pagcor_framework

Regulatory Framework for Offenses and Penalties for Licensed Land-Based Casinos

PAGCOR

Licensing and Regulatory Group Land-Based Operations

Gaming Licensing and Development Department

REGULATORY

1 FRAMEWORK FOR

OFFENSES AND

I PENALTIES

(LICENSED LAND-BASED I CASINOS)

Revision No.: 0 Effectivity: August 13, 2025

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EXECUTIVE SUMMARY

The Regulatory Framework for Offenses and Penalties (Licensed Land-Based Casinos) is established to strengthen the enforcement of the Casino Regulatory Manual, which is the primary regulatory policy for Licensees. Fundamentally, the framework aims to promote a fair, consistent, and adaptable system for classifying regulatory violations and imposing appropriate penalties

This framework operates under the following key guiding principles:

First, the penalty structure follows progressive discipline, escalating sanctions according to the frequency and severity of the violations. This approach encourages licensees to address and correct behavior before more severe penalties are imposed.

Second the penalty structure upholds proportionality, ensuring that the sanction imposed are commensurate with the classification and frequency of the offense, promoting justice and deterrence without being excessive.

Third, the regulatory proceeding is anchored on an impartial procedure that safeguards due process, issuing a formal notice and providing provision for the submission of an answer prior to the imposition of any penalty.

Fourth, the regulatory proceeding is further strengthened by defined timeframes and proper documentation for each stage, promoting accountability and transparency in the enforcement of sanctions.

Through this initiative to institutionalize these principles, PAGCOR fosters a collaborative regulatory environment where the regulator and the Licensees are guided by shared

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responsibility, transparency, and commitment to sound and compliant operations reinforcing public trust in the integrity of gaming oversight.

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L TABLE OF CONTENTS

DEFINITION OF TERMS 4 I PRELIMINARY PROVISIONS U SECTION 1.SCOPE AND COVERAGE 6

SECTION 2.FORM OF REPORTS, COMPLAINTS, E ENDORSEMENTS,OR REFERRALS 6

SECTION 3. COMPOSITION OF THE EVALUATION COMMITTEE 6

II PROCEDURE FOR THE CONDUCT OF REGULATORY PROCEEDINGS

SECTION 4. INITIATION 1 C SECTION 5. INITIAL EVALUATION 8

SECTION 6. ISSUANCE OF NOTICE TO SHOW CAUSE ORDER L AND SUBMISSION OF AN ANSWER 9

SECTION 7.FINAL DISPOSITION 10 C SECTION 8.SUBMISSION OF MOTION FOR RECONSIDERATION - 113

SECTION 9.PAYMENT OF PENALTY 13 W SECTION 10.PROOF OF PAYMENT 13

III PENALTY STRUCTURE L SECTION 11.CLASSIFICATION GUIDELINES 14

IVTABLE OF OFFENSES AND PENALTIES 17 1 V MISCELLANEOUS PROVISIONS 30

ANNEX FORMS 31 B

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U DEFINITION OF TERMS

Written Warning This serves as an initial compliance reminder and does not

carry any additional penalty or corrective action. It is issued for first-time minor violation.

Monetary Penalty A fine imposed based on the seriousness and frequency of

the violation.

Corrective Action Order A formal instruction reguiring the Licensee to adopt, vary. cease, or refrain from any practice in respect to the

conduct of casino operations, which may be

Standalone -- issued independently for operational issues requiring remedial steps in a first-time minor

I violation.

Accessory - issued in conjunction with other penalties (e.g., fines or suspensions) to ensure

I corrective measures are implemented.

L Suspension of Operations A temporary prohibition on the conduct of gaming operations due to serious or repeated violations

1 ancillary or supplemental game offering (e.g., Traditional Suspension may be partial, involving only the specific

I violation. Bingo, Online Gaming Platform) directly affected by the

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U Revocation of License Cancellation of the Provisional/Gaming License due to

grave, willful, or persistent violations. Like suspension, revocation may also be applied partially, involving the specific ancillary game or supplemental game offering implicated in the violation, without affecting the entire scope of the license.

