A prominent legal authority cautions that recent efforts to pass laws banning online gaming could make irresponsible gambling worse by driving operators to operate clandestinely. 

Atty. Tonet Quiogue, head of Arden Consult, a trusted technology consulting firm, issued a 15-page memorandum expressing a clear yet impactful view: banning online gaming entirely would undermine the government's capacity to regulate illegal gaming and its abuses. 


“The real enemy, as any seasoned observer knows, is illegal gambling – operations that bypass all regulations, pay no taxes, and offer no player protections,” argues Quiogue in her memorandum. “If the goal of lawmakers is to eliminate the social ills of gambling, then the logical approach is to surgically strike at these illicit operations, not to outlaw the entire industry and penalize legitimate stakeholders.”


Quiogue’s warning comes on the heels of various bills filed by legislators, including the most recent Senate Bill filed by former Senate President Migz Zubiri. Quiogue’s piece, however, takes direct aim at bills filed by Senators Pia and Alan Cayetano, Joel Villanueva, and Sherwin Gatchalian.

Concerning the bills above filed, Quiogue says that the bill’s preambulars and “whereas clauses” paint gambling as an inherently illicit activity, linked directly to fraud, money laundering, and human trafficking. However, as Quiogue points out, there is no evidence to support this treatment of gaming. 

Quiogue states that this flawed understanding of gambling overlooks the strict legal requirements established by the Philippine Amusement and Gaming Corporation (PAGCOR) that gaming operators must meet before obtaining licenses.

“Every licensed online platform’s software and hardware must be independently certified for fairness and security before launch, said Quiogue, citing PAGCOR’s extensive audits and compliance checks. “Suspicious activities (large irregular bets, anomalous payouts, etc.) can be quickly flagged and investigated, making it very difficult for criminals to exploit licensed platforms for money laundering or fraud.”

Given this, Quiogue emphasizes that the notion regulating gaming is linked to illegal activity is not only incorrect but also risky, since real illicit gambling activities usually occur when gambling is unregulated and unchecked.



“By contrast, unregulated gambling sites truly fit the whereas clause’s dire description – they do provide a haven for illicit activities because they operate in the shadows, outside of Philippine law,” says Quiogue. “It is telling that proponents of a ban cite criminal cases “linked to online gambling operations” without distinguishing whether those were legal or illegal operations. The lack of reported criminal breaches in PAGCOR-supervised online gaming suggests that the current licensed regime has been largely effective in mitigating the very risks cited.“


In addition to this, Quiogue further supports her argument by citing comparative approaches in different legal jurisdictions. Countries such as China, Vietnam, and Indonesia, for instance, were cited by Quiogue as having huge underground gambling problems despite the countries’ absolute prohibitions on gambling. 

Conversely, Quiogue highlights that countries like the United Kingdom, Sweden, and Italy have taken a different approach by legalizing gaming and experiencing markedly different outcomes. He points to Sweden as an example, where bettors shifted promptly to domestically regulated sites rather than offshore bookmakers, with over 85% of Swedish players engaging through legal channels.

As the Philippine legislature weighs these competing approaches, the evidence, according to Quiogue, suggests a clear path forward —one that experts like Quiogue believe the public should fully participate in. As Quiogue points out, it is evidence-based policymaking that works for the benefit of the Filipino, instead of a haphazard patchwork driven by fearmongering. To really protect Filipino gamers from the ills of gambling, the public must come together and collectively reject these empty solutions that destroy working systems and create new crime.