Chapter 1: General Concepts o Purpose of which is to relending or purchasing

receivables or other obligations

Definition  NOT Quasi-banking – if the borrowing is made by
 Banks – entities engaged in the lending of funds obtained in commercial, industrial and other non-financial companies for
the form of deposits. It is required that banks are stock the limited purpose of financing their own needs or the needs
corporation and that its funds are obtained from the public of their agents or dealers
(deposits of 20 persons or more)  NOT Quasi-banking – institution is engaged in buying and
 Banks – moneyed institute founded to facilitate the selling of “without recourse” instruments
borrowing, lending, and safekeeping of money and to deal in
notes, bills of exchange and credits Nature of Business
 Banks – any person engaged in the business carried on by  Public confidence is the anchor of any banking system
banks of deposit, of discount, or of circulation is doing a  Banking business is in the nature of public trust
banking business, although but one of these function is
exercised Utmost Diligence
 Required to exercise utmost diligence in the handling of
Quasi-Banks deposits
 Quasi-banking – entities engaged in the borrowing of funds
through issuance, endorsement, or assignment with Strikes and Lockouts
recourse or acceptance of deposit substitutes for purposes  Any strike or lockout involving banks, if unsettled after 7
of relending or purchasing of receivables and other calendar days shall be reported by the BSP to the Secretary
obligations of Labor who has 2 options:
 Deposit substitutes – alternative forms of obtaining funds o He may assume jurisdiction over and decide the
from the public, other than deposits, through the issuance, dispute
endorsement, or acceptance of debt instruments for the o He may certify the same to the National Labor
borrower’s own account, for the purpose of relending or Relations Commission for compulsory arbitration
purchasing or receivables and other obligations  Law allows the President of the Philippines to, at any time,
 Universal Banks and Commercial Banks may exercise quasi- intervene and assume jurisdiction over such labor dispute in
banking functions without securing prior authority from the order to settle or terminate the same
Monetary Board while other banks must secure such  Presidents or Chief Executive Officers of banks are required
authority to immediately inform the Deputy Governor of the
Supervision and Examination Section of the BSP on the
 Quasi-banking elements: status of the strike and lockout in their bank stating the
o Borrowing funds for the borrower’s own account cause thereof, the bank’s position on its legality and the bank
o Twenty (20) or more lenders at any one time operations affected thereby
o Methods of borrowing are issuance, endorsement, or
acceptance of debt instruments of any kind

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Governing Law
 Banks are governed by RA No. 8791 aka General Banking
Law of 2000
 Took effect on June 13, 2000
 RA No. 7653 aka The New Central Bank Act prevails over
general laws, like the Corporation Code, in the regulation of
banks
 Primary law of Rural Banks is RA 7353
 Primary law for Thrift Banks is RA 7906
 Law for Islamic Banks is RA 6848

Authority To Operate
 Incorporation Stage: Banking or Quasi-banking corporation
cannot be incorporated without the authority from the
Bangko Sentral ng Pilipinas
 Operation: An entity performing banking or quasi-banking
function cannot operate without a certificate of authority from
the BSP
 Determination of whether a person or entity is performing
banking or quasi-banking functions without BSP authority
shall be decided by the Monetary Board
 Monetary Board shall resolve, through the appropriate
supervising and examining department of the BSP, by
examining, inspecting or investigating the books and records
of such person or entity

Cases
 Republic of the Philippines vs. Security Credit and
Acceptance Corporation, et al
 Central Bank of the Philippines vs. the Honorable Judge
Jesus P. Morfe, et al

