PAGCOR Tightens Casino AML Rules After High-Risk Assessment

The Philippine Amusement and Gaming Corporation (PAGCOR) has instructed licensed gaming operators to reassess their anti-money laundering and counter-terrorism financing safeguards after its latest sector-wide review identified significant financial crime exposure across the casino industry.

PAGCOR circulated the directive through an advisory issued on July 13, following board approval of its second Casino Sector Anti-Money Laundering and Counter-Terrorism Financing Risk Assessment on June 25. The assessment examined conditions between 2021 and 2024 and classified money-laundering risk in the Philippine casino sector as high.

The regulator assigned a medium-high rating to terrorism-financing risk. Its review found no confirmed terrorism-financing case involving PAGCOR-regulated casino operations during the assessment period.

“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,” the assessment stated.

PAGCOR linked the overall risk level to cash and value-conversion activity, exposure to higher-risk customers and intermediaries, operational complexity across different gaming channels and uneven implementation of safeguards.

Operators Told to Reassess Customer and Transaction Controls

Licensed operators must incorporate the assessment’s findings into their institutional AML/CFT risk assessments and determine whether their existing policies and controls adequately reflect their individual exposure.

PAGCOR called for stronger customer due diligence and enhanced due diligence where higher risks arise. Measures identified by the regulator include beneficial ownership verification, reviews of source of funds and source of wealth, politically exposed person screening and sanctions checks.

Operators should also apply closer scrutiny to VIP, junket, remote and other high-value customer relationships. PAGCOR highlighted transaction patterns that may warrant greater attention, including unusual buy-ins, rapid redemptions, minimal-play activity and movement of funds between different channels.

The regulator also identified customer-level data aggregation as an area requiring improvement. Better integration of customer information can help operators identify suspicious patterns and reconstruct account or transaction activity when necessary.

Land-based casinos received a high inherent vulnerability classification because of factors including their scale, heavy use of cash, foreign patronage and involvement with VIP and junket activity.

Electronic gaming received a medium-high rating. PAGCOR pointed to the segment’s rapid expansion, broad customer base, frequent transactions, non-face-to-face activity and differences in system maturity between operators.

Larger licensees generally maintain stronger systems, according to the assessment, while smaller venues may have weaknesses in consolidating customer data, monitoring activity across channels and reconstructing transactions within an appropriate timeframe.

Terrorism-Financing Risks Require Separate Attention

PAGCOR directed operators to assess terrorism financing as a distinct risk within their institutional frameworks. The agency wants licensees to account specifically for the characteristics of terrorism-financing activity when designing controls and evaluating exposure.

Additional staff training forms another part of the regulator’s recommendations. PAGCOR identified frontline employees, cage personnel, surveillance teams, electronic gaming staff and compliance personnel as groups that may need further preparation to recognize lower-value or indirect indicators associated with terrorism financing.

The findings will also influence PAGCOR’s future supervisory priorities. Regulatory scrutiny will focus more closely on higher-risk licensees, VIP and junket arrangements, movements involving cash and chips, electronic gaming activities and the quality of regulatory reporting.

PAGCOR stressed that operators need to demonstrate that their compliance measures work effectively in actual operations rather than relying solely on documented policies.

The agency warned licensees that future supervisory reviews may consider how thoroughly they incorporated the new assessment into their risk-management and compliance programs. According to Asia Gaming Brief, a failure to “reasonably consider” its findings could influence subsequent supervisory or enforcement decisions.

Service Providers Also Expected to Use Risk Findings

PAGCOR extended guidance from the assessment beyond entities that directly conduct gaming operations.

Other regulated businesses that provide services to licensed gaming operators should use the recommendations “as guidance in their group-wide risk assessments and in designing controls that support the AML/CFT obligations of Pagcor-licensed gaming operators,” the agency stated.

The latest assessment places responsibility on individual operators to compare their existing safeguards against the risks identified during the 2021–2024 review period and address weaknesses relevant to their businesses.

PAGCOR’s instructions cover customer checks, transaction monitoring, higher-risk relationships and the practical effectiveness of compliance systems. The regulator will use the assessment to shape its own oversight while evaluating how licensees respond to identified vulnerabilities across both land-based and electronic gaming operations.