SIXTEENTH CONGRESS OF THE ) 
REPUBLIC OF THE PHILIPPINES) 
First Regular Session 
) 
SENATE 
S. B. No. 
2106 
Introduced by Senator TEOFISTO "TG" GUINGONA III 
'14 
FEB -5 P 5 :40 
AN ACT DESIGNATING CASINO OPERATORS AS COVERED PERSONS UNDER 
REPUBLIC ACT NO. 9160 (ANTI-MONEY LAUNDERING ACT OF 2001), AS 
AMENDED, FOR THE PURPOSE OF STRENGTHENING THE ANTI-MONEY 
LAUNDERING! COMBATING THE FINANCING OF TERRORISM REGIME OF 
THE PHILIPPINES, AND FOR OTHER PURPOSES 
EXPLANATORY NOTE 
Next to taxes, revenues from the casino sector are among the major sources of income 
of the govermnent. It must be recognized that the casino and gaming industry, under the 
supervision and regnlation of the Philippine Amusement and Gaming Corporation, has been a 
strong and responsible partner of the govermnent in pursuing its development plans. 
However, the casino sector is equally exposed. to the raging threats of money 
laundering and financing of terrorism (MLlFT). Its vulnerabilities to criminal exploitation 
can be attributed to the fact that casinos are cash intensive businesses with high volumes of 
large cash transactions taking place very quickly; that they also offer many financial services 
such as remittance, cash issuing and foreign exchange; that the movement of funds, either 
internationally or domestically undertaken, associated with gaming-related tourism is poorly 
understood and may pose money laundering threats; and, that the casino industry is 
unregnlated for anti-money laundering/combating the financing of terrorism (AMLlCFT) 
purposes. With these identified vulnerabilities, the casino industry appears to be attractive in 
successfully undertaking money laundering activities. 
On this note, it is highly imperative to establish an AMLlCFT regulatory framework 
that would preserve the integrity of the gaming industry and protect it from the evils of 
MLiFT. 
Under the FATFI Recommendations, the international standards on combating money 
laundering and the financing of terrorism and proliferation, casinos is one of the identified 
non-financial businesses vulnerable to the threats of MLiFT. Hence, casinos must be 
1 Financial Action Task Force (FATF) is an inter-governmental body established in 1989 by the Ministers of its Member 
jurisdictions (G7 countries such as Canada, France, Germany, Italy, Japan, UK and USA). The objectives of the FATF are to set 
standards and promote effective implementation of legal, regulatory and operational measures for combating money 
laundering, terrorist financing and other related threats to the integrity of the international financial system. 
1 


regulated for AMLlCFT purposes and be subjected to the requirements set out in the 
Recommendations particularly on customer due diligence, record-keeping and reporting of 
transactions. These requirements are the internationally-accepted preventive measures in 
combating MLiFT. 
After the assessment of the Philippines' AMLlCFT Regime in 2008, which was 
jointly conducted by the World Bank and the Asia Pacific Group on Money Laundering 
CAPG), one of the recommended action plans by the assessment team in order to improve our 
country's AMLlCFT system was to ensure that the casino sector is made subject to a 
comprehensive regulatory and supervisory regime as soon as possible. 
Likewise, it must be noted that during the FATF meetings in June 2013 held in Oslo, 
Norway, members of the FATF noted the recent enactment of Republic Act No. 101682, 
Republic Act No. 101673, and Republic Act No. 103654 by the Philippine Congress. These 
important developments were the basis for the decision of the F ATF to remove the 
Philippines from the list of jurisdictions that are subject to FATF's monitoring process under 
its on-going global AMLlCFT compliance process. This development spared the Philippines 
from the possible imposition of countermeasures from other jurisdictions. However, in the 
same meeting, the Philippines was vehemently urged to work with the APG as it continues to 
address the full range of AMLlCFT issues identified in its Mutual Evaluation Report, in 
particular, in regulating the casino sector in the Philippines for AMLlCFT purposes and 
making it subject to AMLlCFT requirements. 
