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FlowPay, a Philippine digital wallet service, detects unusual cross-border transfers by a merchant client. In the ordinary course of its AML program, FlowPay’s AML compliance officer reviews the transactions and files a Suspicious Transaction Report (STR) with the Anti-Money Laundering Council (AMLC). The merchant sues FlowPay for privacy violations, alleging disclosure of confidential information to the AMLC. FlowPay relies on Safe Harbor immunity under the Anti-Money Laundering Act. (a) Identify the controlling doctrine and the essential elements of Safe Harbor. (b) Apply the doctrine to the facts: does FlowPay’s disclosure satisfy the good-faith requirement and the statutory conditions? (c) If FlowPay had filed the STR knowing the information was false, or if the information was disclosed to persons not authorized by the AMLA, would Safe Harbor still apply? Distinguish between good faith, gross negligence, and malice in this context.