Malacañang issued Memorandum Circular (MC) No. 37 on Monday, directing the urgent implementation of the government’s National Anti-Money Laundering, Counter-Terrorism Financing and Counter-Proliferation Financing Strategy 2023-2027 and calling 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 ICRG Action Plan, assign focal persons to complete the deliverables by 30 November 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 International Co-operation Review Group (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 8 December 2023.

The AMLC will also serve as the lead agency of the ML/TF NRA Working Group and formulate and issue guidelines for the effective implementation of the circular.

The council may also call government department, agency, including GOCCs and also invite LGUs and the private sector to provide assistance in attaining its objectives subject to current laws and rules.

The memorandum circular’s implementation will be funded through the respective appropriations of concerned government agencies and the corporate operating budgets of concerned GOCCs.

– [ ] Under EO 33, the National AML/CTF/CPF Strategy (NACS) 2023-2027 was adopted to enable the Philippines to address the ICRG Action Plans, ensure that the country exits the FATC Grey List and improve its AML/CTF/CPF regime.

The order also provides that the AMLC Secretariat will also serve as the Secretariat of the NACC, and shall provide technical and administrative support to the NACC.

As of September 2023, out of 18 ICRG Actions Plans, the Philippines must still address eight plans for it to exit the FATF Grey List by January 2024.

“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.” | PND

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