In recent weeks, the Philippine Congress has seen a surge of proposed legislation aimed at addressing online gambling some bills advocating for outright bans (Senators Pia and Allan Cayetano’s, Joel Villanueva’s) while others propose stricter regulations within the existing legal framework overseen by PAGCOR (Senator Sherwin Gatchalian’s). However, for any legislative measure to be effective and genuinely beneficial, it must first be founded upon accurate knowledge, comprehensive data, and global perspectives.

As our legislators deliberate on these proposals (and we can expect more to join), I respectfully invite them to undertake a few essential preliminary steps to ensure their efforts yield meaningful and enforceable outcomes.

First, legislators should take the time to familiarize themselves with the current legal and regulatory framework governing online gaming in the Philippines. As someone who deals with PAGCOR regularly - I can attest that the existing system includes rigorous processes and detailed rules designed to ensure transparency, fairness, and security in online gaming operations. Over the past 15 years, across multiple administrations, these rules have finally been codified and structured into a coherent and enforceable regime—and importantly, they are constantly updated to respond to technological developments, market trends, and emerging risks.

I was just at the IAGA conference in Berlin (IAGA, or the International Association of Gaming Advisors, is composed of a diverse group of gaming attorneys, top executives, financial advisors, regulators, consultants, and academics who gather to examine the industry’s future), and I can say with confidence that our framework is now more aligned with international standards than ever before. I continue to receive consistent feedback from colleagues across jurisdictions that the Philippines has made real progress in developing a rules-based system.

Understanding this evolving and strengthened regulatory environment is fundamental before proposing any new legislation. What we may need is not a new set of laws, but rather stronger enforcement, more coordinated implementation, and better support for the regime that already exists.

Second, lawmakers must ground their legislative proposals in accurate and relevant data. Assertions linking online gambling to various crimes, scams, and social harms need rigorous scrutiny. Differentiating between legal and illegal gambling operations is critical for targeted and effective legislation.

Third, it would be immensely beneficial for legislators to consider international experiences in regulating online gambling. Global insights provide invaluable lessons.Are there examples worldwide where complete bans successfully eradicated online gambling and associated problems, or do such prohibitions inadvertently bolster black-market operations? Conversely, how have jurisdictions that implemented strict but fair regulations fared in terms of consumer protection, revenue generation, and crime reduction?

I share these reflections not as a legislator, nor as someone merely familiar with drafting laws. Rather, I write from my professional perspective as a lawyer practicing for 15 years in technology, media, and gaming law, frequently guiding clients through complex PAGCOR application processes, meticulously studying PAGCOR’s gaming manuals, and continually being updated on best practices and standards adopted internationally.

An informed and nuanced legislative approach is crucial for addressing the genuine challenges posed by online gambling. It is with this aim of informed policy-making and robust regulation, rather than impulsive prohibition, that I offer the following analysis.

Criminalizing Players: The Flawed Approach of an Outright Ban

One of the pending bills (Villanueva Bill) takes the extreme step of criminalizing any person who “places, receives, or otherwise knowingly transmits a bet or wager” over the internet, making it punishable by up to six months’ imprisonment or a hefty fine. In effect, it turns ordinary players into criminals, without clearly addressing how the law intends to catch them. This approach is legally unsound and impractical. Unlike a physical casino that can be raided and padlocked, online gambling is borderless and anonymous – accessible via smartphones, encrypted apps, and offshore websites which makes enforcement extremely challenging. The bill provides no realistic mechanism for identifying and apprehending thousands of individual bettors in the privacy of their homes. Punishing users per se also misdirects enforcement toward the lowest rung of the gambling chain (the players) while ignoring organizers and operators. In a professional legal view, this is a misguided and overbroad strategy: it may deter a few casual bettors, but serious gamblers will simply move to unregulated platforms or use VPNs to evade detection. The net effect could be to push online betting further underground, making it even harder for authorities to monitor or control – the exact opposite of the bill’s intent. [1] In short, an outright ban that criminalizes players without an enforceable plan is more likely to clutter dockets and encroach on individual liberties than to meaningfully curb gambling activity. [2] Moreover, by targeting players rather than focusing on illegal operators, the proposal fails to recognize a fundamental enforcement problem: demand for gambling will persist despite criminalization. History shows that when a popular activity is banned,

