Implementation of COSP Resolution 10/6 on Enhancing the Use of Beneficial Ownership Information to Strengthen Asset Recovery
Beneficial ownership reform in the Philippines
An adaptive and user-informed approach to beneficial ownership transparency implementation
The Philippines’ case provides a valuable example of how domestic priorities, such as combating corruption, strengthening investigations, and preventing economic setbacks, combined with strong leadership, international assessments, and the integration of BOT into procurement law, can drive momentum for BO reforms designed to fulfill clear domestic policy goals.
Policy drivers of beneficial ownership transparency reform
The Philippines has grappled with IFFs, with an estimated USD 9.3 billion leaving the country annually between 2002 and 2012. In 2000, the Financial Action Task Force (FATF) placed the Philippines on its risk lists, prompting reforms including the creation of the Anti-Money Laundering Council (AMLC), the passage of the Anti-Money Laundering Act (AMLA) in 2001 the passage of the Terrorism Financing Suppression Act in 2012, the Casino Law, and succeeding amendments to various laws. It remained under scrutiny due to persistent weaknesses in BOT, particularly around corporate anonymity. The Philippines exited the FATF grey list in February 2025 after it was placed there in 2021.
The urgent need to exit the FATF grey list was a key driver of beneficial ownership (BO) reform. The Philippines sought to restore foreign investment and international credibility, both of which had been severely affected by the greylisting. In addition, the greylisting negatively impacted the economy and its citizens. Remittances are a vital source of income for many Filipino households, and greylisting led to increased bank fees for sending money home. This created a financial burden on ordinary citizens. These economic consequences were a primary reason behind the strong national incentive to exit the grey list and accelerate BOT reforms. The FATF’s decision to greylist the Philippines in 2021 triggered a country-level 18-point action plan to address strategic anti-money-laundering/combating the financing of terrorism deficiencies. Among the key priorities was improving transparency of BO, with particular emphasis on the timeliness, adequacy and accuracy of BO information.
A second driver was the growing demand from domestic law enforcement agencies, such as the AMLC, Bureau of Internal Revenue (BIR) and National Bureau of Investigation (NBI), for reliable BO data. Financial intelligence units and investigative authorities increasingly rely on timely BO data to support asset recovery and combat tax fraud, human trafficking and organized crime.
A third driver was the institutional leadership of the Securities and Exchange Commission (SEC), which prioritized BO data as a critical tool for combating financial crime. Championed by its dedicated anti-money-laundering office, the SEC advanced reforms to ensure that BO information would be used not just for regulatory compliance but also for proactive investigations. As part of this effort, the Commission formalized 24 data-sharing agreements (DSAs) with key government agencies to enable secure, timely access to BO information for investigative purposes. [3]
A fourth driver was the Philippines’ engagement in global transparency initiatives, such as the Extractive Industries Transparency Initiative (EITI) and the Open Government Partnership, which elevated BOT as a national reform priority. This momentum was further reinforced by targeted technical assistance from Open Ownership, UNODC and the Asian Development Bank, which helped build institutional capacity and align reforms with international standards.
Philippines’ approach to implementing beneficial ownership transparency reforms
Legal and institutional reform
The Philippines has implemented several legal reforms to enhance its BOT regime, with a focus on promoting compliance. Since 2019, the SEC has issued a series of Memorandum Circulars (MCs) requiring corporations to disclose BO information: SEC MC No. 15 (2019), SEC MC No. 30 (2020), SEC MC No. 01 (2021) and SEC MC No. 10 (2022). These regulations align with FATF Recommendation 24 and require mandatory BO declarations based on FATF definitions. The SEC is currently in the process of conducting public consultations for a consolidated BO policy.
To enforce compliance:
- Administrative fines were significantly increased, up to PHP 2 million (approximately USD 37,000).
- Nonmonetary sanctions, such as the disqualification of directors and the revocation of corporate registration, were introduced.
A positive approach to incentivizing compliance
To incentivize positive compliance, the Philippines launched an innovative amnesty program to help companies fix reporting issues and make doing business easier. The program allowed non-compliant, suspended or revoked entities to update their filings – including BO disclosures – at reduced fixed fees, avoiding additional penalties. This proactive measure encouraged voluntary compliance and regulatory updating, with over 70,000 companies participating. The initiative improved administrative efficiency and supported the national goal of enhancing transparency and moving out of the FATF grey list.
Stakeholder outreach and strengthening partnerships on beneficial ownership data use
Recognizing the importance of building awareness and knowledge around the collection and use of BO information, the SEC launched extensive stakeholder outreach and capacity-building activities. These targeted both companies with an obligation to submit a BO declaration and data users, such as AMLC, BIR and procurement authorities. Key outreach initiatives included:
- Training programs for law enforcement and competent authorities on accessing and verifying BO data
- Focus group discussions with companies to better understand compliance challenges
- Public education campaigns, including an infomercial in both English and Tagalog, that were disseminated via SEC social media platforms
- Online and in-person seminars to clarify BO reporting obligations
- Capacity-building for the SEC’s regional extension offices to support public-facing implementation
The SEC has signed at least 24 DSAs with enforcement and oversight bodies to ensure secure and timely access to BO data. They also aim to foster closer collaboration between the corporate registry and major data users. Over time, these DSAs have served as a foundation for institutional partnerships that are now central to driving policy reforms and enhancing the use of BO information across government. This strategic approach to partnership building and awareness raising was intentional. As Atty. Daniel Luis Macalino, Assistant Director of the SEC, noted: “When we started, we were the only ones who knew what BOT was, which wasn’t a good thing. We wanted everyone to be an expert in BO and its use in their own field.”
