Ex-COA chief on how VP's bank flows may be understated

MANILA, Philippines — Former Commission on Audit commissioner Heidi Mendoza disputed Vice President Sara Duterte's claims that bank transaction records linked to her were “bloated,” saying existing reports may actually understate total fund movements.

“Bago mo sabihing bloated… meron pa ngang hindi pumasok sa sistema,” Mendoza said in an interview on web show "Facts First" on Sunday, April 26. (Before you say it’s bloated… there are even some that weren’t included in the system.)

Mendoza explained that anti-money laundering monitoring systems typically flag transactions above P500,000, but smaller or staggered withdrawals can fall outside automatic reporting thresholds.

“Kung inutay-utay mo iyan… marami pang hindi na-cover sa monitoring,” she said, noting that balances remaining in accounts may not appear in transaction reports submitted to authorities. (If you do it gradually… there are still many that were not covered by the monitoring.)

Duterte had issued statements following last week's impeachment hearings of the House Committee on Justice which scrutinized her supposed bank transactions amounting to P6.7 billion. Her camp claimed that the flows tended to be "bloated" as they reflected the aggregate values and not the bank balance.

What AMLC data may miss

Mendoza said the figures seen in congressional hearings are based on transaction reports from the Anti-Money Laundering Council, not full bank records, which remain protected under bank secrecy laws.

“Yung bank account balance… hindi natin mapapasok iyan… kaya ang pwede lang nating tingnan ay yung AMLC report,” she said. (The bank acount balance can't be looked at, so only the AMLC report could be examined.)

She added that once transactions are broken into smaller amounts or mixed with other funds, they become harder to trace through simple one-to-one matching.

“Hindi iyan one-to-one correspondence… kapag naghalo-halo na iyan, hindi mo puwedeng i-match,” she said. (That is not a one-to-one correspondence.. if they are mixed, it is not possible to match.)

Mendoza also said individuals handling accounts are often advised on how transactions are monitored, including by bank managers familiar with compliance systems.

“Usually ang nag-a-advise sa kanila ay taga-banko rin… alam nila kung paano dapat igalaw iyon,” she said. (Usually they are advised from within the banks... they'd know how to move the funds.)

She, however, stressed that she was explaining possible mechanisms based on audit experience, not making a direct allegation in the current case.

Mendoza also pointed to the use of debit and credit memos within the same bank as a potential area of concern if internal controls are weak, saying such arrangements could allow transfers between accounts if there is “connivance” and delayed oversight.

Call for deeper audit

Given these limitations, Mendoza said a more comprehensive review is needed beyond transaction reports.

“Kung ako ang auditor, dito dapat papasok ang COA. Dapat joint investigation ito,” she said. (If I were the auditor in the case, this is where COA enters. This should be a joint investigation.)

She said full tracing would require access to complete bank statements and reconciliation processes, which are not always immediately available to auditors.

Mendoza’s remarks come amid scrutiny of financial disclosures presented during House hearings on the impeachment complaint against Duterte.