PAGCOR probity checks underpin FATF gains: Legal firm
The Philippine Amusement and Gaming Corporation’s (PAGCOR) fit-and-proper assessments have become a key safeguard in protecting the country’s anti-money laundering (AML) reforms following its removal from the Financial Action Task Force (FATF) grey list in February 2025, according to Philippine legal and regulatory advisory firm Arden Consult.
“Probity checks are not bureaucracy for its own sake. They are part of the Philippines’ commitment to global anti-money-laundering standards set by the Financial Action Task Force (FATF),” wrote Patricia De Guzman of Arden Consult.
The firm said FATF Recommendation 28 requires regulators to prevent criminals and their associates from owning or managing casinos, with PAGCOR responsible for enforcing those standards across the Philippine gaming sector. “The stakes became especially clear during the period the Philippines spent on the FATF ‘grey list,’ when the country faced heightened international scrutiny,” De Guzman wrote.
The Philippines was removed from the FATF grey list on 21 February 2025 after demonstrating improvements to its AML and counter-terrorism financing framework. The government identified President Ferdinand Marcos Jr.’s ban on Philippine Offshore Gaming Operators (POGOs) as one of the measures that contributed to the country’s delisting.
Ownership and management under scrutiny
According to Arden Consult, probity checks extend beyond the corporate entity applying for a licence and cover the individuals behind the business.
“A common misconception is that only the business is assessed,” De Guzman wrote. “In practice, both the applying company and the key people behind it are checked.”
The checks are required when companies apply for new licences or renew existing ones, but they can also be triggered by “intervening events” such as changes to directors, officers, ownership or beneficial ownership. Adverse reports, suspicions of wrongdoing, and routine annual reviews may also prompt an assessment.
Arden Consult noted that licensed entities must notify PAGCOR in writing within 15 calendar days of any changes to their board, officers, or ownership.
“Missing that window is an avoidable misstep that can itself raise questions,” De Guzman said.
Three-tier review system
The framework assesses applicants using three levels of scrutiny depending on their risk profile.
Probity checks may examine identity, address, educational background, professional licences, criminal records, litigation history, bankruptcy or insolvency records, financial standing, regulatory compliance and media reports. Applicants are also screened against AML and terrorism watchlists maintained by the Anti-Money Laundering Council (AMLC), the United Nations and the US Office of Foreign Assets Control (OFAC).
“The framework sets out three tiers of intensity: Minimum (Level 1) for low-risk applicants, Intermediate (Level 2) for medium risk, and Enhanced (Level 3) for high risk,” Arden Consult said.
“PAGCOR’s licensing department assigns it through a risk assessment that weighs your business size, ownership complexity, geographic exposure, financial standing, and compliance history,” De Guzman wrote. “The regulator also retains full discretion to raise the level if new risk indicators emerge.”
The firm added that reviews should generally be completed within 30 calendar days after all required documents have been submitted, although complex cases may take longer.
Full disclosure remains essential
Arden Consult said incomplete documentation remains the most common cause of delays but warned that inaccurate disclosures could have more serious consequences. “It can be tempting to present the cleanest possible picture. Resist that instinct,” De Guzman wrote.
“Failing to submit required documents, providing inaccurate information, or not cooperating within the timelines carries real consequences: a new application may be rejected or treated as withdrawn, an existing license may be suspended or revoked, and where fraud is involved, PAGCOR may pursue legal action,” De Guzman warned.
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