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The POGO Ban Philippines represents one of the country’s biggest regulatory actions against offshore gaming, significantly reshaping AML compliance, banking oversight, and financial crime prevention. Here’s what compliance teams, banks, and fintechs need to know about the 2024 pogo ban philippines crackdown – and what it means for AML obligations moving forward.
Overview of the 2024 POGO Ban in the Philippines
On November 5, 2024, Executive Order No. 74 formally banned all philippine offshore gaming operations, internet gaming licensees, and related offshore gaming services nationwide. The order required every existing POGO and IGL license holder to cease operations by December 31, 2024, or face criminal prosecution.
The ban targets both properly licensed philippine offshore gaming operators and illegal offshore gaming operations that never obtained valid permits. It also sweeps in pogo accredited service providers – payment processors, call centers, BPO firms, and ancillary hubs.
This policy didn’t emerge overnight. President Marcos announced a nationwide POGO ban on July 22, 2024, citing years of mounting controversies. POGOs have been linked to money laundering concerns, human trafficking, cyber-scams, and sustained diplomatic pressure from China, which in 2019 called POGOs a “dangerous tumor.” Economic managers concluded that the social and reputational costs of POGOs outweighed their benefits, despite the sector’s revenue contributions.
For regulated institutions, the ban carries sharp implications for AML, KYC, and broader financial crime compliance – particularly for banks and fintechs that serviced POGOs or entities within the offshore gaming ecosystem.
What Are Philippine Offshore Gaming Operations (POGO) and IGL?
Philippine offshore gaming refers to enterprises operating within the Philippines but targeting bettors located outside the country. Typical offerings included livestreamed e-casino tables, online RNG casino games, sportsbook platforms, and online games accessible via gaming websites and gaming software hosted on Philippine-based servers.
In late 2023, PAGCOR renamed POGOs to internet gaming licensees to distinguish its updated licensing framework. IGLs were subject to regulatory requirements – licenses, tax registration, oversight – but enforcement was uneven. Many entities ran without proper permits or under opaque structures, complicating oversight by relevant government agencies.
Legally, offshore gaming operators were never permitted to serve bettors inside the Philippines. Their revenue models were premised on foreign clients, which created regulatory gaps: identity verification of foreign workers, beneficial ownership transparency, and monitoring of cross-border payment flows were consistently weak.
The Philippine Offshore Gaming Operators contributed about 0.2% to the GDP in 2022. In 2020, there were 70,000 Chinese workers in POGOs, and POGOs reportedly limited hiring of Filipinos in 2019. These dynamics – combined with exposure to money laundering, fraud, and human trafficking – made the sector a persistent compliance headache for any institution touching POGO-related financial flows.
Key Provisions of the 2024 Nationwide POGO Ban
The central policy under Executive Order No. 74 is an immediate nationwide ban on philippine offshore gaming, internet gaming, and all other offshore gaming operations. All new POGO/IGL license applications, renewals, and auxiliary service accreditations are prohibited under the philippine amusement and gaming corporation and any other licensing authority.
Key deadlines:
November 5, 2024: EO 74 signed; no new licenses or renewals permitted
December 15, 2024: PAGCOR formally cancels all remaining POGO licenses
December 31, 2024: All operations must cease entirely
By December 31, 2024, all 42 internet gaming licenses and 18 authorized service providers had been cancelled. A total of 304 physical POGO sites were closed nationwide.
Individuals conducting or aiding offshore gaming operations past these deadlines face severe criminal penalties, including prosecution under existing laws on illegal gambling and the anti money laundering act. The order did not create an entirely new statute – it leverages republic act provisions, penal code sections, and executive authority to reclassify remaining offshore gaming operations as illegal. PAGCOR failed to collect ₱2.2 billion in unpaid dues from POGOs, underscoring why strict enforcement became unavoidable.
