Who really has the authority to shut down illegal online gambling sites in the Philippines? It is a question that continues to cause confusion - not only among the public, but even among legislators and officials directly overseeing the industry. Recent congressional hearings have made this plain, exposing just how blurred the lines are. At one hearing, lawmakers pressed PAGCOR on why it had not simply pulled the plug on illicit gambling apps, as though the agency itself held police powers. Chairman Alejandro Tengco was quick to clarify: PAGCOR has “no power to close illegal sites” and can only refer cases to the proper enforcement bodies. Yet the exchange revealed a deeper problem - even policymakers often misunderstand the scope of PAGCOR’s mandate.
Beneath this misdirection lies the real issue: the unchecked growth of illegal gambling websites, many of them hosted overseas, that continue to siphon off untaxed revenue while exposing Filipinos to unregulated play. PAGCOR’s own monitoring has flagged over 12,000 such sites. But policymakers should recognize a sobering truth: globally, even the most advanced enforcement agencies struggle to pin down the true operators of these platforms. They hide behind opaque ownership structures, offshore registrations, and constant domain shifts. When one Senator suggested in the recent hearing that the “owners” of these sites be summoned to testify, the irony was hard to ignore. These shadowy operators are illegal precisely because they are unaccountable - no one even knows to whom such an invitation could be sent.
This confusion has fueled a public narrative that lays the blame at PAGCOR’s feet, when in fact the power to investigate, prosecute, and shut down illegal operators lies with law enforcement and other agencies: the NTC to block access, the DOJ and NBI to build cases, the PNP to make arrests. By continuing to miscast PAGCOR as the enforcer, debate risks being trapped in the wrong frame - scapegoating a regulator with no police powers instead of strengthening the bodies that do.
This commentary cuts through the myths and seeks to redirect the conversation. It clarifies what PAGCOR can and cannot do, explains which agencies hold the real enforcement tools, and outlines how smarter regulation — built on inter-agency coordination - offers the best path forward. Just as importantly, it highlights the power PAGCOR does have over the gambling ecosystem: through its rule-making and accreditation of providers, it can cut off the very supply chain that illegal operators depend on. Properly enforced, this authority can be game-changing - making the difference between an unregulated free-for-all and a market where operators, suppliers, and platforms are forced to choose between compliance and exclusion. The goal is simple: to move beyond blame and focus on solutions that actually target the illegal online gambling operators themselves.
Limits of PAGCOR’s Enforcement Powers over Illegal Online Gambling
Illegal Gambling Under Philippine Law
To understand PAGCOR’s limits, it is crucial to note how Philippine law defines and penalizes illegal gambling. The Revised Penal Code (Articles 195–199) originally outlawed unlicensed gambling activities, and these provisions were updated by Presidential Decree No. 1602 (1978), which prescribes stiffer penalties for all sorts of unauthorized gambling games. Further reinforcing this framework, Republic Act No. 9287 (2004) increased the penalties specifically for illegal “numbers games” (like jueteng, masiao, etc.), introducing higher fines and longer prison terms especially for organizers, financiers, and protectors of such operations. In short, any gambling activity not sanctioned by PAGCOR or other appropriate agencies (e.g. PCSO for lotteries) is deemed illegal and subject to criminal prosecution.
Under these laws, operating or participating in unlicensed gambling is a crime - punishable by multi-year imprisonment and fines that escalate for repeat offenders or those with a larger role in the operation. Crucially, determining whether an act constitutes illegal gambling (and punishing those responsible) requires due process. Complaints must be filed and investigated by law enforcement, and cases prosecuted in court, with the accused given a chance to defend themselves. In other words, only the proper law enforcement agencies and the judiciary can adjudicate and shut down an illegal gambling enterprise – it’s not something PAGCOR can do unilaterally on mere suspicion. The law mandates that police and prosecutors build a case under statutes like PD 1602 or RA 9287, and secure court orders to arrest operators or seize assets. Due process ensures that any shutdown of a business – even an illicit gambling den or website – has a legal basis (e.g. evidence of the crime and a warrant or court order), to avoid abuse. This legal pathway is why PAGCOR officials often stress that they cannot simply declare an online platform “illegal” and pull the plug without involving the police, the Department of Justice, or the courts.
