive environment for a  strong financial system and an efficient, safe, and 
secure digital payments ecosystem through effective government supervision and 
regulation.
	
This legal primer is the product of a collaborative effort of lawyers from the 
Office of the General Counsel and Legal Services. It is hoped that this legal primer 
will enhance the readers’ knowledge and awareness of the country’s secrecy of 
bank deposits laws, rules, and regulations.
         THE EDITORIAL BOARD AND STAFF
 OFFICE OF THE GENERAL COUNSEL AND LEGAL SERVICES
BANGKO SENTRAL NG PILIPINAS
 BANKING LAWS OF THE PHILIPPINES ANNOTATED
(2012, 2023) 
23     An Act Defining and Penalizing Financial Account Scamming and Other Offenses, and Providing for   	
         the Enforcement Mechanism Therefore (2024).
24     https://www.bsp.gov.ph/SitePages/MediaAndResearch/MediaDisp.aspx?ItemId=7179 (last visited Oct.    	
         2024).
25     Rep. Act No. 12010 (2024), §§ 12, 13, & 14.
26     See Rep. Act No. 12010 (2024), §§ 12 & 14.
27     Rep. Act No. 12010 (2024), § 12.
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Law on Secrecy of Bank Deposits
 
Absolute Confidentiality 
	
All deposits of whatever nature in banks or banking institutions in the 
Philippines and investments in government bonds are absolutely confidential in 
nature.28
1.	
Deposit means the unpaid balance of money or its equivalent 
received by a bank in the usual course of business and for which 
it has given or is obliged to give credit to a commercial, checking, 
savings, time or thrift account, evidenced by a passbook, certificate 
of deposit, or other evidence of deposit issued in accordance with 
Bangko Sentral rules, regulations and other applicable laws, 
together with such other obligations of a bank, which, consistent 
with banking usage and practices, the Board of Directors of the 
Philippine Deposit Insurance Corporation (PDIC) shall determine 
and prescribe by regulations to be deposit liabilities of the bank.29 
Deposit is characterized as being in the nature of a simple loan. The 
placing of a deposit in a bank creates a creditor-debtor relationship 
between the depositor and the bank. The bank, as debtor, has 
the obligation to pay a certain sum of money to the depositor, as 
creditor.30
The term “deposit of whatever nature” is construed broadly to 
include accounts that may be used by banks for authorized loans 
to third persons, although there is no creditor-debtor relationship 
arising from the account, such as money placed under trust 
accounts.31 
2.	
Investments in government bonds refer to investments in 
bonds issued by the government of the Philippines, its political 
subdivisions, and its instrumentalities. Government bonds are 
debt securities that are unconditional obligations of the State and 
backed by its full taxing power. Government bonds include treasury 
bills, treasury notes, retail treasury bonds, dollar linked peso notes, 
and other risk-free bonds.32
28     Rep. Act No. 1405, § 2 (1955).
29     Rep. Act No. 3591, § 5(g) (1963) (last amended in 2022).
30     See Guingona, Jr. v. The City Fiscal, G.R. No. 60033, Apr. 4, 1984 (128 S.C.R.A. 577).
31      Ejercito v. Sandiganbayan, G.R. No. 157294-95, Nov. 30, 2006 (509 S.C.R.A. 190).
32     See Bureau of Internal Revenue, BIR: Investments are not subject to the bank secrecy law, only bank 
deposits and government securities, https://www.officialgazette.gov.ph/2014/08/12/bir-investments- 
are-not-subject-to-the-bank-secrecy-law-only-bank-deposits-and-government-securities/(last visited 
Jan. 2023).
The General Banking Law of 2000 prohibits bank directors, officers, 
employees, or agents from disclosing to any unauthorized person, without order 
of a competent court, any information relative to funds or properties belonging to 
private individuals, corporations, or any other entity in the custody of the bank.33 
It is not required that all the details of a bank deposit be examined, inquired or 
looked into.34 The prohibition applies even if the disclosure pertains only to the 
mere existence of a bank deposit, without revealing the bank or amount.35 
The Thrift Banks Act of 199536 and the Rural Banks Act of 199237 likewise 
prohibit any bank officer, employee, or agent from disclosing any information on 
such funds or properties.38 
Prohibited Acts and Persons Liable 
The following are liable under this law:
1.	
Any person or government official who, or any government bureau 
or office that, examines, inquires, or looks into a bank deposit or 
government bond investment in any of the instances not allowed 
under the law;39
2.	
Any official or employee of a banking institution who makes a 
disclosure concerning bank deposits to another in any instance 
not allowed by law;40 and
3.	
Any person who commits a violation of any of the provisions of the 
law.41
 
Any bank official, director, employee, or agent who discloses information 
relative to funds or properties in the custody of the bank may also be held liable 
under the applicable provisions of The General Banking Law of 2000, Thrift Banks 
Act of 1995, and Rural Banks Act of 1992.
33    Rep. Act No. 8791, § 55.1(b) (2000).
34   Letter of the BSP Deputy Governor & General Counsel to the Chairman of the Committee on Ways & 
Means, House of Representatives (Dec. 13, 2011), citing S. No. 351, Congressional Rec. 1625. 
35    Letter of the BSP Deputy Governor & General Counsel to the Chairman of the Committee on Ways & 
Means, House of Representatives (Dec. 13, 2011), citing BSB Group, Inc. v. Go, G.R. No. 168644, Feb. 16, 
2010 (612 S.C.R.A. 496). 
