How to Report Illegal Online Gambling Sites in the Philippines
A practical legal guide for consumers, payment processors, and hosting providers
1. Why “illegal online gambling” needs to be reported
- Consumer protection. Unlicensed sites offer no guarantee of payout and frequently harvest personal data.
- National revenue. Every peso wagered on an unlicensed platform escapes taxation, shrinking funds that should support schools, universal healthcare, and infrastructure.
- Anti-money-laundering (AML). Rogue gambling portals are prime conduits for fraud, terrorist financing, and large-scale remittance evasion.
- Cyber-crime spill-over. Loan-sharking, “sextortion,” and human-trafficking rings often hide behind or fund illegal gaming operations.
2. The legal framework (core statutes & issuances)
| Law / issuance | Key relevance to illegal online gambling |
|---|---|
| Presidential Decree (PD) 1602 (1981) | Baseline penalties for illegal gambling activities. |
| Republic Act (RA) 9287 (2004) | Increases PD 1602 penalties when the illegal gambling involves large wagers or organized groups. |
| RA 7922 & PAGCOR Charter (PD 1869, as amended by RA 9487) | Vests PAGCOR with exclusive authority to regulate “games of chance,” including e-gaming. |
| EO 13 (2017) | Clarifies that Philippine-based offshore gambling operators (POGOs) need PAGCOR licenses or CEZA/AFAB sub-licenses and may not offer bets to persons located in the Philippines. |
| RA 10175 (Cybercrime Prevention Act) | Adds cyber-offenses, such as online fraud and cybersquatting, and allows real-time traffic collection and computer data preservation. |
| RA 9160 as amended by RA 10927 (Anti-Money Laundering Act) | Brings casinos—including online casinos—into the AML reporting net; requires suspicious-transaction and covered-transaction reports (STR/CTR). |
| BSP Circular No. 1108 (2020) | Orders banks and e-wallets (e.g., GCash, Maya) to monitor gambling-related merchant codes and file AML reports. |
| PAGCOR Regulatory Manual & Gaming Site Audit Regulations | Detail technical, geofencing, and “locally situated bettor” checks licensees must implement. |
| RA 8799 (Securities Regulation Code) & SEC advisories | Penalties on unregistered investment schemes masked as “play-to-earn” or “crypto casino.” |
3. Which conduct is illegal?
- Offering games of chance to persons located in the Philippines without a Philippine government license (PAGCOR, CEZA, AFAB, APECO).
- Licensed POGOs or e-sabong operators accepting local bets (breach of EO 13 and PAGCOR circulars).
- Skin-betting, loot-box wagering, or prediction markets that amount to games of chance but operate without a license.
- Advertising unlicensed gambling using PH-based social-media influencers or SMS blasts (Cybercrime Act & Consumer Act infractions).
- Payment facilitation (banks, e-wallets, crypto-exchanges) for the above, if done with knowledge or gross negligence.
4. Who investigates and enforces?
| Agency | Mandate & useful contact |
|---|---|
| PAGCOR Enforcement and Licensing Department (ELD) | Primary regulator; issues cease-and-desist orders (CDOs) and IP blocks. Email: eld@pagcor.ph • Hotline: (+632) 8521-6468 |
| National Bureau of Investigation – Cybercrime Division (NBI-CCD) | For criminal complaints, digital forensics, and cross-border takedowns. Trunkline: (+632) 8525-6098 local 3400 |
| Philippine National Police Anti-Cybercrime Group (PNP-ACG) | 24/7 complaint desk; joint raids with NBI & PAGCOR. Hotline/Viber: +63917-977-8762 |
| Anti-Money Laundering Council (AMLC) Compliance & Investigation Group | Freezes assets and files civil forfeiture; accepts confidential tips. Email: secretariat@amlc.gov.ph |
| Bureau of Internal Revenue (BIR) Task Force POGO/EGames | Pursues unpaid franchise tax and income tax; joins raids. |
| DICT Cybercrime Investigation & Coordinating Center (CICC) | Coordinates ISP blocking and digital evidence preservation. |
5. Step-by-step reporting procedure
| Stage | What to do | Tips / Legal basis |
|---|---|---|
| A. Gather evidence | • Screenshot the website/app (URL, date/time). • Save transaction receipts, bank/GCash records, chat threads. • Note IP address (use ping/whois) if possible. |
RA 10175 allows you to preserve computer data for 30 days once you lodge a report. |
| B. Identify the right venue | If the site claims any PAGCOR/CEZA license numbers, verify them on the PAGCOR Licensee Directory. If none, treat it as unlicensed and file with PAGCOR ELD and NBI-CCD. | Dual-filing speeds up administrative IP blocking (PAGCOR) and criminal case build-up (NBI). |
| C. File the complaint | 1. Online: - PAGCOR e-Complaint Form (https://www.pagcor.ph/regulatory/complaint.php). - NBI Online Complaints (https://www.nbi.gov.ph). 2. Walk-in: Bring two (2) printed copies of your Affidavit of Complaint plus your ID. 3. AMLC Secure File Upload for bulk STR data. |
Affidavit must detail how you discovered the site, what you bet/lost, and why you believe it’s illegal. Attach all screenshots as annexes. |
