Reporting Online Casino Scams in the Philippines

A comprehensive legal guide for consumers, counsel, and compliance teams

1) Snapshot: what counts as an “online casino scam”?

Common patterns:

Rigged or unlicensed gambling sites using .com/.net domains that accept bets from persons in the Philippines without a Philippine license.
Deposit-only schemes: you can load funds (via e-wallet/bank/crypto) but withdrawals are delayed or denied.
Impersonation of legitimate brands (fake PAGCOR “license badges,” cloned apps/websites, social-media pages).
“Investment” pitches tied to casino VIP rooms, “arbitrage,” or “agent” commissions—often securities or investment schemes in disguise.
Account takeovers (SIM swap/OTP interception) draining e-wallets used to fund gaming accounts.

These may trigger criminal liability (e.g., estafa, illegal gambling, computer-related fraud), administrative action (e.g., against a licensed payment operator), or civil remedies (e.g., damages, chargebacks).

2) Legal framework (Philippine context)

Gambling & licensing

PAGCOR Charter: P.D. 1869 (as amended by R.A. 9487). PAGCOR regulates and licenses gaming.
Offshore vs. onshore: POGOs (offshore) are not allowed to offer to persons located in the Philippines. Only PAGCOR-authorized domestic products (e.g., certain e-games or online platforms expressly permitted) may be offered locally, and only under license terms.
Illegal gambling: Art. 195–199, Revised Penal Code, and special laws; operating or taking part in unlicensed gambling may be penalized.

Cybercrime & fraud

R.A. 10175 (Cybercrime Prevention Act): computer-related fraud, illegal access/interception; empowers preservation orders, search, and seizure of computer data; provides extended jurisdiction and real-time collection subject to due process.
Estafa (Art. 315 RPC) and swindling, qualified theft: classic fits for deposit-but-no-withdrawal and misrepresentation schemes.

Financial services & payments

R.A. 11765 (Financial Products and Services Consumer Protection Act): consumer redress against banks, EMIs, and other financial providers; mandates complaint handling, reversals/chargebacks consistent with rules, and BSP oversight.
R.A. 10870 (Credit Card Industry Regulation Law) and BSP regulations: chargebacks/charge disputes on cards.
R.A. 9160 (AMLA) and rules: reporting of suspicious transactions by covered institutions; funds may be frozen/forfeited via AMLC and the courts.

E-commerce, privacy, and evidence

R.A. 8792 (E-Commerce Act) & Rules on Electronic Evidence (A.M. No. 01-7-01-SC): screenshots, logs, metadata can be admissible when properly authenticated; affidavits from custodians/forensic examiners help.
R.A. 10173 (Data Privacy Act): leakage/misuse of IDs, selfies, and bank details can be reported to the NPC.
R.A. 11967 (Internet Transactions Act of 2023): consumer protections and enforcement tools against online sellers/intermediaries in business-to-consumer dealings; useful where platforms/marketplaces facilitate access to illegal casinos.
R.A. 11934 (SIM Registration Act): aids in tracing numbers; report SIM-swap and phishing to telcos/NTC.

3) Who to report to (and when)

You may report to multiple agencies at once—they cover different angles (criminal, regulatory, consumer redress, payments).

PNP Anti-Cybercrime Group (PNP-ACG)
- For criminal complaints (estafa, cybercrime, illegal gambling, identity theft).
- Ask for digital evidence preservation guidance and a cybercrime incident report reference number.
NBI Cybercrime Division
- Parallel venue for criminal complaints and digital forensics; particularly helpful for complex or cross-border cases.
PAGCOR (Regulatory/Enforcement & Licensing)
- File complaints on unlicensed operators targeting PH users or licensed platforms violating terms (e.g., withdrawal denials, rigged games).
- Request site blocking referral and regulatory action.
Bangko Sentral ng Pilipinas (BSP) – Consumer Assistance
- If deposits/withdrawals moved via banks/e-money issuers (EMIs) or card networks.
- Triggers internal investigations, chargebacks, reversals, or merchant offboarding for rule breaches.
Your bank/e-wallet/card issuer (first line)
- Immediately report unauthorized transfers or merchant fraud; request temporary hold, chargeback, and fraud claim.
- Ask them to escalate to the acquiring bank of the casino/payment processor.
AMLC Secretariat (through your bank/EMI)
- Consumers don’t file STRs directly, but you can submit a tip to your bank/EMI so they file an STR/CTR; this can support asset freezing.
National Privacy Commission (NPC)
- If your KYC documents, selfies, or account data were harvested or leaked.
NTC / DICT-CICC
- For phishing SMS, spoofed domains, VoIP scams; request blocking of numbers/domains (coordinate via PNP/NBI).
- Telco complaints for SIM-swap incidents.
SEC (EIPD)
- If the “casino” is actually selling investment contracts or “VIP share” schemes—possible unregistered securities and investment fraud.