it often resurfaces in black markets rather than disappearing.[3] The experience with online gambling bans in other countries is instructive – a point we return to below. Simply put, penalizing Filipino internet users for placing a bet online, without robust enforcement infrastructure, is a knee-jerk response that betrays a lack of practical legal foresight. A more nuanced approach is needed – one that differentiates between hardened illicit operators and mere consumers, and that realistically accounts for the complexities of policing the internet.

Questionable Claims in the Whereas Clauses

The explanatory note (or “whereas” clauses) of the Cayetanos’ bill paints online gambling as an inherent menace. It asserts that “online gambling has… become a breeding ground for serious criminal activity,” linking it to “fraud, cybercrime, money laundering, and even human trafficking” and concluding that there is an “urgent need” to prohibit it outright. These alarmist claims, however, do not withstand scrutiny when applied to regulated online gambling operations. There is scant evidence that licensed online gaming platforms – those under Philippine Amusement and Gaming Corporation (PAGCOR) oversight – have been hotbeds of such crimes. In fact, the gravest criminal incidents associated with gambling in recent years stemmed from illegal or poorly supervised operations, not from properly regulated online casinos. The reference to human trafficking and cybercrime, for instance, likely alludes to cases involving Philippine Offshore Gaming Operators (POGOs), which at one point were linked to criminal rings and abuses. But those problems arose from a lack of oversight and unscrupulous actors, not from the inherent nature of online gambling. It is misleading to conflate the POGO experience with all online gambling. In contrast, duly licensed online gambling in the Philippines has not been shown to generate kidnappings, trafficking, or large-scale fraud – such allegations have not been reported in the context of regulated local e-casino or sports betting platforms. The blanket characterization of online gambling as a “breeding ground” for crime is therefore exaggerated and unsupported by data. The Cayetanos’ bill also cites the “Gambling WHO Fact Sheet” when it stated that “online gambling is strongly associated with adverse mental health outcomes, including addiction, anxiety, and depression…”. What it fails to provide is that the same WHO Fact Sheet does not say that an outright ban is the solution. Rather, it focuses on proper regulation and concludes that “…WHO acknowledges the need for Member States to closely monitor and effectively regulate gambling operations, products and activities.”

Indeed, under PAGCOR’s existing regulatory framework for online gambling, operators are subject to rigorous audits and compliance checks, and transactions are traceable – measures specifically designed to combat fraud and money laundering. Every licensed online platform’s software and hardware must be independently certified for fairness and security (e.g. testing by accredited labs to international standards) before launch. [4] PAGCOR also maintains a real-time monitoring system that links directly to operators’ betting servers, feeding data to the regulator within 60 seconds of each wager. This means suspicious activities (large irregular bets, anomalous payouts, etc.) can be quickly flagged and investigated, making it very difficult for criminals to exploit licensed platforms for money laundering or fraud. In short, a licensed online casino in the Philippines operates under strict scrutiny “within the watchful eye of the state”. By contrast, unregulated gambling sites (often operated offshore) truly fit the whereas clause’s dire description – they do provide a haven for illicit activities because they operate in the shadows, outside of Philippine law. It is telling that proponents of a ban cite criminal cases “linked to online gambling operations” without distinguishing whether those were legal or illegal operations. The lack of reported criminal breaches in PAGCOR-supervised online gaming suggests that the current licensed regime has been largely effective in mitigating the very risks cited.

