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The Philippines Now a “Major Money-Laundering Country”

By Brad Gershel & Marjorie J. Peerce on March 7, 2017
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The Philippines has been identified by the U.S. as a “major money-laundering country” in the 2017 International Narcotics Control Strategy Report (“Report”), published this month. The country now joins 87 others as one “whose financial institutions engage in currency transactions involving significant amounts of proceeds from international narcotics trafficking.” See 22 U.S.C. § 2291(e)(7).

By way of background, the Report is a legislatively mandated, annual assessment of the efforts of foreign governments to reduce illicit narcotics production, trafficking and use, as well as their efforts to combat money laundering and terrorist financing. Each year, U.S. officials from agencies with AML responsibilities assess the pervasiveness of money laundering in these countries, which includes steps taken (or not taken) to address financial crime and money laundering, and measures to strengthen law enforcement and prosecutorial capabilities.

In regard to the Philippines, the Report concludes that “[m]oney laundering is a serious concern due to [the] international narcotics trade, high degree of corruption among government officials, trafficking in persons, and the high volume of remittances from Filipinos living abroad … [c]riminal groups use the Philippine banking system, commercial enterprises, and particularly casinos, to transfer drug and other illicit proceeds from the Philippines to offshore accounts.”

As support for the heightened designation, the Report cites to the Philippines’ “significant gaps” in its efforts to combat money laundering. For one, the country’s bank secrecy provisions “are among the World’s strictest.” In most cases, Filipino investigators must first obtain a court order to access bank records; such an order is dependent upon a sufficient showing of an ongoing “predicate crime” and neither cybercrime nor tax evasion is classified as such. Despite the country’s effort to centralize AML efforts via the Anti-Money Laundering Council (“AMCL”), since its founding in 2001, cooperation among law enforcement agencies remains “insufficient” and to date, only 49 money laundering cases have been filed. Indeed, Reuters reports that the number of prosecutions and convictions stemming from the 49 has been “virtually nil.”

The Report’s conclusions are an unwelcome development for the Philippines. Though any outcome remains to be seen, their label as a major money-laundering hub may serve as a catalyst for offshore firms to “de-risk” by cutting its ties with local banks and intermediaries.

If you would like to remain updated on these issues, please click here to subscribe to Money Laundering Watch.

Brad Gershel

gershelb@ballardspahr.com | 646.346.8034 | view full bio

Brad focuses his practice on representing individuals and companies in white-collar criminal and civil matters, including government inquiries and internal investigations. Brad has significant experience in a wide range of enforcement, criminal and regulatory matters, including…

gershelb@ballardspahr.com | 646.346.8034 | view full bio

Brad focuses his practice on representing individuals and companies in white-collar criminal and civil matters, including government inquiries and internal investigations. Brad has significant experience in a wide range of enforcement, criminal and regulatory matters, including those relating to fraud, foreign bribery, and public corruption. His experience spans multiple state and federal law enforcement agencies, including the DOJ, FINRA, SEC, and New York County District Attorney’s Office. Additionally, he has represented clients in criminal and regulatory investigations for alleged violations of the False Claims Act and the Foreign Corrupt Practices Act.

Read more about Brad GershelEmail
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Marjorie J. Peerce

peercem@ballardspahr.com | 646.346.8039 | view full bio

Margie is a litigator who, in her more than 30 years of practice, has handled matters across the criminal and regulatory spectrum including white collar criminal defense, regulatory matters, and complex civil litigation. Her work includes…

peercem@ballardspahr.com | 646.346.8039 | view full bio

Margie is a litigator who, in her more than 30 years of practice, has handled matters across the criminal and regulatory spectrum including white collar criminal defense, regulatory matters, and complex civil litigation. Her work includes cases arising from alleged violations of the Internal Revenue Code, the FCPA, the BSA, and a broad range of fraud investigations.

She represents numerous individuals in several AML/BSA investigations by the U.S. Department of Justice and has represented a financial institution in a matter implicating BSA issues. She has handled matters involving Suspicious Activity Reports and Currency Transaction Reports and structuring-related offenses and she has represented individuals accused of money laundering offenses. Margie has also handled a significant number of matters with the SEC, FINRA, and the CFTC.

Read more about Marjorie J. PeerceEmail
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  • Posted in:
    Tax
  • Blog:
    Money Laundering Watch
  • Organization:
    Ballard Spahr LLP
  • Article: View Original Source

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