PAGCOR’s Charter: Regulatory, Not Enforcement, Powers
PAGCOR was created as a regulatory and licensing body for gambling – not a police force. Its authority comes from its charter (Presidential Decree No. 1869, as amended by Republic Act No. 9487 (2007)). Under these laws, PAGCOR is empowered to issue licenses, set rules, and supervise gambling operations that are authorized by the government. It was conceived to centralize the regulation of casinos and betting games, primarily to ensure gaming is conducted by reputable operators and to collect revenue for the state. What PAGCOR does not have is police power: nowhere in its charter is PAGCOR given authority to conduct criminal investigations, make arrests, or unilaterally shut down establishments that it has not licensed. In fact, by definition, any gambling activity outside of PAGCOR’s license system is already illegal under Philippine law – meaning it falls to law enforcement agencies to act on it, not the regulator.
PAGCOR’s own officials have repeatedly acknowledged this limitation. Chairman Tengco, in the recent hearings, explained that the agency’s role is to regulate legal operators and report any unlicensed gambling it discovers to the proper authorities, since PAGCOR has no legal authority to close illegal sites on its own. This is consistent with the corporation’s mandate: PAGCOR can penalize those it licenses (through fines, suspensions, or license revocation), but it cannot arrest or prosecute unlicensed operators, because that is outside its jurisdiction. Enforcement against criminal activities – including unlicensed gambling operations – falls under the authority of law enforcement agencies like the PNP and NBI, and prosecution by the DOJ, not PAGCOR. In essence, RA 9487 and PD 1869 give PAGCOR broad regulatory powers over the gambling industry, but the job of chasing and shutting down illegal gambling dens or websites is left to the police and other agencies. PAGCOR has no armed units or cybercrime division of its own to raid clandestine gambling rings, and it cannot issue binding cease-and-desist orders to unlicensed entities without going through the justice system. This clear delineation in the law is why PAGCOR often says its “hands are tied” when faced with purely illegal gambling operations – it must refer those cases to authorities who have the power to enforce criminal laws.
Role of Other Agencies in Enforcement
Because of PAGCOR’s limited enforcement authority, other government bodies have to carry the spear in combatting illegal gambling, especially online. Several key agencies have distinct mandates that, together, can cover the gap in enforcement:
- National Telecommunications Commission (NTC): The NTC plays a pivotal role in the technical takedown of illegal gambling websites. As the regulator of ISPs and telecoms, NTC can order internet service providers to block access to specified illegal websites. In fact, a recent memorandum (NTC Memorandum Order No. 001- 2023) explicitly empowers ISPs to geo-block or disable domains involved in illegal online gambling upon request by competent authorities (such as the Department of Interior and Local Government or PAGCOR). In practice, this means that when law enforcement or an inter-agency task force identifies web domains hosting unlicensed gambling targeting Filipinos, the NTC can direct Philippine ISPs to block those sites so users can no longer reach them. We saw this mechanism used during the crackdown on e-sabong (online cockfighting) in 2022, when hundreds of e-sabong websites were swiftly taken down or rendered inaccessible after a presidential order – largely through NTC’s coordination with telecom companies. The NTC has no criminal prosecution powers itself, but it is a critical enforcement tool: it effectively “shutters” illegal online operations in the digital realm by cutting off their visibility within the Philippines.
- Department of Justice (DOJ): The DOJ, through its law enforcement and prosecutorial arms, is at the forefront of investigating and charging illegal gambling operators. DOJ prosecutors are the ones who evaluate evidence and file cases in court under PD 1602, RA 9287 or related laws, to formally accuse individuals of illegal gambling. The DOJ also oversees the National Bureau of Investigation (NBI), which has a Cybercrime Division dedicated to probing online offenses (including illegal online casinos or betting scams). In coordination with the Philippine National Police, the NBI can conduct surveillance and entrapment operations against illicit gambling outfits, especially those operating across borders or using online payment channels. Notably, the DOJ’s Office of Cybercrime (OOC) serves as the central authority for cybercrime issues; it can facilitate mutual legal assistance (MLA) requests with foreign jurisdictions and secure court orders for data preservation or website blocking when illegal gambling platforms are hosted abroad. In the context of the recent hearings, DOJ’s role is to take the intel from PAGCOR (e.g. lists of suspicious sites) and from public complaints, then build cases to prosecute the perpetrators. Only through DOJ’s actions in court can illegal operators be met with convictions, penalties, or injunctions to stop their activities. In sum, the DOJ ensures that due process is followed – gathering evidence, charging offenders, and bringing them to justice – which is necessary to formally dismantle an illegal gambling operation.