The whereas clause also ignores the robust safeguards that regulated operators are already required to implement. All personnel working in gaming operations must be registered and vetted, with Gaming Employment Licenses and mandatory training on responsible conduct, ensuring that employees themselves are accountable.[5] Allegations of rigged games or defrauded players, common in unlicensed schemes, are practically unheard of under PAGCOR’s watch – the platforms are continuously audited for fairness, and cheating customers would cost a licensed operator its franchise. Likewise, concerns about fraud are misplaced: online platforms authorized by PAGCOR must implement high-level IT security and even undergo vulnerability assessments and penetration testing as part of maintaining their license, very much like banks and fintech companies do. Major banks and payment gateways will only integrate with an online gaming system after extensive due diligence and security audits (e.g. VAPT certificates), meaning that legal online betting sites in the Philippines are vetted not just by regulators but by financial institutions as well. These checks make large-scale fraud or hacking scandals exceedingly rare in the licensed online gaming sector. In summary, the “breeding ground for crime” narrative is largely a straw man when it comes to regulated online gambling – the real breeding grounds are the unlicensed outfits that a blanket ban would ironically empower (by eliminating their legal competition).

Redundant Measures: Existing Laws and the Task Force Proposal

Another feature of one of the bills seeking an outright ban is the creation of an “Online Gambling Control Task Force (OGCTF)” under the Office of the President, composed of PAGCOR, the Department of Information and Communications Technology (DICT), Department of Justice, AMLC, law enforcement agencies, etc., charged with coordinating enforcement against online gambling. While inter-agency coordination is generally laudable, this provision is redundant. Illegal gambling (including online gambling) is already a crime under existing laws, and agencies today already have

the mandate to coordinate on cybercrime matters. Notably, the Cybercrime Prevention Act of 2012 (Republic Act No. 10175) covers crimes committed “by, through and with the use of” the internet. It explicitly provides that all offenses punishable under other laws (including our gambling and anti-illegal gambling laws) that are committed via computer systems are within its ambit. In other words, if someone operates an illegal gambling website or places bets online illegally, that conduct is already punishable with heightened penalties under RA 10175 in conjunction with our gambling laws.[6] The Philippine National Police and NBI each have dedicated cybercrime units that have, in fact, raided illegal online gambling operations using this existing authority (often in coordination with PAGCOR for technical expertise). Rather than legislate a new inter-agency committee (within “30 days” no less, an almost impossibly short timeline for organizing multiple agencies), Congress could simply support the existing cybercrime and anti-illegal gambling councils by providing them more resources or clearer authority. A targeted amendment to strengthen these mechanisms would be far more efficient than reinventing the wheel.

In summary, enforcement tools to combat illegal online gambling already exist – what is needed is the political will and resources to use them, not a duplicative task force. Declaring all online gambling illegal and then scrambling to stand up a task force suggests a shoot first, figure it out later approach. A more sensible legislative path would be to sharpen the existing enforcement regime. I will give a very specific example. We often assist clients in reporting illegal gaming websites. However, PAGCOR does not have the authority to take them down, so the process for such takedowns includes writing a letter-report to PAGCOR, thereafter PAGCOR will write the NTC (National Telecommunications Commission) Commissioner attaching our report and confirming that the websites are not licensed under PAGCOR. NTC then reviews and writes the ISPs, ordering them to block these sites. At this time (around two weeks after), a hundred other sites have been created.

PAGCOR is of course always blamed, but few understand that PAGCOR only has regulatory powers over those licensed under the agency. These kinds of focused enhancements could be done without dismantling the current licensed industry that is compliant and taxable.

Target the Real Problem: Illegal Gambling and How to Combat It

The real enemy, as any seasoned observer knows, is illegal gambling – operations that bypass all regulations, pay no taxes, and offer no player protections. If the goal of lawmakers is to eliminate the social ills of gambling (addiction, crime, family harm), then the logical approach is to surgically strike at these illicit operations, not to outlaw the entire industry and penalize legitimate stakeholders. A policy response should prioritize stamping out illicit operators, who are the true source of gambling-related social ills. What might such a targeted law contain? Rather than a blunt ban, a wellcrafted bill could include provisions such as:

  • Regulations for B2B Providers: A key strategy in many jurisdictions for combatting illegal online gambling is to focus on the broader ecosystem of support services that enable these platforms to operate. This includes not only game providers or B2B suppliers—who often do not develop their own games but instead rely on outsourced technology—but also marketing affiliates, influencers, and endorsers who lend visibility and perceived legitimacy to unlicensed operators. For example, well-known Filipino athlete Kai Sotto has publicly endorsed 1XBet, an unlicensed online gaming platform that continues to advertise and target Filipino players. These illegal sites are even allowed to sponsor major events in the Philippines, gaining exposure and public acceptance despite operating outside of PAGCOR’s regulatory framework. Importantly, PAGCOR has recognized this risk and has issued specific rules requiring the accreditation of gaming affiliates and support service providers. Under these rules,[7] entities such as marketing agencies, social media managers, and public endorsers that promote gaming platforms must ensure that their clients are licensed. Failure to do so may result in penalties or disqualification from future engagements with PAGCOR-accredited operators. These measures are meant to close the regulatory gaps and hold accountable not just the illegal operators, but the broader network that enables their continued presence in the market.
  • Let’s Target Illegal Gambling; Stiffer Penalties for Unlicensed Operators and Facilitators: Increase the penalties for those who organize or profit from unauthorized online gambling. Rather than penalizing the regulated sector - which already complies with PAGCOR’s standards, pays taxes, creates jobs, and implements responsible gaming policies—lawmakers should focus their efforts on eliminating the root of the problem: illegal and offshore operators. These are entities that deliberately evade regulatory oversight, bypass KYC protocols, and often target vulnerable communities through aggressive marketing and influencer-based promotions.
  • ISP and Payment Blocking Mandates: Require Internet service providers and financial intermediaries to block access to known illegal gambling websites and to refuse processing of gambling payments to unlicensed entities. Regulators could maintain an updated blacklist of illicit websites, similar to what some countries do, and ISPs would be legally compelled to restrict those URLs. Banks and e-wallets, for their part, could be required to flag and halt transfers to known gambling merchant codes or offshore payment accounts, in coordination with the Bangko Sentral and AMLC. E-wallets should also not be viewed as enablers of online gambling harm—but rather as one of the most effective control layers available in our ecosystem. Unlike traditional cashbased transactions or untraceable crypto payments, e-wallets implement the strongest Know-Your-Customer (KYC) protocols under existing financial regulations. These systems are already effective at blocking minors and flagged individuals from transacting on gambling platforms. In fact, many of the e-wallets used today are already integrated with national ID systems and real-time fraud detection tools. Moreover, every peso spent by players - or received by operators - is recorded, allowing regulators and financial authorities to audit transactions for red flags, such as problem gambling behavior or potential money laundering. If legislators ban or limit the use of ewallets in the gaming context, the likely outcome is not reduced play - but rather a shift back to grey and unregulated markets where there is zero visibility, zero compliance, and zero protection for consumers.
  • Streamlined Site-Blocking Orders and Domain Seizure: Authorize a swift administrative or judicial process for the government to obtain takedown orders or block orders against websites offering unlicensed gambling. The key is to make the process nimble: illegal domains can proliferate quickly, so authorities need the ability to block mirror sites and new domains in real time. Perhaps empower the cybercrime units to seek ex parte court orders to block sites within 24 48 hours, subject to post-blocking judicial review to balance due process.
  • Inter-Agency Enforcement Coordination: Rather than creating a new task force, the law can formalize collaboration among PAGCOR, law enforcement, and tech agencies to combat illegal gambling. For example, it could designate PAGCOR as the lead agency to liaise with foreign jurisdictions and international regulators (since many illegal sites are offshore) – a role PAGCOR already effectively plays – while the DOJ’s cybercrime office takes charge of domestic prosecution. Regular joint operations and intelligence-sharing should be institutionalized. (Notably, the ban bill’s OGCTF concept is basically this idea, but it need not be a new bureaucracy; it could function as a council of existing bodies.) The law could also establish a whistleblower program or hotline (as the Cayetano bill suggests) to encourage insiders or the public to report clandestine gambling dens or online rackets, with rewards or anonymity assurances.
  • International Benchmarking: The Philippines should look to more mature international jurisdictions for guidance. Regulators can actively seek partnerships with global technology providers and experienced gaming companies to adopt best practices, tools, and technical solutions. There are already proven technologies available to combat illegal online gaming - ranging from geolocation tracking, IP filtering, and transaction surveillance to sophisticated responsible gaming systems that use behavioral analytics to identify and intervene in cases of problem gambling. Anti-money laundering (AML) safeguards developed in high-compliance jurisdictions can also be adapted locally. Instead of reinventing the wheel, we should be tapping into the collective expertise of global stakeholders to build a modern, responsive, and effective regulatory regime. Many of my clients from the EU, UK and US are ready to provide this.
  • Public Education and Rehabilitation Fund: If Congress truly wishes to mitigate gambling’s ill effects, it should invest in problem gambling prevention and treatment. Even as we penalize illegal operators, a portion of fines andconfiscated assets can be earmarked for a “Victims’ Assistance and Rehabilitation Fund” – similar to what the Cayetano bill proposes. These funds can support counseling services, create public awareness campaigns about the dangers of unlicensed gambling websites (which often scam players), and bolster responsible gaming initiatives. In short, pair the stick of enforcement with the carrot of social support for affected individuals. It is worthwhile to note that PAGCOR has already mandated its licensees to set aside a fund for such programs.