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L A PRELIMINARY PROVISIONS

Section 1 -- Scope and Coverage

have committed acts or omissions in violation of Philippine laws, found to be non- or fail to adhere to any regulatory directives/orders issued by PAGCOR. compliant with the Casino Reguiatory Manual for Licensed Land-Based Casinos (CRM), All Licensed Land-Based Casinos shall be subject to regulatory sanctions if adjudged to

Section 2 -- Form of Reports, Complaints, Endorsements, or Referrals

regulatory evaluation shall be made in writing and must clearly state the factual basis of the alleged violation. Reports, complaints, endorsements, or referrals intended to serve as the basis for

Anonymous submissions where the identity of the complainant cannot be ascertained shall not be acted upon and shall be deemed for record purposes only.

Section 3 -- Composition of the Evaluation Committee-

1 matters involving Licensed Land-Based Casinos, an Evaluation Committee shall be To ensure consistent and objective review of regulatory violations and compliance

U incident and recommend appropriate regulatory action. constituted to assess the facts, documentation, and circumstances surrounding each

The Evaluation Committee shall be composed of the following:

1 U Committee Chairperson -- The Senior Manager of the Casino Licensing and Regulatory Division shall serve as the Chairperson of the Evaluation Committee. The Chairperson

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shall preside over committee deliberations and ensure that assessments are conducted in an impartial and procedurally sound manner.

Designated Member -- The assigned Senior Regulatory Officer overseeing the operations of the Licensee concerned shall serve as a designated member for the specific matter under review. As part of this role, the designated member shall prepare an assessment report to be submitted to the Committee Chairperson for the determination of whether a violation has been committed and the appropriate regulatory action to be taken.

Secretariat -- A fixed member shall be designated to provide administrative support to the Evaluation Committee. The Secretariat shall be responsible for coordinating meetings, maintaining records, monitoring actions taken, and documenting the outcome of each evaluation for reporting and compliance tracking.

The recommendation of the Evaluation Committee shall be submitted to the Assistant Vice President of the Gaming Licensing and Development Department (GLDD) for final review and approval, subject to applicable regulatory policies and procedures.

PROCEDURE FOR THE CONDUCT OF REGULATORY PROCEEDINGS

Section 4 -- Initiation

U Regulatory proceedings may be initiated by the Gaming Licensing and Development

Department (GLDD) either:

on its own initiative, or

upon the formal transmission of the following to GLDD, citing potential violations

of Philippine laws, the CRM, and/or regulatory directives/orders:

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C 1. A complaint from patrons or concerned citizens, claiming alleged

violation(s) accompanied by supporting evidence.

2. An observation report from the PAGCOR Compliance Monitoring and

Enforcement Department - Integrated Resorts, citing the violation(s) committed and the basis for such findings C 3. A referral or endorsement from other PAGCOR departments or a relevant

government agency, indicating the alleged violation(s) and any supporting documentation(s).

C Section 5 -- Initial Evaluatior

U shall conduct an initial evaluation within ten (10) business days. Upon receipt of the complaint, report, referral, or endorsement, the Evaluation Committee

U Based on the results of its initial evaluation, the Evaluation Committee may take any of

C the following regulatory actions:

Refer the matter to the appropriate PAGCOR department or government agency

if the issue is determined to be outside GLDD's regulatory jurisdiction.

L Reguest additional information or clarification from the source of the submission if

C the initial documentation is insufficient to proceed with regulatory evaluation. In such instances, the ten (10)-day evaluation period shall be suspended until the

required information is received.

Archive the complaint without further action if it is deemed manifestly

unmeritorious or frivolous and/or the identity of the complainant cannot be

C ascertained.

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C Keep records on file for future reference if the subject matter has already been

L resolved or is presently under review by another PAGCOR department or government agency. In such case, the Licensee shall be informed accordingly

Issue a Notice to Show Cause Order (NCO) to the concerned Licensee to explain or justify its actions relative to the alleged violation(s), within a specified period

Section 6 -- Issuance of Notice to Show Cause Order and Submission of an Answer

C 6.1. Issuance of Notice to Show Cause Order (NCO)

Upon determination that a regulatory proceeding is warranted, the Evaluation Committee shall issue an NcO, stating why no regulatory sanction should be imposed on the concerned Licensee

C The NCO shall formally state: the alleged violation

C : the factual basis, offense committed, and the corresponding penalty.

