Reporting Illegal Online Casinos in the Philippines
A Comprehensive Legal Primer (2025)

1. Governing Legal Instruments

Area	Key Issuances	Salient Points
Licensing & regulation	• Presidential Decree 1869 (PAGCOR Charter), as amended by RA 9487 • RA 11590 (2021 POGO tax law) • Special‐zone charters: RA 7922 (CEZA), RA 9490 (APECO), RA 9728 (AFAB)	Vests the Philippine Amusement and Gaming Corporation (PAGCOR) with exclusive authority to “operate, authorize and regulate games of chance,” including internet‐based gaming; allows designated economic zones to issue offshore online‐gaming (POGO) licences only for non‑resident play.
Illegal gambling offences	PD 1602 (as amended by RA 9287)	Criminalises betting or wagering “by any electronic or mechanical means” without a government franchise. Penalties range from arresto mayor (1 month 1 day–6 months) to prisión correccional medium (2 yrs 4 mos–4 yrs 2 mos) when minors are involved or the operator is a public officer.
Cyber‑specific offences	RA 10175 (Cybercrime Prevention Act) § 4(b)(2)	Re‑states illegal‑gambling offences when perpetrated “through a computer system,” raising the penalty one degree higher than that set in PD 1602. Grants DOJ‑OOC power to order real‑time collection of traffic data and site blocking.
Financial‑crime overlay	RA 9160 (Anti‑Money Laundering Act) as last amended by RA 11521	Treats unlicensed internet gambling as a predicate offence; covered persons (banks, e‑wallets, even licensed online casinos) must file suspicious transaction reports (STRs) with the Anti‑Money Laundering Council (AMLC).
Taxation	NIRC (Tax Code) § 25 (as amended) & RA 11590	POGO licensees are taxed at 5 % of gross gaming revenue (GGR) + withholding taxes on foreign workers; unlicensed sites incur deficiency taxes, surcharges, and closure under the Tax Code.

2. What Makes an Online Casino “Illegal”?

No Philippine licence at all – i.e., operator is neither (a) a PAGCOR‐authorised internet gaming entity (IGE) nor (b) a POGO issued by PAGCOR or a special‑zone authority.
Wrong‑market licence – a POGO that admits Philippine‑resident players (prohibited under its licence).
Expired, suspended, or revoked authority yet continuing to accept bets.
Front‑end camouflage – use of mirror sites, social‑media “casino” games that covertly pay out cash, or white‑label skins piggy‑backing on another firm’s licence.
Criminal adjunct activity such as credit‑card fraud, crypto mixers, or human‑trafficking rings linked to the gaming operation.

3. Liabilities at a Glance

Party	Criminal	Administrative	Civil
Operators, officers & financiers	PD 1602/RA 9287 imprisonment + ₱20 k–Millions fine; RA 10175 penalty 1 degree higher; AMLA prision mayor (6–12 yrs) & asset forfeiture	PAGCOR/zone fines up to ₱200 million; licence cancellation; BIR closure; NTC domain blocking	Torts (Arts 19–21, 2176, 33, 1157 Civil Code); disgorgement of unlawful gains
Service providers (ISPs, payment gateways, advertisers)	Conspiracy/accessorial liability if knowingly facilitating	AMLC administrative sanctions; BSP penalties (for e‑money issuers)	Contractual indemnity, third‑party damages
Players	PD 1602 – fine ≤ ₱6 k or arresto menor/ mayor; RA 9287 stiffer if bookmakers involve minors	—	Restitution of illicit winnings; possible tax assessment on gains

4. Enforcement Architecture and Jurisdiction

Agency	Mandate	How to Contact
PAGCOR Compliance Monitoring & Enforcement Department (CMED)	Oversees all Philippine‑facing online gaming; may seize servers and request police raids	cmed@pagcor.ph • (+632) 8521‑0000 loc 6044
Department of Justice – Office of Cybercrime (DOJ‑OOC)	Central authority for cybercrime inquiries, MLAT requests, and website blocking orders under RA 10175	report@cybercrime.doj.gov.ph • 24/7 hub (+632) 523‑8481
National Bureau of Investigation – Cybercrime Division (NBI‑CCD)	Forensic preservation, entrapment operations, execution of search warrants	ccd@nbi.gov.ph • (+632) 8523‑8231
Philippine National Police – Anti‑Cybercrime Group (PNP‑ACG)	Initial complaints, take‑downs, on‑site arrests	acg@pnp.gov.ph • Text 8888
Anti‑Money Laundering Council (AMLC)	Probes laundering through gambling channels; may FREEZE assets ex parte	amlc@amlc.gov.ph
National Telecommunications Commission (NTC)	Blocks IPs/domains upon DOJ‑OOC endorsement	consumer@ntc.gov.ph