By focusing on these targeted measures, lawmakers can attack the core of the problem – the lawless operators – rather than casting a wide net that also entangles legitimate businesses and individual freedoms. Such an approach recognizes that the “online” aspect of gambling is not the core evil; the real problems are addiction and criminality, which thrive in the shadows, not in regulated daylight. Indeed, as the position paper submitted to Congress aptly put it, “a blanket ban would forfeit the control and transparency that come with regulation, and hand over the market to unscrupulous illegal operators who evade taxes, ignore rules, and offer no consumer protections”. The smarter legislation, therefore, is one that fortifies the regulatory walls and aggressively ferrets out the outlaws, rather than tearing down the entire house.

Embracing Stricter Regulation of Legal Online Gaming: A Better Path Forward

Not all pending bills take the prohibitionist stance. There are also proposals aiming to tighten the regulation of online gaming while keeping it legal under strict controls. This approach is far more promising. For example, Senator Win Gatchalian’s draft “Online Gambling Regulatory Act” seeks to impose comprehensive safeguards on online gambling operations instead of banning them outright. Such regulatory measures acknowledge a key reality: if properly regulated, online gambling can be made reasonably safe, transparent, and accountable. By bringing operators into the legal fold and then holding them to exacting standards, the government can protect consumers and reap economic benefits (tax revenue, jobs, technological innovation) without the downsides of an underground industry. Key provisions in the regulatory approach include robust Know-Your-Customer (KYC) protocols and age restrictions to protect the youth. For instance, the Gatchalian bill flatly prohibits persons under 21 years old from registering or playing on online gambling platforms, and requires operators to verify age and identity through government IDs, biometrics, or even facial recognition technology. This is already in line with PAGCOR’s current rules, which already mandate age verification and even maintain a nationwide Self-Exclusion Program allowing individuals (or their families) to ban themselves from all gambling venues and sites. Additionally, regulating online gambling allows the imposition of responsible gaming features by law: time and bet limits, clear display of wagering histories, pop-up reminders for prolonged play, and easy access to helpline information. PAGCOR presently requires licensed operators to display responsible gambling messages, offer self-imposed betting limits, and facilitate self-exclusion – these can be further strengthened in new legislation. For example, Congress could mandate that all licensed platforms implement a default loss limit or “cooling-off” period after a certain hours of continuous play, unless the player opts out with proof of financial capability. These kinds of fine-tuned controls target addiction risk directly, something a blanket ban pretends to do but cannot actually enforce.