L an instruction to submit the written explanation within ten (10 business days from receipt

6.2. Submission of Answer

C The Licensee shall submit its written Answer to the NCO within the

prescribed ten (10) business days

The Answer must:

C respond to each cited violation.

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present any supporting evidence 0 indicate any corrective or remedial actions already undertaken, if applicable.

6.3. Request for Extension to file an Answer.

C A request for reasonable extension of time to submit the Answer may be

granted by the Evaluation Committee upon written request, stating justifiable grounds

Failure to submit a timely Answer shall be construed as a waiver of the opportunity to be heard. In such case, the Evaluation Committee shall proceed with the evaluation of the matter based on the submissions and/or documents on file.

Section 7 - Final Disposition

E without submission, the Evaluation Committee shall conduct a Final Evaluation. The Upon receipt of the Licensee's Answer to the NCO or expiration of the period to respond

C final review and approval of its regulatory action. Evaluation Committee shall submit a formal recommendation to the AVP of GLDD for

3 The following rules shall apply in the disposition of its recommendation:

C 7.1. Recommendation Guidelines

1 7.1.1. For Minor and Moderate Offenses

3 a Request for clarification or opinion

The Evaluation Committee may, if deemed necessary request clarification or opinion from the PAGCOR

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Legal Group (LG) or other PAGCOR departments concerned.

b. Issuance of Notice

Based on the available facts and any obtained opinion the Evaluation Committee shall issue either:

3 A Notice of Imposition of Penalty (NIP), if there is

C sufficient ground to impose a regulatory penalty; or

C A Notice of Dismissal (ND), if the Licensee's explanation adequately addresses the issue and

L 7.1.2 For Major Offenses negates the basis for imposing a penalty

C The Evaluation Committee shall apply the following process:

3 Request for Opinion

E The Evaluation Committee shall request a legal opinion from LG, and, if deemed necessary, a

C technical or subject matter opinion from other concerned PAGCOR departments

C b. Submission of Recommendation for the approval of

C the PAGCOR Board of Directors (BOD) Upon receipt of the required legal and/or technical

opinion, the Evaluation Committee shall prepare and

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1 submit the recommendation, signed by the AVP, to the

BOD for consideration and approval.

C. Issuance of Notice and Implementation of BOD

Instructions

G Based on the BOD's decision,the Evaluation

C Committee shall either:

C Issue an NIP or an ND of the regulatory proceedings, as approved.

0 Implement any other instructions issued by the

L BOD, if applicable.

R 7.2. Release of Decision

U The Evaluation Committee shall issue a decision within ninety (90) calendar days from receipt of the Licensee's written reply, or in the

absence thereof, from the lapse of the prescribed period for submission

C 7.3. Issuance of Notice of Referral

Where jurisdictional limitations are established only after further fact-finding or upon receipt and review of the Licensee's written answer, the Evaluation

C or relevant government agency and issue a Notice of Referral to the Committee shall refer the matter to the appropriate PAGCOR department

D concerned Licensee.

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Section 8 Submission of Motion for Reconsideration

U The Licensee may file a Motion for Reconsideration (MR) within fifteen (15)

E working days from receipt of the decision.

N and issue a final decision within thirty (30) working days, either affirming or Upon receipt of the MR, the Evaluation Committee shall evaluate the same

reversing its earlier ruling.

C Only one (1) Motion for Reconsideration shall be entertained for the same matter. No further reconsideration shall be allowed

Section 9 Payment of Penalty

L The Licensee must pay the corresponding monetary penalty within fifteer

(15) days from receipt of the NIP, if applicable. In case of a pending MR L the Licensee shall pay under protest the penalty imposed within the same

prescribed period,without prejudice to the resolution of the MR M A 12% annual interest (pro-rated daily) shall be applied to any amount

unpaid after the 15-day period

1 Section 10Proof of Payment

M Proof of payment must be submitted to PAGCOR Fund Management Department by the concerned Licensee for issuance of Official Receipt and

proper recording A copy of the Official Receipt shall also be furnished to GLDD for monitoring and compliance tracking purposes.

