Philippine gaming regulator PAGCOR has tightened its probity check rules since the country was removed last year from the Financial Action Task Force’s “grey list” of jurisdictions under increased monitoring, tasked with keeping the gaming industry credible, according to Arden Consult.
In a new resource article published Friday, the specialist gaming law firm detailed PAGCOR’s probity check framework, how it is triggered and why the process has become more important than ever for a nation keen to enhance its credibility on the global stage.
“Probity checks are not bureaucracy for its own sake. They are part of the Philippines’ commitment to global anti-money-laundering standards set by the Financial Action Task Force (FATF),” Arden said.
“FATF Recommendation 28 requires regulators to keep criminals and their associates out of the ownership and management of casinos, and PAGCOR is the authority responsible for enforcing that in the gaming sector.
“The stakes became especially clear during the period the Philippines spent on the FATF ‘grey list,’ when the country faced heightened international scrutiny. Following sustained reforms, the Philippines was removed from the grey list in February 2025, a milestone that strengthened confidence in the financial system. Probity checks are one of the main tools PAGCOR uses to protect that hard-won progress and keep the industry credible.”
Under the new PAGCOR framework, probity checks are triggered whenever a person or company applies for a new or renewed license, or when there is an intervening event such as a change in the board of directors, corporate officers, ownership or beneficial ownership.Adverse reports, suspicions of wrongdoing and routine annual reviews can also prompt a check.
Licensed entities are required to notify PAGCOR in writing within 15 calendar days of any change to their board, officer, or ownership, Arden points out, and missing the window can itself raise questions.
Probity checks – which can review everything from identity and address to credit and financial history and even screening against international anti-money-laundering and terrorism watchlists – comprise three tiers of intensity.
Minimum (Level 1), for low-risk applicants, is carried out by PAGCOR’s Investigation and Verification Department (IVD), while Intermediate (Level 2) for medium risk and Enhanced (Level 3) for high risk are carried out by accredited third-party probity checkers with costs borne by the applicant. PAGCOR keeps the system fair by requiring such fees stay transparent and reasonable, with accredited checkers not permitted to charge excessive or arbitrary prices for higher-level assessments.
Arden notes that each level builds on the one below, adding progressively deeper financial, criminal and fraud checks, and that the level is not something the applicant chooses.
“PAGCOR’s licensing department assigns it through a risk assessment that weighs your business size, ownership complexity, geographic exposure, financial standing, and compliance history. The regulator also retains full discretion to raise the level if new risk indicators emerge,” the resource outlines.
According to Arden, most probity checks are complete within 30 days of all documentation being submitted and incomplete information is the most common reason for delay.
But deliberately leaving documents out or providing misleading information can have greater consequences than a simple delay.
“It can be tempting to present the cleanest possible picture. Resist that instinct,” Arden states.
“Failing to submit required documents, providing inaccurate information or not cooperating within the timelines carries real consequences: a new application may be rejected or treated as withdrawn, an existing license may be suspended or revoked, and where fraud is involved, PAGCOR may pursue legal action. Full and accurate disclosure is almost always the safer path than a tidy story that later unravels.
It is also worth setting expectations about what a favorable result means. Passing a probity check is necessary but not sufficient. Your application must still satisfy all other regulatory requirements and receive final approval from the PAGCOR Board, so a clean check is an important step rather than the finish line.”
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