How to Report Illegal Online Casino Operations in the Philippines

This article provides general legal information in the Philippine context. It is not a substitute for tailored legal advice.

1) What counts as an “illegal” online casino?

In the Philippines, gambling is a highly regulated activity. An online casino is generally unlawful if it:

Operates without authority under PAGCOR’s charter (as consolidated in P.D. 1869, as amended by later laws) or other special laws;
Targets persons physically in the Philippines without the proper license, even if the server or corporate entity is offshore;
Promotes, facilitates, or collects bets online for unlicensed games of chance (including through social media, e-wallets, or messaging apps);
Uses unlawful payment channels or circumvents know-your-customer (KYC) and anti-money laundering (AML) requirements;
Violates content or consumer protections (e.g., deceptive advertising, access by minors, failure to present terms/odds).

Note on “POGOs”: Offshore gaming operators are a separate regulatory category historically restricted to servicing non-residents outside the Philippines and require stringent licensing and compliance. Offers targeting individuals located in the Philippines are not covered by offshore authority and are typically unlawful.

2) Legal framework (key references)

While provisions evolve, the core framework typically involves:

PAGCOR charter and regulations – Only duly licensed operators may legally offer casino games; marketing and agents are likewise regulated.
Executive directives against illegal gambling – Clarify inter-agency coordination and intensify enforcement against illicit operations.
Revised Penal Code & special penal laws – Penalize illegal gambling, aids and abets, and related offenses (e.g., swindling/estafa if scams are involved).
Cybercrime laws – Penalize online offenses and enable digital evidence preservation, search, and takedown with proper authority.
Anti-Money Laundering laws – Cover casinos and require reporting of suspicious transactions; enable freezing/forfeiture with court orders.
Consumer protection & e-commerce laws – Address deceptive or unfair practices, abusive terms, and online advertising issues.
Data privacy – Governs handling and disclosure of personal data in reporting and investigations.

3) Which authorities accept reports?

Multiple agencies have jurisdiction depending on the conduct. Parallel reporting is acceptable and often helpful.

PAGCOR (Regulator)
- For licensing status checks, complaints against operators/agents, marketing violations, and requests for enforcement coordination.
NBI – Cybercrime/Anti-Gambling Units (Law Enforcement)
- For criminal complaints, digital forensics, case build-up, and referrals to prosecutors.
PNP – Anti-Cybercrime Group (Law Enforcement)
- For reports involving social media, phishing, online recruitment, and payment fraud linked to illegal casinos.
DOJ – National Prosecution Service (Prosecutors)
- For filing complaints-affidavits leading to inquest or preliminary investigation after law-enforcement intake.
DICT / Cybercrime bodies & incident hotlines
- For technical coordination, incident intake, and assistance with platform/ISP actions when supported by legal process.
NTC (Telecom Regulator)
- For domain or IP blocking requests when authorized by appropriate legal orders or inter-agency directives.
AMLC (Anti-Money Laundering Council)
- Generally via law-enforcement referral; covered institutions (banks/e-money issuers) file Suspicious Transaction Reports (STRs). Individuals can provide leads that may trigger STRs through the institution or be routed to AMLC via investigators.
Platforms & payment providers (Private)
- Social networks, app stores, and e-wallets typically accept abuse reports and will act on credible notices—especially where minors or fraud are involved.

4) Evidence: what to collect (lawfully)

Gather only what you can lawfully access without hacking or circumventing security. Best practice is to preserve originals and create immutable copies.

URLs / domains / handles – Home pages, sign-up pages, payment pages, T&Cs, responsible-gaming pages (or absence thereof).
Date/time-stamped screenshots – Entire browser view with address bar visible; capture sequences (landing → registration → deposit → play).
Network/technical data – WHOIS, passive DNS, IPs (if you know how to collect legally), third-party trackers/SDK notices.
Marketing materials – Ads, influencer posts, messaging app invites, affiliate links.
Communications – Emails, DMs, chat logs with agents; export where possible.
Payment proof – Deposit/withdrawal receipts, wallet IDs, bank transaction references, remittance slips.
Victim impact – Amounts lost, chargebacks denied, account lockouts, minors exposed, threats/harassment.
Licensing claims – Any assertions like “PAGCOR-licensed” or “government approved” with screenshots.

Maintain a simple chain of custody log: who collected the item, when, from where (URL), and any transformation (e.g., “saved as PDF”). Keep devices’ system clocks accurate.

5) How to file: step-by-step pathways

A. Administrative/regulatory complaint (PAGCOR)

Describe the operator: domain, brand, apps, social pages, agents.
State the allegation: unlicensed operation targeting Philippine residents; misleading claims; acceptance of local e-wallets; minors targeted; failure to show responsible-gaming information.
Attach evidence: screenshots, payment references, ad captures.
Request actions: verification of licensing, cease-and-desist, referral to law enforcement, platform notices.

B. Criminal report (NBI/PNP → DOJ)

Initial intake: submit your incident report and evidence list.
Affidavit: execute a Complaint-Affidavit and Affidavit of Witness; include annexed exhibits (label “A”, “B”, …).
Digital evidence: surrender copies; keep originals where possible; if needed, arrange forensic imaging with investigators.
Further steps: inquest (if arrests), or preliminary investigation (if no arrests). Expect subpoenas, counter-affidavits, and possible mediation on civil aspects.

C. Financial/crime-proceeds angle (AMLC via LEA or covered institutions)

If funds moved through a bank or e-wallet, promptly notify the provider with transaction details. Ask about account flags and potential STR filing.
Provide investigators with the flow of funds (screenshots, reference numbers) to support freeze/forfeiture applications where applicable.

