Philippine central bank tightens AML guidance on casino junket risks
The Bangko Sentral ng Pilipinas (BSP), the Philippine central bank, has issued new guidance requiring banks and other BSP-supervised financial institutions (BSFIs) to strengthen anti-money laundering (AML) and counter-terrorism and proliferation financing (CTPF) controls for customers involved in casino junket operations.
The guidance paper forms part of the BSP’s efforts to strengthen the country’s financial crime controls following its review of selected banks with exposure to casino junket operators (CJOs) and junket player transactions.
CJOs are companies or individuals that arrange gaming-related services for high-value casino patrons, including travel, credit facilities and gaming room bookings. While these services support the VIP gaming segment, the BSP warned that they also present elevated risks for money laundering, terrorism financing, proliferation financing and other illicit activities.
“Financial transactions linked to CJOs can pose elevated money laundering risks,” Lyn Javier, BSP Deputy Governor, said. “We identify the best practices and red flags BSFIs need to watch out for to be strong partners in our shared goal of curtailing crime and safeguarding the integrity of the financial system.”
Five areas for stronger controls
According to the BSP, BSFIs should strengthen risk management across five key areas. These are board and senior management oversight, money laundering and terrorism financing prevention programmes, customer acceptance and identification, ongoing transaction monitoring and suspicious transaction reporting, and self-assessment and staff training.
The regulator also highlighted practices such as enhanced due diligence for high-risk customers, automated transaction monitoring systems, client link analysis, independent verification with regulatory agencies, and participation in information-sharing initiatives.
According to the memorandum, all BSFIs are expected to use the guidance paper to enhance their AML and CTPF frameworks and improve their ability to identify, measure and mitigate risks associated with casino junket operators.
The BSP also stressed that information sharing between supervisory authorities, particularly the BSP and the Philippine Amusement and Gaming Corporation (PAGCOR), remains critical
Wider regulatory push
The guidance comes days after PAGCOR directed licensed gaming operators to review and strengthen their own AML controls after its latest Casino Sector Anti-Money Laundering and Counter-Terrorism Financing Risk Assessment classified the Philippine casino sector as high risk for money laundering and medium-high risk for terrorism financing.
The regulator’s assessment identified land-based casinos as particularly vulnerable because of their reliance on cash transactions, foreign patrons and exposure to VIP and junket business. Electronic gaming was also assessed as medium-high risk due to rapid growth, high transaction volumes and non-face-to-face customer interactions.
Speaking exclusively to SiGMA News following PAGCOR’s advisory, iGaming consultant Jonas Diego said licensed operators should expect tighter scrutiny over their highest-risk customer segments. “This means stricter customer due diligence, enhanced monitoring of high-value transactions, and closer scrutiny of intermediaries,” Diego said.
Atty. Russell Stanley Geronimo, founder of Geronimo Law, said the regulator’s latest actions show that compliance is becoming a governance issue rather than simply a regulatory requirement. He added that operators should revisit their institutional risk frameworks to address foreign VIP customers, cash-intensive transactions and complex settlement arrangements.
“Ultimately, this shifts AML compliance from a routine back-office function directly into board-level accountability and continuous supervisory alignment,” Geronimo said.
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