5. Step‑by‑Step Guide to Reporting

Capture evidence
- Save URLs, IP addresses, chat logs, screen‑recordings of wagers, payment receipts, e‑wallet or bank transfers (Rule on Electronic Evidence allows screenshots when authenticated by affidavit).
Draft a Complaint‑Affidavit (Rule 112, Revised Rules of Criminal Procedure)
- Parties & addresses, complete narration of acts, laws violated, and reliefs sought; attach all digital exhibits on a USB/DVD or cloud link.
File with the appropriate body
- Local play? → PAGCOR‑CMED plus NBI‑CCD/PNP‑ACG.
- Offshore site accessible to Filipinos? → DOJ‑OOC for blocking, AMLC for STR trigger.
Request immediate preservation under Sec. 13 RA 10175 to compel ISPs/payment processors to retain traffic or subscriber data for 90 days (renewable once).
Follow‑up & witness protection
- Secure your copy‑stamped complaint; track docket no.; consider Witness Protection Program (RA 6981) if personal safety is compromised.
Civil redress (optional)
- File a separate action for annulment of wagering contract and recovery of losses under Art 2014 Civil Code within 5 years.

6. Administrative Blocking Procedure (Simplified Timeline)

Day	Action
0	Complaint lodged with DOJ‑OOC (or OSG/NBI request)
1–3	Prima‑facie evaluation; ex‑parte preservation order to ISP
3–7	DOJ‑OOC issues Provisional Takedown Order (PTO) max 14 days
≤14	Full‑blown hearing (written memoranda)
≤30	Issuance of Site Blocking Order for renewable 6‑month periods; NTC executes via memo to ISPs

7. Interplay with Anti‑Money Laundering Rules

Covered‐persons test: banks, e‑money issuers, remittance & transfer companies, and even licensed online casinos must flag:
- Unlicensed‐site transactions,
- Wagers ≥ ₱5 million in one day, or
- Multiple smaller bets that appear “structured”.
Failure to report → fines up to ₱500 k per transaction and criminal prosecution of compliance officers.
AMLC may freeze suspected accounts for 20 days (extendible to 6 months) ex parte; petition for civil forfeiture follows in a regional trial court.

8. Recent Policy Developments (2023–April 2025)

Senate Bills 1902 & 2346 propose a total ban on POGOs; the House counterpart seeks tighter due‑diligence instead.
PAGCOR’s 2024 IRR now black‑lists individual directors & ultimate beneficial owners found running illegal sites, barring them from any gaming franchise for 10 years.
BIR Revenue Regulation 2‑2024 obliges ISPs and app stores to submit quarterly lists of gaming domains accessible from PH IP ranges.
AMLC’s 2024 Typology Report cites cryptocurrency mixers and “play‑now‑pay‑later” schemes as emerging laundering channels via illicit casinos.

9. Practical Checklist for Complainants

☐ Verify licence on www.pagcor.ph/verify/.
☐ Screenshot every wager & transaction before logging out.
☐ Keep original e‑wallet SMS or email confirmations.
☐ Lodge report within 60 days of discovering the offence for easier tracing.
☐ Never accept “refund” offers from the site—these may waive your claims.

10. Conclusion

The Philippines runs a dual system: it welcomes tightly regulated online gaming, yet criminalises any operation or play that strays outside the licensing envelope. Reporting an illegal online casino is therefore not merely a civic duty; it helps protect the integrity of the broader, legitimate industry and the financial system. By understanding the legal framework, the proper fora, and the evidentiary standards, a whistle‑blower or aggrieved player can trigger swift administrative blocking, criminal prosecution, and even recovery of lost funds. If in doubt, consult a lawyer—most bar associations now run cyber‑gambling hotlines that can assist pro bono.

This article reflects statutes, regulations, and policy issuances in force as of April 21 2025 (Manila time). It is for general information only and does not constitute legal advice.