Embedding beneficial ownership in procurement reform
In July 2024, the Philippines enacted the New Government Procurement Act (Republic Act No. 12009), which mandates BO disclosure by all bidders and contractors and public access to this data. The law also integrates BO checks into the government’s electronic procurement platforms to prevent collusion, identify shell companies and promote accountability.
Allowing public access to extractive companies’ beneficial ownership data
The Philippines EITI has been maintaining the only publicly accessible BO portal in the country, containing extractive companies’ BO data obtained through a voluntary reporting mechanism under EITI. In September 2025, the Philippines enacted the Enhanced Fiscal Regime for Large-Scale Metallic Mining Act (Republic Act No. 12253), which includes BO in the list of extractive-related data that could be made publicly available.
Outcomes and policy impact
The Philippines is beginning to see early results from its adaptive, user-informed and homegrown approach to BO reforms:
Removal from the Financial Action Task Force grey list and European Union high-risk list
In February 2025, the FATF officially removed the Philippines from its grey list, having determined that the country had met all requirements under its action plan. FATF commended the Philippines for establishing one of the world’s strongest BO regulatory frameworks. Similarly, in June 2025, the European Union (EU) removed the Philippines from its high-risk list. Increased awareness and cross-sector engagement with BO reforms led to broader institutional buy-in and contributed to the Philippines’ successful removal from the FATF grey list.
The greylisting had real economic consequences. For example, the remittance fees that are vital for many low-income Filipino families will potentially reduce transaction costs for remittances following the country’s removal from the list, easing the financial burden on households and restoring trust in the Philippine financial system.
Effective use of beneficial ownership data in investigations
BO data from the SEC is now routinely used by Philippine enforcement and regulatory agencies to uncover the real individuals behind legal entities, especially in cases involving money-laundering, investment fraud and the misuse of corporate vehicles for illicit activities.
BO data supports case development by helping analysts trace control structures, link entities and identify incorporators and beneficial owners involved in complex criminal schemes. Notable examples include:
- Human trafficking and electoral fraud: A foreign national who ran for mayor was identified as the beneficial owner of multiple shell companies involved in illegal online gambling and human trafficking.
- VAT refund scam: BO data exposed one individual behind 100 companies used to fraudulently claim tax refunds, enabling a successful prosecution. (See Box 1.)
- Flood control corruption scandal: Criminal charges for graft, malversation of public funds and violation of procurement laws were filed against government officials as well as beneficial owners of company contractors involved in “ghost” or substandard flood control projects.
Improved compliance
The amnesty program and other reforms by the Philippine government led to a significant improvement in compliance. According to an SEC advisory, over 70,000 of the approximately 600,000 registered firms applied for the amnesty as a result of these and other reforms, the SEC reported a significant improvement in compliance rates – from 26 per cent in 2021 to 69 per cent in 2024 – for the BO disclosure of active and registered companies.
Box 1. Using beneficial ownership data to uncover a PHP 50 billion tax fraud scheme
A major VAT tax refund scam, allegedly costing the Philippine government an estimated PHP 50 billion (approximately USD 886 million) in unpaid taxes, was recently uncovered by authorities. The NBI charged a syndicate led by a businessperson alleged to have orchestrated a long-running scheme involving at least 103 shell companies, alongside dozens more still under investigation. The syndicate was suspected of using these dummy corporations to issue fake invoices and receipts, thereby fraudulently claiming VAT refunds.
A major VAT tax refund scam, allegedly costing the Philippine government an estimated PHP 50 billion (approximately USD 886 million) in unpaid taxes, was recently uncovered by authorities. The NBI charged a syndicate led by a businessperson alleged to have orchestrated a long-running scheme involving at least 103 shell companies, alongside dozens more still under investigation. The syndicate was suspected of using these dummy corporations to issue fake invoices and receipts, thereby fraudulently claiming VAT refunds.
This case highlights how the use of BO data can be used in tackling tax evasion crimes. The BIR and NBI were able to match ownership records across numerous shell firms, exposing a single individual at the center of the fraud.
Conclusion and next steps
The Philippines’ experience demonstrates how strong leadership, a locally adapted reform strategy and a focus on positive incentives and cross-sector engagement can meaningfully advance BOT. Rather than applying a one-size-fits-all model, the SEC tailored its approach to national priorities, combining legal reforms with public awareness campaigns, interagency collaboration and non-punitive measures, such as the BO amnesty program. This case demonstrates that building shared ownership of reforms and enabling the practical application of BO data, particularly in investigations and procurement, can significantly enhance implementation and yield tangible impact in the real world.
Looking ahead, three critical next steps will be key to sustaining momentum:
- Improve access to BO data and ensure that it remains relevant, accurate and up-to-date through systems that are designed based on user needs.
- Promote the use of BO data by providing training, guidance and resources to data users and DSA partners.
- Continue improving the BO disclosure regime and communicating the benefits for implementation through monitoring and evaluation, and development of measurement tools and strategies.