Another vital area is advertising and promotion, which a regulatory law can tightly circumscribe. The draft regulatory bill requires that any online gambling advertisements be “socially responsible”, not targeting minors or vulnerable groups, and never misleadingly suggesting that gambling is a solution to financial problems. It even prohibits gambling ads in schools or youth-oriented events. These are prudent measures and again, are ALREADY mandated by PAGCOR. By contrast, in an outright ban scenario, advertising would vanish from lawful companies but black-market gambling would still quietly advertise in illicit ways (spam, word-of-mouth, etc.), with zero standards. Regulation, therefore, gives the Stat leverage to ensure marketing is done in a muted and responsible manner, if at all. The bills proposing stricter regulation also sensibly call for third-party auditors and compliance monitoring, recognizing that independent oversight (e.g. external IT security audits, financial audits, game fairness certification) adds an extra layer of accountability. PAGCOR already employs third-party testing labs for games and requires ISO-standard security certifications; enshrining these in law will further cement those best practices. Crucially, a regulated model is one where stakeholders can collaborate to fine-tune the system. The government, industry, tech experts, financial sector, and even civil society can all contribute to crafting rules that are enforceable and effective. For instance, regulators can work with banks on how to best implement transaction monitoring without stifling legitimate commerce. They can work with platform operators on implementing advanced player protection tools (data analytics to detect problem gambling behavior, for example). The legal framework can be dynamic – if certain games prove too addictive or problematic, the regulator can tweak or restrict them (instead of having to prohibit everything by law). This flexibility is only possible if online gambling remains legal and regulated. Otherwise, with a ban, the government loses all influence over an activity that will likely continue regardless. It is also worth noting the economic and technological benefits of a regulated regime. The Philippines has developed significant institutional knowledge in online gaming regulation through PAGCOR. Reputable international gaming companies have engaged Filipino engineers, creatives, and support staff in legal operations. These generate revenue and employment that benefit the economy. A collaborative regulatory reform could address shortcomings (say, ensuring revenue is properly taxed, or that only persons of good moral standing can be licensees) without throwing away the proverbial baby with the bathwater. In contrast, a ban would likely just drive these companies and jobs offshore, as happened when other countries abruptly outlawed segments of gambling – only to see a rise in offshoring and loss of local visibility.

The growth of the Philippine Inland Gaming Operator (PIGO) model should not be misinterpreted as a rise in gambling addiction. On the contrary, it signals a positive migration from the grey market into a regulated and accountable space. Back in 2022, grey or offshore gaming was estimated to be nearly four times the size of the licensed domestic market. Today, over 55 % of online activity is now channeled through legal, tax-paying PIGOs—a dramatic shift toward legitimacy and protection. This shift enhances consumer protections, introduces responsible gaming tools, and brings significant revenue to the state—all outcomes that would be impossible in an unregulated setting. In Q1 2025 alone, PAGCOR reported e-games revenue of ₱51.39 billion - accounting for nearly half of the industry’s ₱104.12 billion gross gaming revenue - demonstrating strong market capture and fiscal benefit. The growth in regulated platforms is a policy win, not a warning sign. In sum, the regulatory approach is a constructive path: it acknowledges the realities of the digital age (that you cannot simply ban the internet at the borders), it leverages the “eye of the state” to keep gambling transparent, and it focuses on mitigation of harm through rules rather than naive prohibition.

International Lessons: Regulation Works Where Prohibition Fails

Any debate on gambling policy should be informed by the experiences of other jurisdictions. We have ample global evidence that outright bans on online gambling rarely work as intended. No country has successfully eradicated the social ills of gambling merely by banning online gambling – on the contrary, the usual outcome is that gambling goes underground, and the very problems the ban sought to solve (addiction, fraud, criminality) often worsen. Let’s consider a few examples:

  • China maintains one of the world’s strictest bans on all forms of online gambling (aside from state lotteries). Yet, by the Chinese government’s own estimates, hundreds of billions of yuan are wagered illegally each year by Chinese punters through offshore websites. Massive underground networks have emerged, utilizing VPNs, cryptocurrencies, and front companies to circumvent the ban. Despite aggressive crackdowns – including cross-border arrests and the Great Firewall’s censorship – online gambling remains widespread in China, accompanied by the very cybercrimes and capital flight issues that concern policymakers. In short, prohibition there has not been an effective deterrent; it has mainly driven the activity into harder-to-reach channels.
  • Vietnam and Indonesia likewise outlaw online gambling and impose stiffcriminal penalties. Yet enforcement struggles to keep up. In Vietnam, police have busted massive illegal online betting rings involving tens of thousands of users and hundreds of millions of dollars in turnover. Officials admitted that the lack of legal alternatives pushes players into the arms of criminal networks. Indonesia’s authorities block thousands of websites every month, but gambling still thrives via encrypted apps, chat groups, and foreign-hosted sites, with billions in bets flowing out to offshore operators. It’s a continuous cat-and mouse game, where regulators are perpetually one step behind tech-savvy illicit operators. These countries also illustrate another cost of blanket prohibition: zero tax revenue from gambling and zero visibility into the market. All play happens in the black market, meaning the state cannot even monitor patterns to preempt crimes like match-fixing or to offer help to problem gamblers. By stark contrast, jurisdictions that have embraced robust regulation have generally seen better outcomes both in terms of revenue and harm reduction. Take the United Kingdom, for example. The UK chose to legalize and regulate online gambling comprehensively under a licensing regime (Gambling Act 2005). As a result, today approximately 98% of online bets in the UK occur on legal, licensed sites, with only ~2% on black-market sites.[8] High “channelization” (i.e., the proportion of gamblers using legal channels) means the illegal market is negligible. The benefit? The UK government collects billions in taxes each year from online betting, and consumers enjoy strong protections – such as mandatory age verification, self-exclusion programs, and a dispute resolution system – which are nonexistent in the underworld. The UK Gambling Commission actively works with operators to monitor and prevent fraud, money laundering, and match-fixing, leveraging data from the regulated industry to catch illicit activity. Rather than gambling being a free-for-all, it is largely contained within a framework where authorities can keep watch and intervene when needed. The result has been a safer gambling environment and a reduction in truly criminal gambling enterprises. I strongly encourage our lawmakers to read the September 2024 report by Alvarez & Marsal, Online Gambling Regulation: International Precedent and Best Practice, which offers a comprehensive, evidence based analysis of regulatory approaches across jurisdictions and highlights how well designed regulation can achieve high channelization, generate tax revenue, and reduce gambling-related harm. Other European countries like Sweden and Italy have comparable success stories after moving from prohibition or monopoly to regulated regimes. Sweden’s channelization of online gambling rose to ~80–85% once it opened up licensing in 2019, meaning the majority of Swedish bettors moved to domestically regulated sites from previously offshore sites. Italy’s regulator, by embracing licensing, gained the capability to block thousands of illegal websites and enforce anti-money laundering rules on licensees – tools they simply didn’t have when online gambling was taboo. The overarching lesson from abroad is clear: countries that regulated online gambling have largely succeeded in keeping the activity within accountable channels and minimizing criminality, whereas those that stuck to blanket bans are still fighting ghosts in the dark. As one analysis summarized, attempts at prohibition often “drove play to rogue websites… whereas replacing [ban] with a regulated regime enabled authorities to monitor the market and address crimes in ways not possible before”. [9] Thus, when Philippine legislators ask, “What country has banned online gaming and solved the problems we worry about?” – the honest answer is none that provide a convincing example. On the contrary, our neighbors and international partners offer more cautionary tales of failure, or positive models of regulation, than any success story for prohibition. The prudent course for the Philippines is to learn from these precedents: avoid the path that has failed elsewhere, and instead adapt the best practices of jurisdictions that have balanced gambling and governance. We already have, in PAGCOR’s system, many elements of those best practices. Rather than scrapping it, we should be building on it.

