Republic of the Philippines

ANTI-MONEY LAUNDERING COUNCIL

The Philippines’ Financial Intelligence Unit

I. Introduction

1
The Anti-Money Laundering Council (AMLC) was created pursuant to Republic Act
(RA) No. 9160, otherwise known as the “Anti-Money Laundering Act of 2001” (AMLA), to
protect the integrity and confidentiality of bank accounts and to ensure that the Philippines
shall not be used as a money laundering site for the proceeds of any unlawful activity.

The AMLC is the Philippines’ Financial Intelligence Unit (FIU) tasked to implement
the AMLA, as amended by RA Nos. 9194, 10167, and 10365, as well RA No. 10168,
otherwise known as the “Terrorism Financing Prevention and Suppression Act of 2012”.

Vision

To be a world-class financial intelligence unit that will help establish and maintain an
internationally compliant and effective anti-money laundering regime which will provide the
Filipino people with a sound, dynamic, and strong financial system in an environment
conducive to the promotion of social justice, political stability, and sustainable economic
growth. Towards this goal, the AMLC shall, without fear or favor, investigate and cause the
prosecution of money laundering offenses.

Mission

1
http://www.amlc.gov.ph/about-us

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To protect and preserve the integrity and confidentiality of bank accounts.

To ensure that the Philippines shall not be used as a money laundering site for proceeds of
any unlawful activity.

To extend cooperation in transnational investigation and prosecution of persons involved in

money laundering activities, wherever committed.

The AMLC Seal

The new AMLC seal features a stylized young Philippine eagle rendered in blue, red,
and yellow strokes. Characterized by strength and a keen vision, the Philippine eagle is
known for its ability to fly high and soar toward its goal. The main elements encase the text
inscriptions “AMLC” and “Anti-Money Laundering Council.” These elements have no
enclosure, signifying openness, freedom, impartiality, and objectivity of the AMLC.

a. Principal Elements

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 1. The Philippine eagle, the Philippines’ national bird, is the world’s largest eagle
and is a symbol of strength, courage, and determination in the pursuit of the
mandate; independence from outside forces/pressure; honesty in public service;
guardianship against attempts to make the Philippines a money-laundering site;
and the eagle eye for clarity of vision.
2. Three strokes represent the three pillars or virtues of the AMLC — independence,
integrity, and cooperation.
3. The Council’s acronym, “AMLC,” is given prominence to make the agency more
familiar to the public.

b. Colors

1. The blue stroke represents security, trust, reliability, and responsibility.

2. The red stroke symbolizes passion, action, strength, courage, and determination.
3. The yellow stroke symbolizes optimism, wisdom, and logic.
4. The black font color of the text “AMLC” denotes strength and authority.

c. Font or Typeface

BlairMdITC TT, medium, for “AMLC,” characterized by a streamlined, solid,

and balanced line, suggesting AMLC’s way of performing its mandate.

II. Background

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 a. History

b. Countries Involved

c. Purpose

d. Who Constitute

III. Contributions / Accomplishments

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 a. Awards

The AMLC has been awarded the Best Egmont Case Award (BECA) last 2016. This was
granted by the Egmont Group of Financial Intelligence Units. The BECA highlights the
vital role of the AMLC in the investigation process, which entails tracing, freezing, and
seizing the proceeds involved in the scam cited in its submitted case.

The Egmont Group, a global organization of 151 financial intelligence units (FIUs), seeks
to provide a forum for international cooperation in the fight against money laundering and
terrorism financing, especially in the areas of information exchange, training, and sharing
of expertise. The group created BECA in 2011 to recognize successful cases from which
member-FIUs can learn and to appreciate real-life examples of cases that have been
successfully prosecuted and publicly reported. 2

b. Tangible results

The AMLC has frozen P8 billion worth of assets, of which P3 billion has been forfeited,
over the past 20 years. This was confirmed by AMLC Secretariat Executive Director
Matthew David wherein he relayed to the Senate committee that the financial intelligence
unit has frozen approximately P8 billion worth of assets, including bank accounts, real
estate properties and personal properties over the past 20 years.

From January to June of 2022, David also reported to the Senate committee that the
AMLC filed 21 cases for issuance of freeze order, application for bank inquiry and
petition for civil forfeiture, as well as nine applications for bank inquiry. He said illegal
drug deals topped the list in terms of predicate offenses, with freeze orders amounting to
P401.97 million and $6,999. Also frozen were real estate property worth P36.21 million,
motor vehicles worth P7.73 million and other monetary assets worth P8.07 million.
Civil forfeiture proceedings linked to illegal drugs were also initiated, amounting to P65.4
million, including real properties worth P5.56 million, and motor vehicles worth P1.43
million.

