The Politics of the Anti-Money Laundering Act of the Philippines: An Assessment of the Republic Act 9160 and 9194

Bing Baltazar C. Brillo


The article is about the influence of international organizations on the policymaking process. It contends that the procedure followed in enacting Republic Act 9160 otherwise known as the Anti-Money Laundering Act (AMLA) and its amendment Republic Act 9194, as a financial regulation policy is atypical. The enactment of the policy exhibited an unusual pattern in the policymaking process. The AMLA was largely exogenously driven and was enacted mainly by virtue of external pressure. The policy was passed principally to satisfy the demand of the Financial Action Task Force (FATF) to conform to the global standard, to beat the deadline, to avoid the imposition of countermeasures, and to be removed from the list of Non-Cooperative Countries and Territories (NCCT). To avoid sanctions, the Philippine Government made extraordinary efforts to ensure compliance, such as the collaboration shown by the executive agencies, the swift action taken by the legislators, the circumvention of rules and procedures, and the manipulation of the Bicameral Conference Committee (BCC). The steps taken speak of the tremendous influence an international organization can have on the policy actors and the lawmaking proceedings; how an external entity would dictate to institutional actors and regulate the policymaking process.

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