To maintain efforts in understanding the recently effected Casino Implementing Rules and Regulations (CIRR) of Republic Act (RA) No. 10927, the Anti-Money Laundering Council (AMLC) and the Office of Anti-Corruption and Integrity of the Asian Development Bank (ADB-OAI) held training courses for casino operators from 4 to 5 and 7 to 8 December 2017 at the Bangko Sentral ng Pilipinas Complex. Previously, the AMLC and ADB-OAI conducted trainings for casino regulators, Philippine Amusement and Gaming Corporation (PAGCOR), Cagayan Economic Zone Authority (CEZA), and Aurora Pacific Economic Zone and Freeport Authority (APECO), from 23 to 25 October 2017 at the Century Park Hotel Manila. 

The Anti-Money Laundering Act of 2001 (AMLA), as amended, ensures that the Philippines will not be used as a money laundering site for proceeds of unlawful activities. Since money launderers and their activities in the financial system are complex, the AMLC has adopted a risk-based approach to combat money laundering and terrorist financing, which optimizes resources by primarily focusing on persons, activities, and circumstances that pose the highest risk. 

Similar to banks and other financial institutions, casinos undertake high-volume and high-speed financial activities but in the gaming context. Casinos are generally large cash-based businesses, competitive in its growth and susceptible to criminal activity. Internet-based casinos, casino junket operations, and reduced transparency of high rollers, which usually make up a majority of casino turnover yet only a minority of casino patrons, raise substantial challenges. Vulnerabilities are noted with identifying sources and movements of funds. 

RA No. 10927, which designates casinos as covered persons, took effect on 29 July 2017 and included casinos within the scope of AMLA, while the CIRR was implemented on 4 November 2017. To minimize the exposure of casinos to money laundering and terrorism financing, AMLA and the CIRR provide three (3) institutional layers of prevention. First, casinos, as primary layer, should ensure they have established anti-money laundering and combating the financing of terrorism (AML/CFT) standards in their respective Money Laundering Prevention Programs (MLPP) with adequate board and senior management oversight and internal controls. Second, appropriate government agencies (AGA), namely PAGCOR, CEZA, and APECO, with respect to their casino operations and licensees, supervise these casinos’ compliance with their MLPPs. Finally, the AMLC ensures that the AGAs, as the supervising authorities, as well as covered persons comply with their duties over casinos on AML/CFT matters. 

As the first institutional layer, casinos should ensure that the three (3) lines of defense are in place: the operations business units (frontliners) that deal and transact directly with customers; casino compliance functions for officers that ensure the day-to-day compliance with AML/CFT obligations; and an audit function that conducts post-assessment reviews of casinos’ compliance with AML/CFT obligations. 

Apart from an overview of the CIRR, the AMLA, and the Terrorism Financing Prevention and Suppression Act, the training covered the requirement to identify and conduct due diligence on customers, keep records of transactions, and submit covered and suspicious transaction reports to the AMLC. It likewise included lectures on risk management; typologies and red flag indicators; and AML compliance in casinos. Forty-six (46) casino operators attended the training.

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