- Philippine National Police (PNP): The PNP, particularly units like the PNP Anti- Cybercrime Group (PNP-ACG) and local police intelligence divisions, handles the on-the-ground law enforcement against illegal gambling. The PNP conducts raids, arrests, and seizures when an illegal gambling den or online operation is identified. They have the police power that PAGCOR lacks – for example, if there’s an illicit online betting hub operating in a clandestine office, the PNP can get a search warrant and storm the premises to halt the operation and detain those involved. Even for purely online platforms, the PNP-ACG works to identify the people behind the websites (often in coordination with the NBI) and can file cybercrime charges. During the House discussions, lawmakers emphasized that PAGCOR should be closely coordinating with the PNP so that the moment an illegal gambling outfit is detected, police can be alerted to take action on the ground. The bottom line is that the PNP are the ones who physically “shut down” illegal gambling operations through law enforcement action, since they have the authority to enforce criminal laws on the ground.
It’s worth noting that other bodies also contribute – the Cybercrime Investigation and Coordinating Center (CICC)under the DICT aids in technical intelligence, the Anti-Money Laundering Council (AMLC) freezes funds connected to illegal gambling, etc. – but the NTC, DOJ (with NBI), and PNP are the primary agencies mentioned in the context of PAGCOR’s enforcement limitations. Each plays a specialized part: NTC cuts off digital access, PNP/NBI collar the offenders and gather evidence, and DOJ prosecutes them in court. PAGCOR’s role, by contrast, is more adjunct in these cases – it provides information and expertise, but it cannot execute these enforcement actions by itself.
What PAGCOR Can Do Within Its Powers
While PAGCOR cannot raid underground gambling dens or summarily block websites on its own, it is not entirely toothless in addressing the online gambling problem. Within the scope of its authority over licensed gaming, PAGCOR has a Compliance Monitoring and Enforcement Department (CMED) that keeps a close watch on all registered operators. This department conducts audits and investigations to ensure that licensees strictly follow regulations – from anti-money laundering rules to Know Your-Customer (KYC) protocols (e.g. verifying players are 21 or older). If a licensed online gambling platform violates any of PAGCOR’s regulations or the terms of its license, PAGCOR can impose administrative sanctions. These range from hefty fines and warnings, up to suspending or revoking the operator’s license in severe cases.This kind of penalty is administrative (under PAGCOR’s regulatory powers) rather than criminal, but it’s a critical tool to enforce responsible conduct in the legal gaming sector.
PAGCOR can also contribute to the fight against unlicensed gambling through coordination and intelligence-sharing. PAGCOR’s CMED and cybersecurity units monitor the internet for new unlicensed gambling websites targeting Filipinos. PAGCOR can also file formal complaints or assist in case build-up by providing industry expertise (for instance, explaining how an illegal site mirrors a legitimate one, or how money flows through these platforms) to help prosecutors. Essentially, PAGCOR acts as the “eyes and ears” for the licensed market – it knows when something fishy appears online and can raise the alarm. This collaborative posture was emphasized by Rep. Poe, who called for strengthening PAGCOR’s enforcement arm (the CMED) so it can better gather evidence on illegal operators and liaise with police. Strengthening PAGCOR’s compliance monitoring could mean more resources for detecting illicit gambling and faster referrals to authorities, thereby plugging some of the enforcement gaps without giving PAGCOR direct police power.
In summary, within its legal bounds, PAGCOR can: (1) enforce strict compliance among the operators it licenses – ensuring issues like underage gambling, problem gambling, or money-laundering red flags are addressed swiftly through fines or license sanctions; (2) penalize and even shut down licensed operators that break the rules or abet crimes, as seen in the recent fines and license cancellations; and (3) serve as an active partner to law enforcement by monitoring the industry and reporting illegal gambling activities for prosecution and takedown. What PAGCOR cannot do is execute raids or make arrests – those actions remain the province of agencies like the PNP – but through regulatory pressure and inter agency collaboration, it can indirectly contribute to shutting down bad actors.
Cutting Off Support to Illegal Gambling Operators: PAGCOR’s Rule-Making Role
Although PAGCOR has very limited enforcement powers against illegal gambling operators - it cannot raid offices, seize assets, or make arrests - the agency still holds a powerful tool that can disrupt their operations: cutting off the supply chain. By exercising its authority as a regulator over service and content providers, PAGCOR can deny illegal websites access to the games, platforms, and services that make them attractive to players. In many ways, this is similar to how financial regulators fight money laundering and terrorist financing: they may not directly catch the criminals, but by cutting off access to banks, payment processors, and correspondent accounts, they choke the flow of funds that sustain illicit activity. Just as cutting access to capital cripples money launderers, cutting access to games and technology weakens unlicensed gambling operators.