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I PENALTY STRUCTURE

This section provides an overview of the penalty matrix and outlines the guidelines on interpreting and applying its provisions.

Section 11 Classification Guidelines

Offenses shall be categorized into Minor, Moderate, or Major based on their impact on

public order, financial losses to the government, and integrity of gaming operations. The corresponding sanction may include a Corrective Action Order to address underlying issue.

11.1. Offense Classification and Corresponding Sanctions

Classification Definition Penalty

Technical or administrative non-compliance with the

Casino Regulatory Manual (CRM) that has minimal or

Minor no adverse impact on: Publictrust order and Warning /Corrective Action Order First Instance Second Instance : P 20,000.00 : Written

revenue Government Third Instance: P 30,000.00

Fairness and

credibility of game integrity

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Minor offenses arise from simple negligence, characterized by unintentional oversight or a lack of due care in fulfilling

regulatory obligations.

non-compliance with the Technical or administrative First Instance : P 40,000.00

CRM that has significant Second Instance : P 50,000.00 adverse implications for: Third Instance Suspension/ P 60,000.00

Public trust and order

Government revenue Action Order Accessory Penalty: Corrective

Moderate Fairness and

credibility of game integrity

Moderate offenses involve either:

Gross negligence defined as a serious failure to exercise the level of diligence or control expected

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in gaming operations, or

Malicious intent, where the act is committed deliberately or with willful disregard for regulatory requirements. A serious breach involving any local or national law of Major the Philippines that has an adverse effect on national License Suspension or Revocation of

security and interest.

11.2. Application and Interpretation

: Monetary Thresholds for Penalty Classification

P 50, 000.00 Monetary and below Range No or minimal impact on Gross Gaming Revenue (GGR) Description Monetary Thresholds Penalty Classification Minor

Significant adverse implications

P 50,000.00 above traceability. on GGR, affecting accuracy or Moderate

Note: The monetary thresholds are general guidelines for classifying violations based on GGR impact. PAGCOR may reclassify any offense at

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its discretion, considering factors such as recurrence and/or risk to public trust and order, fairness, and credibility of game integrity, and on national security and interest, among others.

Determination of Repeat Offenses for Penalty Escalation

For penalty escalation purposes, repeated commission of the same offense under the same offense code shall be counted as subseguent instances of that offense. Separate or unrelated offenses shall be

1 treated independently when determining the applicable escalation level.

Habitual Violation

Repeated commission of the same offense under the same offense code for the fourth (4th) time and beyond and within the applicable penalty cycle shall warrant elevation of the penalty to the next higher 1 classification.

IV.TABLE OF OFFENSES AND PENALTIES

1 applicable to Licensed Land-based Casinos. Each entry consists of the following The table below enumerates the list of regulatory offenses and corresponding penalties

components:

. Offense Code -- A unique reference number assigned for tracking and

L documentation.

L Description of the Offense - A brief outline of the violation, specifying the act or omission involved.

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Penalty Classification -- The prescribed sanction based on the nature and gravity

Of the offense. For purposes of assessing violations, multiple instances of the same offense occurring under the same operational condition and discovered within a single audit or monitoring period shall be considered as one count of violation, unless committed across different gaming areas, separate operational days, or involving materially distinct circumstances.

For further guidance, please refer to the Penalty Structure under Regulation III for the corresponding definitions and application of the Penalty Classification.

I Offense Code Unauthorized implementation or modification of gaming operational activities that reguire Description of the Offense Penalty Classification

prior submission of CRM-prescribed forms or

CRM 01 act or omission has minimal or no material securing of regulatory approval, where such Minor

impact on Gross Gaming Revenue (GGR) and/or game integrity. Non-compliance with CRM-prescribed

1 including but not limited to deviations in game standards, or internal control procedures,

CRM 02 rules, table procedures, card handling, usage of gaming equipment or paraphernalia, or Minor

system configurations, where such act or omission has minimal or no material impact on GGR or game integrity.