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 regulations of the Securities and Exchange
Chapter 2: Classification of Banks Commission
o If the investment house functions are performed
Universal Banks directly by the universal bank, such functions shall
 Universal Banks – have the authority to exercise, in addition be undertaken by a separate and distinct department
to the powers of a commercial bank, powers of an or other similar unit in the bank
investment house, and the power to invest in non-allied o It cannot perform functions of an investment house
enterprises both directly and indirectly. This means that if it
 Has the power to own up to 100% of the equity in a thrift already exercises the functions of an investment
bank, rural bank, financial allied enterprise, or a non-financial house through a subsidiary, the universal bank can
allied enterprise no longer open a department or a unit within the
 In case of publicly listed universal banks, the power to own same bank to act as an investment house
up to 100% of the voting stock of only one other universal
bank or commercial bank Non-allied Enterprise
 Required to offer to sale equity shares to the public  Broad category of non-allied undertakings in which a
stockholders universal bank may invest directly or through its subsidiary
 Public stockholders refer to all stockholders excluding the shall require prior approval of the Monetary Board
bank’s directors, shareholders owning up to 20% or more of  No prior approval is necessary if investment is to be made in
the bank’s subscribed capital stock together with those of any of the following broad categories:
their relatives within the fourth degree of consanguinity or o Enterprise engaged in physically productive activities
affinity, and corporations controlled or affiliated with them in agriculture, mining and quarrying, manufacturing,
 Required minimum public stock offering is 10% of the public utilities, construction, wholesale trade and
required minimum capital community and social services following the
industrial groupings in the Philippine Standard
Investment House Industrial Classification
 Investment House – enterprise which engages or purports to o Industrial park projects and/or industrial estate
engage, whether regularly or on an isolated basis, in developments
underwriting of securities of another person or enterprise o Financial and commercial complex projects arising
 Underwriting of securities – act or process of guaranteeing from or in connection with Government’s
distribution and sale within the Philippines of securities of the privatization program
Government or its instrumentalities o Such other broad categories as the Monetary Board
 Universal Bank may perform the functions of an investment may declare as appropriate
house directly or indirectly through a subsidiary investment
house; subjected to the following rules: Commercial Banks
o Underwriting or equity securities and securities  Commercial banks – perform general powers incident to
dealing shall be subject to the pertinent laws and corporations and investment banking

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  Functions: accepting drafts; issuing letters of credit;  Development Bank of the Philippines – provide credit
discounting and negotiating promissory notes, drafts, bills of facilities for development in agriculture, commerce, and
exchange, and other evidences of debt; accepting or industry
creating demand deposits; receiving other types of deposits
and deposits substitutes; buying and selling foreign
exchange and gold or silver bullion; acquiring marketable Foreign Banks
bonds and other debt securities; extending credit, subject to  Entry of foreign banks in the Philippines through the
the rules of Monetary Board establishment of branches shall be governed by the
provisions of the Foreign Banks Liberalization Act
Cooperative Banks  To create a more competitive environment and encourage
 Cooperative Banks – organized primarily to provide financial greater foreign participation
and credit services to cooperatives. It may perform any or all  Philippine laws shall not reply to the following matters:
services provided by a rural bank o Creation, formation, organization, or dissolution of
 Membership of a cooperative bank shall include ONLY corporations
cooperative and federations of cooperatives o Fixing of the relations, liabilities, responsibilities
o Duties of stockholders, members, directors or
Rural Banks officers of corporations to each other or to the
 Rural banks – banks that promote rural development corporation
 MB may revoke:
Thrift Banks o Foreign bank is insolvent
 Thrift banks – encourages the industry, frugality and o Imminent danger of insolvency
accumulation of savings of the public o Its continuance in business will involve probably loss
to those transacting with it
Islamic Banks
 License must be renewed or reissued again
 Islamic banks – promote socio-economic development in
 Foreign banks may enter in the Philippines with prior
autonomous region by performing banking and investing
approval of the BSP through the following modes:
function based on Islamic concept of banking
o Acquiring, purchasing or owning up to 60% of the
Other Banks voting stock of an existing domestic bank
o Investing in up to 60% of the voting stock of a new
 Government-owned and controlled that are created by
special laws for specific purposes banking subsidiary incorporated under the laws of
 Philippine Veterans Bank – created to provide government the Philippines
o Establishing branches with full banking authority
depository to veterans for appreciation of grateful nation
 Land Bank of the Philippines – finance distribution of estate
to resale to small landowners