36    Rep. Act No. 7906 (1995).
37    Rep. Act No. 7353 (1992) (last amended in 2013).
38    Rep. Act No. 7906, § 2(a)(2) (1995) & Rep. Act No. 7353, §26(a)(2) (1992) (last amended in 2013).
39     See Rep. Act No. 1405, § 2 (1955).
40    Id., § 3.
41     Id., § 5.
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Exceptions to Confidentiality
	
Bank deposits and investments in government bonds may be examined, 
inquired, or looked into under the following limited exceptions:
1.	
Law on Secrecy of Bank Deposits
Bank deposits and investments in government bonds may be 
examined, inquired, and looked into in the following instances:42
a.	
Upon written permission or consent in writing by the 
depositor. For consent to be valid, it should be made 
knowingly, voluntarily, and with sufficient awareness of the 
relevant circumstances and likely consequences.43 
b.	
In cases of impeachment of the President, Vice President, 
members of the Supreme Court, members of the 
Constitutional 
Commissions,44 
and 
Ombudsman 
for 
culpable violation of the Constitution, treason, bribery, 
graft and corruption, other high crimes, or betrayal of 
public trust.45
c.	
Upon order of a competent court in cases of bribery46 or 
dereliction of duty of public officials.47 
Cases of unexplained wealth are similar to cases of bribery 
or dereliction of duty and no reason is seen why these two 
classes of cases cannot be excepted from the rule making 
bank deposits confidential.48
As bribery and plunder are analogous, the exception under 
the Law on Secrecy of Bank Deposits applicable in cases of 
bribery must also apply to cases of plunder.49
d.	
In cases where the money deposited or invested is the 
subject matter of the litigation. The money deposited 
should be the very thing in dispute.50
42    Id., § 2.
43   See Premiere Development Bank v. Central Surety and Insurance Company, Inc. G.R. No. 176246, Feb. 
13, 2009 (579 S.C.R.A. 359).
44   Commission on Elections, Civil Service Commission, and Commission on Audit.
45    Constitution, Art. XI, § 2 (1987).
46    See Act No. 3815, Arts. 203, 210-211 (1930) (last amended in 2017).
47    Id., Arts. 204-209. 
48    Ejercito v. Sandiganbayan, G.R. Nos. 157294-95, Nov. 30, 2006 (509 S.C.R.A. 190), citing Philippine National 
Bank v. Gancayco, G.R. No. L-18343, Sept. 30, 1965.
49    Ejercito v. Sandiganbayan, G.R. Nos. 157294-95, Nov. 30, 2006 (509 S.C.R.A. 190).
50    Mellon Bank, N.A. v. Magsino, G.R. No. 71479, Oct. 18, 1990 (190 S.C.R.A. 633).
2.	
Other Laws and Jurisprudence
Bank deposits and investments in government bonds may be 
examined, inquired, or looked into as provided in other laws and 
jurisprudence:
a.	
Investigation by the Ombudsman under The Ombudsman 
Act of 198951 
The Ombudsman has the power to issue subpoena and 
subpoena duces tecum, take testimony in any investigation 
or inquiry, as well as examine and access bank accounts 
and records.52 The power of the Ombudsman to subpoena 
deposit information of a government official may be 
exercised when the following conditions concur:
i.	
There must be a case pending before a court of 
competent jurisdiction;
ii.	
The account must be clearly identified;
iii.	
The inspection must be limited to the subject 
matter of the pending case; and
iv.	
The bank personnel and the account holder must 
be notified to be present during the inspection, 
and such inspection may cover only the account 
identified in the pending case.53
b.	
Cases of Unexplained Wealth of Public Officials or 
Violations of the Anti-Graft and Corrupt Practices Act54
Bank deposits of a public official, his spouse, and 
unmarried children may be taken into consideration in the 
enforcement of the dismissal or removal of the said public 
official due to unexplained wealth.55
c.	
Borrowings of directors, officers, stockholders, and their 
related interests who are required to execute a written 
waiver of secrecy of bank deposits under The New Central 
Bank Act56
51     Rep. Act No. 6770 (1989).
52     Id., § 15(8).
53     Marquez v. Desierto, G.R. No. 135882, June 27, 2001 (359 S.C.R.A. 772). See Office of the Ombudsman v. 
Ibay, G.R. No. 137538, Sept. 3, 2001.
54     Rep. Act No. 3019 (1960) (last amended in 2016).
55     Id., § 8; See Philippine National Bank v. Gancayco, G.R. No. L-18343, Sept. 30, 1965.
56    Rep. Act No. 7653, § 26 (1993), as amended by Rep. Act No. 11211 (2019).
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Directors, officers, stockholders, and their related interests 
who contract a loan or any form of financial accommodation 
with their bank or related bank are required to execute a 
written waiver of secrecy of deposits in accordance with 
The New Central Bank Act.
d.	
Application for Compromise of Tax Liability, Determination 
of Decedent’s Estate, and Exchange of Tax Information 
under the National Internal Revenue Code (NIRC)57
The Commissioner of Internal Revenue is authorized to 
inquire into bank deposit accounts in relation to:
i.	
An application for compromise of tax liability or a 
determination of a decedent’s gross estate under 
the NIRC; and
ii.	
