Since 2016, the Philippine gaming industry has grown rapidly, driven by liberal gambling laws and a mix of online gaming platforms and land-based casinos targeting international markets, particularly Chinese customers. Despite the ban on Philippine Offshore Gaming Operators (POGOs) in 2024 due to serious crimes like human trafficking, the Philippine Amusement and Gaming Corporation (PAGCOR) expects the gaming sector’s revenue to remain strong, with the electronic gaming segment projected to generate PHP 160 billion (US$ 2.75 billion) in 2025.

Given the rapid growth and the shift from POGOs to PIGOs (Philippine Inland Gaming Operators), it has become increasingly clear that a more stringent license application process is imperative. The ban on POGOs exposed serious vulnerabilities that have cast a shadow over the industry’s reputation. To ensure the long-term sustainability and integrity of PIGOs, it is critical that PAGCOR implement a more rigorous vetting process during the license application phase. This would involve more comprehensive background checks, enhanced scrutiny of financial stability, thorough verification of business practices, and tighter control over key personnel involved.

This blog offers an overview of the PAGCOR probity check process for PIGO applicants, covering key components, documentary requirements, and the steps followed by FilePino, the sole PAGCOR-accredited probity checker. Read on and tell us in the comments how we can assist you with your PIGO license application. 

What are PIGOs?

Philippine Inland Gaming Operators (PIGOs) are licensed gaming operators that run gaming activities within the Philippines, targeting local customers rather than international markets. Unlike POGOs, which primarily cater to foreign customers, PIGOs are authorized by PAGCOR to operate gaming establishments and platforms, including online casinos, sports betting, and other gaming services, exclusively for residents of the Philippines.

PAGCOR is a government-owned and controlled corporation created pursuant to its charter (“PAGCOR Charter”) to enable the Philippine government to regulate and centralize all games of chance authorized by law. The Charter includes the grant of a franchise to PAGCOR to operate and maintain casinos, clubs, and other amusement places. This means PAGCOR is both the country’s primary gaming regulator, as well as an operator of casinos.

What is a Probity Check?

Probity is broadly defined as a standard of ethical and moral behavior which concludes that a person or company complies with appropriate principles of “integrity, uprightness, and honesty.” 

In the context of gambling operations, Probity Checks are a series of background checks conducted by a PAGCOR-accredited probity checker to determine if the company and its directors and shareholders applying for a gaming license are “fit and proper” to be involved in the provision of gambling services to a sector of the public. 

Key Components of a PAGCOR Probity Check

PAGCOR-required probity checks require comprehensive reports that assess not only legal compliance but also the identities, credit histories, integrity, criminal associations, statutory and operational documents, and other relevant information of the operator-applicant and its key people to support the approval or denial of a PAGCOR license application.

The probity check reports transmitted by FilePino to PAGCOR typically consist of findings from the following background checks, which apply to both the company as an entity and its directors and shareholders. 

Ocular Inspection

This involves visiting the operator’s registered business address to inspect the premises, machinery, and equipment. It also includes interviews with the authorized representative and directors to assess the operational setup.

Ocular Interview  

This involves a face-to-face interview with the shareholders to validate the information provided in their Personal Data Sheet (PDS) and résumés. The interview also aims to verify personal details.

Address Verification 

This process confirms that the shareholders of a gaming company actually reside at the addresses they declare. This process helps establish the legitimacy of investors and prevents shell corporations or illegal operations.

NBI Criminal Record Check

This check is conducted to determine if the directors and shareholders have any criminal records, such as final convictions, cases with bail, or outstanding arrest warrants, with the National Bureau of Investigation (NBI).  

Credit Record Check

This check gathers a comprehensive report on the credit history, past employment, insurance, and credit-related matters (e.g., mortgages, loans, missed payments) of the directors and shareholders.

Global Dataset Check

This involves searching global and country-specific databases, search engines, social media platforms, the Official Gazette of the Philippines, and other media to verify whether the directors and shareholders have been linked to activities related to terrorism, money laundering, UN sanctions, or fraud.

Metropolitan/Regional Trial Court Criminal Record Check

Similar to the NBI Criminal Record Check, this check focuses on verifying any criminal and civil cases through the Municipal/Regional Trial Court with jurisdiction over the residence of each director and shareholder.

Business Permit and Licensing Office (BPLO) Permit Verification

This check verifies the legitimacy of the company’s operations based on the business permits issued by the Local Government Units (LGUs), i.e., by visiting the Business Permits and Licensing Office (BPLO) of the city or municipality where the company’s address is located. 

