The Philippine Amusement and Gaming Corp (Pagcor), the country’s gaming regulator, has instructed casino operators to strengthen their anti-money laundering and countering the financing of terrorism (AML/CFT) frameworks after completing its latest sector-wide risk assessment.
The agency also warned that the industry’s controls must keep pace with risks linked to VIP gaming, junkets, electronic gaming and cross-border transactions.
The directive is contained in an advisory formally circulating Pagcor’s second casino sector AML/CFT risk assessment, covering the period from 2021 to 2024.
The regulator stated that all Pagcor-licensed gaming operators are expected to review and update their institutional AML/CFT risk assessments, incorporate the report’s findings into their compliance frameworks, and assess whether existing policies, procedures and controls remain appropriate for their risk profiles.
The advisory added that future supervisory activities would take into account the extent to which operators had incorporated the assessment’s findings into their risk management and compliance programmes.
Where appropriate, failure reasonably to consider the assessment could be factored into Pagcor’s supervisory and enforcement actions, it added.
The agency assessed the Philippine casino sector as facing a high money laundering risk and a medium-high terrorism financing risk.
It said casinos remained materially exposed to proceeds from serious crimes because of high-value transactions, cash-intensive operations, VIP and junket business, electronic gaming and remote channels, even though no confirmed terrorism-financing case involving a Pagcor-regulated casino was identified during the assessment period.
The regulator said operators should strengthen customer due diligence and enhanced due diligence measures, including beneficial ownership verification, source-of-funds and source-of-wealth reviews, politically exposed person screening, and sanctions checks.
Pagcor also called for enhanced oversight of VIP, junket, remote and other high-value customer relationships, alongside stronger monitoring of unusual buy-ins, rapid redemptions, minimal-play activity and cross-channel movement of funds.
It urged licensees to improve customer-level data aggregation so suspicious patterns could be detected more effectively and customer activity reconstructed when required.
For terrorism financing risks, Pagcor said operators should treat it as a distinct component of their institutional risk assessments rather than merely an extension of money laundering risk.
The regulator also urged additional staff training for frontline, cage, surveillance, electronic gaming and compliance personnel to improve detection of lower-value or indirect terrorism financing indicators.
Pagcor said the assessment would also guide its own supervisory priorities, with greater attention to higher-risk licensees, junket and VIP arrangements, cash and chip movements, electronic gaming operations and reporting quality.
The agency stated that operators should focus on ensuring controls are effective in practice, rather than relying solely on formal policies and procedures.
Other Pagcor-regulated entities that do not conduct gaming operations but provide services to licensed gaming operators, should use the latest recommendation “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.
