Online Gaming Scams in the Philippines

A comprehensive legal briefing (May 2025)

Executive Summary

Online gaming has exploded in the Philippines—both legitimate operations licensed by the Philippine Amusement and Gaming Corporation (PAGCOR) and unlicensed outfits that prey on players, investors and even their own workers. The resulting scams now account for a significant share of cyber-enabled fraud reported to the PNP Anti-Cybercrime Group (PNP-ACG) and the National Bureau of Investigation (NBI). While the country already has a dense web of criminal, administrative and AML statutes, enforcement is racing to keep up with ever-evolving schemes and with the regional shift of transnational scam “hubs” into Philippine territory.(Respicio & Co., AP News)

1 The Philippine Online-Gaming Landscape

Regulated sector. PAGCOR licenses domestic i-gaming, e-bingo and electronic casinos; offshore licenses (POGOs) are also issued but have come under heavy political fire in 2024-2025.(Pagcor, AGB)
Grey & black markets. Hundreds of unlicensed betting apps and “pop-up” casino websites target Filipinos from abroad, while scam call-centres masquerade as gaming studios. A 2025 Pasay City raid rescued trafficked workers and seized 400+ suspects running gambling/crypto confidence tricks.(AP News)

2 Typology of Common Scams

Modus operandi	Typical legal hooks
Account-phishing & credential-stuffing to loot in-game wallets	Illegal access (RA 10175 §4[a][1]); estafa (RPC Art 315)
Skin/asset marketplace fraud – buyer never pays or receives item	Computer-related fraud (RA 10175 §4[b][2])
Fake top-up / gift-card vendors on social media	Swindling/estafa; AMLA for proceeds
Clone casino sites & forged PAGCOR certificates	Unlicensed gambling (PD 1602); use of falsified documents (RPC Art 172)
Investment or “play-to-earn” Ponzi schemes	Securities Regulation Code; Syndicated estafa
Trafficking-based scam hubs forcing workers to operate rigged gaming & romance scams	RA 9208 (anti-trafficking); RA 10364 (expanded)
Money-laundering through high-volume betting wallets	RA 9160 as amended by RA 10927 (casinos/POGOs as covered persons)

Recent PAGCOR advisories flag a surge in forged licences and spoof websites, while the AML Council is issuing freeze orders against e-wallets linked to gaming swindles.(Pagcor, AMLC)

3 Governing Statutes & Regulations

Cybercrime Prevention Act of 2012 (RA 10175). Core offences—computer-related fraud (§4[b][2]), identity theft (§4[b][3]), illegal access (§4[a][1])—carry prision mayor (6-12 years) plus one-degree-higher penalties when an underlying RPC offence (e.g., estafa) is computer-facilitated (§6). Extraterritorial jurisdiction is granted when any element, device or victim is in the Philippines (§21).(Wikipedia)
Revised Penal Code. Estafa (Art 315), falsification (Arts 171-172), usury-related frauds.
PAGCOR Charter (PD 1869 as amended by RA 9487) & PD 1602. Criminalises unlicensed gambling; authorises PAGCOR to impose administrative fines up to US$250 000 per violation.(Respicio & Co.)
Anti-Money Laundering Act (RA 9160) plus RA 10927. Brings casinos, e-gaming and POGO licensees into AML coverage; failure to report suspicious gaming transactions is a predicate offence.
Data Privacy Act of 2012 (RA 10173). Penalises unauthorised processing or negligent disclosure of player data (1-7 years plus fines).(National Privacy Commission)
Consumer Act (RA 7394) and DTI e-commerce policies protect buyers of in-game goods; civil and administrative remedies apply.
Securities Regulation Code (RA 8799). “Play-to-earn” tokens or profit-sharing game credits offered to the public without registration invite criminal liability.