A foreign tax authority’s request for tax information 
of specific taxpayers in the Philippines pursuant to 
an international convention or agreement on tax 
matters to which the Philippines is a signatory or 
a party.58
e.	
As a Remedy for the Collection of Delinquent Taxes or 
Duties under NIRC59
The national government, through the Bureau of Internal 
Revenue (BIR) and the Bureau of Customs (BOC), and 
the local government units may collect delinquent 
taxes60 or duties and taxes61 by distraint of goods and 
other personal property of whatever character, including 
debts, credits, bank accounts, and interests in and rights 
to personal property. The term “distraint” refers to the 
seizure by government of the personal property (tangible 
or intangible) of a taxpayer, to enforce the payment of his 
tax liabilities.62
57    Rep. Act No. 8424 (1997) (last amended in 2021).
58    Id., § 6., such as Foreign Account Tax Compliance Act.
59    Rep. Act No. 8424, § 205 (1997) (last amended in 2021); Admin. Ord. No. 270, Art. 26 (1992); & Rep. Act No. 
10863, § 1132 (2016).
60    Rep. Act No. 8424, § 205 (1997) (last amended in 2021) & Admin. Ord. No. 270, Art. 262 (1992).
61     Rep. Act No. 10863, § 1132 (2016).
62    Aguirre, Estelita C., Philippine Tax Collection System, Its Evolution and Direction, https://www.bir.gov. 
ph/index.php/downloadables/features.html (last visited Jan. 2023).
With respect to bank accounts, the commissioners of BIR 
and BOC issue a warrant of garnishment to seize the bank 
deposits of a delinquent taxpayer.63 Bank accounts are 
garnished by serving a warrant of garnishment upon the 
delinquent taxpayer or importer and upon the president, 
manager, treasurer, or other responsible officer of the 
bank. Upon receipt of the warrant of garnishment, the 
bank shall turnover to the commissioner so much of the 
bank accounts as may be sufficient to satisfy the claim of 
the government.64
f.	
Garnishment of Deposits in Satisfaction of Judgment 
under the Rules of Court65
To satisfy a final judgment in a collection case, the court 
officer may levy on debts due the judgment obligor and 
other credits, including bank deposits. Levy is made by 
serving notice upon the persons owing such debts or 
having in his possession or control such credits to which 
the judgment obligor is entitled.66
The responsible bank official to whom the writ of 
garnishment is directed must disclose information if 
the judgment debtor has a deposit with the bank. The 
disclosure of the existence of a deposit is purely incidental 
to the execution process. The measure of protection 
afforded by this law is not intended to enable debtors to 
evade payment of their just debts through the expedient 
conversion of their assets into cash and depositing the 
same in a bank. It is not the intention of the law to place 
bank deposits beyond the reach of execution to satisfy a 
final judgment.67
g.	
Deposits or Investments Related to Unlawful Activities 
or Money Laundering Offenses under the Anti-Money 
Laundering Act of 2001 (AMLA)68
The AMLA69 authorizes the Anti-Money Laundering Council 
(AMLC) to examine and inquire into bank deposits or 
investments with banks or non-bank financial institutions 
– 
63     Rep. Act No. 8424, § 208 (1997) (last amended in 2021) & Rep. Act No. 10863, § 1134 (2016).
64     Id. 
65     Rules of Court, Rule 39, § 9(c) (1997).
66     Id. 
67     China Banking Corporation v. Ortega, G.R. No. L-34964, Jan. 31, 1973 (49 S.C.R.A. 355).
68     Rep. Act No. 9160 (2001) (last amended in 2021).
69     Id. 
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i.	
With court order, when there is probable cause 
that the deposits or investments are related to an 
unlawful activity or a money laundering offense;70 
and
ii.	
Without need of court order, when probable cause 
exists that a particular deposit or investment 
with any banking institution is related to certain 
predicate crimes, such as kidnapping for ransom, 
violation of the Comprehensive Dangerous Drugs 
Act,71 hijacking and other violations under Republic 
Act No. 6235,72 destructive arson, and murder as 
defined under the Revised Penal Code,73 including 
those perpetrated by terrorists against non-
combatant persons and similar targets.
Upon verified ex parte petition by AMLC and after 
determination that probable cause exists that any 
monetary instrument or property is in any way related 
to an unlawful activity, the Court of Appeals may issue a 
freeze order, which shall be effective immediately and shall 
be valid for a period of twenty (20) days unless extended by 
the court.74
As a financial investigator, AMLC has the power to 
investigate the following: (i) suspicious transactions75 
and covered transactions76 deemed suspicious after 
investigation by AMLC; (ii) Money Laundering/Terrorism 
Finance activities; or (iii) any property or funds that are in 
any way related to Terrorism Finance or acts of terrorism.77 
70    Id., §§ 3(i) & 4.
71     Rep. Act No. 9165 (2002) (amended in 2014).
72    An Act Prohibiting Certain Acts Inimical to Civil Aviation, and For Other Purposes (1971).
73    Act No. 3815 (1930) (last amended in 2017).
74    Rep. Act No. 9160, § 10 (2001) (last amended 2021).
75    Covered Transaction refers to (1) a transaction in cash or other equivalent monetary instrument   
exceeding Five Hundred Thousand pesos (PhP500,000.00); (2) a transaction with or involving jewelry     
dealers, dealers in precious metals and dealers in precious stones in cash or other equivalent monetary 
instrument exceeding One Million pesos (PhP1,000,000.00); or (3) a casino cash transaction exceeding 
Five Million Pesos (PhP5,000,000.00) or its equivalent in other currency. 2018 IRR of Rep. Act No. 9160, 
as amended, Rule 2, § 1.
