The move to ban Philippine Offshore Gaming Operators (POGOs) by President Ferdinand Marcos Jr. is a step in the right direction, but more will be necessary for the Philippines to get off the FATF grey list, says a Moody’s analyst.
The analyst notes that further efforts should be placed on managing non-financial institutions, such as casino operators, with continued regulatory oversight.
“Across the region and in fact across the world, traditionally the corporate organizations are not as regulated as the financial institutions […] A lot of these organizations are the ones serving some of the high-risk clients,” analyst Choon Hong Chua told Bloomberg.
Of particular concern has been the post-ban transition of POGOs into other types of illegal underground operations, such as scam centers.

Regionally, scam centers have become a top priority for governments, aiming to eliminate human trafficking, money laundering and illegal online gaming operations.
This has been particularly prevalent in regions such as Myanmar, but the increased enforcement actions in the Philippines following the POGO ban have seen continued cases of underground operations. These involve different scales and venues – oftentimes running out of gated communities or even resorts.
The Philippines has set a lofty goal of being removed from the Financial Action Task Force’s grey list within this year.
The country has substantially completed its action plan, consisting of 18 items that have led to increased monitoring since June 2021. An on-site visit is planned for early this year by the FATF’s Asia/Pacific Joint Group on Money Laundering.
But illegal online gaming is not the only concern for exiting the grey list, with concerns over AML/CFT controls over casino junkets and risk-based supervision for designated non-financial businesses and professions (DNFBPs) also key areas of reform requested by the FATF.
Additionally, improving law enforcement access to beneficial ownership (BO) information; increased use of financial intelligence and enhancing money laundering investigations and prosecutions; measures within the non-profit organization (NPO) sector and enhanced financial sanctions frameworks for terrorism financing and proliferation financing are also of primary concern.
Numerous government departments and officials have pledged to make the exit from the FATF list a top priority, which would have a significant ripple effect on how the nation’s financial flows are treated internationally.
Given the large amount of remittances from outside the nation, this could prove highly beneficial for individuals and companies based abroad and needing to transfer money to the Philippines.
Back in May, 2024, before the country’s mutual evaluation by the FATF in October, Choon Hong Chua had indicated that Manila was “on track” to exit the grey list, noting “it is clear the country is committed to strengthening anti-money laundering and counter-financing of terrorism controls and has implemented more stringent requirements”.
Chua now suggests that the Philippines should leverage changes in legislation and enforcement to tackle the evolving role that underground operators (particularly former POGOs) take in order to continue their illegal activities.