An AFASA disputed transaction in the Philippines lets your bank or e-wallet hold a scam transfer for up to 30 days.
Short answer Under the Anti-Financial Account Scamming Act (AFASA, Republic Act No. 12010) and BSP Circular No. 1215, banks and e-wallets supervised by the BSP may hold the funds of a disputed electronic transfer for an initial period of up to 5 calendar days, extendable by up to 25 more, for a total of no more than 30 calendar days unless a court extends it. Report the transfer through your own bank’s or e-wallet’s 24/7 fraud reporting channel as soon as you notice it.
By zpeso Desk · BSP Circular No. 1215 and GCash terms .
At a glance
- LawRepublic Act No. 12010, the Anti-Financial Account Scamming Act; footnoted in the circular as effective August 13, 2024BSP ↗ ·
- Initial holdup to 5 calendar daysBSP ↗ ·
- Extended holdup to 25 calendar days after the initial holdBSP ↗ ·
- Total cap30 calendar days, longer only by court orderBSP ↗ ·
- Where to reportthe 24/7 fraud reporting channel of the institution that sent your moneyBSP ↗ ·
What counts as a disputed transaction
BSP Circular No. 1215, approved by the Monetary Board on May 22, 2025, covers electronic transfers of funds from one financial account to another. A transfer becomes a disputed transaction when a BSP-supervised institution has reasonable grounds, from another institution, a complaint or its own fraud monitoring, to believe it is:
| Type | What the circular means |
|---|---|
| Unusual | Inconsistent with the account owner’s usual behaviour, profile or known financial capacity |
| Without clear economic purpose | No underlying legal or trade obligation, purpose or economic justification |
| From an unknown or illegal source | A source that cannot be established, or proceeds of an unlawful activity |
| Facilitated through social engineering | Sensitive identifying information obtained by deception, for example someone pretending to act for a bank, leading to unauthorized access to an account |
The rules do not apply to erroneous transactions, meaning money sent to the wrong account number or in the wrong amount because of the sender’s own encoding mistake. Those follow the BSP’s consumer-protection rules instead; for GCash, see GCash wrong number. Credit card transactions are also outside the rules, except card-funded electronic fund transfers through an automated clearing house.
How the hold works
- You report. The source account owner files a complaint through the 24/7 fraud reporting channel of the originating institution, the bank or e-wallet that sent the money. The institution verifies your identity and the transaction: reference number, amount, date and time, how it was sent and who received it.
- Initial hold. The originating institution sends an initial holding request, through an automated tracing system, to every receiving institution in the chain of transfers. Each holds the disputed funds for up to 5 calendar days from receipt of the request. For this first hold an institution may rely on your allegations.
- Documents. You submit supporting documents, such as a sworn complaint, affidavit or police report, within the initial holding period, unless the industry protocol says otherwise.
- Extended hold. The originating institution may request an extension of up to 25 more calendar days.
- Coordinated verification. All institutions in the chain trace and verify the transfer and contact the account owners involved, within the 30-day holding period.
- Release. The funds go back to the recipient when the hold lapses or the transfer is shown to be legitimate. They are returned to the sender’s institution instead if the recipient waives the claim in writing, or if the verification concludes the funds came from money muling, unlawful activity, a transfer with no economic purpose or a social engineering scheme.
Source: BSP Circular No. 1215 ↗ ·
While funds are held, the circular treats the amount as credited to the recipient’s account but not withdrawable. If no funds could be held, for example because they were already withdrawn, the verification still runs: within 30 calendar days, extendable for meritorious reasons up to 60 calendar days in total.
What the institution must tell you
The circular requires the institutions to notify the account owners whose accounts are affected, including the reasons for a hold and how a recipient can challenge it. On request, the sender’s institution must give the source account owner the transaction reference numbers, the receiving institutions involved and the dates and times of the transfers. After a release, both account owners must be told where the funds went and why.
A hold or release does not end your other remedies: the circular says the decision is “without prejudice to any other legal remedy available to the aggrieved party”.
Example: GCash’s own terms
GCash’s terms of use show how one e-wallet applies these powers. They allow GCash to hold an amount under investigation for a potentially fraudulent transaction “for up to thirty (30) calendar days” from the date it determines or is notified of the activity, or longer if reasonably necessary, and to credit proven fraud proceeds to the affected user. For an incorrect debit or credit that is not your fault, the terms ask for a report through the GCash Help Center within 15 business days of the transaction. Step-by-step reporting in the app is on Report a GCash scam.
Source: GCash Terms and Conditions, sections 18 and 23 ↗ ·
Warning GCash’s report form warns that filing false information in bad faith that leads to funds being held can be a crime of malicious reporting under AFASA. Report only a transfer you did not authorize or were tricked into.
If the institution does not resolve it
Keep the complaint reference from your bank or e-wallet. If its action or response does not settle the case, escalate to the BSP through BSP Online Buddy (BOB), as explained on BSP bank complaint.