Legal Grounding: Republic Acts, PAGCOR Authority, and the Supreme Court
PAGCOR – the Philippine Amusement and Gaming Corporation – holds the statutory mandate to license, regulate, and oversee gambling under its charter and enabling legislation, including relevant republic act no provisions governing the gaming corporation’s authority. Prior to the ban, PAGCOR issued rules for philippine offshore gaming that were challenged in court by stakeholders questioning the agency’s jurisdiction over offshore operations.
The supreme court dismissed petitions questioning PAGCOR’s authority over POGOs, effectively upholding the regulatory framework for offshore gaming before the 2024 policy shift. This judicial backing gave the executive branch solid legal footing for EO 74.
The November 2024 order does not legalize new gambling activity. Instead, it uses executive power and existing laws to phase out and classify remaining offshore gaming operations as illegal after the cutoff. The ban also aligns with broader legislative momentum: Republic Act No. 12312, signed on October 23, 2025, declared all POGOs illegal – institutionalizing the ban through congressional action. This legislation, referred to as the anti pogo act (or the Anti-POGO Act of 2025), permanently institutionalizes the ban on POGOs.
Financial institutions must still comply with AML/CTF obligations under the anti money laundering council framework and related republic acts, even as the sector winds down. The national internal revenue code also continues to apply to tax settlement obligations.
Ban of POGO/IGL and Other Offshore Gaming Operations
The order explicitly bans the issuance of new licenses to any offshore gaming operators, IGL, or auxiliary provider. This includes pogo gaming content providers, pogo services provider entities, and firms that offer offshore gaming technology or marketing services from Philippine territory.
All ongoing offshore gaming businesses targeting foreign clients must gradually cease by December 31, 2024. Existing licensees are required to:
Close physical and digital operations
Settle all taxes, fees, and outstanding obligations with the Bureau of internal revenue
Terminate leases and service contracts
Cancel alien employment permits for foreign staff
Repatriate or downgrade visas for foreign workers
Any offshore gaming operators that never obtained proper PAGCOR licenses are immediately classified as illegal and prioritized for law-enforcement action. The government has signaled zero tolerance for attempts to conceal offshore gaming operations under alternative corporate structures or renamed entities.
The ban covers both on-premises pogo hub locations – including pogo buildings, dormitories, call centers – and distributed online platforms. This extends to servers, marketing offices, and communication technology devices operating from Philippine territory. Approximately 40,000 workers nationwide were displaced by the shutdown, with the largest hub (Island Cove compound in Kawit, Cavite) spanning 33 hectares with 57 buildings.
Comprehensive Strategy and Technical Working Groups (TWGs)
EO 74 mandates the creation of inter-agency Technical Working Groups tasked with implementing the ban and ensuring proper and effective implementation across national government agencies. These TWGs are responsible for designing a comprehensive strategy that balances enforcement with economic transition.
TWG membership includes representatives with decision-making authority from:
PAGCOR
Law enforcement agencies (PNP, NBI)
Bureau of Immigration
Department of Labor and Employment (DOLE)
Department of Foreign Affairs
Other concerned agencies including the Presidential Anti-Organized Crime Commission (PAOCC)
The respective heads of these bodies coordinate on visa cancellation schedules, enforcement timelines, and intelligence sharing. A key TWG mandate is planning upskilling, reintegration, and employment programs. Filipino workers displaced by the ban received assistance for transitioning to other jobs through DOLE job fairs and livelihood programs managed by the skills development authority and non government organizations.
For compliance readers, TWG reports and guidelines will directly influence how banks and payment firms handle account closures, suspicious transaction reports, and customer due diligence for POGO-linked clients during the wind-down period.