76   Suspicious Transaction refers to a transaction, regardless of amount, where any of the suspicious 
circumstances is determined, based on suspicion or, if available, reasonable grounds, to be existing. 
2018 IRR of Rep Act No. 9160, as amended, Rule 2, § 1.
77     2018 IRR of Rep Act No. 9160, as amended, Rule 6, §1.9.1.
h.	
Annual Testing of Numbered Accounts under AMLA78
	The Bangko Sentral is authorized to –
i.	
Inquire 
into 
or 
examine 
bank 
deposits 
or 
investments in the course of a periodic or special 
examination to ensure compliance with the 
AMLA;79 and
ii.	
Conduct annual testing, which is limited to the 
determination of the existence and true identity of 
the owners of numbered accounts.80
i.	
Cases of Unsafe or Unsound Banking and Failure of 
Prompt Corrective Action (PCA) under Republic Act No. 
3591, as amended, or the PDIC Charter81 
i.        Cases of Unsafe or Unsound Banking 
	The PDIC and Bangko Sentral are authorized to inquire 
into or examine bank deposits and all information related 
thereto when there is a finding of unsafe or unsound 
banking. 
A court order is not required for PDIC and Bangko Sentral 
to exercise their respective authority to inquire into bank 
deposits. It is sufficient that their inquiries are based on a 
finding of unsafe or unsound banking.82
ii.       Failure of PCA
The PDIC and Bangko Sentral may examine, inquire, or 
look into the deposit records of a bank if there is a failure 
of PCA as declared by the Monetary Board due to capital 
deficiency. Pursuant to this authority, banks and their 
officers and employees are mandated to disclose and 
report to PDIC and Bangko Sentral or their duly authorized 
officers and employees the required deposit account 
information. Thus, any act done pursuant to this power 
is not violative of the Law on Secrecy of Bank Deposits, 
Foreign Currency Deposits Act of the Philippines,83 The 
General Banking Law of 2000, and other similar laws 
78     Rep. Act No. 9160, §§ 9 & 11 (2001) (last amended 2021).
79     Id., §11.
80     Id., §9; 2018 IRR of Rep Act No. 9160, as amended, Rule 17, § 3.
81       An Act Establishing the Philippine Deposit Insurance Corporation, Defining its Powers and Duties and 
For Other Purposes (1963).
82     Rep. Act No. 3591, § 9 (1963) (last amended in 2022). 
83     Rep. Act No. 6426 (1974) (last amended in 1978).   
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protecting or safeguarding the secrecy or confidentiality 
of bank deposits. The PDIC and Bangko Sentral, their 
officers or employees are, however, prohibited from 
disclosing deposit information to any person, government 
official, bureau, or office. Unauthorized disclosure shall be 
subject to the same penalty under the laws on secrecy or 
confidentiality of bank deposits.84
j.	
Examination Pursuant to the Anti-Terrorism Act of 202085
The Anti-Terrorism Act of 2020 authorizes AMLC, upon the 
issuance by the court of a preliminary order of proscription 
or in case of designation, either upon its own initiative 
or at the request of the Anti-Terrorism Council (ATC), to 
investigate: (i) any property or funds that are in any way 
related to financing of terrorism86 or violation of certain 
sections of the Anti-Terrorism Act of 2020;87 and (ii) property 
or funds of any person or persons in relation to whom there 
is probable cause to believe that such person or persons 
are committing or attempting or conspiring to commit, 
or participating in or facilitating the financing of certain 
sections of the Anti-Terrorism Act of 2020.88
For this purpose, AMLC is authorized to inquire into or 
examine deposits and investments with any banking 
institution or non-bank financial institution and their 
subsidiaries and affiliates without a court order.89
k.	
Examination 
Pursuant 
to 
the 
Terrorism 
Financing 
Prevention and Suppression Act of 201290
The AMLC, either upon its own initiative or at the request 
of the ATC, is authorized to investigate: (i) any property or 
funds that are in any way related to financing of terrorism 
or acts of terrorism; or (ii) property or funds of any person 
or persons in relation to whom there is probable cause 
to believe that such person or persons are committing or 
attempting or conspiring to commit, or participating in or 
facilitating the financing of terrorism or acts of terrorism as 
84     Id., § 11. 
85     Rep. Act No. 11479, § 35 (2020).
86     See Rep. Act No. 10168 (2012).
87     Rep. Act No. 11479, §§ 4, 6, 7, & 10-12 (2020).
88     Id. 
89     Id., § 35.
90     Rep. Act No. 10168 (2012).
defined in the law.91 
For this purpose, AMLC is authorized to inquire into or 
examine deposits and investments with any banking 
institution or non-bank financial institution and their 
subsidiaries and affiliates without a court order.92
l.	
