Under Philippine law, particularly under the Anti-Money Laundering Act (AMLA) and its amendments, "covered transactions" are specific types of financial activities that are subject to strict monitoring and reporting requirements by financial institutions. These requirements aim to prevent and detect money laundering and other forms of financial crime.

Here's a meticulous breakdown of covered transactions under the Anti-Money Laundering Act (AMLA), as amended by Republic Acts No. 9194, 10167, 10365, 10927, and 11521:

1. Definition of Covered Transactions

A "covered transaction" under the AMLA refers to transactions in cash or other equivalent monetary instruments that meet certain thresholds or involve specific parties or situations that present a high risk for money laundering or financial crimes.
The Anti-Money Laundering Council (AMLC), the primary government body responsible for implementing AMLA, establishes guidelines and additional parameters for what constitutes a covered transaction.

2. Types of Covered Transactions

Covered transactions primarily include:

Single, Series, or Aggregate Transactions Over a Specified Threshold:
- As stipulated in AMLA, a covered transaction generally refers to a single, series, or aggregate transaction in cash or other monetary instruments that exceeds Php 500,000 (approx. USD 10,000) within a single business day.
Suspicious Transactions:
- Regardless of the amount, transactions that are deemed "suspicious" must also be reported. These transactions often exhibit unusual patterns or lack an apparent legal or economic purpose. Key indicators of suspicious transactions include:
  - Transactions that appear to be structured to avoid being reported (e.g., structuring or smurfing).
  - Transactions inconsistent with the customer's financial profile, such as large withdrawals, deposits, or transfers that deviate from the usual behavior.
  - Complex and irregular transactions that may indicate attempts to disguise illegal activities.
Transactions Involving High-Risk Individuals or Entities:
- Transactions involving high-risk individuals or entities (e.g., Politically Exposed Persons, or PEPs) may be considered covered transactions, depending on the institution's risk-based assessment.
Cross-Border Transfers:
- Transfers of funds across borders that involve substantial sums are closely monitored and may also be reported as covered transactions if they exceed certain thresholds or raise red flags due to their characteristics.
Real Estate Transactions (as Amended by R.A. No. 10927):
- As amended by Republic Act No. 10927, real estate transactions that involve a single cash transaction exceeding Php 7.5 million must be reported as covered transactions.
  - This particular amendment expands AMLA’s reach to include high-value real estate transactions, reflecting a broader approach to anti-money laundering in sectors beyond traditional financial services.

3. Entities Required to Report Covered Transactions

Under the AMLA and its amendments, specific financial institutions and covered persons are mandated to report covered transactions. These include:
- Banks and Non-Bank Financial Institutions: Commercial banks, rural banks, quasi-banks, trust companies, and other non-bank financial institutions.
- Insurance Companies: Life insurance, pre-need, and insurance companies involved in financial transactions.
- Securities Dealers and Investment Houses: These include brokers, dealers, and other entities involved in securities trading and investments.
- Money Service Businesses: Includes remittance agents, foreign exchange dealers, and electronic money issuers.
- Casinos (as Amended by R.A. No. 10927): The 2017 amendment (R.A. No. 10927) expressly brought casinos under AMLA coverage, requiring them to report transactions that meet covered transaction criteria.
- Real Estate Dealers and Brokers: With the recent amendments, real estate professionals involved in high-value transactions must report these as covered transactions.
Other Entities as May Be Designated by the AMLC:
- The AMLC may identify other institutions or professionals that, by the nature of their business, may be exposed to high risks of money laundering activities. These institutions may also be required to comply with reporting obligations.

4. Reporting Requirements and Procedures

Mandatory Reporting of Covered Transactions:
- Covered institutions and persons must report covered transactions to the AMLC within five (5) working days from the date of the transaction. This reporting period allows institutions to verify, document, and confirm the transactions before submission.
Suspicious Transaction Reporting (STR):
- Suspicious transactions must also be reported within five (5) days after discovery, as per the institution’s internal protocols for identifying suspicious activities.
Data and Documentation Requirements:
- The report must include all necessary documentation that substantiates the transaction, including customer identification details, transaction amounts, nature of the transaction, and any additional details required by AMLC.
Confidentiality in Reporting:
- The reporting entity and its employees are protected by strict confidentiality provisions under AMLA. Disclosure of reports or providing information to unauthorized individuals is punishable by law to maintain the integrity of AML compliance efforts.

5. Penalties and Sanctions for Non-Compliance

The AMLA prescribes penalties for financial institutions and covered persons who fail to comply with the reporting requirements. These include:
- Administrative Fines: Monetary penalties can range from minor fines to substantial financial penalties for consistent or intentional non-compliance.
- Criminal Penalties: Severe cases of non-compliance, particularly those involving conspiracy to cover up money laundering activities, may lead to imprisonment of responsible parties.
- Revocation of License: For repeated non-compliance, institutions may face the suspension or revocation of their licenses by their regulatory bodies (e.g., Bangko Sentral ng Pilipinas, Insurance Commission).

6. AMLA’s Framework for Monitoring and Compliance

The AMLC oversees compliance by establishing a risk-based approach for financial institutions and covered persons, who must implement appropriate internal controls and training programs for employees.
Know Your Customer (KYC) Procedures:
- Institutions are required to maintain robust KYC protocols to verify customer identities, establish beneficial ownership, and monitor transactions.
Enhanced Due Diligence (EDD) for High-Risk Clients:
- Institutions must perform EDD on high-risk customers, particularly PEPs or those from jurisdictions known for lax anti-money laundering standards.
Regular Audits and Inspections:
- The AMLC, along with other regulatory bodies, conducts audits and inspections to ensure institutions meet AMLA requirements, reviewing transaction records, KYC documentation, and reporting procedures.

7. Amendments to AMLA Enhancing Covered Transactions

R.A. No. 10365 (2013): Enhanced AMLA’s scope to include foreign exchange dealers, money changers, remittance centers, and pre-need companies.
R.A. No. 10927 (2017): Incorporated casinos as covered institutions, acknowledging that casinos are vulnerable to money laundering risks due to large cash transactions.
R.A. No. 11521 (2021): Expanded AMLA’s reporting requirements to cover even more entities and emphasized AMLC’s authority in ensuring compliance through stricter regulations and penalties.

This meticulous interpretation of covered transactions under AMLA highlights the Philippine government’s proactive approach to combating money laundering and its commitment to meeting international anti-money laundering standards. Institutions are advised to strictly comply with AMLA's provisions, as the penalties for non-compliance are substantial, and the ramifications of money laundering extend beyond financial harm to social and political stability.