2
Accessed at http://www.amlc.gov.ph/16-news-and-announcements/67-four-years-after-its-launch-in-2011-the-prestigious-best-egmont-
case-award-goes-to-the-philippines-anti-money-laundering-council

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 This was followed by terrorism financing, as bank accounts amounting to P2.15 million
were under freeze orders as well as civil forfeiture of assets covering P585,518.

Meanwhile, civil forfeiture amounting to P138,836, as well as fraud with P330,702 were
filed in relation to corruption cases of public officers and employees.

For 2021 until the first half of 2022, the AMLC has undertaken enforcement actions,
including reduced assessments on 25 banks, one casino, and one money services business
operator amounting to P22.06 million. The AMLC has also issued 85 warning letters, 32
compliance letters and 39 notarized compliance commitments.3

c. Progress towards exclusion from the gray list

The Financial Action Task Force (FATF), a Paris-based watchdog, again added the
Philippines to its “gray list”, or the roster of countries under increased monitoring, after
failing to address strategic deficiencies to counter money laundering as well as terrorist
and proliferation financing.

The efforts of the country failed to satisfy the FATF-International Cooperation Review
Group (ICRG) in addressing the technical deficiencies raised by the Asia Pacific Group
(APG) on money laundering under its mutual evaluation review in October 2019.

Landing on the FATF’s gray list means higher interest rates and processing fees, as well as
more layers of scrutiny from financial institutions.4

As a sign of progress, the AMLC has expressed confidence that the Philippines will be
removed from the FATF “gray list” by January 2023, as it works with other government
agencies to plug gaps in implementing measures against “dirty money” and terrorism
financing.

3
Accessed at https://www.philstar.com/business/2022/10/04/2214039/amlc-freezes-assets-worth-p8-billion
4
Accessed at https://www.rappler.com/business/philippines-lands-global-dirty-money-watchdog-gray-list-again/

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 The FATF noted that the Philippines has developed and implemented guidance on
delisting and the unfreezing of assets for targeted financial sanctions related to
proliferation financing, reducing the action plan items to 17 from 18 that need to be
addressed.

Countries that are under increased monitoring of the FATF like the Philippines are
required to submit reports every January, May and September to show the progress done
in implementing anti-money laundering and counter-terrorism financing measures.

The action points of the FATF include increasing the employees of the AMLC’s Financial
Intelligence Analysis Group and proving an improvement in the timeline of sharing
intelligence information with law enforcement agencies.

The government also needs to tighten measures to ensure that foreign currency
declarations are followed in major sea and airports. The country is looking to prove to the
FATF that it has increased the number of foreign currency declarations, as well as
confiscations when the Customs rules are violated.

To accomplish these deliverables, he said the AMLC is working with the Bureau of
Customs, the Philippine National Police, and the Armed Forces of the Philippines, among
others. The AMLC has also mentioned that no further legislation is needed for the
Philippines to be able to exit from the FATF’s gray list.5

The FATF has recently recognized that the Philippines has made good progress in
addressing the technical compliance deficiencies identified in its report.

The Philippines’ latest mutual evaluation report (MER) is deemed “largely compliant” on
two of 37 recommendations based on the 18 action plans necessary to delist the
Philippines from the grey list.6
d. Reportorial contributions to recent controversies

5
Accessed at https://www.bworldonline.com/top-stories/2021/10/25/405905/phl-on-track-to-exit-gray-list-by-2023/
6
Accessed at https://mb.com.ph/2022/08/28/fatf-cites-ph-progress-on-fight-vs-dirty-money/

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 The Binay family’s bank accounts are among the 242 ordered frozen by the Court of
Appeals as petitioned by the AMLC. The Binay bank accounts frozen totaled P600
million.7

In another case, investigators of the AMLC concluded that bank accounts of Sen. Ramon
Revilla Jr. and his family, as well as those of Janet Lim-Napoles and her pseudo-NGOs,
were possibly involved in a scheme to launder the controversial “pork barrel” funds.