Audit of Government Deposits under the Constitution93 
and the Government Auditing Code94
By virtue of the Constitution and the Government Auditing 
Code, the Commission on Audit is authorized to examine 
and audit government deposits pertaining to the revenue 
and receipts of, and expenditures or uses of funds and 
properties, owned or held in trust by, or pertaining to, 
the government or any of its subdivisions, agencies, or 
instrumentalities, 
including 
government-owned 
and 
controlled corporations with original charters.95
The authority and powers of the Commission on Audit 
extend to and comprehend all matters relating to, among 
other things, the following:96
i.	
Examination and inspection of books, records, and 
papers relating to the accounts of the government; 
and
ii.	
Audit and settlement of accounts of all persons 
respecting funds or property received or held by 
them in an accountable capacity.
m.	
Investigation To Recover Ill-Gotten Wealth under Executive 
Order No. 197
The Presidential Commission on Good Government 
(PCGG), in the conduct of its investigations to recover ill-
gotten wealth accumulated by former President Ferdinand 
E. Marcos, his immediate family, relatives, subordinates, 
and close associates, may issue subpoenas requiring 
the attendance and testimony of witnesses and/or the 
91      Id., § 10.
92     Id.
93     1987 Philippine Constitution.
94     Pres. Dec. No. 1445 (1978).
95    See Constitution, Art. IX-D, § 2(1) & Op. No. 95, Dep’t of Justice (May 31, 1991), citing Pres. Dec. No. 1445 
(1978).
96     Pres. Dec. No. 1445, § 26 (1978).
97     Creating the Presidential Commission on Good Governance (1986).
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production of books, papers, contracts, records, statement 
of accounts, and other documents as may be material to 
its investigation.98 Bank secrecy laws cannot prevail over 
the mandated functions of the PCGG in the conduct of 
investigations to accomplish its purposes, specifically to 
recover ill-gotten wealth from the Marcoses and their 
cronies.99 To hold otherwise would frustrate PCGG’s mission 
as clearly directed by law.100
n.	
Review of Records by a Rehabilitation Receiver under the 
Financial Rehabilitation and Insolvency Act (FRIA) of 2010101
In the rehabilitation of financially distressed enterprises 
and individuals, the rehabilitation receiver, upon issuance 
by the court of a Commencement Order, is vested with all 
the powers and functions under FRIA, such as to review 
and obtain records to which the debtor’s management and 
directors have access. These records include bank accounts 
of whatever nature of the debtor subject to the approval by 
the court of a performance bond filed by the rehabilitation 
receiver.102
o.	
Escheat Proceedings under the Act No. 3936, as amended, 
or the Unclaimed Balances Law103
All banks, building and loan associations, and trust 
corporations are required to submit to the Treasurer of 
the Philippines a statement under oath, of all credits and 
deposits held by them in favor of persons known to be dead, 
or who have not made further deposits or withdrawals 
during the preceding ten (10) years or more.104 
The submission by banks to the Treasurer of the Philippines 
of the sworn statement is the initial step in implementing 
the Unclaimed Balances Law. The submission of this 
statement is not violative of the Law on Secrecy of Bank 
Deposits; otherwise, it would defeat the very purpose and 
implementation of this law since the information in the 
statement precisely constitutes the basis for institution of 
98      Id. § 3(e).
99      Op. No. 13, Dep’t. of Justice (Feb. 24, 1987). 
100    Id. 
101      Rep. Act No. 10142 (2010).
102     Id., § 17(a).
103    An Act Requiring Banks, Trust Companies, Savings and Mortgage Banks, Mutual Building and Loan 
Associations, and Banking Institutions of Every Kind to Transfer Unclaimed Balances Held by them to 
the Insular Treasury, and For Other Purposes (1932).
104    Act No. 3936, § 1 (1932), as amended by Pres. Dec. No. 679 (1975).
escheat proceedings.105 The Unclaimed Balances Law and 
the Law on Secrecy of Bank Deposits may be simultaneously 
implemented without defeating their respective purposes 
and policies.106 
p.	
Coordinated Verification of a Disputed Transaction; and 
Authority of the Bangko Sentral to Inquire and Investigate 
into Financial Accounts and Issue Rules on Information 
Sharing and Disclosure with Law Enforcement and 
Competent Authorities  under the Anti-Financial Account 
Scamming Act (AFASA)107
i.	
Coordinated Verification of a Disputed Transaction
Upon receipt of a complaint, an information from 
another Institution,108  or detection through the Fraud 
Management System (FMS), the institutions and 
account owners involved have to initiate a coordinated 
verification 
process 
to 
validate 
the 
disputed 
transaction, regardless of whether the funds remain in 
the banking system or not.109  The provisions of existing 
laws on secrecy of deposits and data privacy shall not 
apply during the coordinated verification process of a 
disputed transaction110  under the AFASA.
ii.	
Investigation and Inquiry into Financial Accounts111  
under the AFASA
For the limited purposes of enforcing the AFASA and 
implementing of Republic Act No. 11765,112  also known 
as the Financial Products and Services Consumer 
Protection Act, the duly authorized officer or body 
from Bangko Sentral is authorized to investigate and 
inquire into financial accounts that may be involved in 
the commission of the following prohibited acts and 
offenses under AFASA:113
105    Op. No. 104, Dep’t of Justice (July 9, 1975).
106    Id.
107    Rep. Act No. 12010 (2024).
108    The term “Institution” refers to banks, non-banks, other financial institutions, payments and financial 	
           services providers under the jurisdiction of the Bangko Sentral. Id., §3(f).