In view of the foregoing, early passage of this measure is strongly recommended. 
o "TG" GUINGONA III 
Senator 
2 "An Act Defining the Crime of Financing of Terrorism, Providing Penalties Therefor and for Other Purposes" 
3 "An Act To Further Strengthen the Anti-Money Laundering Law, Amending for the Purpose Sections 10 and 11 of Republic Act 
No. 9160 Otherwise Known as the 'Anti-Money Laundering Act of 2001', As Amended, and for other Purposes" 
4 "An Act Further Strengthening the Anti-Money Laundering Law, Amending for the Purpose Republic Act No. 9160, otherwise 
Known as the 'Anti-Money Laundering Act of 2001' as Amended" 
2 


SIXTEENTH CONGRESS OF THE ) 
REPUBLIC OF THE PHILIPPINES) 
First Regular Session 
) 
SENATE 
S.B.No. 
2106 
Introduced by Senator TEOFISTO "TG" GUINGONA III 
·14 
FEB -5 P5:41 
AN ACT DESIGNATING CASINO OPERATORS AS COVERED PERSONS UNDER 
REPUBLIC ACT NO. 9160 (ANTI-MONEY LAUNDERING ACT OF 2001), AS 
AMENDED, FOR THE PURPOSE OF STRENGTHENING THE ANTI-MONEY 
LAUNDERINGI COMBATING THE FINANCING OF TERRORISM REGIME OF 
THE PHILIPPINES, AND FOR OTHER PURPOSES 
Be it enacted by the Senate and the House of Representatives of the Philippines in Congress 
assembled: 
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Section 1. Short Title.-This Act shall be known as the "CASINO AML/CFT ACT 
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OF 2014." 
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Section 2. Declaration of Policy. - It is hereby declared the policy of the State to 
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ensure that the Philippines shall not be used as a site for the laundering of the proceeds of any 
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unlawful activity and for the financing of terrorism. To this end, it shall protect and preserve 
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the integrity of the casino industry with a strong and efficient Anti-Money Laundering / 
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Combating the Financing of Terrorism (AMLlCFT) regime. Consistent with its foreign 
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policy, the State shall extend cooperation in transnational investigations and prosecutions of 
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persons involved in money laundering and terrorist financing activities wherever committed. 
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Section 3. Designation of Casino Operators. -Casino operators, with respect to their 
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gaming operations, are hereby designated as covered persons under RepUblic Act No. 9160, 
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otherwise known as the Anti-Money Laundering Act of2001, as amended. 
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Section 4. Definition of Terms. - For purposes of this Act, the following terms are 
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hereby defined as follows: 
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(A) ACCOUNT - shall refer to membership account, customer's credit account, check 
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cashing account, deposit account or any other account opened with a casino by or 
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on behalf of a customer. 
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(B) AGGREGATION - shall refer to multiple or series of transactions that are treated 
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as a single cash transaction if done by or on behalf of a specific customer 
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involving an amount exceeding the designated threshold in one (1) trading day. 
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(C) CASH - means currency notes and coins considered as legal tender in the country 
of issue. 
(D) CHECK IN - shall mean transactions involving the receipt of cash by a casino 
paid by or on behalf of a customer. These include, but are not limited to the 
following: 
1) Purchases of chips, tokens, and other gaming instruments; 
2) Front money deposits; 
3) Safekeeping deposits; 
4) Payments on any form of credit, including markers and counter checks; 
5) Currency received by a casino for transmittal of funds through wire 
transfer for a customer; 
6) Purchases of a casino's check; 
7) Exchanges of currency for currency, including foreign currency; and 
8) Bills inserted into electronic gaming devices. 
(E) CHECK-OUT -shall mean transactions involving the payout of cash by a casino 
to a customer or to any person in his behalf. These include, but are not limited to 
the following: 
1) Redemptions of chips, tokens, tickets, and other gaming instruments; 
2) Front money withdrawals; 
3) Safekeeping withdrawals; 
4) Advances on any form of credit, including markers and counter checks; 
5) Payments by a casino to a customer based on receipt of funds through wire 
transfers; 
6) Cashing of checks or other negotiable instruments; 
7) Exchanges of currency for currency, including foreign currency; 
8) Travel and complimentary expenses and gaming incentives; and 
9) Payment for tournament, contests, and other promotions. 
(F) CASINO - shall refer to gambling casinos where the building, room or space is 
used for social amusements; specifically, one used for gambling through games of 
chance, games of cards and games of numbers and are being regulated and 
supervised by the Philippine Amusement and Gaming Corporation (P AGCOR), 
the Cagayan Economic Zone Authority (CEZA), or any other appropriate 
supervising authority. For purposes of this Act, it also includes internet- and ship-
based casinos. 