4) Step-by-step reporting workflow (practical playbook)

Step 1 — Secure and freeze

Kill access: change passwords; enable MFA; freeze your e-wallet/card if needed.
Contact your bank/EMI immediately: dispute the transaction(s), ask for chargeback/reversal and merchant tracing.
Preserve funds: request a hold on pending transfers; ask whether the receiving account is flagged.

Step 2 — Preserve evidence (same day)

Screenshots/recordings of the site/app, profile, chat, transaction flows, deposit/withdrawal screens, T&Cs, and “license” badges.
Full URLs (with parameters), domain WHOIS, social profiles, ads you clicked.
Payment proofs: confirmations, receipts, reference numbers, bank/EMI statements, card authorization logs.
Communications: emails, SMS, in-app chats—export as .eml, .pdf, or .txt when possible.
Device data: keep the phone/PC un-wiped; note OS, browser, app version; avoid “cleaners.”
Keep date/time (Philippine time) and IP/location notes for each event.

Step 3 — File criminal and regulatory complaints (within 24–48 hours)

PNP-ACG/NBI: submit a Sinumpaang Salaysay (sworn statement) with annexes; request data preservation letters to ISPs, telcos, hosting, and payment processors.
PAGCOR: if the brand is unlicensed or violating conditions (e.g., refusing lawful withdrawals), ask for investigation and site-blocking referral.
BSP + your bank/EMI: lodge a formal consumer complaint referencing your dispute/chargeback case number.

Step 4 — Civil options (parallel)

Through counsel, send a Demand Letter to any identifiable PH entity (e.g., local “agents,” payment intermediaries) and consider a civil action for damages.
For larger losses, consider asset preservation motions and injunctions where defendants or intermediaries are within PH jurisdiction.

Step 5 — Follow-through

Track reference numbers from each agency.
Respond promptly to requests for logs/devices; chain-of-custody matters for admissibility.

5) Evidence and admissibility notes

Authentication: Under the Rules on Electronic Evidence, electronic documents are admissible if authenticated (by the author, a custodian, or forensic examiner). Hash values, email headers, and app logs strengthen your proof.
Best evidence: Prefer native exports (e.g., .eml for emails) over screenshots; keep original devices.
Hearsay & provenance: Keep notes on who captured each screenshot/recording and when.
Preservation orders: R.A. 10175 allows expedited preservation of computer data upon application to a cybercrime court. Ask investigators to move for these quickly (hosts and platforms recycle logs).
Cross-border: Use MLAT channels (via DOJ Office of Cybercrime) when servers, registrars, or operators are abroad.

6) How payment reversals actually work

Cards (Visa/Mastercard/JCB/UPI): File a chargeback through your issuer citing fraud or merchandise not received/services not provided. Provide the merchant name, ARN, amounts, timestamps, and evidence of withdrawal denial.
E-wallets/EMIs: Request merchant dispute and reversal; if the counterparty is a restricted merchant (unlicensed gambling), acquirers may be compelled to offboard and claw back illicit funds when possible.
Bank transfers: Ask for fraud recall; success depends on the receiving bank freezing funds before they’re moved.
Crypto: On-chain transfers are typically irreversible; focus on exchange choke points (KYC’d accounts) through law enforcement and AMLC.

7) Liability map

Operators: illegal gambling, estafa, cybercrime offenses, AMLA violations.
Local “agents” / cash-in runners: potential criminal participation; civil liability for inducing participation; possible tax exposure.
Payment processors/acquirers: regulatory exposure if they knowingly board illegal gambling merchants.
Victims: generally not criminally liable for reporting losses; however, repeated participation in illegal gambling may have legal consequences—seek counsel before making statements.