Revilla was said to have gotten P224.5 million in “commissions and rebates” from 2006 to
2010 from his Priority Development Assistance Fund projects that were awarded to five
Napoles NGOs. The commissions and rebates were reportedly coursed through Cambe.8

In another recent case, The AMLC imposed a freeze order on the property and funds,
including related accounts of National Democratic Front (NDF) leader Luis Jalandoni and
nine other individuals after the Anti-Terrorism Council tagged them as terrorists. The
AMLC said the freeze order will take effect immediately against Jalandoni, also known as
Louie/Ka Rosendo/Bernie/Lopez/Bern/ Munding /Cinco/Fernando /Andres, a member of
the Communist Party of the Philippines' (CPP) Central Committee, National Democratic
Front of the Philippines, and founder of the designated terrorist organization Christian for
National Liberation (CNL).9

7
Accessed at https://opinion.inquirer.net/84918/where-did-binay-wealth-come-from
8
Accessed at https://ph.news.yahoo.com/blogs/the-inbox/how-amlc-found-possible-laundering-of-revillas-pdaf-101340503.html
9
Accessed at https://www.manilatimes.net/2022/06/16/news/national/amlc-freezes-accounts-of-jalandoni-9-others/1847533

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IV. Relevance

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V. Related Laws Passed

1. R.A. NO. 9160

ANTI-MONEY LAUNDERING ACT OF 2001
September 29, 2001

Purpose:

To protect and preserve the integrity and confidentiality of bank accounts and to
ensure that the Philippines shall not be used as a money laundering site for the
proceeds of any unlawful activity. Consistent with its foreign policy, the State shall
extend cooperation in transnational investigations and prosecutions of persons
involved in money laundering activities wherever committed.

Highlight:

 This act covers provisions on the following:

 Money Laundering Offense
 Jurisdiction of Money Laundering Cases.
 Prosecution of Money Laundering
 Creation of Anti-Money Laundering Council (AMLC)
 Creation of a Secretariat
 Prevention of Money Laundering; Customer Identification
Requirements and Record Keeping
 Authority to Freeze
 Authority to Inquire into Bank Deposits
 Forfeiture Provisions

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  Mutual Assistance among States
 Penal Provisions
 Congressional Oversight Committee

2. R.A. No. 10168

THE TERRORISM FINANCING PREVENTION AND SUPPRESSION ACT OF
2012
June 18, 2012

Purpose:

To protect life, liberty, and property from acts of terrorism and to condemn terrorism
and those who support and finance it and to recognize it as inimical and dangerous to
national security and the welfare of the people, and to make the financing of terrorism
a crime against the Filipino people, against humanity, and against the law of nations.

Highlight:

 This act covers provisions on the following:

 Financing of Terrorism
 Attempt or Conspiracy to Commit the Crimes of Financing of
Terrorism and Dealing with Property or Funds of Designated Persons
 Accomplice
 Accessory
 Prohibition Against Dealing with Property or Funds of Designated
Persons
 Offense by a Juridical Person, Corporate Body or Alien
 Authority to Investigate Financing of Terrorism
 Authority to Freeze
 Exceptions for Investigative Requirements
 Humanitarian Exemptions
 Appropriation and Use of Funds of Public Attorney’s Office (PAO)

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  Publication of Designation
 Duty of the Covered Institutions and/or Relevant Government
Agencies Upon Receipt of the Freeze Order
 Predicate Offense to Money Laundering
 Civil Forfeiture, Extra-Territorial Application of this Act
 Extradition, Applicability of the Revised Penal Code
3. Executive Order No. 68
ADOPTION OF THE NATIONAL ANTI-MONEY LAUNDERING AND
COUNTERING THE FINANCING OF TERRORISM (AML/CFT) STRATEGY
AND CREATION OF THE NATIONAL AML/CFT COORDINATING
COMMITTEE
November 12, 2018

Purpose:

To ensure that the Philippines shall not be used as a money laundering site for the
proceeds of any unlawful activities.

Highlight:

 This order covers provisions on the following:

 Adoption of the National Anti-Money Laundering and Countering the
Financing of Terrorism Strategy
 Creating of a National AML/CFT Coordinating Committee
 Functions of the National AML/CFT Coordinating Committee
 Members of the National AML/CFT Coordinating Committee
 Secretariat
 Sub-Committees
 Review and Updating of the NACS

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4. Anti – Money Laundering Council
GUIDELINES FOR ACCREDITATION OF INSTITUTIONAL TRAINING
PROVIDERS ON AMLA, AS AMENDED, ITS IRR, TFPSA, AND OTHER
ISSUANCES OF THE ANTI-MONEY LAUNDERING COUNCIL, ANTI-MONEY
LAUNDERING COUNCIL
December 2018

Purpose:

To facilitate compliance of Covered Persons with the requirement of the IRR and to
achieve the objectives under the NACS, guidelines for the accreditation of
Institutional Training Providers are hereby issued.

Highlight:

 This issuance covers provisions on the following:

 Definition of Institutional Training Providers
 Qualifications/Disqualifications
 Application Procedure
 Additional guidelines for Accredited Institutional Training Providers
 Additional guidelines for In-house Training
 Additional guidelines for E-learning Providers
 Reportorial Requirements
 Continuing Requirements
 Target Participants
 Learning Content

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 Validity of Accreditation
 Annual Review
 Reservations

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