Moody’s Warns Philippines to Maintain Vigilance on Crypto and iGaming Despite Delisting from High-Risk Watchlists

Despite the Philippines’ recent removal from key international money laundering watchlists, Moody’s has issued a warning that the country must remain vigilant—particularly regarding risks associated with cryptocurrency and online gambling sectors.

The advisory comes after the European Commission delisted the Philippines from its roster of high-risk jurisdictions, a move that followed the country’s removal from the Financial Action Task Force’s (FATF) gray list in 2023. That gray list designation, which had subjected the Philippines to more than three years of heightened scrutiny, was lifted after the country addressed 18 regulatory shortcomings identified by the FATF in 2021.

The developments are being widely welcomed by investors and regulators alike, as they are expected to strengthen the Philippines’ financial credibility and enhance access to global capital markets—especially in the European Union.

However, credit rating agency Moody’s cautioned that the improved status does not signal an end to risk. According to Xiao Chen, associate director at Moody’s, the country still faces significant vulnerabilities in certain sectors.

“Continued vigilance will be essential, especially in online gaming and cryptocurrency, to ensure that residual risks are effectively managed,” Chen said. He acknowledged that reforms had taken place in the aftermath of the Philippine Offshore Gaming Operators (POGO) crackdown, but noted that “sustained monitoring and enforcement are necessary to prevent backsliding.”

The Philippine government appears acutely aware of the evolving landscape. Bangko Sentral ng Pilipinas (BSP) Governor Eli Remolona Jr., who also serves as chairman of the Anti-Money Laundering Council (AMLC), described the nation’s current efforts as an “arms race” against increasingly sophisticated threats.

Remolona pointed to the rapid advancement of digital technologies as a driver of new financial crime vectors, emphasizing that regulators must continuously adapt enforcement mechanisms to keep pace. “Government institutions are in an arms race against evolving illicit finance threats,” he stated.

The Philippines has a long history of engagement with global anti-money laundering standards. It was blacklisted by the FATF back in 2002 due to deficiencies in its legal and enforcement frameworks but was removed in 2005 after implementing key reforms.

In 2021, the FATF again flagged the country—this time placing it on the gray list—triggering enhanced monitoring. That designation had tangible consequences, including the potential for delayed or more expensive cross-border financial transactions, especially in critical sectors such as remittances and broader financial services.

By 2023, the Philippines had successfully addressed the issues raised and was subsequently removed from the FATF’s list. The European Commission’s recent move aligns with the FATF’s earlier decision and is seen as a further endorsement of the Philippines’ regulatory progress.

Still, both Moody’s and other analysts stress that delisting should not be interpreted as a free pass. Crypto-related businesses and online gambling remain high-risk sectors that continue to draw global regulatory scrutiny. Analysts note that the EU and FATF will likely maintain close observation, even post-delisting.

“While there have been improvements in the post-POGO landscape,” said Chen, “residual risks remain.” The message is clear: the Philippines may have passed a significant milestone, but the journey toward sustainable financial integrity is far from over. 

By fLEXI tEAM