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 Capacity of Depositor
 Incapacitated persons are generally not allowed to open an
account with the bank
 Minors are allowed to open savings and time deposits
provided that they are:
Chapter 3: Deposit Function o At least 7 years of age
o Able to read and write
Bank o Have sufficient discretion
 Basic functions: acceptance of deposits from the public and  Married women are allowed to open bank accounts without
lending the funds obtained from deposits the assistance of their husbands. Women of legal age,
 Not a bank if deposit function is absent regardless of civil status, shall have the capacity to act and
 Although other entities or persons may extend loans, they enter into contracts
will not be considered performing banking business if they do  Corporations are required to open an account before its life
not accept deposits from the public commences. Life starts from the issuance of the Certificate
of Incorporation by the Securities and Exchange
Voluntary Creditor-Debtor Relationship Commission which can only be issued upon the approval of
 Contract of loan – contract entered into between bank and the Articles of Incorporation
depositor
 Depositor – one who pays money into the bank in the usual Bank as Debtor
course of business, to be placed to his credit, and subject to  Bank has no duty to preserve the amount deposited
his check or beneficiary held by the bank  Money deposited belongs to the bank and may be used for
any lawful purpose as it may deem fit
Voluntary Agreement  Since the contract is governed by rules on simple loan and
 Contracts by their nature are voluntary not contract of deposit, the money received by the bank is
 May be liable only if the non-acceptance is discriminatory or not being held for safekeeping for the depositor
contrary to law, morals, and good customs  Relationship: creditor(client)-debtor(bank)
 Bank is not bound to receive deposits from any one, but may o Bank can make use of the money deposited.
choose those whom it will accept as depositors and the Amount is not being held in trust for the depositor
terms and conditions on which it will accept deposits nor is it being kept for safekeeping
 BSP instructed banks to adopt Know-Your-Customer o Third persons who may have the right to the money
standards deposited cannot hold the bank responsible unless
 Basic rule in the Manual of Regulations for Banks is for the there is a court order or garnishment
depositor to submit necessary specimen signatures and o Banks deposits are not preferred credits under the
proper documents for identification Civil Code
o Bank has the right to compensation

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  Obligation of the bank is to return the same value to the  Person whose name appears as depositor in the passbook
depositor and not to return exactly the same thing that was and other bank documents is presumed to be the owner of
given the money in the bank account
 Depository bank does not have a unilateral right to freeze the
accounts of its depositor based on its mere suspicion that
the funds therein were proceeds of fraudulent acts.
 Banks do not owe any obligation to third persons – another
Legal Compensation reason why banks cannot likewise freeze the account of its
 Bank has the right to set off the deposits in its hands for the depositor to honor the claim of third persons
payment of the indebtedness of the depositor provided that  Article 559 does not apply
all the requisites for a valid legal compensation are present
 If the indebtedness was the result of payment against Liability For Trust Account
uncollected deposit of checks, the bank may debit another  Bank cannot stop the withdrawal of funds from an account
account of the depositor in the same bank if the account on the basis of an allegation that the money deposited in the
where the check was originally deposited is already closed account is held in trust by the depositor for another person
 If a depositor placed a time deposit in a bank, the depositor and that the withdrawal is in breach of such trust
has the right to expect that the bank accurately recorded his
transactions with it Cause Of Action Against Banks In Case Of Breach Of Trust
 A bank may be held liable if it took part in committing the
Deposit Not Trust Under The Civil Code fraudulent act
 Bank’s relationship with the depositor is not a trustor-trustee
relationship under Title V of the New Civil Code Dishonest Assistance
 In a deposit, the bank becomes the owner of the cash that  Requisites for dishonest assistance:
was deposited subject to the obligation to pay the depositor o There must be a trust or other fiduciary relationship
o There must be a breach of trust
Basic Obligations To Depositor o Person upon whom liability is to be imposed must as
 Depository bank owns the deposited monies in the account a matter of fact have been an accessory or assisted
of the depositor because the deposit of money in banks is in the misfeasance or breach of trust
governed by the Civil Code provisions on simple loan o Accessory must be dishonest
 Even though the depository bank owns the deposits, it
cannot prevent the depositor from demanding payment of Knowing Receipt
the depository bank’s obligation  Another exception involving disposition in breach of trust that
is recognized in common law is when there is knowing
Unilateral Freezing Of Account Not Allowed receipt
 Under this exception, claimant must show the ff:

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 o Disposal of the claimant’s assets in breach of  Time Deposits – payment of which generally cannot legally
fiduciary duty be required within a specified number of days. No time
o Beneficial receipt by the defendant of assets which deposit shall be accepted for a term of less than 30 days.
are traceable as representing assets of the claimant o Minimum maturity is 731 days
o Knowledge on the part of the defendant bank that
the assets he received are traceable to a breach of Solicitors
fiduciary duty  Bank may be authorized by the BSP to solicit and accept
deposits outside the bank premises through deposit solicitors
 Passbook shall be returned to the depositor not less than the
following business day

