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The Philippine Amusement and Gaming Corporation (PAGCOR) has placed greater emphasis on its probity assessment process as the Philippines works to maintain anti-money-laundering reforms that contributed to its removal from the Financial Action Task Force (FATF) grey list in February 2025.
According to a July 10 analysis by legal and regulatory advisory firm Arden Consult, these reviews now carry increased significance as the country seeks to preserve confidence in its financial and gaming sectors while preparing for another international assessment scheduled for 2027.
Arden Consult, which advises companies operating in areas including gaming, fintech, digital assets and technology, explained that PAGCOR uses probity checks to determine whether companies and the individuals connected to them are suitable to receive gaming licenses, authorizations or accreditations. The reviews can extend beyond corporate entities and include directors, officers, major shareholders and beneficial owners. Investors holding at least 20% of an entity generally fall within the scope of these assessments.
“Probity checks are not bureaucracy for its own sake,” Patricia De Guzman from Arden Consult wrote, describing them as part of the Philippines’ compliance with international anti-money-laundering and counter-terrorism financing standards.
Greater Focus Following FATF Grey List Exit
The Philippines spent several years under increased international scrutiny while listed by FATF as a jurisdiction subject to enhanced monitoring. Arden noted that the country’s eventual removal from the grey list marked an important development for its financial system and reinforced the value of the controls implemented during that period.
Arden Consult further explained the role these reviews play within the broader regulatory framework.
“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.”
When FATF announced the Philippines’ removal from the list, it cited substantial improvements to the country’s anti-money-laundering and counter-terrorism financing framework. Among the factors highlighted were stronger safeguards related to casino junkets and evidence that authorities were effectively supervising sectors that include casinos.
“The Philippines is now actively combating the risk of dirty money flowing through casinos in the country,” FATF President Elisa de Anda Madrazo said after the decision, according to Asia Gaming Brief.
Although the country left the grey list, FATF requested continued cooperation with the Asia/Pacific Group on Money Laundering to ensure reforms remain in place. The next evaluation, expected in 2027, will examine whether those measures continue to operate effectively.
What Triggers a PAGCOR Probity Check?
PAGCOR may initiate a probity review in several situations. New license applications, renewals and significant corporate changes can all prompt scrutiny. Changes involving directors, officers, ownership structures or beneficial ownership are among the most common triggers.
Arden also noted that adverse reports, suspicions of misconduct and routine annual reviews may result in additional assessments.
Licensed operators must inform PAGCOR in writing within 15 calendar days whenever changes occur involving board members, corporate officers or ownership arrangements. Failure to meet this reporting requirement may itself attract regulatory attention.
The reviews can involve a broad examination of an applicant’s background. Depending on the level assigned, investigators may review identity information, addresses, financial records, credit history, regulatory compliance records, criminal histories and screening results against international anti-money-laundering and terrorism watchlists.
Three-Tier Assessment System and Disclosure Requirements
PAGCOR applies a risk-based framework consisting of three levels of review. Lower-risk applicants undergo Level 1 assessments conducted by PAGCOR’s Investigation and Verification Department. Medium- and high-risk cases proceed through Level 2 and Level 3 reviews, which are handled by accredited third-party providers. Applicants bear the costs of these external assessments, although PAGCOR requires fees to remain transparent and reasonable.
The regulator determines the appropriate review level through its own risk assessment process. Business size, ownership complexity, geographic exposure, financial standing and compliance history all influence the classification. PAGCOR also retains authority to increase the review level if additional risk factors emerge during the process.
Most reviews conclude within 30 calendar days after all required documentation has been submitted, according to Arden Consult. Delays often result from incomplete filings, although more complex cases may require additional time. The firm warned that inaccurate disclosures can lead to serious consequences.