1) Internet-Based Casino -shall refer to gambling 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 for facilitating communication. 
2) Ship-Based Casino -shall refer to gambling casinos, the operation of which 
is undertaken on board a vessel, ship, boat or any other water-based craft 
wholly or partly intended for gambling. 
(G) COVERED TRANSACTION - Notwithstanding the provision of Section 3(b) of 
Republic Act No. 9160, as amended, for purposes of casino-related transactions, 
covered transaction shall refer to a single or an aggregate of transactions 
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undertaken by any individual with the casino involving an amount in excess of 
Three million pesos (Php3,000,000.00). 
(H) CUSTOMER - shall refer to any person who transacts or attempts to transact with 
a casino, whether or not that person participates, or intends to participate, in the 
gaming activities offered by the casino. 
(I) MONETARY INSTRUMENT shall refer to: 
I) Coins or currency of legal tender in the Philippines, or in any other 
country; 
2) Negotiable checks such as casino check, personal check, bank draft; 
3) Casino Value instruments such as casino chips, casino reward cards, 
Ticket in/Ticket out, markers, cashier's order, chip purchase order, chip 
check, gift certificates, casino draft;and 
4) Other similar instruments where title thereto passes to another by 
endorsement, assignment or delivery. 
(J) MONEY LAUNDERING - shall refer to acts punished under Section 4 of 
Republic Act No. 9160, as amended. 
(K) OFFENDER-shall refer to any person who commits money laundering offense 
and/or terrorist financing. 
(L) PERSON-shall refer to any natural or juridical person. 
(M) 
PROCEEDS-shall refer to an amount derived or realized from an unlawful 
activity. It includes: 
1) All material results, profits, effects and any amount realized from any 
unlawful activity; 
2) All monetary, financial or economic means, devices, documents, papers or 
things used in, or having any relation to, any unlawful activity; and 
3) All moneys, expenditures, payments, disbursements, costs, outlays, 
charges, accounts, refunds and other similar items for the financing, 
operations, and maintenance of any unlawful activity. 
(N)PROPERTY-shall refer to anything or item of value, real or personal, movable or 
immovable, tangible or intangible, or any interest therein or any benefit, privilege, 
claim or right with respect thereto. 
(0) SUPERVISING AUTHORITY-shall refer to the PAGCOR, CEZA, or any other 
appropriate agency, as may be determined by law. 
(P) SUSPICIOUS TRANSACTION is a transaction, regardless of the amount 
involved,where any of the following circumstances exists: 
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I) The casino operator or any of its employees knows, suspects, has reason to 
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suspect, or should have known, by the exercise of due diligence, that the 
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transaction: 
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a. Involves funds derived from an unlawful activity or from a money 
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laundering offense; 
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b. Is designed to evade any of the requirements under this Act or of 
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Republic Act No. 9160, as amended; 
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c. Has no business or apparent lawful purpose or is not the sort in which 
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the particular customer would normally be expected to engage, and the 
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casino operator or any of its employees knows of no reasonable 
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explanation for the transaction after examining the available facts, 
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including the background and possible purpose of the transaction; or 
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d. Involves the use of casinos to facilitate unlawful activity, money 
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laundering and/or terrorist financing. 
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2) Any of the circumstances for the filing of Suspicious Transaction Report 
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under Sec. 3 (b-l) ofR.A. 9160, as amended. 
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3) And any other circumstances that may be determined suspicious by the 
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Anti-Money Laundering Council (AMLC). 
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(Q)TERRORIST FINANCING - shall refer to acts defined and punished under 
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Sections 4,5,6,7 and 8 of Republic Act No. 10168. 
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(R) TRADING DAY - refers to the normal business day of a casino. If the casino 
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offers 24-hour gaming, the term shall mean that 24-hour period by which the 
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casino keeps its books and records for business and accounting purposes. 
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(S) TRANSACTION-means purchase or redemption of casino chips or tokens, or 
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other gaming instruments or any other payment, transfer, or delivery by, through, 
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or to a casino, by whatever means effected. 
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For purposes of reporting Covered Transactions, cash transaction shall mean the 
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physical transfer of cash from one person to another. A non-cash transaction, on 
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the other hand, shall mean the transfer of funds by means of bank check, bank 
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draft, wire transfer, or other written order. 