D. Platform & ISP actions

File Trust & Safety reports with social networks and app stores hosting the casino or its ads.
Provide clear violation theory: illegal gambling, deceptive claims, lack of age gating, phishing, or malware.

6) Drafting a strong complaint

Include:

Your identity (or organizational authority). If safety is a concern, ask about confidentiality and witness protection options available to law enforcement.
Clear narrative: who, what, when, where (including online locations), how you discovered the operation, and how it targets persons in the Philippines.
Legal characterization: “unlicensed online casino targeting Philippine residents,” “illegal gambling operations conducted via [platform],” “possible money-laundering schemes through [payment channels].”
Relief sought: investigation, takedown/blocking pursuant to law, prosecution, and AML actions; restitution where appropriate.

Sample headings (keep it concise, factual, unemotional):

Parties
Jurisdiction & Venue
Factual Background
Specific Instances & Evidence (Exhibits A–G)
Violations & Legal Bases
Reliefs Requested
Verification & Affidavit

7) Affidavit templates (short forms)

A. Complaint-Affidavit (individual)

I, [Name], Filipino, of legal age, residing at [Address], after having been duly sworn, depose and state:

On [date], I accessed the website/application “[brand]” at [URL/domain] which offers casino-style games.

The site solicits players located in the Philippines and accepts deposits via [bank/e-wallet/remittance], as shown in Exhibit A (screenshots with timestamps).

I registered an account under [username/email/phone] and was able to [deposit/attempt to deposit], as shown in Exhibit B.

The operator claims to be “[licensed/authorized]” but does not appear in PAGCOR’s list of licensees (see Exhibit C, marketing claims).

I lost ₱[amount] on [date] and was denied withdrawal on [date], as shown in Exhibit D (transaction references).

Based on these facts, I believe respondents are operating an illegal online casino targeting persons in the Philippines and violating applicable laws on illegal gambling, cybercrime, consumer protection, and AML.

I respectfully request a full investigation, seizure of instrumentalities, blocking of domains/apps as authorized by law, and prosecution of responsible persons.

IN WITNESS WHEREOF … [Signature/Verification/Jurat]

B. Affidavit of Witness (IT staff / platform user)

I, [Name], attest that Exhibits E–G were captured by me on [dates] using [device], with system time synchronized via [method]; files were saved to [media hash/fingerprint if available]. I did not alter the content.

8) Practical do’s and don’ts

Capture full-page screenshots with visible URL and timestamps.
Preserve original files (HTML/PDF exports, emails with headers, APK hashes).
Note agents’ phone numbers, Telegram/WhatsApp IDs, and referral codes.
Ask payment providers for written confirmations of transaction references.

Don’t

Engage in hacking, credential sharing, packet sniffing on networks you don’t own, or social-engineering beyond standard consumer interactions.
Transmit minors’ data or sensitive personal data unless requested through official channels and secured.
Publicly “name and shame” before filing; it risks defamation and evidence contamination.

9) Special situations

Minors or vulnerable persons: Flag immediately. Request urgent takedown and protective actions. Preserve evidence but do not recirculate sensitive content.
Employment coercion / trafficking indicators: If the operation involves forced labor or trafficking, state this explicitly and request referral to the appropriate inter-agency task force.
Cross-border rings: Emphasize fund flows, hosting locations, and agent hierarchies; ask investigators to engage international cooperation channels.
Corporate victims (banks/e-wallets/telcos): Coordinate with internal compliance; retain logs and trigger AML/FRM processes.

10) Remedies and outcomes

Criminal penalties: Fines and imprisonment for principals, accomplices, and accessories in illegal gambling and related offenses.
Administrative action: Cease-and-desist, revocation of permits, and directives to platforms/ISPs subject to proper authority.
Asset measures: Freeze and forfeit crime proceeds through AML mechanisms with court approval.
Restitution/civil claims: Recovery of losses where fraud or breach is proven; possible consumer redress and damages.
Compliance clean-up: Removal from app stores, domain seizures or blocking orders, and de-platforming of payment channels.

11) Quick checklist (tear-off)

Identify operator (brand, domain, apps, handles).
Confirm targeting of persons in the Philippines (ads, PH payments, PH language/currency).
Collect evidence package (screenshots, receipts, chats).
Draft complaint-affidavit and annexes.
File with PAGCOR (admin) and NBI/PNP (criminal); request DOJ intake.
Notify payment provider; request STR consideration and account flags.
File platform abuse reports; request geoblocking/takedown as authorized.
Maintain chain of custody; keep originals.

12) Frequently asked questions

Q: Can I remain anonymous? Agencies may accept tips anonymously, but formal complaints and prosecutions typically require an identified complainant or witness. You can request confidentiality; discuss safety concerns with investigators.

Q: Is it illegal to make a small “test” deposit to prove the case? Gathering evidence as an ordinary consumer is generally permissible, but do not escalate to conduct that would constitute participation in illegal gambling beyond what is necessary to document the offense.

Q: The operator claims to be “licensed abroad.” Is that a defense? Foreign licensure does not authorize targeting persons located in the Philippines. Local law and jurisdiction are triggered by where the gambling is offered or accessed.

Q: Can I force a bank/e-wallet to refund my losses? Refunds are uncommon absent fraud, unauthorized transactions, or consumer law violations. Still, promptly notify your provider; they may freeze counterparties or assist investigators.

13) Final guidance

Move quickly, preserve evidence carefully, and report through multiple appropriate channels. Where significant sums, organized activity, or risk to minors are involved, request priority handling and inter-agency coordination. For businesses, activate internal incident response, legal, and compliance teams to support law-enforcement referrals and AML actions.