PAGCOR Calls on Casino Operators to Reinforce AML/CFT Controls

PAGCOR Issues New AML/CFT Guidance for Licensed Casinos

The directive was issued through an advisory formally releasing PAGCOR's Second Casino Sector AML/CFT Risk Assessment, which evaluates the Philippine gaming industry over the 2021–2024 period.

Under the advisory, all PAGCOR-licensed operators are expected to review and update their institutional AML/CFT risk assessments, integrate the report's findings into their compliance frameworks, and determine whether their existing policies, procedures and internal controls remain appropriate for their respective risk profiles.

PAGCOR also confirmed that future supervisory reviews will consider the extent to which gaming operators have implemented the recommendations contained in the assessment.

The regulator further noted that, where appropriate, a failure to adequately consider the report's findings could be taken into account during supervisory and enforcement actions.

Philippine Casino Sector Classified as High Risk for Money Laundering

According to the assessment, the Philippine casino industry continues to face a high risk of money laundering and a medium-high risk of terrorism financing.

PAGCOR explained that casinos remain vulnerable because of several characteristics common to the sector, including:

• High-value financial transactions.
• Cash-intensive gaming operations.
• VIP gaming programs.
• Junket operations.
• Electronic gaming platforms.
• Remote gaming channels.
• Cross-border customer activity.

Although the regulator stated that no confirmed terrorism financing cases involving PAGCOR-regulated casinos were identified during the assessment period, it emphasized that operators should continue strengthening preventive controls.

Enhanced Due Diligence Recommended

PAGCOR urged casino operators to reinforce customer due diligence measures by strengthening:

• Beneficial ownership verification.
• Source-of-funds and source-of-wealth reviews.
• Politically exposed person (PEP) screening.
• Sanctions screening procedures.

The regulator also called for stronger oversight of VIP customers, junket relationships, remote gaming activities and other high-value customer segments, while increasing monitoring of unusual buy-ins, rapid redemptions, minimal-play activity and the movement of funds across multiple gaming channels.

In addition, PAGCOR encouraged licensees to improve customer-level data aggregation to facilitate the detection of suspicious transaction patterns and enable more effective reconstruction of customer activity when required.

Separate Focus on Terrorism Financing Risks

The regulator advised casino operators to treat terrorism financing as a distinct component of their institutional risk assessments rather than simply as an extension of money laundering risk.

To strengthen compliance capabilities, PAGCOR recommended additional AML/CFT training for frontline employees, cage personnel, surveillance teams, electronic gaming staff and compliance officers to improve the identification of lower-value or indirect indicators of terrorism financing.

Supervisory Priorities Will Target Higher-Risk Operations

PAGCOR said the findings of the assessment will also shape its supervisory strategy going forward, with greater attention given to:

• Higher-risk licensees.
• VIP gaming operations.
• Junket arrangements.
• Cash and chip movements.
• Electronic gaming operations.
• Regulatory reporting quality.

The regulator emphasized that operators should ensure their AML/CFT controls are effective in practice rather than relying solely on documented policies and procedures.

PAGCOR also clarified that regulated entities providing services to licensed gaming operators, even if they do not directly conduct gaming activities, should use the latest assessment as guidance when developing group-wide risk assessments and designing internal controls that support the AML/CFT obligations of PAGCOR licensees.

The updated guidance reflects PAGCOR's continued efforts to strengthen regulatory oversight and align the Philippine gaming industry with international AML/CFT standards as the country's regulated casino and electronic gaming sectors continue to expand.