Signal Spotlight · Philippine gaming, patron screening and restricted persons
What happened
On March 30, 2026, the Department of Justice and PAGCOR signed a memorandum of agreement under which the DOJ and its attached agencies share the names, job titles, and photos of their personnel with PAGCOR, as reported by the Manila Bulletin, GMA News, and Focus Gaming News. The DOJ has around 60,000 employees across its main offices and attached agencies, and the Manila Bulletin reports more than 56,000 names are being shared. They are added to PAGCOR’s National Database of Restricted Persons, which PAGCOR and its licensees use to screen patrons, alongside PAGCOR’s facial recognition systems at licensed venues.
The legal basis is Presidential Decree 1869, the PAGCOR charter, which prohibits government officials and employees from gambling, along with a related memorandum circular. Justice Secretary Fredderick Vida said violators will be dismissed outright on top of facing criminal, civil, and administrative charges. At the signing, the National Bureau of Investigation was not yet included because the DOJ was still working through issues tied to its law enforcement role at gaming venues, and Vida said NBI Director Melvin Matibag would sign at a later date. We haven’t found confirmation that the NBI has signed.
PAGCOR Chairman and CEO Alejandro Tengco said the agreement is the first of its kind between PAGCOR and a government agency. He said the restricted list currently holds only about 600,000 names, against roughly 4.5 million government officials and employees, and that PAGCOR voided more than ₱310 million (about US$5.5 million, per Focus Gaming News) in winnings in 2025 after verification showed the players were barred. He added that PAGCOR had previously struggled to get personnel data because some agencies declined to share it, citing the Data Privacy Act.
Why it matters
The accurate reading changes who carries the risk. The restriction applies to who may enter and play, not who may work. Nothing in the agreement points to a screening burden on operators’ own employees, and the idea that a flagged person could be a compliance breach inside an operator’s workforce doesn’t follow from it. The operator exposure is at two points: keeping restricted persons out at the door, and the payout, where winnings from banned players are voided.
The size of the DOJ list is less significant than the model. Roughly 56,000 names are about 1 percent of the 4.5 million government officials and employees Tengco cited, so the immediate coverage gain is small. What the agreement establishes is a template for agency-to-regulator data sharing, signed by an agency that is itself responsible for enforcing the law, after others had declined on privacy grounds. If other agencies follow, the restricted list grows from 600,000 toward its target population, and screening gets stricter without any new rule.
For online operators, the nearest reported precedent is separate and from 2025. The Department of the Interior and Local Government said it would give PAGCOR a list of its personnel for a ban on online gambling by its staff and local officials, and that PAGCOR would forward the list to licensed operators, who would be expected to run KYC against the names. That was a different directive and not the DOJ agreement. We haven’t found a PAGCOR circular setting out how agency lists will be used by online operators, and that process is the open question.
The data itself carries obligations. Tengco assured that shared employee data will be protected. Reporting in March also noted an earlier incident in which PAGCOR’s restricted-persons list was reportedly exposed and its contents disputed. Operators that receive or use restricted-persons data inherit the privacy and security duties that come with it.
What to watch
More agencies signing. DOJ is the first. Another agency agreement would show whether this becomes the standard route to filling the list.
The NBI. Its signing was deferred at the March ceremony, and we haven’t found confirmation that it has happened.
A PAGCOR circular on screening for online operators. The practical question is whether and how licensed online operators will be required to screen against agency lists.
Handling of errors. A published process for people who are wrongly listed, and for winnings voided in error, has not been reported.
The next voided-winnings figure. The ₱310 million for 2025 is the baseline for showing whether stricter screening is working.
What this means for operators
Confirm that your patron screening checks the National Database of Restricted Persons at entry and at registration, and that you have a documented process for payouts to flagged players. If you run online products, ask PAGCOR how agency lists will be shared with licensed online operators before it arrives as a directive.
What this means for compliance
Treat list updates as a recurring process, not a one-time load: define how often you refresh the database, who has access, and how matches are escalated. Review how you store and secure restricted-persons data, since it is personal data of government employees.
What this means for industry bodies
Ask PAGCOR for the screening procedure for online operators, a remedy for wrongly listed individuals, and a clear rule on whether and when operators bear liability for a match missed in good faith. Raising those now is easier before more agencies join and the list grows.