Court Order Or Garnishment

 Bank may be liable if there is already a court order which
recognizes the right or third person or which effectively Deposit
prohibits the bank from releasing funds from the account  Contract of loan is real contract
 Deposit slips – proof that an amount was deposited in an
Effect of Insolvency On Deposit account
 In the excess amount covered by the insurance (provided by  Bank must exercise due diligence in proper validation of
PDIC), the deposit is treated as an ordinary unsecured credit bank deposits

Kinds Of Deposits Withdrawal

 Demand Deposits – liabilities of banks which are  When cash is deposited in the account, the depositor can
denominated in Philippine currency and are subject to withdraw the amount at any time provided that he complies
payment in legal tender upon demand by presentation of with the prescribed procedure
checks  Demand deposits – withdrawn through duly issued checks
o Only universal banks or commercial banks can  Savings account – presenting deposit slips duly signed by
accept or create demand deposits. Other banks the depositor
cannot accept unless MB approves.  Bank is liable if it allows withdrawal of funds on the basis of
 Savings Account – has an investment feature because forged signatures in withdrawal slips
savings accounts are normally opened for the purpose of  Combo Plan account – depositor maintains a saving account
earning interest and a checking account with the same bank and agree that
 Negotiable Order Of Withdrawal Accounts (NOW) – interest- funds may be automatically transferred from the savings
bearing deposit accounts that combine the payable on account
demand feature of checks and investment feature of savings
accounts Effect Of Miscredit

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  Depositor is entitled to recover from the bank the amount o Manner of interest payment i.e. whether credited in
which was erroneously deducted from his account and advance or otherwise
without his authority o Basis of interest payment
 Depositor has no right to withdraw the amount which was not o Effective rate of interest
actually deposited Joint Accounts
 Joint accounts – whenever 2 or more persons open an
Consumer Protection account
 BSP requires banks to establish and maintain  Presumed that depositors own equal shares in the deposit
comprehensive information security program and ensure that
they are properly implemented and strictly enforced Anonymous Accounts
 Anonymous accounts – accounts under fictitious names
Interest On Deposits  Exception: Foreign Currency Deposit Act where the law
 Demand, savings, NOW accounts, time deposits and deposit allows the opening of “numbered accounts” for foreign
substitutes shall not be subjected to interest ceilings currency deposits
 Interest or yield on time deposit/deposit substitute may be
paid at maturity or upon withdrawal or in advance. However,
interest or yield paid in advance shall not exceed the interest Deceased Depositor
for 1 year  If a depositor dies, heirs cannot withdraw the balance of the
account unless the estate of the deceased is settled
Matured Time Deposits/Deposit Substitutes  A bank that is aware of a depositor’s death must not allow
 Time deposit not withdrawn or renewed on its due date shall withdrawal of the balance of the account unless a certificate
be treated as a savings account and shall earn interest from of payment of the estate tax is submitted
maturity to the date of actual withdrawal or renewal at a rate o Exception: allows the withdrawal not exceeding
applicable to savings deposits P20,000
 A deposit substitute instrument not withdrawn or renewed on
its maturity date shall from said date become payable on Survivorship Agreements
demand and shall earn an interest or yield from maturity to  In case of death of one the depositors in a joint account, it is
actual withdrawal or renewal at a rate applicable to a deposit presumed that the depositors own the account share and
substitute with a maturity of 15 days share-alike
 Survivorship agreement – contract supported by
Disclosure Requirement consideration where the joint depositors agree to permit
 Banks are required to disclose to depositors the ff either of them to withdraw the whole deposit during their
information on interest computation and payments: lifetime and transferring the balance to the survivor upon the
o Type/kind of deposit death of one of them
o Nominal rate of interest and period covered
Closure Of Accounts

