Philippine Casinos Hit With Stricter Controls on VIP Junket Operations

Philippine casinos face a high money laundering risk rating, with the sector remaining materially exposed to proceeds from serious predicate crimes. According to Pagcor, this elevated risk rating stems from a combination of a high-threat environment and medium-high vulnerability across the industry. The main drivers include cash-based transactions, high-risk clients and intermediaries, complex business operations, and exposure to serious criminal activities. Pagcor identified several crimes generating illicit funds seeking entry into the sector, including illegal drug trafficking, fraud, estafa, cybercrime, environmental offenses, and tax evasion. In fact, casinos also face a medium-high risk of terrorism financing.

Pagcor Orders Immediate Implementation of Casino Risk Assessment Findings

Following the enactment of Republic Act No. 10927, which designated casinos as covered persons under the Anti-Money Laundering Act, Pagcor conducted the Casino Sector Risk Assessment in 2018. The assessment aimed to determine casino vulnerability to money laundering and terrorist financing, identify potential improvements to the AML/CFT regime, and enhance casino operators’ understanding of these risks.

The assessment revealed that land-based casinos pose the highest risk to ML/TF, followed by internet-based casinos, with electronic gaming and poker licensees presenting the least risk. One factor exposing land-based casinos to high ML/TF risk was junket operations. The overall money laundering and terrorism financing risks associated with junket operations received a MEDIUM rating, based on criminal threat assessments, ML/TF vulnerabilities, and the financial or reputational impact of exploitation.

Junket operations face a MEDIUM level of criminal threat, with consequences rated as MODERATE for both stakeholders and the regulator. The financial impact proves substantial. From 2018 to 2020, junket operations contributed an average of more than 20% of total gross gaming revenue. In 2020, junkets provided PHP 21.76 billion or 22.03% of the PHP 98.80 billion GGR.

Pagcor deployed the Casino AML Risk Rating System to assess whether risk management policies, practices, and internal controls effectively prevent money laundering and terrorist financing.

Why VIP Junket Operations Present Critical Vulnerabilities

Junket operations create multiple layers of opacity that shield illicit financial flows from scrutiny. Casino operators maintain no contractual relationship with individual junket players, leaving them without visibility into player identities, individual contributions to collective front money pools, or the source and ultimate ownership of funds. According to the Financial Action Task Force, junket programs involve large amounts of money moving across borders through multiple casinos via third parties, with junket participants relying on operators to transfer funds to and from casinos.

The opacity extends beyond financial transactions. Arrangements between junket tour operators, players, and affiliated third parties remain deliberately obscure. Funds transfer from abroad to casino operators who deal exclusively with junket tour operators or their representatives, creating distance from the actual source. This structure helps junket players and third parties avoid scrutiny while facilitating money laundering.

Criminal infiltration presents another vulnerability. Junket tour operators extend credit to players and enforce gambling debts, which remain illegal to collect in mainland China. Violence and extra-judicial debt recovery methods increase the likelihood of organized criminal involvement. Foreign nationals comprised 95 per cent of junket players in Australia between April 2018 and March 2019.

How Philippine Casinos Must Strengthen Anti-Money Laundering Controls

Casinos operating under Philippine jurisdiction must file transaction reports when receiving cash from customers or processing payouts. Since being removed from the Financial Action Task Force gray list in early 2025, the Philippines maintains heightened oversight of high-risk sectors, with casinos, real estate, and import-export businesses facing close monitoring.

Republic Act No. 10927, enacted in 2017, brought casinos within the Anti-Money Laundering Act’s coverage. The Anti-Money Laundering Council now subjects all gaming licensees to FATF-aligned customer due diligence and suspicious transaction reporting. Operators must conduct appropriate money laundering and terrorist financing risk assessments, implementing controls to prevent illicit activity.

Philippine casinos must treat customers using money service business facilities as high risk, subjecting them to enhanced customer due diligence measures. Staff require training to assess customer documentation, particularly identifying false and AI-generated documents. Operators need robust onboarding checks, considering whether identification document verification sufficiently identifies false, stolen, or third-party credentials.