109    Rep. Act No. 12010 (2024), § 8.
110     Id.
111      The term “Financial Accounts” refers to an account used to avail of products or services offered by    	
           Institutions such as:
           (1) An interest or non-interest-bearing deposit, trust, investment, or credit card account;
           (2) Other transaction account maintained with a bank, non-bank, or financial institution;
           (3) E-wallet; and
           (4) Any other account used to avail of financial products or services defined under Section 3(c) of    
           Republic Act No. 11765, or the “Financial Products and Services Consumer Protection Act.” Rep. Act   	
           No. 12010 (2024), § 3(d).
112     An Act Affording More Protection to Consumers of Financial Products and Services (2022).
113     Rep. Act No. 12010 (2024), § 12.
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(a) Money Muling Activities - A person performing   
any of the followings acts for the purpose of obtaining, 
receiving, depositing, transferring, or withdrawing 
proceeds that are known to be derived from crimes, 
offenses, or social engineering schemes:114 
(1) Using, borrowing or allowing the use of a    
financial account;
(2) Opening a financial account under a fictitious 
name or using the identity or identification 
documents of another;
(3) Buying or renting a financial account;
(4) Selling or lending a financial account; or
(5) Recruiting, enlisting, contracting, hiring,	
utilizing, or inducing any person to perform the          	
acts mentioned in items 1 to 4 above.
(b) Social Engineering Schemes - Committed by a   
person who obtains sensitive identifying information of 
another person, through deception or fraud, resulting 
in unauthorized access and control over the person’s 
financial account, by performing any of the following 
acts:115 
(1) Misrepresenting oneself as acting on behalf 
of institution, or making false representations 
to solicit another person’s sensitive identifying 
information; or
(2) Using electronic communications to obtain 
another person’s sensitive identifying information.
(c) Economic Sabotage - The prohibited acts under 
Money Muling Activities and Social Engineering 
Schemes shall be considered as economic sabotage 
when 
committed 
under 
any 
of 
the 
following 
circumstances:116 
114     Rep. Act No. 12010 (2024), §§ 4 &12.
115     Id.
116     Id.
(1) By a group of three (3) or more persons 
conspiring or confederating with one another;
(2) Against three (3) or more persons individually             
or as a group;
(3) Using a mass mailer; or
(4) Through human trafficking.
(d)	  Other Offenses117 
(1) Willfully aiding or abetting in the commission 	
of any of the offenses enumerated under Items (i)
(ii) and (iii) above;
(2) Willfully attempting to commit any of the 
offenses enumerated under Items (i)(ii) and (iii) 
above;
(3) Opening a financial account under a fictitious 
name or using the identity or identification 
documents of another; or
(4) Buying or selling a financial account.
A person found guilty of knowingly or willfully 
obstructing, impending, frustrating, or delaying the 
inquiry and investigation of Bangko Sentral shall 
be penalized with imprisonment of not less than 
one (1) year but not more than five (5) years, or a fine 
of not less than Fifty thousand pesos (P50,000.00) 
but not exceeding Two hundred thousand pesos 
(P200,000.00), or both, at the discretion of the court.118 
The authority of Bangko Sentral to investigate and 
inquire into financial accounts shall not be enjoined by 
any court below the Court of Appeals.119 
117     Rep. Act No. 12010 (2024), §5.
118     See Rep. Act No. 12010 (2024), § 16 (f).
119     See Rep. Act No. 12010 (2024), § 12.
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iii.	 Sharing of Information on Financial Accounts 
under the AFASA
Bangko Sentral has authority to issue rules on 
information-sharing 
and 
disclosure 
with 
law 
enforcement and other competent authorities in 
connection with its inquiry and investigation of 
financials accounts under the AFASA.120   
Any information on the financial accounts that may 
be shared by Bangko Sentral shall be solely used to 
investigate and prosecute cases involving violations 
of Sections 4 (Money Muling, Social Engineering, and 
Economic Sabotage) and 5 (Other Offenses) of the 
AFASA; and to implement the relevant provisions of the 
Financial Products and Services Consumer Protection 
Act.121 
q.	
Records of Closed Banks based on Jurisprudence
Employees and officers of a closed bank cannot be 
prosecuted for violation of Law on Secrecy of Bank Deposits 
when they disclose information concerning a bank account, 
which was used in the perpetration of anomalies.122   The 
disclosure of a bank account is not prohibited under the 
law as the closed bank is no longer a “banking institution” 
within the spirit and letter of the law.123  
Penalties
Violation of the Law on Secrecy of Bank Deposits will subject the offender, 
upon conviction, to the following penalties:
1.	
Imprisonment of not more than five (5) years;
2.	
Fine of not more than PhP20,000.00; or
3.	
Both imprisonment and fine.
120    Rep. Act No. 12010 (2024), §14.
121     See Rep. Act No. 12010 (2024), §14.
122    See Soriano v. Gutierrez and Manuzon, C.A. G.R. SP No. 87634, May 30, 2006, which was affirmed by     
          the Supreme Court in a Minute Resolution, G.R. No. 174944, Jan. 24, 2007.