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  Bank can expressly reserve the right to close an account  Upon the order of a competent court in cases where the
(even without prior notice) whenever certain identified events money deposited or invested is the subject of litigation
will occur  Cases involving unexplained wealth
 Inquiry by the Commissioner of Internal Revenue for the
Duty Of Care purpose of determining the net estate of a deceased
 Banks are required to exercise the highest degree of care in depositor
the handling of deposits by their clients  Money laundering
 Dormant deposits for at least 10 years under the Unclaimed
Balances Act
 Upon order of Court of Appeals when there is probable
cause under the Human Security Act
 Inquiry or examination by the PDIC/BSP
Garnishment
 Garnishment of bank deposits does not violate RA 1405
 When a bank account is garnished, no real inquiry is made
on the account and the disclosure of the deposit made by the
bank is purely incidental
Secrecy Of Bank Deposits
 Foreign currency are exempt from attachment or
 RA No. 1405
garnishment
 To encourage deposit in banking institutions
 Bank is not liable whenever it releases the amount garnished
 To discourage private hoarding so that bans may lend such as ordered by a court of competent jurisdiction
funds and assist in the economic development of the country
 Do not apply to foreign currency deposits whether owned by
Filipinos or aliens

Deposits Covered
 All bank accounts of whatever nature
 Investments in bonds issued by the Philippine government,
its branches, and institutions

Exceptions
 When there is written permission of the depositor or investor
 Impeachment cases
 Upon the order of a competent court in cases of bribery or
dereliction of duty of public officials

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  If the deposit is less than P500,000, it is covered by the
insurance
 Even foreign currency deposits are covered by the insurance

Separate Deposits In Branches

 Sum of all deposits in all branches in the Philippines shall be
used in determining if the deposit exceeds P500,000
 Excluded however the deposits in foreign branches of the
same bank

Same Right And Capacity

 PDIC will add all deposits in the bank maintained in the
same right and capacity for his benefit either in his own
name or in the name of others

In Joint Accounts
 Joint accounts shall be insured separately from any
individually-owned deposit account
Deposit Insurance
 Maximum insured deposit shall be divided into as many
 Governed by RA No. 3591 – created Philippine Deposit equal shares
Insurance Corporation which administers the mandatory
 However total amount of the share in each joint-account
deposit insurance system in the country
should not exceed P500,000
 If the account is held by a juridical person or entity jointly
Rationale
with one or more natural persons, the maximum insured
 Provides a safety net to depositors against the risk of losing
deposit shall be presumed to belong entirely to such juridical
the amount they deposited with a bank
person or entity
 Safety net contributes to economic stability because it
prevents bank runs in times of financial instability Kinds Of Deposits
 Law does not make distinction as to the type of deposit that
Covered Banks
is insured
 All banks and banking institutions which are engaged in the
 Covers all deposit accounts
business of receiving deposits are mandatorily insured with
the PDIC
Deposit Not Covered By Insurance
 Excess of P500,000
Insured Deposit
 Deposit in foreign branches
 Insured deposit does not exceed P500,000

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  Investment products such as bonds and securities, trust  Insured amount = Deposit + Interests – Unpaid Obligations –
accounts, and other similar instruments WHT
 Deposit accounts or transactions that are unfounded,
fictitious, or fraudulent Interest Computation
 Deposit accounts or transactions constituting unsafe and  6% - from the time it is judicially demanded
unsound banking practices
o Determined by PDIC with BSP consultation Remedy For Denial Of Insurance Claim
 Proceeds of an unlawful activity  No appeal is given under the law on the denial of an
 Deposit accounts that resulted from splitting of deposits insurance claim by PDIC
Risks Insured Against  Decision of PDIC is final and executor
 Risk involved is the closure and takeover of the bank by the  Only remedy: special civil action for certiorari
Monetary Board (under BSP)
 PDIC shall take charge of the bank assets and liabilities of a Remedy Of Depositors For Amount In Excess Of Coverage
bank upon:  If PDIC paid an insurance claim of P500,000 but the deposit
o Bank is unable to pay its liabilities is more than such amount, the depositor may claim the
o Bank has insufficient realizable assets balance from the remaining assets upon liquidation of the
o Bank cannot continue in business without involving closed bank
probable losses  Uncovered deposit insurance is considered as an ordinary
o Bank has willfully violated a cease and desist order credit
involving acts which amount to fraud and dissipation
of the assets Splitting Of Deposits
 Splitting of deposits – whenever a deposit account with an
Filing Of Claim outstanding balance of more than the statutory maximum
 Depositor is required to file a claim within 2 years from actual amount of insured deposit maintained under the name of
takeover of the bank natural or juridical persons is broken down and transferred
into 2 or more accounts
 Notice shall be published in a newspaper of general
circulation that the depositor is already required to file a
Unclaimed Balances
claim
 Deposits that have become dormant for a period of 10 years
 If such a claim is made, PDIC is required to pay the
may be escheated in favor of the government
depositor within 6 months from the filing of the claim.
Responsible PDIC officer may be held criminally liable if the  Bank is required to report to the Treasurer of the Philippines
claim is not settled within such period  Treasurer would inform the Solicitor General
 Failure on the part of the depositor to file a claim, depositor
is no longer entitled to the insurance proceeds

