How to Report Fake Casino Apps to the NTC, NBI, and PAGCOR (Philippines)
This article is for general information only and does not constitute legal advice.
Executive Summary
“Fake casino apps”—mobile or web applications that mimic legitimate casinos to harvest data or money—can be tackled through three primary Philippine authorities:
- NBI – Cybercrime Division (criminal investigation and case build-up)
- PAGCOR (regulatory/administrative action for gambling operators and brand misuse)
- NTC (telecom and internet access issues, e.g., blocking orders, spam/SMS promotion)
Most effective cases involve parallel reports: file a criminal complaint with the NBI, submit a regulatory complaint to PAGCOR (if gambling is involved or brands are misused), and raise a telecom/internet-access complaint with the NTC (especially for blocking, SMS blasts, or domain/app takedowns). Preserve evidence carefully and prepare a sworn Complaint-Affidavit with annexes.
What Counts as a “Fake Casino App”?
- Uses names, logos, or slogans of a licensed casino without permission
- Promises real-money gambling “under PAGCOR” but has no verifiable license
- Forces deposits through e-wallets/cryptocurrency/bank accounts not under any cashiering controls
- Phishes for credentials or harvests IDs (“KYC”) then monetizes data
- “Investment” or “VIP agent” recruitment disguised as casino affiliate programs
- Redirects to offshore domains, APK side-loads, or requests device admin permissions
Legal and Regulatory Framework (Philippine Context)
- Revised Penal Code (RPC) – Estafa/Swindling (Art. 315): false pretenses, fraudulent schemes.
- Cybercrime Prevention Act (RA 10175): computer-related fraud, illegal access, data interference; special rules on jurisdiction/venue, preservation, and chain of custody for electronic evidence.
- Rules on Electronic Evidence (A.M. No. 01-7-01-SC) and Rules on Cybercrime Warrants/Procedure (A.M. No. 17-11-03-SC): admissibility and handling of digital proof.
- Intellectual Property Code (RA 8293): trademark/copyright infringement for fake branding.
- Access Devices Regulation Act (RA 8484): credit/debit/e-wallet fraud and skimming.
- Anti-Money Laundering Act (RA 9160 as amended): tracing and freezing of proceeds.
- SIM Registration Act (RA 11934): SIM misuse in promotion/OTP fraud.
- Presidential Decrees and special laws on illegal gambling (e.g., PD 1602 as amended; RA 9287 for numbers games): criminal liability for unlicensed gambling.
- Pagcor Charter and regulations: licensing/oversight of gaming; misuse of PAGCOR name or false claims of authorization.
You do not need to cite every law in your complaint, but aligning your facts with the correct offenses helps authorities frame the case.
Evidence: What to Collect and How to Preserve It
A. Capture the app and its behavior
- App name, publisher, version, package identifier (for APKs), store page, download source
- Screenshots/screen recordings of registration, deposit/withdrawal flows, T&Cs, and any PAGCOR/brand claims
- In-app chats, “customer service” handles, Telegram/WhatsApp links, and admin usernames
B. Transaction trail
- Deposit/withdraw receipts; e-wallet/bank/crypto TXIDs; account names and numbers; timestamps (PH time)
- SMS/Email/Push notifications related to deposits, OTPs, or “bonuses”
C. Infrastructure indicators
- Domain/URL, IP (if visible), link shorteners used, referral codes, promo texts sent via SMS
D. Victim impact
- Amounts lost (principal and fees), dates, mental distress, time spent
E. Integrity steps (helps admissibility)
- Export original files (PNG/JPG/MP4, PDFs) and avoid editing.
- Compute and note file hashes (e.g., SHA-256) and keep a simple Evidence Log:
Item #, Description, Source, Date/Time captured, Hash. - If possible, preserve the device (don’t factory reset), and avoid re-installing the app after capture.
- Keep a written narrative: who, what, when, where, how; list of witnesses.
Reporting Pathways (Step-by-Step)
1) File a Criminal Complaint with the NBI – Cybercrime Division
Who should report? Any victim or witness (including corporate representatives with authority).
