PAGCOR Orders Casino AML Reset After High-Risk Review
The Philippine Amusement and Gaming Corporation, in an advisory dated July 13, 2026, directed licensed casinos and gaming service providers to review their anti-money laundering and counter-terrorism financing controls after its second Casino Sector AML/CTF Risk Assessment.
The assessment covers 2021 to 2024 and rates the sector’s money laundering risk as High and terrorism financing risk as Medium-High.
PAGCOR’s findings require operators to update their institutional risk assessments according to their own products, customers, payment channels and geographic exposure. Boards and senior management must document their oversight, set deadlines for remediation and arrange independent testing of corrective measures.
Licensees must also circulate the assessment among directors, executives, compliance teams, internal auditors and frontline employees. PAGCOR plans to examine how operators apply the findings, with administrative sanctions possible where compliance remains inadequate.
VIP and Cash Activity Drive Exposure
Land-based casinos remain the most exposed segment, PAGCOR found, because of large transaction values, cash use, foreign customers and VIP or junket relationships.
Electronic gaming received a Medium-High vulnerability rating due to its rapid growth, remote access, frequent transactions and differences in system maturity between operators.
High-value play and intermediary-led relationships, the regulator said, can obscure the source of funds, beneficial ownership and who controls an account. Other warning signs include large buy-ins followed by minimal play, rapid redemption, repeated cash-outs, unusual chip transfers and payments to people with no clear economic connection to the customer.
Money laundering exposure in the sector stems from proceeds tied to drug trafficking, fraud, cybercrime, corruption, environmental offences, tax crimes and human trafficking, according to PAGCOR. Funds may pass through banks, e-money issuers, remittance firms, virtual asset service providers or corporate entities before they reach casino accounts.
Operators must strengthen customer and beneficial-owner checks, politically exposed person controls, sanctions screening, source-of-funds reviews and cross-channel transaction monitoring. Closer oversight of VIP, junket, remote and high-value relationships is also expected, along with better suspicious transaction report records and escalation procedures.
The regulator found no confirmed terrorism financing case linked to PAGCOR-regulated casino operations during the assessment period. However, it warned that casinos can receive funds after they move through banks, remittance services, e-money channels or informal transfer networks. Checks that focus only on high-value transactions may therefore miss smaller, repeated or indirect patterns.
💡TGJ Take
This is an operational test, not another policy update for the compliance folder. Operators now need customer-level monitoring across cages, tables, electronic gaming and payment channels, which may expose data gaps at smaller properties first. VIP and junket controls will draw the closest scrutiny because PAGCOR has tied them directly to unclear fund ownership and settlement flows. Suppliers that support transaction monitoring or customer records should expect licensees to demand clearer audit trails before the next examination.