Computation Of Claims

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 Economic Rationale
 Depriving potential money launderers of access to financial
markets helps those markets maintain a reputation for
integrity which enhances their stability and attractiveness

The Offense
 Money Laundering Offense – crime whereby the proceeds of
an unlawful activity are transacted in such a way it would
appear that they come from a legitimate source
 Committed by the following:
o Any person knowing that any monetary instrument or
property represents, involves or relates to, the
proceeds of any unlawful activity, transacts or
attempts to transact said monetary instrument or
property
o Any person knowing that any monetary instrument or
property involves the proceeds of any unlawful
activity, performs or fails to perform any act as a
Anti-Money Laundering Act result of which is facilitates the offense of money
 Policy of the State to protect and preserve the integrity and laundering
confidentiality of bank accounts and to ensure that the o Any person knowing that any monetary instrument or
Philippines shall not be used as a money laundering site for property is required under this act to be disclosed
the proceeds of any unlawful activity and filed with the Anti-Money Laundering Council,
 Covered entities: all supervised or regulated by the Bangko fails to do so
Sentral ng Pilipinas  All cases on money laundering: Regional Trial Court
 Committed by public officers and private persons who are
Deterrence Function conspiring with public officers: Sandiganbayan
 Meant to stop not only the practice of money laundering in all
its stages but more importantly the crimes that generated the Terms Defined
proceeds that are being laundered  Covered transaction – transaction in cash or other equivalent
 Placement Stage – proceeds of the crime are deposited in a monetary instrument involving a total amount in excess of
financial institution P500,000 within 1 banking day
 Layering Stage – proceeds are moved so as to sever any  Suspicious transaction – transaction with covered
audit trail to make the tracing of the source harder institutions, regardless of the amounts involved, where any
 Integration Stage – criminal resumes control of the proceeds, of the following may exist:
free from any link to the criminal source

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 o No underlying legal or trade obligation, purpose or o Management of banks, savings, or securities
economic justification account
o Client is not properly identified o Organization of contributions for the creation or
o Amount involved is not commensurate with the operations of companies
business or financial capacity of the client o Creation, operation or management of juridical
o Clients’ transaction is structured in order to avoid persons or arrangements and buying and selling
being the subject of reporting requirements under entities
this act  Excluded: lawyers and accountants acting as independent
o Transaction which is observed to deviate from the legal professionals in relation to information concerning their
profile of the client and/or the client’s past clients or where disclosure of information would compromise
transaction with the covered institution client’s confidences or the attorney-client relationship
o Transaction is in any way related to an unlawful
activity or offense under this act that is about to be, Prevention
is being, or has been committed  Customer identification – based on official documents
o Any transaction that is similar or analogous to any of  Record keeping – records of all transactions of covered
the foregoing institutions shall be maintained and safely store for 5 years
 Monetary Instrument – coins or currency of legal tender of  Reporting of covered and serious transactions – covered
the Philippines or of any other country; drafts, checks and institutions shall report to the AMLC all covered or suspicious
notes; etc transactions within 5 working days

Covered Institutions
 Banks, non-banks, quasi-banks, trust entities, foreign Freezing Of Monetary Instrument Or Property
exchange dealers, pawnshops, money changers, remittance  Person whose account has been frozen may file a motion to
and transfer companies and other similar entities and all life the freeze order and the court must resolve this motion
other persons and their subsidiaries and affiliates supervised before the expiration of the 20 day original freeze order
and regulated by the BSP  No court shall issue a temporary restraining order or a writ of
 Insurance Companies, regulated by Insurance Commission injunction against any freeze order, except the Supreme
 Security dealers, brokers, salesmen, and other similar Court
persons managing securities or rendering services as
investment agent, advisor or consultant
 Investment companies (trust fund, mutual fund, etc)
 Entities administering or dealing in currency
 Jewelry Dealers in precious metals and precious stones
 Persons who provide the ff services:
o Managing of client’s money and assets

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