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(T) UNLAWFUL ACTIVITIES - shall refer to the crimes or offenses listed under 
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Section 3 (i) of Republic Act No. 9160, as amended. 
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Section 5. Prevention of Money Laundering; Customer Identification Requirements 
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and Record Keeping. -
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(A) Customer Identification, - Casino operators shall: 
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I) Based on official documents, establish and record the true and full identity 
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of their customers engaging in a single or an aggregate transaction in 
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excess of Two hundred thousand pesos (Php200,000.00). 
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2) Maintain a system of verifying the true and full identity of their customers 
and, in case of corporate customers, require a system of verifying their 
legal existence and organizational or control structure, as well as the 
authority and identification of all persons purporting to act on their behalf. 
3) Take reasonable measures to obtain information sufficient to identity and 
verify the identity of every beneficial owner of the customer's account. 
4) Develop clear, written and graduated customer acceptance policies and 
procedures including a set of criteria for customers that are likely to pose 
different levels of risk to their operations, as well as the standards in 
applying the appropriate degree of due diligence, including a set of 
conditions for the denial of account opening. 
5) Based on the assessment of risk, endeavor to identity Politically Exposed 
Persons (PEPs) and shall apply enhanced customer due diligence. 
6) Based on the assessment of risk, continually monitor the transactions in 
each of its customer's accounts to ascertain whether the transactions are 
consistent with the casino operator's knowledge of the customer, his 
income profile, and his source or sources of funds. 
7) Periodically review the adequacy of information they have obtained in 
respect of customers and beneficial owners of customer's account and 
ensure that the information is kept current, particularly for categories of 
customers that the casinos may assess to present higher risk of money 
laundering and terrorism financing. 
The provisions of existing laws to the contrary notwithstanding, anonymous 
accounts, accounts under fictitious names, and all other similar accounts shall be 
absolutely prohibited. 
(B)Record Keeping - All records of all transactions of customers shall be maintained 
and safely stored for at least five (5) years from the date of the last transaction, 
unless the casino operator is required in writing by the AMLC to retain the records 
for a longer period, due to a pending judicial action relevant to the records. 
(C)Reporting of Covered and Suspicious Transactions -
1) Casino operators shall report all covered transactions and suspicious 
transactions to the AMLC in a manner and within the period prescribed 
under Republic Act No. 9160, as amended. 
2) Should a transaction be determined to be both a covered transaction and a 
suspicious transaction, it shall be reported as a suspicious transaction. 
3) Notwithstandingthe preceding paragraphs, casino operators are exempted 
from reporting the following covered transactions -
i. Check-out transactions to the extent the currency is won in a money 
play and is the same currency the customer wagered in the money play, 
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or check in transactions to the extent the currency is the same currency 
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the customer previously wagered in a money play on the same table 
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game without leaving the table; 
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ii. Jackpot winnings from slot machine; and 
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iii. Other covered transactions that may be determined by the AMLC. 
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CD) Confidentiality of Reports-
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When reporting covered or SUSpICIOUS transactions to the AMLC, casino 
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operators and their officers and employees are prohibited from communicating, 
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directly or indirectly, in any manner or by any means, to any person or entity, 
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including the media, the fact that a covered or suspicious transaction has been 
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reported or is about to be reported, the contents of the report, or any other information 
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in relation thereto. Neither may such reporting be published or aired in any manner or 
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form by the mass media, electronic mail, or other similar devices. In case of violation 
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thereof, the concerned officer and employee of the casinos and media shall be held 
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criminally liable. 
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Casino operators, including any of its officers and employees, may not be 
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compelled, by subpoena or otherwise, to disclose a Suspicious Transaction Report, or 
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disclose the fact that a Suspicious Transaction Report was filed or is about to be filed, 
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or disclose any information contained in or in relation to a Suspicious Transaction 
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Report. 
This, however, is without prejudice to the exercise of the supervising 
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authority of its supervisory or regulatory powers under its charter. 
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The AMLC, P AGCOR, CEZA, or any government or prosecutorial agency 
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shall not be compelled to identify or name, in any manner or in any venue, any casino 
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as the source of information about any person or entity that probably committed 
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money laundering offense, terrorist financing or any other offense or violation under 
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this Act or Republic Act No. 9160, as amended. 
