LARO77 Anti Money Laundering Rules at a Casino Cashier
Republic Act No. 10927 added casinos, including internet casinos, to the anti money laundering law as covered persons.
Key facts and contents
- LARO77 eGames and PAGCOR's Electronic Gaming Categories
- PAGCOR does not define eGames as one product.
- LARO77 GLI Explained
- GLI is Gaming Laboratories International, an independent testing laboratory.
- LARO77 Junket Explained
- A junket is a gaming-room arrangement: a registered promoter brings foreign-passport players to a licensed casino's junket tables under a written agreement, and the casino stays answerable to PAGCOR for it.
- LARO77 Know Your Customer Checks, Step by Step
- A know your customer check is the step where a regulated business establishes your true identity from an official ID.
- LARO77 NBI Cybercrime
- Save screenshots with the address bar, your wallet's reference numbers, dates, amounts and chat messages, report to GCash or Maya in the wallet's own help, then take the case to the NBI through nbi.gov.ph.
- LARO77 Phishing Site
- A phishing site is a page built by a fraudster to look like the real one so you type your password into it.
- LARO77 Proof of Address
- The saved GCash, Maya and Bangko Sentral texts list valid IDs, not a separate proof-of-address list.
The anti money laundering law is the reason a casino cashier asks who you are. RA 9160, the Anti-Money Laundering Act of 2001, was amended by RA 10927 to bring casinos inside it, and the rules that followed spell out what a casino must record, keep and report. Read this page next to the wider trusted online casino checks and the cashier stops being a mystery.
AML, AMLA and AMLC: three abbreviations
AML stands for anti-money laundering, and the three short forms you will meet in the law’s texts point to different things.
| Short form | What it points to | Source |
|---|---|---|
| AML | The subject: rules to prevent money laundering | RA 9160 and RA 10927 |
| AMLA | Republic Act No. 9160, “Anti-Money Laundering Act of 2001”, as amended | lawphil.net text of RA 10927 |
| AMLC | The Anti-Money Laundering Council, which AMLC’s own site calls “the Philippines’ independent financial intelligence unit tasked with preventing and combating money laundering, terrorist financing, and proliferation financing” | amlc.gov.ph |
PAGCOR adds its own layer. Its Regulatory Order No. RO-2020-03-001 of March 16, 2020 sets AML guidelines for casinos and says the enactment of RA 10927 “now includes casinos as covered persons”.
Covered person: how RA 10927 brought casinos in
A covered person is a business the law makes responsible for identifying customers and reporting. RA 10927 is titled “An Act Designating Casinos as Covered Persons Under Republic Act No. 9160”. Its Section 1 amends Section 3(a) of RA 9160 to list “(8) casinos, including internet and ship-based casinos” among covered persons.
Section 3 of RA 10927 adds definitions for these casinos. Internet-based casinos are casinos “in which persons participate by the use of remote communication facilities such as, but not limited to, internet, telephone, television, radio or any other kind of electronic or other technology”. A “casino cash transaction” covers “the receipt of cash by a casino paid by or on behalf of a customer” and “the payout of cash by a casino to a customer or to any person in his/her behalf”.
Section 2 of RA 10927 amends Section 3(b) and sets two reporting thresholds:
| Transaction | Threshold in the law’s text |
|---|---|
| General covered transaction | “a total amount in excess of Five hundred thousand pesos (₱500,000.00) within one (1) banking day” |
| Covered persons under Section 3(a)(8), which means casinos | “a single casino transaction involving an amount in excess of Five million pesos (₱5,000,000.00) or its equivalent in any other currency” |
The Act was approved on July 14, 2017. These figures decide when a casino files a covered transaction report; they are not the point at which you are asked for an ID.
What a covered person must do
The Casino Implementing Rules and Regulations (CIRR) of RA 10927, published in the Official Gazette, turn the law into duties. Each row below gives the text and what you see.
| Duty | What the text says | What the player sees |
|---|---|---|
| Customer identification | RA 9160 Sec. 9(a): covered institutions “shall establish and record the true identity of its clients based on official documents”. CIRR Sec. 16 says the same for casinos | A request for ID when an account is opened |
| Minimum customer information | CIRR Sec. 19 lists name, date and place of birth, present and permanent address, contact information, nationality, proof of identification and number, nature of work, and source of funds | A form or screen asking for personal details |
| Face-to-face contact | CIRR Sec. 20 requires contact at account opening or as reasonably practicable, and allows information and communication technology if the casino has verified the submitted ID first | A face-to-face or video check |
| Prohibited accounts | RA 9160 Sec. 9(a): “anonymous accounts, accounts under fictitious names” are “absolutely prohibited” | An account only in your true name |
| Record keeping | RA 9160 Sec. 9(b) and CIRR Sec. 25: records kept for “five (5) years” | Your ID and transactions stay on file |
| Reporting | CIRR Sec. 28: covered and suspicious transactions are reported to the AMLC “within five (5) working days” unless the AMLC prescribes a different period | Nothing: RA 9160 Sec. 9(c) bars telling anyone a report was made |
PAGCOR’s order adds that casinos must apply customer due diligence “when a customer creates an online gaming account for the internet-based casino” (Section 5(a)(i)(b)). It also says a casino unable to complete due diligence should, as far as practicable, not open the account or perform the transaction.
What this means at a cashier
Three behaviours at the cashier trace back to these texts.
- An ID is asked for. CIRR Sec. 16 and Sec. 19 require the casino to establish and record who you are and to take a copy of an identification document when an account opens.
- Names must match. CIRR Sec. 22 says that where a transaction is made “in behalf of another”, the casino shall record the true identity of both the account holder and the person on whose behalf the transaction is conducted.
- Someone else’s payment is refused. CIRR Sec. 23(2) prohibits “receiving cash, the purpose or ownership of which cannot be ascertained within a period of at least seven (7) days from the date of receipt”. A payment from another person’s wallet puts a second identity into the transaction, so a cashier has these sections to point to.
Use your own wallet, in the name on your account, and follow the steps on the know your customer procedure page when a wallet asks you to verify. These rules cover the money and the people. The fairness of the games is a separate question, answered by GLI test certificates.
An example with the numbers
Say you deposit ₱2,000 into a new account. That is far below ₱500,000 and far below ₱5,000,000, so no covered transaction report arises from the amount alone. Identification still applies, because PAGCOR’s order applies customer due diligence when an online gaming account is created, whatever the first deposit.
FAQ
What is the anti money laundering law in the Philippines?
It is Republic Act No. 9160, the Anti-Money Laundering Act of 2001, as amended. Republic Act No. 10927, approved on July 14, 2017, added casinos to it.
Is an online casino a covered person?
Yes, by the law's own text. Section 3(a)(8) as amended names "casinos, including internet and ship-based casinos", and RA 10927 defines internet-based casinos as casinos in which persons participate by remote communication facilities.
Why does a casino cashier ask for my ID?
The Casino Implementing Rules and Regulations say casinos shall establish and record the true identity of their customers based on identification documents. The question at the cashier is that rule at work.
What is the ₱5,000,000 figure in RA 10927?
It is the covered transaction threshold for casinos: a single casino transaction involving an amount in excess of five million pesos or its equivalent in another currency. Identification starts long before that amount.
Bakit hindi puwedeng gamitin ang wallet ng ibang tao?
Hinihingi ng patakaran na itala ang pagkakakilanlan ng may-ari ng account at ng taong pinagmumulan ng transaksyon. Gamitin ang sarili mong wallet, sa pangalang kapareho ng account.