DOJ's Casino Ban Agreement Is About Patrons, Not Operators' Employees

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.