A Philippine law firm has called on the country’s central bank, the Bangko Sentral ng Pilipinas (BSP), to strengthen its proposed regulations on online gambling payments, warning that the current draft fails to protect vulnerable users adequately.

In formal comments submitted to the BSP on its Draft Circular on Online Gambling Payment Services, Russell Stanley Geronimo, founder of Geronimo Law, said that while the initiative is a “welcome step” toward regulation, it overwhelmingly focuses on institutional compliance rather than addressing player-level harms.

“Only one out of ten substantive provisions in the Draft Circular directly addresses player-level transaction restrictions,” Geronimo wrote. “The rest focus on institutional compliance, onboarding procedures, and reporting obligations of payment providers and online gambling operators.”

Geronimo expressed confidence that “the largest payment providers have all resources in the world to meet these requirements,” and that major gambling operators are “capable of adapting to the Draft Circular’s proposed framework.” However, he stressed that these compliance provisions are unlikely to “curb harmful gambling behavior among vulnerable users or alter the supply-side conditions that enable it.”

At the heart of Geronimo’s critique is Section 1106.6 of the draft, which outlines transaction-level controls. “This is the only provision that directly attempts to influence user behavior,” he emphasized, urging regulators to refocus attention there.

An “ineffective” daily spending cap

One of Geronimo’s central concerns is the draft’s proposed daily spending cap, which limits funding to online gambling accounts to 20 percent of a user’s average daily balance. He argued that this limit is both ineffective and easily manipulated.

For low-income users, he explained, the cap still allows gambling at levels that could disrupt basic living expenses, such as meals, transport, or utility bills.

For high-income users, meanwhile, the rule permits substantial gambling activity that may still be harmful or compulsive, especially in the absence of an absolute monetary ceiling. He also noted that users could artificially inflate their account balances through short-term deposits to raise their gambling limits.

Another provision requiring PSPs to restrict online gambling payments to a six-hour daily window was described by Geronimo as superficial. He argued that such a measure does not reduce the total volume or intensity of gambling but merely concentrates it into a narrower time frame.

Compulsive users, he warned, would simply adjust their behavior to match the permitted window. Moreover, he pointed out that different platforms could offer overlapping time windows, rendering the restriction meaningless.

Geronimo also criticized the provision on “heavy usage,” which allows PSPs to impose a 24-hour cooling-off period at their discretion. Leaving the definition of heavy usage to the platforms themselves creates a moral hazard, he warned, because PSPs that benefit from high transaction volumes may have little incentive to apply the rule rigorously or consistently. Without uniform standards, the same behavior might be treated differently across platforms.

He further expressed concern about the draft’s heavy reliance on self-imposed safeguards under the proposed Responsible Online Gambling Policy (ROGP). These include voluntary limits and opt-in controls that depend on user self-control. Citing behavioral research, Geronimo warned that such an approach is ineffective in preventing harm among users experiencing compulsive gambling behavior.

“This creates the illusion of consent while enabling compulsive behavior…Behavioral economics and addiction research consistently show that users with problematic gambling behavior are least likely to make rational, preventative choices.”

Russell Stanley Geronimo

Introducing user tiered transaction limits

In response, Geronimo proposed a comprehensive set of alternative measures. He recommended introducing tiered transaction limits based on users’ verified financial profiles, with lower limits for unverified or low-income users and absolute caps to prevent excessive gambling.

He called for real-time dashboards that show users their cumulative gambling losses, frequency of transactions, and days active within the month. He also proposed mandatory cooling-off periods when users change their own limits, and minimum lockout periods when gambling accounts are voluntarily disabled.

Geronimo further recommended that the BSP establish a clear, uniform definition of heavy usage that would automatically trigger cooling-off periods. He proposed thresholds such as cumulative gambling top-ups exceeding PHP2,000 ($35) within seven days, more than 10 gambling-related transactions in a week, or gambling transactions comprising more than half of a user’s outgoing payments.

To address the issue of credit use, he urged the BSP to require platforms to disable all lending and credit-related features—not just within the gambling account, but across the entire platform. He warned that unless all embedded credit pathways are covered, users may still indirectly borrow to gamble.

Finally, he criticized the draft for presenting key protections as discretionary rather than mandatory.

“Without codifying these safeguards at the system level, the ROGP risks becoming a collection of soft nudges rather than a regulatory tool that meaningfully prevents harm.”

Russell Stanley Geronimo

Geronimo concluded his letter by offering to engage further with the BSP: “Should the BSP require further clarification or wish to discuss any of the proposals in this letter, I may be reached through the contact details provided.”

The full comment letter, dated July 21st, 2025, was submitted to the BSP’s Payments Policy and Development Department.

The country’s government is currently assessing the broader implications of a complete ban on all forms of online gambling, as pressure mounts from lawmakers calling for decisive action against what they describe as a growing epidemic affecting Filipino citizens.

The push for a complete ban has prompted a coordinated response from the gaming industry, with 14 licensed online gaming operators recently issuing a joint statement opposing an outright prohibition on July 17th, instead advocating for enhanced regulatory frameworks to protect consumers while maintaining the industry.