The Philippine Gaming Regulatory Commission is upgrading its anti-money laundering review from an administrative procedure to a risk management system that spans the entire lifecycle of a license. A recent analysis by legal consulting firm Arden Consult points out that this system, named "Integrity Review," is not just a simple process enhancement, but a core component of the Philippines' compliance with international anti-money laundering standards—according to FATF recommendations, regulatory bodies must ensure that criminals and their associates cannot enter the ownership or management of gaming enterprises. After officially exiting the FATF "grey list" in February 2025, PAGCOR has been strengthening this hard-won compliance foundation, and the upgraded integrity review mechanism is a key defense line in maintaining the results of the de-grey process.
Three levels of review correspond to three risk levels, with third-party institutions involved in medium and high levels
The new system divides integrity reviews into three levels, each corresponding to different risk levels. Low-risk applicants undergo a first-level review, directly handled by PAGCOR's Investigation and Verification Department; medium-risk and high-risk applicants enter the second and third levels of review, implemented by officially recognized third-party institutions, with related costs borne by the applicants. Regulatory bodies also require that third-party fees must be publicly transparent and not arbitrarily priced under the name of higher-level reviews.
As the level of review increases, the depth of investigation also increases step by step—from the applicant's identity information, address, credit record, financial status, extending to criminal records, fraud risk assessment, and whether they appear on international anti-money laundering and anti-terrorism sanction lists. Applicants cannot choose their review level—PAGCOR will conduct a comprehensive risk assessment based on factors such as company size, complexity of equity structure, business coverage area, financial status, and compliance records over the years. More importantly, once new risk signals are detected during the regulatory process, PAGCOR has the right to raise the review level at any time. In other words, entering the low-risk channel does not mean you can easily reach the end.
Triggering a review is not only about new licenses—changes in equity, senior management replacements, and even annual routine audits are within range
The trigger coverage of the new system is worth every licensed enterprise's comparison. Not only do new license applications and license renewals trigger integrity reviews, but significant changes in a company's directors, senior management personnel, shareholders, and ultimate beneficiaries also require this procedure. Negative reports, suspected illegal activities, and even annual routine audits may initiate background investigations.
If there are changes in the board members, senior management, or equity structure of a licensed enterprise, they must notify PAGCOR in writing within 15 natural days. Failure to report on time may itself become a focus of regulatory attention and trigger further investigation. On a practical level, most integrity reviews are completed within 30 days after the application materials are complete. Industry insiders reveal that the most common cause of delays is not that the review itself takes too long, but that the information submitted is incomplete—a seemingly minor issue that repeatedly occurs in companies rushing to push through license changes.
Hiding information is more fatal than underreporting: once caught, new licenses may be denied, and existing licenses may also be suspended or revoked
Arden Consult in its analysis offers a piece of advice worth noting for all applicants: never beautify your own situation with wishful thinking. Compared to the correctable delay of supplementary material submission, intentionally concealing information or providing false data has much more severe consequences—not only could it lead to the rejection of new license applications, but existing licenses could also be suspended or revoked. If fraud is involved, regulatory bodies may even initiate legal proceedings. Passing the integrity review is just an important step in obtaining a gaming license and does not mean the application has been approved. Applicants still need to meet all other regulatory requirements set by PAGCOR and ultimately obtain board approval to officially obtain the relevant operating qualifications.
PASA's official website believes that PAGCOR's upgraded integrity review system is essentially a denser and deeper screening net laid down in the transformation process of Philippine gaming regulation from "pass-line enforcement" to "international standard benchmarking." For enterprises that are already licensed in the Philippines or are applying for a license, the lethality of this system lies not in the severity of the review itself, but in how broad the trigger coverage is—from license renewal to equity changes to senior management replacements, almost every key node in the enterprise lifecycle is included in the review scope. Those operators who are accustomed to treating compliance as a one-time certification action and ignoring reporting obligations once they obtain a license will most easily step on the 15 natural day red line that many people overlook.
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