8) Red flags before you deposit

Claims that the casino is “licensed abroad” yet markets to PH players (illegal without PH authorization).
No verifiable corporate identity; support is via Telegram/WhatsApp only.
Bonus bait requiring “turnover” x100 before any withdrawal.
Agent recruitment promising fixed daily returns (this is classic securities fraud territory).
Payment only via vouchers/peer-to-peer/crypto with no card acquiring or reputable EMI integration.

9) Templates (you may copy-paste and edit)

A) Short affidavit (Sinumpaang Salaysay) outline

I, [Name], of legal age, [status], and residing at [Address], after being duly sworn, depose and state:

1) On [Date/Time, PH Time], I created an account at [Website/App, URL].
2) I deposited a total of [Amount, Currency] via [Bank/EMI/Card/Crypto], with reference nos. [list].
3) On [Dates], I requested withdrawals totaling [Amount] which were denied/delayed without valid reason.
4) The site displays a [PAGCOR badge/foreign license claim], but I could not verify a valid PH license.
5) I communicated with [handles/phone numbers/emails]; copies are attached as Annexes "A" to "H".
6) I believe I am a victim of [estafa/cybercrime/illegal gambling].
7) I request investigation, preservation of computer data, and prosecution of responsible persons.

[Signature]
[ID details]

SUBSCRIBED AND SWORN to before me this [date] at [city], affiant exhibiting [ID].

B) Evidence checklist for annexes

A1: Account profile & KYC page
A2: Deposit receipts and bank/EMI statements
A3: Withdrawal requests and denials
A4: Chat/email/SMS transcripts (exported)
A5: Screenshots of “license” claims, terms, promos
A6: Domain/WHOIS printouts; app store listing
A7: Device info, IP logs (if available)
A8: Demand letter (if issued)

C) Bank/EMI dispute letter (1 page)

Subject: URGENT DISPUTE – Suspected Illegal Online Gambling Merchant / Fraudulent Transactions

Dear [Issuer/EMI]:

Please dispute and reverse the following transactions as unauthorized/fraudulent and/or services not provided:
- Date/Time (PH): [..]  Amount: [..]  Merchant: [..]  Ref/ARN: [..]

The merchant appears to be an unlicensed online casino targeting PH users. Withdrawals were denied; evidence attached. 
Please (1) initiate chargeback/reversal, (2) freeze and trace downstream accounts, and (3) escalate to the acquiring bank and, if applicable, AMLC.

Sincerely,
[Name, contact, case no.]

10) Frequently asked questions

Can I get my money back? Possibly—through chargebacks, reversals, or recovery of frozen funds. Speed and documentation are critical.

If I gambled, can I still report? Yes. Being a victim of fraud does not bar you from reporting. Discuss with counsel to frame facts accurately.

The site shows a “Curacao” or other foreign license—does that make it legal for PH players? No. Foreign licenses do not authorize offering to persons in the Philippines. PH authorization is distinct.

Should I pay a “verification fee” to unlock withdrawals? No. That is a classic advance-fee trick; it will likely lead to further loss.

11) Counsel’s quick checklist

File ACG/NBI complaint; seek preservation orders.
Notify PAGCOR (licensing check; blocking referral).
Lodge BSP consumer complaint; push card/EMI chargebacks.
Coordinate with AMLC via covered institutions.
Consider civil action and ex parte asset preservation where feasible.
Protect client’s privacy; report to NPC if data compromised.
Maintain chain of custody for devices and exported data.

12) Important cautions

Legality and policy can evolve (e.g., treatment of offshore operators, site-blocking protocols, platform obligations). Always check the current PAGCOR, BSP, and Supreme Court issuances before filing.
Keep communication factual; avoid admissions that are not necessary to prove fraud and lack of license.
Do not negotiate privately with “agents” who demand payment to “release” funds.

Bottom line

If an online casino takes your money but stonewalls withdrawals—or solicits Philippine players without a Philippine license—treat it as fraud and illegal gambling. Move fast: secure accounts, preserve evidence, file multi-track complaints (ACG/NBI, PAGCOR, BSP + your issuer), and pursue civil and AML avenues. Proper documentation and swift reporting give you the best chance to stop losses and recover funds.