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(E) Safe Harbor Provision -
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No administrative, criminal or civil proceeding-shall lie against any person for 
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having made a covered or suspicious transaction report in the regular performance of 
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hislher duties in good faith, whether or not such reporting results in any criminal 
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prosecution under this Act or any other law. 
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Section 6. Prohibited Transactions - Casino operators shall be prohibited from 
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engaging in the following transactions or activities: 
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(A)Any transaction involving the conversion of money from one form to another 
without being used for gaming, including -
1) The receipt of cash for transmittal of all or part thereof through wire or 
telegraphic transfer for or on behalf of a customer; 
2) Payments in cash of funds received through wire or telegraphic transfer; 
3) The cashing of checks or other negotiable instruments; and 
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(B) 
Receiving money, the purpose or ownership of which cannot be ascertained 
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within a period of at least seven (7) days from the date of the receipt. 
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Section7. Authority to Inquire into CustomerAccounts-The AMLC may inquire into 
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or examine any particular account, including related accounts, with any casino operator that 
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is deemed related to any unlawful activity or money laundering offense as defined under 
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Republic Act No. 9160, as amended,or financing of terrorism as defined under Republic Act 
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No. 10168. 
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For purposes of this section, 'related accounts' shall refer to accounts, the funds and 
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sources of which originated from and/or are materially linked to the accounts subject of a 
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freeze order(s) issued by a competent authority or subject of an inquiry under the preceding 
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paragraph. 
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Section 8. Freezing and Forfeiture of Monetary Instruments or Properties- The 
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freezing and forfeiture of monetary instruments or properties shall be governed by Republic 
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Act No. 9160, as amended. Casino operators shall not lift the effects of any freeze order 
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without seeking official confirmation from the AMLC; Provided, that freeze or forfeiture 
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orders shall not apply against the general funds of casinos, in the event that the monetary 
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instruments or properties of the customer have been commingled with other funds or 
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properties of the casino, rendering the same difficult to be identified or segregated, for 
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purposes of enforcing the freeze or forfeiture order. 
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Section 9.AMLlCFT Program Requirements for Casinos- Casino operators are 
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hereby given one (1) year, from the effectivity of the Implementing Rules and Regulations of 
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this Act, to formulate their respective money laundering and terrorism financing prevention 
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programs (MLlTF Prevention Programs) in accordance with this Act including, but not 
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limited to, information dissemination on money laundering and terrorism financing activities 
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and its prevention, detection and reporting, and the relevant training of responsible officers 
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and personnel of casinos.The program must be approved by their respective Board of 
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Directors. 
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The MLlTF Prevention Program should be designed to ensure and monitor 
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compliance with the requirements set forth in this Act. A system of internal control as well 
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as internal testing for compliance must be in place to ensure ongoing compliance. 
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Casino operators should designate a compliance officer, to monitor the compliance 
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with the policies and procedures under its own MLlTF Prevention Programs, and to conduct 
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the necessary coordination to ensure compliance with the requirements set forth in this Act. 
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Section 10. On-site inspection- To ensure compliance of casino operators with this 
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Act and Republic Act No. 9160, as amended, the AMLC may conduct on-site inspection of 
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relevant casinos records and documents. 
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Section 11. Penal and Administrative Sanctions - Non-compliance with any of the 
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provisions of this Act shall be punished with penalties and sanctions provided for under 
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Republic Act No. 9160, as amended. 
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Section 12. Implementing Rules and Regulations. - Within one hundred twenty (120) 
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days from the effectivity of this Act, the AMLC and the Supervising Authoritiesshall 
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promulgate the rules and regulations to implement its provisions. 
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Section 13. Separability Clause. -
If any provlslOn of this Act is declared 
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unconstitutional, the same shall not affect the validity and effectivity of other provisions 
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thereof 
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Section 14. Repealing Clause.-All laws, decrees, orders, and issuances or portions 
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thereof, which are inconsistent with the provisions of this Act, are hereby repealed, amended 
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or modified accordingly; Provided, that all provisions of Republic Act No. 9160, as amended, 
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which are not inconsistent with this Act are hereby adopted. 
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Section 15. EjJectivity.-This Act shall take effect fifteen (15) days following its 
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pUblication in at least two (2) newspapers of general circulation. 
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