Conclusion: Towards a Balanced and Effective Policy

Online gambling is a polarizing issue, especially in a country like the Philippines, and the impulse to ban it outright is often driven by commendable intentions – protecting the young, shielding society from addiction and crime, upholding moral values. However, as this analysis has shown, good intentions do not automatically make good law. An outright ban, especially one structured as clumsily as penalizing individual bettors, is more likely to create a host of new problems: unenforceable mandates, invasion of privacy, loss of legitimate economic activity, and a boom for illegal operators who will fill the void. It is far wiser to target the true problems (unlicensed gambling and problem gambling) with precision tools rather than wield a sledgehammer that misses the target and breaks the surrounding structure. From a legal standpoint, we already possess the tools to police illegal online gambling – what’s needed is to sharpen them. And from a policy standpoint, we should recognize that regulated online gaming, done right, can coexist with social welfare. Just as total alcohol prohibition gave way to regulated sale plus drunk driving laws and age limits, gambling too can be managed. Stricter regulation, not prohibition, strikes the better balance between individual freedom and public interest. It allows the government to keep gambling visible and controllable, to intervene when there is fraud or abuse, and to channel economic gains to the public good (including funding rehabilitation for those who do develop problems). The current controversy is an opportunity for lawmakers to craft a comprehensive, fair, and evidence-based policy on online gambling. That means engaging stakeholders – regulators, law enforcement, operators, mental health professionals,

even the players themselves – in a dialogue about how to make online gambling safer. It also means being humble enough to heed international lessons: no law operates in a vacuum, and attempting to outlaw internet-based activities by fiat has consistently proven quixotic. The Philippines can instead position itself as a regional model for smart gambling regulation, balancing innovation with responsibility. In closing, the choice need not be “morals versus money” as some prohibitionists frame it. A well-regulated system can uphold our societal values (by keeping vice in check) while also harnessing the realities of the digital economy. The real enemy is not the internet, nor gambling per se – it’s the unchecked, unregulated exploitation that flourishes when we turn off the lights and pretend a problem has gone away. Legislate with eyes wide open. In the realm of online gambling, banning the light will only let the shadows grow. Let us instead shine that light brighter through sensible regulation and steadfast enforcement of the laws that truly matter.

Citations

[1] Stewart, D. (2006, May). David Stewart examines policy implications of Internet gambling. Ropes & Gray LLP. https://www.ropesgray.com/-/media/files/publications/2006/05/david-stewart-examines-policy-implications-of-internet-gambling.pdf

[2] Sparrow, M. K., Bazelon, C. D., & Jackson, C. (2009, December 2). Can internet gambling be effectively regulated? Managing the risks. John F. Kennedy School of Government, Harvard University.

[3] Kulick, J. D., Prieger, J. E., & Kleiman, M. A. R. (2015, July 13). Unintended consequences of cigarette prohibition, regulation, and taxation. Pepperdine University.

[4] PAGCOR. (2025). Regulatory framework for the accreditation of service providers and processing of system-related requests (Rev. No. 3). https://www.pagcor.ph/regulatory/pdf/GSRM/Regulatory%20Manuals/Regulatory%20Framework%20for%20the%20Accreditation%20of%20Service%20Providers%20and%20Processing%20of%20System-Related%20Requests%20Rev.%20No.%203.pdf

[5] PAGCOR. (2016, April). Gaming Employment License manual for employers (Version 3.0). https://www.pagcor.ph/regulatory/pdf/Gaming%20Employment%20License%20Manual%20for%20Employers.pdf

[6] Republic Act No. 10175 (Cybercrime Prevention Act of 2012) § 4(c), § 6 (Phil.).

[7] PAGCOR. (n.d.). Regulatory framework for the accreditation of gaming affiliates and support service providers (Rev. No. 0). https://www.pagcor.ph/regulatory/pdf/GSRM/Regulatory-Manuals/Regulatory-Framework-for-the-Accreditation-of-Gaming-Affiliates-and-Support-Service-Providers-Rev-No-0.pdf

[8] Alvarez & Marsal. (2024, September). Online gambling regulation: International precedent and best practice. Prepared for the Betting and Gaming Council.

[9] Ibid.

www.ardenconsult.org