A key example is PAGCOR’s accreditation framework for B2B service providers, which now requires all gaming content suppliers, game aggregators, payment processors, and similar support companies to be formally approved by PAGCOR before servicing licensed operators. By acting as a gatekeeper for these game providers and service suppliers, PAGCOR can ensure they uphold strict standards and do not aid unlicensed gambling. Accredited Gaming Service Providers (such as software vendors, platform or content providers) must operate purely on a B2B basis – they cannot offer games directly to players – and they are only permitted to service the specific PAGCOR licensed operators listed in their accreditation. This rule-making power means PAGCOR can cut off the “supply chain” to illegal operators: if a provider is caught supporting unlicensed gambling platforms targeting Philippine players, PAGCOR can refuse or revoke that provider’s accreditation, effectively banning them from the legal market. In practice, this creates a strong disincentive for legitimate game studios and tech vendors to have any dealings with rogue operators, under threat of losing access to all legitimate business in the country.
International Best Practices in Supplier Regulation
Other jurisdictions have successfully used supplier licensing and enforcement to squeeze illegal gambling markets – a strategy that underlines the importance of PAGCOR’s role as a rule-maker. Research indicates that when regulators require gaming software and content providers to be licensed and to avoid servicing unlicensed sites, it becomes harder for illegal gambling operations to thrive. In fact, an international study noted that jurisdictions which don’t regulate B2B providers tend to “exacerbate black market leakage” because unlicensed sites can still access popular game content freely [1]. Conversely, cutting off the supply of quality games and services to illegal platforms can deal a heavy blow to their viability. Enforcement against the gambling supply chain – for instance, penalizing licensed providers who sneak their products into black-market sites – creates “considerable friction” for illegal operators and makes it much harder for them to do business. [2] This approach has been adopted in several countries. Great Britain, Belgium, Germany, Ontario (and as of 2025, Denmark) all mandate licensing for key gambling suppliers, using this as a tool to ensure that only legal markets benefit from reputable service providers. Sweden offers a clear recent example: in 2023 it introduced a new gambling software supplier license specifically to “discourage illegal gambling.” Under this regime, any game developer or platform provider must work exclusively with licensed operators, and unlicensed gambling sites are barred from using suppliers who hold a Swedish license. [3] Regulators reasoned that if illegal sites are denied access to the high-quality games and tech that licensed sites have, many players will stick to the regulated options – a strategy aimed at boosting channelization (i.e. keeping gamblers in the legal, monitored sector). Academic and industry analyses support this supply-chain enforcement tactic: pressuring or prosecuting the third-party providers that serve illicit operators can prompt those providers to withdraw from grey markets, thereby weakening illegal gambling enterprises from within. All of this suggests that PAGCOR’s assertive oversight of game content suppliers and other support services is a powerful lever to choke off the resources that illegal gambling sites depend on.
Intensifying B2B Sanctions on Illicit Market Enablers
Given these insights, PAGCOR should intensify its efforts to blacklist or sanction any game providers, content studios, or other service partners (including payment providers) that continue to empower unlicensed gambling targeting the Philippines. The newly instituted B2B accreditation rules provide the mechanism to do so – any accredited supplier found abetting an illegal operation can swiftly lose their accreditation and be barred from all dealings with PAGCOR-licensed entities. This hardline approach sends a clear message: vendors who work with unauthorized gambling outfits will face serious consequences. Explicitly blacklisting game developers or platform suppliers who knowingly supply unlicensed Philippine-facing websites – PAGCOR can further deter legitimate industry players from lending their products or expertise to the black market. Cutting off these lifelines (games, payment channels, IT support, etc.) can greatly disrupt illicit operators, who often rely on the same popular casino games and reliable tech used by legal sites. In summary, through proactive rule-making and strict enforcement, PAGCOR can leverage its oversight of the supply chain to isolate and stifle illegal gambling enterprises, even if it doesn’t have direct police powers to raid or arrest those running the sites.
Coordinating with Other Agencies for Greater Impact
PAGCOR’s regulatory moves will have an even greater impact if complemented by the actions of other government bodies. A whole-of-government approach is advisable to truly shut down illicit gambling operations and their enablers. Key agencies that can support PAGCOR include:
- Tax and Corporate Regulators: The Bureau of Internal Revenue (BIR) and the Securities and Exchange Commission (SEC) should aggressively pursue unlicensed gambling service providers or offshore gaming content companies that are “doing business” in the Philippines without proper authority. This could mean auditing and penalizing entities for tax evasion and failure to register, or even coordinating with PAGCOR to refuse business permits to any service provider tied to illegal gambling. (Notably, Philippine law already requires online gaming operators to present a valid PAGCOR license before they can register with the BIR and pay taxes. Those operating outside the law obviously flout these requirements.) By invoking tax laws and corporate regulations, agencies can shut down or penalize suppliers profiting from the Philippine market without a license, hitting them with fines or closure orders for illicit operations.
