PAGCOR has ordered licensed casino operators and gaming support service providers to immediately review and strengthen their anti-money-laundering and counter-terrorism-financing controls after a sector assessment found Philippine casinos remained a high-risk environment for money laundering and a medium-high-risk environment for terrorism financing.
According to the agency’s Casino Sector AML/CTF Risk Assessment 2021-2024, the industry remains a priority for supervision because it handles substantial value, relies heavily on cash and high-value play, and serves a broad customer base that includes VIP and junket-linked players as well as electronic and remote gaming users.
The assessment said casinos can be used to place, move, disguise or integrate illicit funds if controls are not effective in practice. It noted that money can be converted into chips, credits or other gaming value, moved through play or account activity, and later redeemed in a way that may appear to be the proceeds of legitimate gaming.
Land-based casinos were flagged as especially exposed because of their scale, cash intensity, high-value play, foreign patronage and VIP or junket activity. Electronic gaming was also described as more complex to supervise, with wider customer reach, higher transaction frequency and more moving parts across venues, systems and platforms.
The report also said offshore-style activity has contracted sharply, but left residual risk because of foreign-facing, non-face-to-face and intermediary-based characteristics. It added that casinos are not a primary terrorism-financing channel, but can still be exposed when funds that passed through banks, remittance channels, e-money platforms or other intermediaries later enter casino activity.
The assessment assigned the sector an overall money-laundering risk rating of High, and said the underlying vulnerability remains High while the quality of AML controls is only Medium, leaving residual vulnerability at Medium-High. It also said the terrorism-financing risk is Medium-High, and that no confirmed TF case involving PAGCOR-regulated casino operations was identified during the review period.
PAGCOR said the most serious money-laundering drivers include high-value transactions, cash activity, VIP and junket relationships, electronic gaming, remote channels and weak controls. It also said illicit funds entering the sector commonly originate from drug trafficking, fraud, estafa, cybercrime, environmental offences and tax evasion.
The agency said the legal and supervisory framework has improved, with more structured customer due diligence, governance and policies, but implementation is uneven across licensees. Smaller venues may still lack customer-level aggregation, cross-channel monitoring, good data quality and the ability to reconstruct activity quickly, while frontline practice, suspicious transaction reporting and recordkeeping do not always match the formal programme on paper.
CDC Gaming reported that PAGCOR’s advisory told operators to strengthen their risk frameworks, customer due diligence, transaction monitoring and suspicious transaction reporting. Yogonet said the directive also covered gaming support service providers, and that operators must update internal risk assessments, identify weaknesses, improve source-of-funds and source-of-wealth checks, sanctions screening and staff training, and circulate the assessment to boards, senior management, compliance officers, internal audit teams and frontline staff.
PAGCOR warned that inadequate compliance could lead to administrative sanctions, and said it will conduct examinations to test how effectively operators have implemented the updated risk assessment.
