Philippine gaming regulator PAGCOR has issued a directive requiring the country’s casino operators and support service providers to immediately review their existing risk models and update their anti-money laundering (AML) and counter-terrorism financing (CTF) frameworks in line with the findings of its latest Casino Sector Risk Assessment.
The review, spanning 2021 to 2024, found that the nation’s casino sector was at “High Risk” for money laundering and “Medium Risk” for terrorism financing. In an advisory dated 13 July 2026, PAGCOR determined that operators were therefore expected to strengthen their risk framework, customer due diligence, transaction monitoring and suspicious transaction reporting.
Operators must, it added, provide the Casino Sector Risk Assessment to all directors, management, compliance officers, internal audit teams and frontline staff, and review existing risk models to determine if existing controls are sufficient. Improvements are expected in any areas deemed to be deficient.
Specifically, the risk assessment identifies both land-based casinos and electronic gaming operations as being vulnerable to such risks because they deal with large cash transactions and do not always have full visibility of customers’ source of funds – particularly in the VIP junket space.
It states, “The sector remains materially exposed to proceeds from serious predicate crimes, particularly where high-value transactions, cash activity, VIP or junket relationships, electronic gaming, remote channels or weak controls are present.”
On the heightened risk posed by the VIP segment – particularly in regard to land-based operations – the assessment continues, “High-value play, intermediated customer relationships, foreign patronage and complex settlement arrangements can reduce transparency over the source of funds, beneficial ownership and the true person controlling the activity.”
Illicit funds entering the casino sector are typically the result of drug trafficking, fraud, estafa, cybercrime, environmental offenses and tax evasion, PAGCOR noted.
It added that although casinos are not considered to be a primary channel for terrorism financing funds – and no confirmed cases involving PAGCOR-licensed entities have been identified during the assessment – they may still be exposed when funds that moved through banks, remittance channels, e-money, money service businesses, informal transfer systems or intermediaries later enter casino activity.
As per PAGCOR’s advisory, all licensed casinos and gaming service providers must update their internal AML/CTF risk assessments to align with PAGCOR’s sector-wide findings, with boards, executives, compliance officers and internal auditors expected to play a more active role in overseeing AML compliance.
Operators are also expected to strengthen their customer due diligence, transaction monitoring, sanctions screening, source-of-funds verification and suspicious transaction reporting.
Likewise, gaming platform and support service providers are expected to ensure their systems support the AML obligations of casino operators and minimize opportunities to conceal transaction trails.
PAGCOR said it will conduct examinations to specifically assess how well operators have implemented the new risk assessment, with inadequate compliance potentially resulting in administrative sanctions.
RelatedPosts