Educational Check

This check verifies the educational credentials of the directors and shareholders, such as their college degree, university attended, years of attendance, and academic achievements, and other violations committed or recorded, if any, with the Office of the Registrar of the respective institution.

Employment Check

This helps determine the past and current employment details of directors or shareholders, based on submitted documents such as personal disclosure statements and résumés.

Company Financial Check

This assessment aims to generate a comprehensive report on the financial health of the company, including its shareholders and directors, by obtaining the latest Audited Financial Statements (AFS) through the SEC Express System or directly from the company itself.

PAGCOR Probity Check Requirements

To ensure the integrity and compliance of PIGO applicants, the following documents are required for thorough probity checks:

Company Incorporation Documents

These documents include the SEC Certificate of Incorporation, Articles of Incorporation and Bylaws, and the most recent General Information Sheet (GIS). For sole proprietorships, a Department of Trade and Industry (DTI) Certificate of Registration is required.

For foreign corporate entities, counterpart documents, such as Certificates of Incorporation, Management Accounts, Memorandum of Articles of Incorporation (MAA), and Certificate of Incumbency, are required.  

Financial and Tax Documents

These include the company’s latest Audited Financial Statements (AFS) and Income Tax Returns (ITRs) along with the latest bank statements of the business, as well as those of its shareholders and directors. Sole proprietorships must also provide their ITRs.

Authorization Documents

These include authorization and release form signed by the company directors and shareholders, accompanied by valid government-issued identification cards with three (3) wet specimen signatures.

PAGCOR Personal Disclosure Statements (PDS)

These forms are to be duly accomplished by the directors and shareholders of the company, along with their individual résumés, providing detailed information on their educational background, personal details, and work experience.

Other Additional Documents

Depending on the circumstances or nature of the applications, clearance certificates and additional documents may also be required. For example, foreign national directors and shareholders require photocopies of their National IDs with original wet signatures.

Once you engage with our Background Check Team for the probity check, you will receive a comprehensive packet containing detailed instructions, documentary requirements (both for individual and corporate applicants), and the service agreement.

How We Conduct PAGCOR Probity Checks

As a PAGCOR probity checker, we, at FilePino, play a crucial role in ensuring the integrity of gaming operations in the Philippines. Here’s how we conduct our PAGCOR probity checks: 

1. Gathering Documentary Requirements

We require PIGO applicants to submit necessary documents such as business registration, financial statements, and identification of key officers. Additionally, we ask for an authorization signed by the directors and stakeholders, granting us permission to conduct background checks on the individuals involved. 

2. Conducting the Background Checks/Verification

We conduct thorough background checks on the operators and their key personnel, including address verification, criminal history, financial integrity, business reputation. We also check if there are involvements in illegal activities, such as money laundering or fraud. With these, we try to identify potential risks and ensure that all individuals involved meet the legal and regulatory requirements. 

3. Ocular Inspection

We also conduct an intensive ocular inspection of the registered business address and proposed gaming site of the PIGO applicant and its key personnel, including personal interviews with the directors and shareholders who are subject to a probity check.

4. Consolidating Verification Results and Preparing Reports

After completing the rigorous background checks, we compile the findings into comprehensive reports that detail our evaluations of the PIGO’s compliance with regulations, financial health, and business history and further highlight issues or red flags, if any. 

5. Submission of Reports to PAGCOR

At the final stage, we submit our reports to PAGCOR for their review and decision-making. PAGCOR uses the reports to evaluate whether the operator and its key people meet the legal requirements and standards needed to operate the gaming business legally and ethically in the country. Based on the findings, it will decide whether to grant or deny gaming license, or request further actions and clarifications.

PAGCOR Probity Check Timeline

With our probity check service, we typically complete the entire process, from gathering documentary requirements to submitting reports to PAGCOR within thirty (30) days. However, this may still vary depending on the applicant’s ability to comply with requirements as soon as possible,  the location of the establishment (e.g., in Visayas or Mindanao), the number of directors and shareholders, and other factors. We are also equipped to handle rush probity checks or reports with an additional processing fee, which are required to be completed within 1-2 weeks. 

… and you might just need our assistance.

FilePino is the sole and long-term PAGCOR-accredited probity checker in the Philippines. We conduct legally compliant, comprehensive, and fast background checks to verify the authenticity of the information of PIGO license applicants. 

Ready to work with our background check investigators for your PIGO license application? Set up a consultation with FilePino today! Call us at (02) 8478-5826 (landline) and 0917 892 2337 (mobile) or send an email to info@filepino.com.