The Migrant Workers and Overseas Filipinos Act of 1995,  as Amended by Republic Act No. 10022 (No.2) 29 September 2010 No.10-013 We refer Members to the previous Circular issued in June 2010 on the amendments to the Filipino Migrant Workers Act of 1995 (the Amended Migrant Workers Act - AMWA) that became law on 8 March 2010. The International Group (IG) understands that the relevant government agencies have now finalised the necessary Omnibus Implementing Rules and Regulations (IRR), and additional Insurance Commission "Guidelines" (ICG) dealing specifically with the compulsory insurance provisions of the Act, that have now been published. However, the ICG will not apply to the deployment of seafarers until the Philippine Overseas Employment Administration (POEA) issues a Governing Board Resolution (GBR) and Memorandum Circular (MC). The GBR and MC are not expected to be in force until the third or fourth week of October. Implications for Members We refer Members to the concerns of the IG as outlined in the previous circular in relation to the compulsory insurance provisions within the final text of the AMWA, in particular that Club cover does not extend to all of the "minimum" compulsory insurance requirements of the AMWA, nor does it provide cover directly to seafarers. As an example, and not withstanding the issue of policy deductibles, the AMWA creates an obligation to arrange insurance cover in respect of "money claims" brought by an employee, and the scope of such a claim could involve disputed or unpaid wages not covered by P&I. Similarly, the obligation to arrange insurance cover does not contain any exception in relation to liabilities specifically excluded from P&I, such as those arising from acts of terrorism or war risks. It is also unlikely that P&I cover could indemnify a Member's obligations under the Act to provide "subsistence allowance benefit" of  "at least"  USD 100 per month, for a maximum of 6 months. The IG has conti