PAGCOR AML warning raises compliance expectations, experts say
The Philippine Amusement and Gaming Corporation’s (PAGCOR) latest anti-money laundering (AML) risk assessment is expected to reshape how licensed gaming operators approach compliance, with industry experts saying operators must move beyond routine regulatory obligations towards continuous, risk-based oversight.
Speaking exclusively with SiGMA News, iGaming consultant Jonas Diego and Atty. Russell Stanley Geronimo, founder of Geronimo Law, said PAGCOR’s classification of the casino sector as being at high risk for money laundering will require operators to strengthen governance, modernise compliance systems and place greater focus on electronic gaming and VIP and junket operations.
“Licensed operators will tighten AML frameworks, especially in electronic gaming and VIP/junket segments,” Diego said. “This means stricter customer due diligence, enhanced monitoring of high-value transactions, and closer scrutiny of intermediaries.”
Diego’s comments follow PAGCOR’s directive requiring casino operators and gaming service providers to incorporate the findings of its latest Casino Sector Anti-Money Laundering and Counter-Terrorism Financing Risk Assessment into their institutional risk assessments and compliance frameworks.
The gaming regulator’s review, shared via an advisory released on 13 July, covering 2021 to 2024, found the casino sector to be at high risk for money laundering and medium-high risk for terrorism financing. Land-based casinos were identified as particularly vulnerable because of their reliance on cash transactions, foreign patronage and exposure to VIP and junket business, while electronic gaming was assessed as medium-high risk due to rapid growth, high transaction volumes and non-face-to-face customer interactions.
Compliance moves to the boardroom
According to Atty. Russell Stanley Geronimo, founder of Geronimo Law, PAGCOR’s latest assessment represents more than another compliance requirement.
“The high-risk assessment forces licensed operators to move away from check-the-box compliance toward dynamic, risk-based oversight,” Geronimo said.
He said operators should revisit their institutional risk frameworks to specifically address foreign VIP customers, cash-intensive transactions and complex settlement arrangements.
“Ultimately, this shifts AML compliance from a routine back-office function directly into board-level accountability and continuous supervisory alignment,” Geronimo explained.
PAGCOR has instructed operators to review customer due diligence procedures, source-of-funds verification, transaction monitoring and oversight of VIP, junket, remote gaming and other high-value customer relationships.
The regulator also warned that operators failing to reasonably incorporate the sector-wide assessment into their compliance programmes could face greater supervisory attention and enforcement action.
Technology seen as key to stronger controls
Both experts believe technology will play a central role as operators seek to meet stricter regulatory expectations without disrupting business operations.
Geronimo said operators should focus on automating compliance processes rather than relying solely on manual reviews. “To satisfy regulator expectations without stalling floor operations, operators should prioritise automating real-time transaction monitoring and customer due diligence across all gaming channels,” he said.
Diego also pointed to artificial intelligence as one of the most practical ways to strengthen compliance while improving efficiency.
“Use AI-driven monitoring to reduce manual workload,” he said.
He added that operators should prioritise resources where risks are highest. “Focus resources on VIP/junket and high-volume e-gaming, rather than spreading thin across low-risk segments.”
A unified compliance platform would also help firms respond more quickly to suspicious activity, according to Diego.
A change in mindset
Beyond technology and enhanced monitoring, Diego believes the industry’s biggest challenge will be changing how operators view compliance.
“I believe that a change in mindset will also be necessary,” he said. “All too often, risk management and compliance come after the fact rather than part of a proactive strategy.”
He argued that PAGCOR‘s latest directive raises the strategic importance of AML programmes. “Given PAGCOR’s direction, compliance is shifting from a regulatory obligation to a competitive differentiator,” Diego said.
“Operators who can prove themselves will gain smoother regulatory relations and reputational advantage, which will be crucial for long-term sustainable success.”
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