President Marcos has ordered the urgent implementation of the national anti-money laundering, counter-terrorism financing and counter-proliferation financing strategy 2023-2027 in order to meet international standards and enable the Philippines to exit the "grey list."

Through Memorandum Circular No. 37, Marcos made the directive and called on concerned agencies to support efforts in fighting money laundering and terrorism financing risk assessment.

“In accordance with their respective mandate, all concerned departments, agencies, bureaus, and instrumentalities of the National Government, including government-owned or –controlled corporations (GOCCs) are directed, and all the local government units (LGUs) are encouraged, to immediately and timely formulate and implement relevant strategies, plans and programs to implement NACS 2023-2027 [National AML/TF/CPF Strategy], particularly its Strategic Objective No. 1,” the memorandum read.

The circular, signed by Executive Secretary Lucas Bersamin, also tasked all agency heads to review and assess their deliverables under the International Co-operation Review Group (ICRG) Action Plan, assign focal persons to complete the deliverables by Nov. 30, 2023, and establish a mechanism to monitor the progress of each deliverable.

The National AML/CFT Coordinating Committee (NACC) Secretariat was directed to furnish all concerned agencies of the respective deliverables and office targets under the ICRG Action Plans and other relevant documents including pertinent NACC resolutions.

The memorandum also directed the AMLC to submit to the office of the Executive Secretary, through the Office of the Deputy Executive Secretary for Legal Affairs, a comprehensive report on the status of the implementation of the NACS 2023-2027, particularly the Strategic Objective 1, on or before Dec. 8, 2023.

In October 2019, the Financial Action Task Force (FATF) placed the Philippines under a 12-month observation period in terms of its technical compliance with international anti-money laundering /counter terrorism financing standards.

In June 2021, the country was included in the FATF list of "jurisdiction under increased monitoring" or the "grey list" for its failure to show tangible and positive progress in addressing all key recommended actions.

Under Executive Order No. 33, the NACS 2023-2027 was adopted by the government to ensure that the Philippines exits the "grey list."

As of September 2023, the Philippines still has eight, out of the 18 ICRG action plans, that it must address to exit the "grey list" by January next year.

“The urgent implementation of the NACS 2023-2027, particularly its Strategic Objective 1, will intensify and expedite efforts to address deficiencies identified by the FATF ICRG,” the memo said, adding another Mutual Evaluation will be conducted in 2026.

“Under international standards on combating ML/TF, countries are required to identify, assess and understand the money laundering and terrorism financing risk for the country, and are mandated, based on said assessment, to apply a risk-based approach to ensure that measures to prevent or mitigate ML/TF are commensurate with the risks identified,” the circular noted.