123    Id.
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Foreign Currency Deposit Act of the Philippines
 
Absolute Confidentiality 
All foreign currency deposits are absolutely confidential and cannot be 
examined, inquired, or looked into by any person, government official, bureau, or 
office, whether judicial or administrative or legislative, or any other private or public 
entity. Foreign currency deposits are also exempt from attachment, garnishment, 
or any other order or process of any court, legislative body, government agency, or 
any administrative body whatsoever.124 
Foreign currency deposits refer to funds in foreign currencies that are 
accepted and held by authorized banks in the regular course of business with the 
obligation to return an equivalent amount to the owner thereof, with or without 
interest.125
Prohibited Acts and Persons Liable
The following are liable under this law:
1.	
Any person or government official who, or any government bureau 
or office that, examines, inquires, or looks into a foreign currency 
deposit without the written permission of the depositor;126
2.	
Any official or employee of a banking institution who makes a 
disclosure concerning foreign currency deposits to another, in any 
instance not allowed by law;127
3.	
Anyone who shall attach, garnish, or subject the foreign currency 
deposit to any other order or process of any court, legislative body, 
government agency, or any other administrative body;128 or
4.	
Any person who commits a willful violation of any of the provisions 
of Foreign Currency Deposit Act of the Philippines or regulation 
issued by the Monetary Board pursuant to the said law.129
124     Rep. Act No. 6426, § 8 (1974) (last amended in 1978).
125     MORFXT, § 45(4) in relation to § 70 (2022).
126     Rep. Act No. 6426, § 8 (1974) (last amended in 1978). 
127     See Id., § 10.   
128     Id., § 8. 
129     Id., § 10.
Exceptions to Confidentiality
Absolute confidentiality is mandated for all foreign currency deposits 
subject to the following limited exceptions:
1.	
Foreign Currency Deposit Act of the Philippines
The only exception to the absolute confidentiality under this law 
is when there is written permission of the depositor.130 Absent the 
written permission of the depositor and subject to other exceptions 
provided under other laws, banks cannot be compelled to disclose 
any information on foreign currency deposits; otherwise, it might 
expose itself to criminal liability.131
2.	
Other Laws and Jurisprudence
The exceptions to the absolute confidentiality as regards the foreign 
currency deposits under other laws are almost similar to those 
in the Law of Secrecy of Bank Deposit.132 Hence, foreign currency 
deposits may be lawfully examined, inspected, and inquired into by 
authorized persons and entities in the following instances:
a.	
Borrowings of directors, officers, stockholders, and related 
interests who are required to execute a written waiver of 
secrecy of deposits of whatever nature in all banks in the 
Philippines, in accordance with The New Central Bank 
Act;133
b.	
In cases of application for compromise of tax liability, 
determination by the Commissioner of BIR of a decedent’s 
gross estate, and exchange of tax information;134
c.	
A covered institution that reports foreign currency deposits 
in covered transaction reports or suspicious transaction 
reports to AMLC;135
d.	
Inquiry by AMLC into deposits or investments related to 
unlawful activities or money laundering offenses;136
130    Rep. Act No. 6426, § 8 (1974) (last amended in 1978) & People v. Ligot, C.T.A. Crim. Case Nos. O-241, 
O-242, O-243 & O-244, Jan. 8, 2019.
131      GSIS v. Court of Appeals, G.R. No. 189206, June 8, 2011 (651 S.C.R.A. 661).
132     People v. Ligot, C.T.A. Crim. Case Nos. O-241, O-242, O-243 & O-244, Jan. 8, 2019.
133     See Rep. Act No. 7653, § 26 (1993), as amended by Rep. Act No. 11211 (2019), & MORFXT, § 76 (1) (2022).
134     See Rep. Act No. 8424, § 6 (1997) (last as amended in 2021) & MORFXT, § 76(8) (2022).
135     See MORFXT, § 76(2) (2022).
136     See Rep. Act No. 9160 (2001) (last amended in 2021) & MORFXT, § 76(3) (2022).
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e.	
Investigation by AMLC of deposits and investments related 
to financing or acts of terrorism;137 
f.	
Conduct of annual testing by Bangko Sentral that is solely 
limited to the determination of the existence and true 
identity of the owners of foreign currency non-checking 
numbered accounts, to prevent money laundering;138 
g.	
Inquiry or examination of deposits or investments by 
Bangko Sentral in the course of a periodic or special 
examination to ensure compliance with the AMLA;139
h.	
Inquiry by PDIC and Bangko Sentral in cases of unsafe or 
unsound banking and failure of PCA;140 
i.	
Audit of government deposits by Commission on Audit;141  
j.	
Investigation by PCGG to recover ill-gotten wealth;142  and
k.	
Coordinated verification of a disputed transaction; and 
authority of the Bangko Sentral to inquire and investigate 
into financial accounts and issue rules on information 
sharing and disclosure with law enforcement and 
competent authorities  under the AFASA.143 
3.	
Grounds of equity as declared by jurisprudence
a.	
Account of a non-resident alien 
The garnishment of a foreign currency deposit account of a 
non-resident alien found guilty of raping a minor was allowed 
on the basis of equity.144 
b.	
Account of a co-payee of a check
A co-payee of a check who filed a suit for recovery of sum of 
money was considered, in a pro hac vice ruling by the Supreme 
Court, as a depositor in view of the distinctive circumstances of 
the case.145
137     See Rep. Act No. 10168, § 10 (2012); Rep. Act No. 11479, § 35 (2020); & MORFXT, § 76(4) & (9) (2022).
138     See Rep. Act No. 9160, § 9 (2001) (last amended in 2021) & MORFXT, § 76(6) (2022).
139     See Rep. Act No. 9160, § 11 (2001) (last amended in 2021) & MORFXT, § 76(5) (2022).
140     See Rep. Act No. 3591, §§ 9 & 11 (1963) (last amended in 2022) & MORFXT, § 76(7) (2022).
141      See Constitution, Art. IX-D, § 2(1); Op. No. 95, Dep’t of Justice (May 31, 1991), citing Pres. Dec. No. 1445    	
           (1978); & MORFXT, § 76 (2022).