4 Enforcement Architecture

Agency	Powers & recent activity
PNP-ACG	Front-line complaints desk; digital forensics; regular “Scam Watch” advisories.(Respicio & Co.)
NBI-Cybercrime Division	Undercover entrapments (e.g., 2023 “Dragon888” bust); cross-border extraditions.
DOJ-Office of Cybercrime	Mutual legal assistance & Budapest Convention negotiations.(Portal)
AMLC	Real-time transaction monitoring; ex-parte freeze of e-wallets used for gaming fraud.(AMLC)
PAGCOR	Site blocking, licence suspension, administrative penalties.(Pagcor)
Congress & Senate	Pending bills seek a total POGO ban and stricter liability for platform owners.(GMA Network, The Register)

Special cyber-crime courts (Regional Trial Courts acting as “e-courts”) have exclusive jurisdiction over RA 10175 cases; civil damages may be filed in the same action. Search-and-seizure of server data requires a warrant, but data preservation orders can issue ex parte for 30 days (extendable).

5 Penalties & Liability Matrix

Violation	Imprisonment	Fine / Other
Computer-related fraud (RA 10175 §4[b][2])	6-12 years (prisión mayor)	up to ₱1 000 000
Estafa ≥ ₱2 M, syndicate	20-40 years (reclusión temporal/ perpetua)	Treble amount swindled
Unlicensed online gambling (PD 1602)	Up to 6 years	₱5 000-₱200 000 + asset forfeiture
Money-laundering	7-14 years	₱500 000-₱3 000 000 + property forfeiture
Data-privacy breach (RA 10173 §25-27)	1-7 years	₱500 000-₱5 000 000
PAGCOR administrative	—	up to US$250 000 per count; licence revocation

6 Landmark Cases & Operations

Procap International (May 2025) – DOJ faces the country’s first syndicated estafa complaint against an online casino; investors claim ₱780 M in unpaid winnings.(The Manila Times)
Pasay City Scam Hub Raid (March 2025) – 401 foreign nationals arrested for running gambling-cum-investment scams; workers treated as trafficking victims.(AP News)
2023 “Dragon888” Takedown – NBI seized servers in Cavite linked to US$10 M credit-card fraud through rigged betting bots.(Respicio & Co.)

7 Current Policy Moves

POGO phase-out. Senate Bill (TBA) and President Marcos’ 2024 directive aim to revoke all offshore licences by 31 Dec 2024, citing links to kidnapping and scams.(AGB, GMA Network, The Australian)
Accession to the Budapest Convention. DFA has signalled intent; draft alignment bills are with the House Committee on ICT.(Portal)
Stronger KYC & e-wallet rules. BSP’s 2024 circular tightens transaction limits for gaming top-ups pending AML risk reviews.

8 Compliance Checklist for Legitimate Operators

PAGCOR Licence + POGO Authority (if targeting foreign bettors).
AML/CFT Programme – risk-based KYC, STR filing, 24-hour reporting to AMLC.
Data-privacy by design – NPC-registered DPO, privacy-impact assessment, breach notification within 72 h.
Fair-game certification – independent RNG or game-math testing.
Responsible-gaming tools – self-exclusion, deposit caps, age-verification using PhilSys.

Failure to meet any of the above can ground both criminal and administrative charges.

9 Practical Remedies for Victims

Preserve evidence: screenshots, transaction logs, e-mail headers, chat histories.
Report immediately: PNP-ACG eReport portal or NBI-CCD cyber complaint centre.
Request asset freeze: provide transaction references so AMLC can issue a freeze order within 24 h on suspect e-wallets.
File criminal affidavit: estafa and RA 10175 charges before the appropriate Prosecutor’s Office; civil damages may be claimed in the same action.
Notify platform & payment provider for possible charge-backs or indemnification.

10 Future Outlook & Recommendations

Legislative: Consolidate gambling laws into a single “Interactive Gaming Act” clarifying licence categories and player protections.
International cooperation: Fast-track Budapest Convention accession to streamline evidence-sharing.
Tech controls: Mandate real-time IP geolocation blocking for unlicensed sites and adopt e-KYC using the PhilSys national ID.
Consumer education: PAGCOR and DepEd joint modules on scam awareness for students.
Labour protection: Expand anti-trafficking inspections to gaming BPOs and require PAGCOR human-rights audits for licensees.

With these measures, the Philippines can preserve the economic upside of a vibrant e-gaming sector while choking off the scams that threaten both consumers and the country’s reputation.

Prepared by: [Assistant] – updated 27 May 2025 (UTC+8)