What to bring/submit
- Complaint-Affidavit (see template below), signed and sworn (notarized or executed before an NBI agent/prosecutor)
- One government-issued ID
- Annexes: screenshots, recordings, transaction proofs, SMS/email copies, evidence log, and any correspondence with app “support”
- If a company is the complainant: board/secretary’s certificate authorizing the representative
What the NBI can do
- Conduct cyber investigation, forensic imaging, preservation requests, take sworn statements, coordinate with banks/e-wallets and ISPs, recommend filing of Information for estafa/cybercrime, and coordinate with prosecutors and courts for warrants and takedowns.
Practical tips
- Present your facts chronologically; specify exact amounts and dates.
- Identify the modus (e.g., impersonation of a PAGCOR casino, phishing, investment-like returns).
- Flag ongoing risk (e.g., live SMS blasts, active domains) to justify urgent action.
2) Lodge a Regulatory Complaint with PAGCOR
Use PAGCOR if:
- The app claims PAGCOR authorization, misuses its logo, or offers real-money casino play to PH residents without a visible, verifiable license;
- A licensed operator’s brand is being impersonated;
- You want administrative and industry enforcement (e.g., advisories, coordination with app stores/hosts, referral to law enforcement).
What to submit
- Letter or email complaint with: your identity, contact details, description of the app, evidence of false PAGCOR claims or unlicensed gambling, proof of loss (if any), and screenshots of branding misuse.
- If you are from a licensed operator: include the proof of your own license and evidence of confusion/brand dilution.
What PAGCOR can do
- Validate licensing status, issue advisories against the fake app, refer to law enforcement, coordinate with payment channels, and request de-listing from stores/hosts. It may also initiate action against licensed entities that partner (knowingly or negligently) with illicit operations.
3) Escalate to the NTC (Telecom/Internet Angle)
Use NTC if:
- The fake app is spread via SMS spam, illegal SIM promotions, or short links;
- You seek network-level measures (e.g., blocking/seizure requests channeled to ISPs as authorized);
- You need action against SMS senders, content providers, or value-added services abusing the networks.
What to submit
- Complaint describing the mode of dissemination (SMS, calls, links), phone numbers/sender IDs, timestamps, and screenshots.
- Evidence tying the telecom channel to the fake app (e.g., link in the SMS that lands on the app download page).
- Your request (e.g., investigate sender, coordinate with carriers, restrict access consistent with legal authority).
What NTC can do
- Coordinate with carriers to identify abusive senders, order disabling of numbers/services, and—upon proper legal basis/endorsement—facilitate blocking of identified domains/URLs/APKs within the limits of its mandate.
Which One First?
- If you lost money or data → NBI first (criminal case build-up), PAGCOR next (regulatory), then NTC (distribution channel).
- If you’re a brand/licensee being impersonated → PAGCOR (brand/licensing), NBI (IP crime/fraud), then NTC (takedown of spam/distribution).
- If you’re receiving mass spam promoting the app → NTC (spam/SMS), NBI (fraud), and PAGCOR (if gambling claims are present).
Parallel filings are common and helpful.
If You Already Deposited Money
- Immediately notify your bank/e-wallet for dispute/chargeback or freeze request citing fraud; provide transaction IDs and a copy of your NBI complaint.
- If funds moved to another PH account, ask the institution to trigger AML red flags and freeze protocols as permitted by law.
- Change passwords; enable 2FA on accounts; consider replacing compromised SIMs.
- If personal data was uploaded (ID/selfie), monitor for identity theft and file a separate complaint with the National Privacy Commission for any suspected data breach/misuse.
Template: Complaint-Affidavit (Sworn Statement)
(Title) COMPLAINT-AFFIDAVIT I, [Name], of legal age, Filipino, with address at [Address], after having been duly sworn, depose and state:
- Personal Background. I am [occupation]. I can be contacted at [email/mobile].
- Respondents. The persons behind the mobile application “[App Name]”, and the entities operating the deposit channels with account names [names/numbers]. Their identities are presently unknown and will be ascertained during investigation.