CRM 03 Any other technical or administrative non compliance, where such act or omission has Minor

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minimal or no material impact on GGR or game integrity

CRM 04 Submission of falsified, invalid, materially erroneous, or misleading reports, whether Moderate

deliberate or due to gross negligence. Non-compliance with any issued corrective

CRM 05 order, any other relevant communication or memorandum issued by PAGCOR,and/or any Moderate

national/local laws of the Philippines

CRM 3.1 Breach of the PAGCOR-approved gaming capacity for gaming tables. Moderate

CRM 3.2 Breach of the prescribed Table Games Mix Ratio Moderate

CRM 3.3 gaming tables Unauthorized installation and operation of Moderate

CRM 3.4 Wagering System for Table Games. Unauthorized implementation of a Progressive Moderate

CRM 3.5 linked Jackpot for Table Games Unauthorized implementation/cessation of Moderate

Breach of the PAGCOR-approved gaming CRM 4.1 capacity for Electronic Gaming Machines (EGMs) Moderate

CRM 4.2 Unauthorized installation and EGMs operation of Moderate

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CRM 4.3 Configuration of EGMs below or above the prescribed Return-to-Player (RTP) percentage Moderate

Implementation of promotional Baccarat or CRM 4.4 Baccarat tournamentswithoutPAGCOR Moderate

approval

Use of any gaming equipment not approved by CRM 5.1 PAGCOR or which has been revoked or Moderate

suspended. Use of any approved gaming equipment which CRM 5.2 has been modified without PAGCOR's Moderate

approval.

Use of unapproved Casino Management CRM 6.1 System, features, or unauthorized software Moderate

changes. Failure to ensure integrity of player tracking. CRM 6.2 Within the CMS. credit issuance, or reporting functionalities Moderate

Alteration of critical CMS data during emergency software patch implementation

CRM 6.3 without an audit trail or where the system Moderate

operates in a default "enabled" or unprotected mode. Implementation of remote access to the

CRM 6.4 the required access controls (e.g., identity Casino Management System (CMS) without Moderate

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verification, authorized and temporary access activity logs, security system protections)

CRM 7.1 Modifying the surveillance system or plan without prior PAGCOR approval Moderate

CRM 7.2 of the surveillance system or its recordings. Unauthorized tampering with or compromise Moderate

CRM 7.3 Failure to retain or secure surveillance footage as required. Moderate

CRM 8.1 Issuance or redemption of chips and/or plaques not approved by PAGCOR Moderate

CRM 8.2 and/or plaques Circulation or acceptance of counterfeit chips Moderate

Improper documentation,handling,or disposa

CRM 9.1 sort, store, or discard cards in accordance with of playing cards, including failure to record Moderate

prescribed procedures.

Unauthorized procurement of gaming

1 CRM 10.1 equipment from suppliers not enrolled with Moderate

GLDD

CRM 10.2 PAGCOR clearance Importation of gaming equipment without prior Moderate

C CRM 12.1 Unauthorized pull-out or transfer of gaming equipment and paraphernalia without the Moderate

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approval of PAGCOR and/or permit from the Department of Finance (DOF or the Special

Economic Zone Authority (SEZA) or other government agencies as may be applicable resulting inuninspected, unverified, O unregisteredequipmentbeingused in operations. Use or storage of gaming equipment not CRM 12.2 inspected by the PAGCOR Inspection Team Moderate

following the pull-out or transfer.

Unauthorized decommissioning of gaming

CRM 13.1 equipmentwithoutDOFand/or SEZA clearance, and/or without reguired oversight Moderate

by PAGCOR Failure to destroy sensitive components of

CRM 13.2 decommissionedequipment(e.g.,EGM cabinets, chips), or falsification of destruction Moderate

records

CRM 14.1 Circumvention of internal control procedures (e.g., cage, count, drop box processes). Moderate

Implementation of unapproved deviations from

CRM 14.2 theapproved CORGorrelatedcontrol Moderate

procedures.

