BSP fines RCBC PHP 1 billion after Bangladesh Bank funds passed through
Rizal Commercial Banking Corporation (RCBC) · Banking
The case in brief
Visible before detection
Checks that could have surfaced it, on hindsight
Counterparty existence
Would have tested whether the account holders existed and were verified.
Can mislead when: Real companies can be used as pass-throughs. Existence does not prove a real trade, so C6 and C7 still apply.
Bank credits vs books
Would have flagged large credits unrelated to the account profile.
Can mislead when: AA only sees the accounts the company links, so an undisclosed account stays invisible. Cash-heavy businesses and timing differences create false flags.
End-use tracing of funds
Would have traced onward payments to casinos and junket operators.
Can mislead when: Kubr sees only the company's own accounts. Once money reaches a third party's bank, Kubr can flag the payee but cannot see the next hop without that party's consent.
Governance signals
Would have flagged branch-level control gaps.
Can mislead when: Private companies file late, so these signals are lagging. Kubr uses them to support other flags, not to prove anything alone.
Where Kubr services would have helped
Borrower monitor
Offered in India- C1 Would have flagged large credits unrelated to the account profile.
- C6 Would have traced onward payments to casinos and junket operators.
- C11 Would have flagged branch-level control gaps.
Proceeds tracer
Offered in India- C1 Would have flagged large credits unrelated to the account profile.
- C4 Would have tested whether the account holders existed and were verified.
- C6 Would have traced onward payments to casinos and junket operators.
Verified Snapshot
Offered in India- C4 Would have tested whether the account holders existed and were verified.
- C11 Would have flagged branch-level control gaps.
Financial diligence
Offered in India- C1 Would have flagged large credits unrelated to the account profile.
- C4 Would have tested whether the account holders existed and were verified.
Mapped from the checks each service runs. A hindsight reading of public records, not a promise that the failure would have been found.
Same pattern
A summary of public documents. It reports what the sources say. It is not Kubr's finding and not a statement of guilt.