- Facts. On [date/time], I encountered [how you found the app: SMS/FB/website] linking to [URL/store page/APK]. The app represented itself as [licensed by PAGCOR/partner of X], as shown in Annex A.
- I registered using [number/email] and deposited ₱[amount] via [bank/e-wallet/crypto] (Annex B – receipts/transaction records). My funds were not withdrawable; “support” demanded additional payments/fees (Annex C – chat logs).
- I later learned the app is not licensed and is impersonating [Brand/PAGCOR] (Annex D – comparative screenshots).
- Offenses. Respondents committed estafa under Art. 315, computer-related fraud/illegal access under RA 10175, and trademark infringement under RA 8293. Other offenses may be determined by investigators.
- Reliefs Sought. I request criminal investigation, preservation of electronic evidence, identification and prosecution of respondents, takedown of the app/domains, and freezing/tracing of my funds.
- Evidence Integrity. I collected the attached files on [dates] and kept original copies with the following hashes (Annex E – Evidence Log).
- I am executing this affidavit to attest to the truth of the foregoing.
[Signature over Printed Name] [Date and place]
JURAT/ACKNOWLEDGMENT (to be completed before a notary public or authorized officer)
Evidence Log (Simple Format)
| Item # | File name / Description | Source/Link | Date–Time (PH) | Hash (SHA-256) | Notes |
|---|
Chain of Custody Tips (Digital Evidence)
- Label devices/media; limit handlers.
- Document transfers: from whom, to whom, date/time, purpose.
- Store copies with write-protection when possible; keep originals untouched.
- Use read-only tools to extract files; keep hash values stable.
Coordinating with App Stores/Hosts and Carriers
- Send a notice of infringement/fraud with screenshots, proof of identity/brand rights (if any), and your NBI/PAGCOR complaint reference numbers.
- For SMS/telecom abuse, submit sending numbers/Sender IDs and timestamps to your carrier and the NTC, requesting investigation and blocking.
Jurisdiction & Venue (Where to File)
- For cybercrimes, venue is proper where any element occurred, which can include where you received the message, made the deposit, or used your device, as well as where servers or accounts are accessed. Choose the venue that best aligns with your facts and practical access to investigators.
Frequently Asked Practical Questions
Q: I only have screenshots; are those enough? A: Screenshots help, but add original files (HTML/PDF, videos, app APK if safely obtained), and transaction records from your bank/e-wallet. More original metadata = stronger case.
Q: Is a notarized affidavit required? A: It’s standard to swear your complaint before an NBI agent/prosecutor or a notary. Follow the receiving office’s practice—sworn statements carry more weight.
Q: Can I stay anonymous? A: You must usually identify yourself to investigators. If there are safety concerns, ask about protective measures and avoid public posting of sensitive details.
Q: Will the site/app be blocked immediately? A: Network restrictions generally need a proper legal basis or endorsement. Your NBI and/or PAGCOR filings make it far easier for NTC to coordinate lawful blocking with carriers.
Quick Checklists
For Individuals
- IDs, contact details
- Complaint-Affidavit (sworn)
- Screenshots/recordings with timestamps
- Bank/e-wallet/crypto proofs
- Evidence log + hashes
- Any brand/PAGCOR misuse proofs
For Licensed Operators Being Impersonated
- Proof of license/brand ownership
- Confusion evidence (side-by-side graphics)
- Demand to hosts/app stores
- Parallel filings: PAGCOR, NBI, NTC
Final Notes
- Parallel reporting to NBI (criminal), PAGCOR (regulatory/licensing), and NTC (telecom/ISP action) gives the best chance of takedown and recovery.
- Be methodical: clean evidence, clear narrative, precise timestamps and amounts.
- Move fast on bank/e-wallet disputes and identity-protection steps to reduce further harm.
If you want, I can turn this into a fill-in-the-blanks PDF kit (Complaint-Affidavit + Evidence Log + covering letters) that you can use immediately.