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Manipulating game outcomes to favor certain

CRM 15.1 players,whether deliberatelyor through Moderate

repeated procedural failures. Repeated dealing or payout errors resulting CRM 15.2 from failure to observe standard procedures or Moderate

controls.

Unauthorized issuance or removal of gaming

CRM 16.1 required documentation, inventory records, or chips/plaques from gaming tables without Moderate

PAGCOR approval. Failure to open, count, reconcile, or document CRM 16.2 the contents of drop boxes in accordance with Moderate

prescribed procedures. Use, circulation, or redemption of expired CRM 16.3 invalid, or unapproved gaming chips or chip Moderate

purchase vouchers. Permitting visibly intoxicated individuals to

CRM 16.4 public order, player safety, and the reputationl engage in gaming activities, posing risks to Moderate

of regulated casino operations. Unauthorized photography or recording of

C CRM 16.5 gaming operations or surveillance-restricted surveillance integrity, or player privacy areas, compromising game security, Moderate

CRM 17.1 Unauthorized implementation of rebate or rolling commission programs without Moderate

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PAGCOR's approval or in violation of prescribed guidelines, resulting in potential GGR misstatement or abuse of incentives.

CRM 18.1 Unauthorizedimplementation of marketing and/or casino promotions. Moderate

Engaging in junket agreements without the

C CRM 19.1 required notification to PAGCOR, resulting in unmonitored activities that impact GGR and regulatory oversight. Moderate

Entering junket agreements with individuals or

CRM 19.2 entities identified or classified as banned personalities, posing significant risk to public Moderate

interest and regulatory integrity. Failure to verify suspicious entries and

N CRM 19.3 regularly update the Junket Player Database. allowing ineligible players to participate and compromising regulatory safeguards. Moderate

D U CRM 19.4 Hiring or deploying junket runners without PAGCOR's notification or beyond permitted Video streaming of junket tables without platforms, or geographic restrictions. Moderate

C CRM 19.5 enabling unregulated player solicitation and securing prior written approval from PAGCOR Moderate

gaming activity.

C CRM 19.6 backgrounds, derogatory records, or inclusion Employing junket runners with known criminal Moderate

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in PAGCOR's banned list, undermining the integrity of casino operations and increasing reputational and compliance risks.

CRM 21.1 Gross Misstatement, under-declaration, or falsification of GGR report from table games. Moderate

Omission or misclassificationof income

CRM 21.2 components from table gaming operations Moderate

(e.g., side bets, bad beat jackpots, fees. Adoption of unapproved formulas, systems, or adjustments in computing GGR from table

CRM 21.3 games without prior PAGCOR approval, Moderate

thereby violating standard financial reporting frameworks.

CRM 22.1 Gross Misstatement, under-declaration, or falsification of GGR report from EGMs. Moderate

Unauthorized clearing or reset of EGM CRM 22.2 Random Access Memory (RAM) without PAGCOR oversight Moderate

Tampering with, or unauthorized access to. EPROMs, logic doors, or seals of EGMs, CRM 22.3 and the credibility of regulated posing risks to game integrity, audit reliability, EGM Moderate

operations.

CRM 24.1 Monitoring Team (PMT) of an unresolved Failure to immediately notify the PAGCOR Moderate

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patron dispute and to inform the patron of their right to request a PMT investigation, resulting in denial of due process and regulatory oversight.

Failure to pay a patron's validated claim within 30 days of final resolution by the Patron

CRM 24.2 PAGCOR exemption, constituting a breach of Dispute Committee, without securing Moderate

regulatory settlement procedures and patron trust. Failure to maintain complete and verifiable

CRM 24.3 records of dispute proceedings, undermining auditability, transparency, and potential re Moderate

examination of decisions.

Refusal or willful failure to cooperate with

CRM 27.1 PAGCOR Monitoring Team (PMT) audit, Moderate

inspection, or surveillance activities Deliberate denial of access to gaming records

CRM 27.2 surveillance systems, electronic logs, or restricted physical areas to authorized PMT Moderate

personnel.

