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Philippine Gambling Ad Ban Faces Offshore Enforcement Gap

A proposed nationwide gambling advertising ban in the Philippines could place greater pressure on licensed operators. At the same time, it could leave offshore platforms difficult to control, according to gaming lawyers.

Russell Stanley Geronimo, founder of Geronimo Law, warned that a broad advertising prohibition could restrict regulated businesses. Meanwhile, illegal operators could continue reaching Filipino consumers through channels such as SMS, private messaging and affiliates.

Gaming lawyer Tonet Quiogue has raised similar concerns. She argued that a blanket ban could unintentionally push consumers toward offshore gambling platforms that already operate outside the regulated market.

Two Gambling Advertising Bills Proposed

The debate centres on two separate bills with different scopes. Senate Bill No. 2347, filed by Senator Francis “Chiz” Escudero on July 26, proposes a broad prohibition covering gambling advertising and sponsorship across television, radio, print, outdoor media, online platforms and social media. Furthermore, it would prohibit celebrity and influencer endorsements.

Meanwhile, House Bill No. 10982, introduced by Cebu 3rd District Representative Karen Hope Garcia on August 26, specifically targets advertising, promotion and sponsorship for online gambling. Unlike the Senate proposal, it would not prohibit advertising for licensed land-based casinos.

Offshore Operators Remain Difficult to Police

Existing advertising controls primarily apply to PAGCOR licensees and accredited service providers. The Advertising Standards Council (ASC) also operates as a self-regulatory body. However, its rules cannot directly penalise offshore operators or non-members.

This creates an enforcement gap because unlicensed platforms can use international programmatic advertising networks, social media, affiliates and direct messaging. These platforms do not rely on the same local media channels as regulated operators.

Geronimo noted that enforcing Philippine criminal law directly against overseas operators would remain difficult because criminal jurisdiction is generally territorial. Authorities could instead rely on measures such as website and advertising-domain blocking and payment restrictions.

Regulation Could Affect Channelization

Quiogue warned that restricting advertising by licensed operators could weaken the regulated market. This risk grows if offshore platforms continue promoting their services illegally.

She argued that lower licensing costs, stronger customer verification and enforcement against illegal websites have helped shift players toward regulated platforms. In contrast, a broad advertising ban could potentially undermine that progress by reducing the visibility of legal operators.

However, estimates regarding the licensed share of online gambling use different methodologies. For that reason, they should not be treated as equivalent to official transaction data.

Defining Advertising and Liability

Another concern is how broadly the legislation defines advertising, promotion and sponsorship. Geronimo said overly broad language could potentially cover corporate branding, sports sponsorships, naming-rights agreements and responsible gaming campaigns.

He recommended distinguishing commercial promotion from public-interest information and communications required by regulators.

Geronimo also called for liability to reflect the role and knowledge of each party. He urged greater responsibility for operators, advertisers, agencies and affiliates that create or distribute paid promotions.

Enforcement Balance Will Be Critical

The proposed legislation highlights a key challenge for the Philippines. The country must strengthen gambling advertising controls without unintentionally giving offshore operators a competitive advantage.

As lawmakers consider the two bills, the effectiveness of the final framework will depend not only on restrictions placed on licensed businesses. It will also rely on the government’s ability to address offshore advertising, payments and access.

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