Gorriceta Africa Cauton & Saavedra | View firm profile
By: Atty. Mark Gorriceta & Atty. Edrian M. Apaya
October 3, 2025 – The Philippines’ battle against dirty money is far from over. Although the country had been removed from the Financial Action Task Force (FATF) “grey list” in February 2025, unrestricted gambling remains a major source of corruption and money laundering.
When the FATF placed the Philippines under increased monitoring in June 2021, online and offshore gambling operations were flagged as key channels for laundering funds — as seen in high transaction volumes and deficiencies in regulatory mechanisms designed to prevent illicit financial activities.
Expressing alarm over financial risks, particularly those linked to online gambling, the Bangko Sentral ng Pilipinas (BSP) cautioned that gambling-related transactions could expose the country to heightened money laundering threats, potentially landing the country back on the international “dirty money” watch list, a setback that would carry serious reputational and economic consequences.
In response, the BSP proposed stricter rules to curb illegal gambling-related payments and online operations, including:
– Stringent account holder verification. Only individuals and entities meeting rigid KYC (know your customer) standards are qualified to be Online Gambling Transaction Account (OGTA) holders.
Government officials and employees are prohibited from having OGTAs.
– Dedicated OGTAs. Online gambling payments must pass through distinct, traceable accounts that are monitored and kept apart from regular funds.
– Licensing and oversight. Only licensed individuals, corporations and other private entities are allowed to operate as Online Gambling Operators (OGOs). Payment service providers must also ensure that they engage only with OGOs in good standing, compliant with government registration, permits, and other requirements. To this end, payment service providers must conduct enhanced due diligence prior to enabling OGTA linkages.
– Enhanced account verification and controls. Payment service providers must use robust onboarding, biometric identity verification, continuous monitoring, and prompt reporting of suspicious activity.
– Service limitations. Gambling transfers are capped at 20 percent of the user’s average daily balance, with transactions being allowed only within a six-hour daily window. A 24-hour cooling-off period applies after heavy use, and lending or credit services are strictly prohibited.
Additionally, through Memorandum M-2025-029, the BSP mandates all e-wallets, payment applications, and other BSP-supervised institutions to unlink their platforms from online gambling sites within 48 hours.
This suspension remains in effect pending the finalization of the comprehensive policy on online gambling payment services. These measures are intended not only to address anti-money laundering (AML) weaknesses, but also to strengthen consumer protection and mitigate social concerns such as addiction risk, harm to financially vulnerable persons, and fraud.
Despite recent reforms, however, the Philippines continues to grapple with gambling-related scandals that expose persistent weaknesses and significant vulnerabilities in governance and financial oversight.
The scandal involving government officials and substandard or nonexistent flood control projects have reignited debates on offshore gaming and gambling platforms and the many ways in which they can be used as vehicles for corruption, political compromise, and illicit financial flows.
Investigations have pointed to the use of POGO-linked entities and casino channels to launder bribe money, disguise kickbacks, and even facilitate proceeds from organized crimes. These highlight the convergence between gambling and other high-risk activities, from public sector corruption to transnational fraud.
The link between gambling, corruption, and financial crime, coupled with the growing sophistication of fraud tactics means that AML rules cannot be treated as mere compliance checklists; they must continuously adapt, evolve, be actively and consistently enforced.
While recent measures have curtailed many offshore gaming operations, unresolved questions remain over past illicit flows, the effectiveness of suspicious transaction reporting, and transparency in casino and gaming financials.
Staying off the FATF grey list will require more than new rules on paper. It demands uncompromising enforcement, transparent reporting by casinos and payment providers, stronger cross-border cooperation, and zero tolerance for corruption.
The Philippines can only consolidate its AML progress and protect its global reputation by proving that its gambling industry operates within a clean, transparent, and trusted financial system.
This article was also published under The Manila Time You may find the full article here: How the BSP is curbing money laundering | The Manila Times