Casinos handed by Pagcor six-month ultimatum on corruption red flags
By Derco Rosal
At A Glance
- State-run gaming regulator Philippine Amusement and Gaming Corp. (Pagcor) has ordered licensed gaming operators and their service providers to integrate specific red flag indicators into their compliance systems within six months.
The Philippine Amusement and Gaming Corp. (Pagcor) ordered casino operators to integrate specific corruption-linked red flags into their compliance systems, escalating its clampdown on dirty money moving through the country’s gaming hubs.
Licensed operators and their service providers have six months to build the indicators into their monitoring systems, according to a May 28 advisory from the state-run regulator’s anti-money laundering supervision and enforcement department.
Pagcor said the new mandate is designed to establish risk-based triggers specifically targeting the abuse of casinos by corrupt actors.
Under the new guidelines, individuals in government or those with close ties to public officials represent a primary risk category. Pagcor is requiring casinos to cross-reference patrons against media reports, public records, and internal databases to spot public officials, government employees, public-works contractors, or anyone performing prominent public functions. The rule extends to individuals closely related or connected to those figures.
This indicator should guide casinos in their risk-based approach to customer due diligence (CDD), enhanced due diligence (EDD), monitoring, and suspicious transaction reporting (STR) considerations.
Pagcor clarified that red flags are only warning indicators and not a final finding of money laundering, but they should prompt casinos to exercise greater vigilance and escalate the matter to determine whether a transaction is suspicious.
Beyond identity-based risks, Pagcor is also targeting suspicious betting behavior, specifically flagging “large chip cash-outs or sustained ‘winning’ patterns despite brief or low-intensity play, suggesting statistically implausible outcomes.”
This includes minimal-play scenarios where the total turnover is only a small fraction of the initial chip purchase.
Philippine Amusement and Gaming Corp. is also tightening oversight on coordinated activities, instructing operators to assess group play risks—such as cases where one person funds or controls multiple patrons, or where a financier distributes chips or cash to several players.
Further, the regulator is reviewing how clearly patrons disclose the origin of their wealth. It said it is a warning sign if a customer fails or repeatedly delays providing source of funds (SOF) or source of wealth (SOW) information beyond vague descriptions, such as repeatedly identifying themselves only as a businessman or investor even after further details are requested by the casino.
Failure to adopt these measures could be “treated as evidence of weak AML controls and may increase liability in later enforcement proceedings.”
Gaming operators are expected to complete a review and approve necessary updates to their AML policies “within three months from issuance” and fully integrate the red flag indicators into their monitoring rules and alert scenarios “within six months from issuance.”