| D. Cooperate in the investigation | Expect follow-up for additional logs or to execute a Certificate of Authenticity (COA) of digital evidence. | Under Rule 11, Sec. 2 of the Cybercrime Rules of Court, failure to authenticate screenshots can get them excluded. |
| E. Monitor and follow up | Use the case reference number to check status. PAGCOR posts quarterly lists of domains it has blocked; NBI issues subpoena/ad-testificandum if prosecution is imminent. | Government offices have 15 working days to issue an initial action per Republic Act 11032 (Ease of Doing Business Law). |
| F. Consider civil remedies | Request restitution or damages in the criminal case or file an independent civil suit for fraudulent inducement (Civil Code Art. 19–21). | Winning a civil suit requires proof the operator or its PH agent is reachable for service of summons and has assets within jurisdiction. |
6. Penalties operators (and facilitators) face
| Offense | Fine / imprisonment |
|---|---|
| Illegal gambling under PD 1602 & RA 9287 | ₱20,000 – ₱6 million fine and 6 months–12 years jail (graduated by role: bettor < financier < protector). |
| Cyber-offenses (RA 10175) | +1 degree higher penalty than the underlying crime (e.g., estafa becomes reclusion temporal). |
| AML violations (RA 9160/10927) | ₱500,000 – ₱1 million/day of violation; forfeiture of assets; possible closure of the financial institution for willful blindness. |
| Tax evasion (NIRC, RA 11590 for POGOs) | 25 %–50 % surcharge, 12 % interest, and criminal prosecution. |
| Advertising unlicensed gambling (Consumer Act & PAGCOR memos) | Up to ₱300,000 per violative ad plus takedown orders against influencers/marketing agencies. |
7. Whistle-blower and witness protection
- Witness Protection, Security and Benefit Act (RA 6981). If you are an employee of the illegal site, you may qualify for immunity and relocation.
- AML good-faith defense. Bank officers who file STRs “in good faith” are statutorily immune (Sec. 9-B, AMLA).
- Data privacy. PAGCOR and NBI treat complainant data as confidential law-enforcement data under the Data Privacy Act (RA 10173).
8. Cross-border domain and payment blocking
- Domain Name System (DNS) blocking. PAGCOR coordinates with the DICT and NTC to compel Philippine ISPs to null-route or single-point-blacklist offending domains under RA 7925.
- Payment interdiction. AMLC and BSP rapidly blacklist merchant category codes (MCC 7995/7800) tied to illicit sites; e-wallets must suspend accounts within 24 hours once notified.
- Mutual Legal Assistance Treaties (MLATs). The DOJ Office of Cybercrime liaises with ASEAN, U.S., and E.U. counterparts to freeze offshore bank accounts and seize servers.
9. Practical tips & common pitfalls
| Do | Don’t |
|---|---|
| Use a screen-recording tool to capture the wagering process live (adds credibility). | Don’t alter screenshots—metadata tampering will be obvious in forensic review. |
| Report immediately; funds move quickly and logs rotate every 30 days. | Don’t expect PAGCOR to refund your losses; it’s a regulator, not an ombudsman. |
| If large amounts (₱500k+) are involved, loop in a lawyer early for stronger evidence packaging. | Don’t “test-bet” again after discovering illegality; you could be charged as a bettor. |
| For corporate ISPs or payment processors, draft a board resolution authorizing the report—it shows institutional good faith. | Don’t rely on “.ph” domain absence; many rogue sites run on “.com” but still target locals. |
10. Template: Affidavit of Complaint (core clauses)
- Identification – Name, age, citizenship, address.
- Jurisdictional statement – That the offense was committed within the Philippines via an internet connection located at _____.
- Factual narration – Dates, times, URLs, amount wagered/lost, promises made by the site, chats/emails.
- Legal allegations – Violation of PD 1602, RA 9287, RA 10175, EO 13, and other pertinent laws.
- Prayer – Request for investigation, issuance of subpoena, CDO, asset freeze, and prosecution.
- Verification and notarization.
Key takeaways
- Multi-agency approach. File with at least PAGCOR and either NBI-CCD or PNP-ACG; coordinate with AMLC for large sums or obvious laundering.
- Time is of the essence. Digital footprints fade; act within the 30-day retention window set by the Cybercrime Act.
- Documentation wins cases. Courts are wary of “he-said-she-said” cyber-evidence; your best weapon is a clean chain of custody.
- Civil & tax angles amplify pressure. Parallel BIR and AMLC actions often compel rogue operators to settle or abandon the PH market.
- Stay within the law yourself. Mere participation in unlicensed gambling is punishable; reporting does not grant retrospective immunity.
Disclaimer: This guide is for informational purposes only and does not constitute legal advice. Laws and regulations change; consult a qualified Philippine lawyer or the relevant agency for specific situations.