Directives to National Government Agencies
EO 74 assigns specific enforcement roles to core law enforcement agencies:
Agency | Role |
|---|---|
PAOCC | Lead enforcement against organized crime, scam hubs, and trafficking linked to POGOs |
PNP / NBI | Conduct raids, arrests, and criminal investigations |
Anti-Cybercrime Group | Target cyber-fraud, gaming websites used for scams, and information and communications technology-enabled crimes |
Bureau of Immigration | Cancel or downgrade 9G visas for such foreign national workers employed under POGOs in staged batches |
BIR | Conduct final tax audits and collect outstanding fees |
DOLE | Manage local and foreign employment transition |
These above agencies must intensify operations against illegal offshore gaming operations, including hubs involved in scams, kidnappings, and human trafficking. The Department of Human Settlements ensures that residential or commercial buildings are not repurposed as POGO offices, while the Department of Tourism monitors hotels and resorts.
Special economic zone authorities, including the cagayan economic zone authority and other enterprise zone authority bodies, as well as investment promotion agencies, are directed to revoke any POGO-related registrations. For financial institutions, this cross-agency coordination will likely increase requests for KYC files, beneficial ownership data, and transaction monitoring records related to POGO-linked accounts.
Local Government and Private Sector Support
Local government units are encouraged to pass ordinances and enforce existing local codes to suppress illegal gambling and offshore gaming within their jurisdictions. The Department of the Interior and Local Government (DILG) coordinates monitoring of local government actions – from zoning enforcement to building inspections and business permit revocations.
The order calls for private sector cooperation from landlords, lessors, building administrators, and providers of ancillary services such as security service, janitorial, internet connectivity via respective internet service providers, and utilities. Any duly constituted business enterprise providing services to POGOs is urged to cooperate with the wind-down.
To accelerate shutdowns, the government encourages waiving penalties and fees tied to early contract termination with POGOs/IGLs. The consequences of the ban included increased vacancy rates in commercial properties and reduced rental income – but continuing to service POGO entities post-ban carries far greater legal and reputational risk.
The ban also resulted in the exit of foreign investors primarily from China and other regions. For banks and payment companies, proper collaboration with authorities must balance lawful disclosure with client confidentiality. The securities and exchange commission and other government agencies may request financial standing reports or beneficial ownership disclosures during investigations.
Issues, Controversies, and High-Profile Raids Leading to the Ban
From 2016 onwards, POGOs proliferated – from fewer than a hundred to over 300 licensed entities at peak. In 2019, nearly 200 illegally-operated POGOs were shut down, yet the sector continued expanding with weak oversight over tax registration, beneficial ownership, and the financial standing of operators.
POGOs were linked to various criminal activities including human trafficking and money laundering. From January 2017 to June 2023, 4,355 crime victims were recorded. Of those, 65 of 113 cases from 2019 to 2023 involved human trafficking. In 2023, police raids rescued almost 5,000 victims from POGOs. From 2017 to 2019, ₱14 billion of transactions were suspicious, highlighting the scale of financial crime flowing through the sector.
Key raids included:
Bamban, Tarlac (2023–2024): Hongsheng Gaming Technology and Zun Yuan Technology Inc. – over 1,400 workers detained; torture rooms and underground tunnels uncovered. A pogo site refers to compounds exactly like these.
Lucky South 99, Pampanga (2024): 158 foreigners rescued from a compound where pogo gaming equipment refers to devices used for facilitating such illegal act operations.
Lapu-Lapu City (2024): In 2024, authorities raided a POGO hub and rescued 169 foreign nationals allegedly forced into online scam operations.
POGO-related crimes may risk ₱16.7 billion in foreign investments. China’s repeated warnings about cross-border gambling, combined with these incidents, helped push policymakers toward a total ban. The ban aims to improve the Philippines’ international reputation to attract desirable foreign investments. Authorities also recovered pogo gaming paraphernalia and other computer related devices during these operations, where pogo gaming paraphernalia refers to equipment used to facilitate illegal gaming.
Impact on AML, Financial Crime Risk, and Security Verification
The ban sharply reshapes AML and financial crime compliance obligations for regulated entities. Existing POGO-linked accounts may exhibit unusual patterns during wind-down:
Large outbound transfers to jurisdictions with weak AML controls
Attempts to re-route funds via shell companies or crypto platforms
Rapid account closures without proper settlement
Use of alternative payment rails or other relevant outbound data channels
These are critical red flags for transaction monitoring. Institutions must also guard against malicious bots and automated systems attempting to exploit ph performing security verification gaps during the transition period.
