The Philippines’ gaming regulator is misconstrued in regards to its actual enforcement ability for shutting down illegal operators. A top expert points out that its primary avenues for shutting down bad actors lie more in blacklisting or sanctioning game providers, content studios and service providers.
In a commentary shared with AGB, Tonet Quiogue, legal expert and CEO of Arden Consult, said that while PAGCOR lacks direct enforcement authority over illegal operators, it holds a powerful regulatory tool through its accreditation of suppliers.
‘By exercising its rule-making powers, PAGCOR can cut off the very supply chain that illegal operators depend on. If a provider is found servicing unlicensed gambling platforms, PAGCOR can revoke its accreditation, effectively shutting them out of the legal market,’ Quiogue noted.
The call comes amid ongoing confusion over PAGCOR’s enforcement powers. Recent congressional hearings highlighted a widespread misconception that the regulator can unilaterally shut down illegal gambling websites.
PAGCOR Chairman Alejandro H. Tengco clarified that the agency has ‘no power to close illegal sites’ and can only refer cases to law enforcement agencies such as the National Bureau of Investigation (NBI) or the Philippine National Police (PNP).
Quiogue stressed that the power to investigate, prosecute, and shut down illegal operators lies with enforcement bodies. The National Telecommunications Commission (NTC) can block access to websites, the Department of Justice (DOJ) and NBI can build criminal cases, and the PNP has the authority to conduct raids and arrests.
‘PAGCOR’s role is regulatory, not enforcement,’ she explained, noting that even lawmakers often misunderstand the agency’s mandate.
Despite these limitations, PAGCOR still plays an important role in monitoring the industry and reporting suspicious activities. Its Compliance Monitoring and Enforcement Department audits licensees and can impose fines, suspensions, or license revocations on those who breach regulations. But against purely unlicensed operators, it must rely on cooperation with law enforcement agencies.
Cutting the supply chain
While PAGCOR has no police powers, Quiogue emphasized that it can disrupt illegal gambling networks by targeting their supply chain.
Under its accreditation framework, service providers — including game developers, platform suppliers, and payment processors — must secure approval from PAGCOR to work with licensed operators. Any supplier caught assisting unlicensed gambling platforms risks losing accreditation and being banned from the legal market.
International examples highlight the effectiveness of this approach. Sweden, Great Britain, and Ontario mandate supplier licensing to ensure vendors work only with authorized operators. This strategy denies unlicensed sites access to popular games, reliable payment channels, and other essential services, making them less competitive and pushing players toward regulated platforms.
‘Explicitly blacklisting developers or platform suppliers that knowingly support unlicensed sites sends a clear message: vendors who work with unauthorized gambling outfits will face serious consequences,’ Quiogue wrote.
The issue is urgent. PAGCOR has flagged more than 12,000 unlicensed gambling websites targeting Filipinos, many hosted overseas and masked by shifting domains and opaque ownership structures. These platforms siphon off untaxed revenues while exposing consumers to risks such as fraud, money laundering, and gambling addiction.
Private sector collaboration
Quiogue also underscored the role of industry collaboration in combating unlicensed operators. In an exclusive statement to AGB, she pointed to the newly launched PlaySafe Alliance — a coalition of licensed operators and accredited providers — as a platform for proactive private-sector action.
‘With the PlaySafe Alliance now established, private sector stakeholders must continue taking a proactive role in addressing illegal online gambling,’ she said. ‘Licensed operators and accredited providers should work with regulators and telecoms to block unlicensed sites, enforce stronger KYC and AML standards, and differentiate themselves from illegal competitors.’
She added that the next stage requires concrete collective measures: ‘Operators must align under the Alliance to share intelligence in a structured way, pool funds to support monitoring and enforcement, and run consumer campaigns that warn against the risks of unregulated play.’
According to Quiogue, a whole-of-government approach — with PAGCOR acting as gatekeeper, the NTC blocking websites, law enforcement pursuing criminal cases, and industry stakeholders closing ranks — offers the best chance of stemming the growth of illegal gambling in the Philippines.
‘Through proactive rule-making and strict enforcement, PAGCOR can leverage its oversight of the supply chain to stifle illegal gambling enterprises — even without police powers,’ she said.