- Telecommunications and Web Blocking: The National Telecommunications Commission (NTC) plays a crucial role in cutting off internet access to illegal gambling sites. In practice, PAGCOR coordinates with the NTC to block websites: when a suspicious gambling domain is reported, the NTC can issue a 72- hour “provisional block” on that site while PAGCOR verifies its status. After due process, longer-term blocking orders follow. This is an effective one-two punch - PAGCOR identifies illegal sites and the NTC makes them inaccessible to users in the Philippines. Even if illicit operators are based offshore, this strategy works: PAGCOR can invoke international cooperation (e.g. Mutual Legal Assistance Treaties) to go after operators abroad, while NTC simultaneously blocks local access and the Anti-Money Laundering Council (AMLC) freezes any Philippine linked bank or e-wallet accounts tied to the operation. Going forward, PAGCOR and NTC should continue to intensify website blocking, including mirror sites and new domains that illegal operators often spawn. By making it technically difficult for Filipinos to reach these unlicensed gambling platforms, it curtails the illegal market’s reach despite the borderless nature of the internet.
- Law Enforcement Action on Local Facilitators: Even though many illegal online casinos operate from overseas, they often maintain agents, marketing affiliates, or support offices on Philippine soil. The Philippine National Police (PNP), National Bureau of Investigation (NBI), and other law enforcement agencies should target these onshore points of contact. This means investigating and prosecuting any local representatives or sales agents of unlicensed gambling companies – for example, those who recruit players, handle payments, or provide technical support for the illegal sites. Such individuals or businesses could be charged under gambling laws (for abetting or conspiring in illegal gambling) or under general business laws for operating without a license. By sanctioning the local facilitators, authorities remove the “human infrastructure” that illegal operators rely on within the country. PAGCOR can assist by flagging leads (through its monitoring of the industry) and by providing expert support to these agencies, but the actual raids, arrests, and criminal prosecutions would be carried out by the PNP, NBI, and DOJ. This kind of inter-agency crackdown – with PAGCOR as the industry expert and regulator, and police as the enforcement muscle – has already been employed in cases like the 2023 raids on POGO hubs involved in fraud and human trafficking. Strengthening these collaborations (including with the Department of Information and Communications Technology for cyber forensics, and the DOJ for legal action) will ensure that illegal operators and their accomplices are not only deprived of service providers but are also actively investigated and brought to justice.Through strict rule-making and unified enforcement, PAGCOR and its partner agencies can significantly hamper the operations of unlicensed gambling outfits. While PAGCOR cannot unilaterally conduct armed raids or make arrests – those remain the domain of law enforcement – its policies can indirectly bring about the shutdown of “bad actors” by starving them of services and exposing them to criminal liability. In essence, PAGCOR’s role as a regulator and industry watchdog, bolstered by inter-agency support, is vital in cutting off the oxygen supply (games, funding channels, and local networks) that illegal online gambling operations need to survive. This multi-pronged strategy has proven effective in other countries and is increasingly crucial as the Philippines seeks to protect its gaming industry’s integrity and the public from the harms of illicit gambling.
At the end of the day, the current legal framework places PAGCOR in a critical but limited position: it is the gatekeeper for legal gambling and a key informant on illegal gambling, yet it relies on broader law enforcement machinery to actually crack down on the lawbreakers. Lawmakers and PAGCOR officials seem to agree that better coordination is the immediate solution – as Rep. Poe said, “we need all hands on deck” to address the billions being bled by illegal gambling. The public, too, has a stake: beyond revenue loss, illegal gambling can victimize individuals (through scams or unchecked addiction). Thus, clear delineation of responsibilities – PAGCOR regulating legal play, police and DOJ pursuing the illegal – with robust communication between them, is the enforcement model being strengthened under current laws. The limits on PAGCOR’s direct powers are there by design, to prevent abuse and conflict of interest, but with the ongoing reforms, those limits need not translate into impotence. Instead, PAGCOR’s regulatory reach, combined with the investigative muscle of the DOJ and the blocking capability of the NTC, can form a comprehensive response to illegal online gambling under existing statutes.
Citations
[1] Regulus Partners. (2024, September). Reducing online gambling black markets: An analysis of international practices used to combat online gambling black markets. Regulus Partners. Retrieved from https://www.entaingroup.com/media/zh2n0i0s/regulus-report-2024-black-marketgambling.
[2] Id.
[3] O’Boyle, D. (2022, September 23). Sweden to open applications for B2B licences on 1 March. iGaming Business. Retrieved from https://igamingbusiness.com/legal-compliance/licensing/swedenapplications-b2b-licences-1-march/
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