Robust security verification and enhanced due diligence become essential to distinguish legitimate wind-down activity from attempts to launder proceeds of illegal offshore gaming operations. Risk scoring must be updated to reflect that any entity still connected to offshore gaming after December 31, 2024 is operating illegally.
ZIGRAM’s solutions directly address these challenges: name screening catches entities linked to known POGO hubs; Entity Hero provides entity risk assessment across jurisdictions; Transact Comply flags suspicious payment patterns; and adverse media monitoring via Dragnet Alpha and SATOC captures emerging reports of human trafficking, forced labor, and cyber-scams tied to offshore gaming.
A verification successful outcome in onboarding or off-boarding workflows must be backed by strong data, sanctions checks, respond ray id verification protocols, and consistent documentation – especially for high-risk former philippine offshore gaming clients.
Guidelines, Funding, Reporting, and Sanctions
TWGs are empowered to issue implementing guidelines, standard operating procedures, and inter-agency protocols for efficient and effective prevention of illegal offshore gaming. These guidelines address everything from raid coordination to account closure procedures for the anti money laundering council.
Key implementation details:
Funding: Sourced from regular appropriations of concerned agencies, with future allocations supporting enforcement and worker transition
Reporting: Monthly and final reports from TWGs and PAOCC to the Office of the President, documenting closures, arrests, enforcement actions, and economic impact
Worker support: All the retirement benefits and livelihood support programs are coordinated through DOLE; pogo local gaming agents and staff receive job transition assistance
Sanctions for non-compliance are severe. Public officials who fail to enforce the order face administrative and disciplinary penalties. Entities that continue to support or finance illegal offshore gaming operations face criminal prosecution and asset seizure. House bill no provisions and senate bill no proposals in Congress have reinforced these penalties through the Anti-POGO Act of 2025.
The order includes separability and repeal clauses: invalid provisions do not affect the remainder, and all inconsistent prior rules are amended or repealed. Entities misleading the public by claiming valid licenses after cancellation are specifically warned. Immigration authorities monitor international and local airports for departing foreign nationals linked to POGO operations.
Implications and Next Steps for Regulated Institutions (ZIGRAM Perspective)
For banks, fintechs, insurers, brokers, and crypto platforms, the pogo ban philippines demands immediate action. Here’s a practical compliance checklist:
1. Portfolio Review Identify all clients with direct or indirect exposure to philippine offshore gaming operations – including cross-border affiliates, payment processors, and any duly constituted business enterprise that serviced POGOs.
2. Update Risk Ratings and KYC Refresh customer risk ratings. Verify visa status, business registrations, and permit/licensing status. Confirm beneficial ownership, even where nominees or shell structures exist.
3. Tune Transaction Monitoring Adjust scenarios for POGO typologies: large foreign-currency inflows, outflows to high-risk jurisdictions, fund transfers among related companies, and use of crypto. Offshore gaming refers to a now-illegal activity – any associated financial activity warrants immediate escalation.
4. Leverage RegTech ZIGRAM’s Complete AML System – PreScreening.io for name screening, Transact Comply for payment monitoring, and Entity Hero for entity risk assessment gives you total AML compliance. Also, with DueDiliger for enhanced due diligence and Dragnet Alpha for adverse media – provides the automation needed to handle high-volume POGO off-boarding while maintaining audit trails.
5. Prepare for Regulatory Examinations Document how each POGO-related client was handled: dates of license cancellation, closure of services, suspicious activity reports filed, and account termination records.
The POGO ban is not the end of compliance obligations – it’s a regulatory inflection point that demands sharper tools and faster response. Institutions that clean up exposure now will be best positioned when examiners come knocking.
Ready to strengthen your AML framework? Book a demo or schedule a discovery call with ZIGRAM to ensure your compliance program is prepared for the post-POGO regulatory environment.