142     See Exec. Ord. No. 1, § 3(e) (1986) & MORFXT, § 76 (2022).
143     See Rep. Act No. 12010 (2024), §§  8, 12, & 14..
144     Salvacion v. Central Bank of the Philippines, G.R. No. 94723, Aug. 21, 1997 (278 S.C.R.A. 27).
145     China Banking Corporation v. Court of Appeals, G.R. No. 140687, Dec. 18, 2006 (511 S.C.R.A. 110).
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Penalties
Violation of the Foreign Currency Deposit Act of the Philippines shall 
subject the offender, upon conviction, to the following penalties:
1.	
Imprisonment of not less than one (1) year but not more than five 
(5) years; or
2.	
Fine of not less than PhP5,000.00 but not more than PhP25,000.00; 
or
3.	
Both imprisonment and fine.
The following sanctions may also be imposed against a bank or any 
bank director and officer for violation of the Foreign Currency Deposit Act of the 
Philippines and Bangko Sentral regulations issued pursuant to said law:
1.	
Revocation or suspension of the authority of the bank to accept 
new foreign currency deposits;146 and
2.	
Administrative sanctions provided under Section 37 of The New 
Central Bank Act, as may be applicable.
146     See MORFXT, § 87 (2022).
Revised Non-Stock Savings and Loan Association Act of 1997
 
Non-Stock Savings and Loan Associations (Associations) are non-stock, 
non-profit corporations engaged in the business of accumulating the savings of 
its members and using such accumulations for loans to members to service the 
needs of households by providing long-term financing for home-building and 
development, and for personal finance.147
	
Absolute Confidentiality 
	
All deposits of whatever nature with an Association in the Philippines are 
considered absolutely confidential in nature and may not be examined, inquired, 
or looked into by any person, government official, bureau, or office.148 
	
Deposits in an Association are obtained from its members. Membership in 
an Association shall be confined to a well-defined group of persons. An Association 
shall not transact business with the public.149
Prohibited Acts and Persons Liable
The following are liable under this law:
1.	
Any person and government official who, or any government 
bureau or office that, examines, inquires, or looks into deposits in 
the Association in any of the following circumstances:
a.	
Without the written permission of the depositor or not 
involving an impeachment case;150 
b.	
Without a court order in cases of bribery or dereliction 
of duty of public officials, or in cases where the money 
deposited or invested is the subject matter of litigation;151 or
c.	
In any instance not permitted by other laws or jurisprudence.
2.	
Any official or employee of an Association who makes a disclosure 
concerning deposits to another, in any instance not allowed by 
law.152
147     Rep. Act No. 8367, § 3(a) (1997).
148     Id., § 6.
149     Id., § 4. 
150     Id., § 6.
151      Id.
152     Id.
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Exceptions to Confidentiality 
1.	
Revised Non-Stock Savings and Loan Association Act of 1997
Deposits in an Association may be examined, inquired, or looked 
into under the following instances:153
a.	
When there is written permission of the depositor;
b.	
In cases of impeachment;
c.	
Upon order of a competent court in cases of bribery or 
dereliction of duty of public officials; or
d.	
In cases where the money deposited or invested is the 
subject matter of litigation. 
2.	
Other Laws 
Examination or inquiry into deposits with the Association may be 
allowed in the following instances:
a.	
Inquiry by AMLC into deposits or investments related to 
unlawful activities or money laundering offenses;154
b.	
Investigation by AMLC of deposits and investments related 
to financing or acts of terrorism;155
c.	
Conduct of annual testing by Bangko Sentral that is solely 
limited to the determination of the existence and true 
identity of the owners of numbered accounts, to prevent 
money laundering;156
d.	
Inquiry or examination of deposits or investments by 
Bangko Sentral in the course of a periodic or special 
examination to ensure compliance with the AMLA;157 and
e.	
Investigation by PCGG to recover ill-gotten wealth; 158 and;
153     Id. 
154     See Rep. Act No. 9160 (2001) (last amended in 2021).
155     See Rep. Act No. 10168, § 10 (2012); Rep. Act No. 11479, § 35 (2020).
156     See Rep. Act No. 9160, § 9 (2001) (last amended in 2021).
157     See Id., §11.
158     See Exec. Ord. No. 1, § 3(e) (1986).
f.	
Coordinated verification of a disputed transaction; and 
authority of the Bangko Sentral to inquire and investigate 
into financial accounts and issue rules on information 
sharing and disclosure with law enforcement and 
competent authorities under the AFASA.159
Applicability of Penalties under the Law on Secrecy of Bank Deposits
Any official or employee of an Association shall be punished under the Law 
on Secrecy of Bank Deposits for violation of the absolute confidentiality of deposits 
in an Association.160
159    See Rep. Act No. 12010 (2024), §§ 8, 12, & 14.
160    Rep. Act No. 8367, § 6 (1997).
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