Non-remittance or under-remittance of license

CRM 29.1 fees from bingo operations due to inaccurate reporting or intentional misstatement of gross Moderate

receipts.

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Use or circulation of unapproved, counterfeit,

CRM 29.2 or improperly inventoried bingocards, Moderate

compromising game integrity and traceability. Maintaining bingo hall facilities in a condition

CRM 29.3 that compromises the security, accuracy, or Moderate

fairness of the game. Implementation of unauthorized bingo game formats or prize structures without PAGCOR

CRM 29.4 review or approval, leading to unregulated Moderate

payout liabilities and untracked player incentives.

Failure to adhere to prescribed dispute or

CRM 29.5 game cancellation protocols, resulting in unresolved patron claims and potential abuse Moderate

of game results. Non-resolution or mismanagement of

CRM 29.6 technical failures in linked electronic bingo games,affecting game outcomes and Moderate

undermining player confidence.

Operation of sports betting games, systems, CRM 29.7 formats, events without prior evaluation and Moderate

approval from PAGCOR. Failure to maintain or establish a secure offsite

CRM 29.8 backup database server for the betting system, risking total data loss, revenue Moderate

misstatement, and post-event audit failure

PAGCOR REGULATORY FRAMEWORK OF OFFENSES AND (LICENSED LAND-BASED CASINOS) DEVELOPMENT DEPARTMENT GAMING LICENSING AND PENALTIES Page No. Effectivity Rev. No. Page 28 of 31 AU6 1 3 2025 0

Breach of sworn undertakings on legal,

CRM 29.9 secure, operations, potentially exposing the enterprise and compliantsportsbetting Moderate

to legal liability, and endangering public trust.

Operation of cruise ship casino without valid

CRM 30.1 issued approval, constituting unauthorized PAGCOR authority or outside the terms of Moderate

gaming activity under Philippine jurisdiction. Failure to notify PAGCOR of ship arrival or to allow inspection prior to or during gaming CRM 30.2 operations, compromising regulatory Moderate

presence, jurisdictional control, and oversight of GGR-generating activities.

Any act or omission not specifically listed but which, through deliberate intent or gross

CRM 06 undermines public trust and order, or negligence, reduces government revenue, Moderate

compromises the fairness and credibility of gaming operations.

Engaging in or facilitating unauthorized or illegal gambling activities, including operations

GO 01 without appropriate licenses or beyond Major

permitted scope, in violation of R.A. No. 9287 and other applicable laws.

PAGCOR REGULATORY FRAMEWORK OF OFFENSES ANDT (LICENSED LAND-BASED CASINOS) DEVELOPMENT DEPARTMENT GAMING LICENSING AND PENALTIES Page No. Effectivity Rev. No. Page 29 of 31 AU6 1 3 2025 0

Obstruction of justice or willful concealment of

GO 02 material facts relevant to ongoing regulatory. legal, or criminal investigations, affecting Major

national security and interest.

Use of the casino premises or systems for any

GO 03 unlawful purpose, including fraud, identity theft, or cybercrime activities punishable under Major

R.A. No. 10175 (Cybercrime Prevention Act). Commission of acts or omissions in violation of applicable national or local laws that materially] GO 04 or the integrity of government-regulated compromise national security, public interest, Major

gaming operations. Deliberate refusal or failure to cooperate with duly authorized investigations, audits, or compliance reviews conducted by the AMLC,

GO 05 such non-cooperationundermines lawful BIR, or other competent authorities, where Major

enforcement mechanisms and poses a material threat to national security, financial system integrity, or public interest. The failure of the Licensee to remit, in full or in

GO 06 part, the required License Fee within the prescribed period, without valid justification Major

and despite notice or demand.

PAGC REGULATORY FRAMEWORK OF OFFENSES AND (LICENSED LAND-BASED CASINOS) DEVELOPMENT DEPARTMENT GAMING LICENSING AND PENALTIES Page No. Rev. No. Effectivity Page 30 of 31 AU6 1 3 2025 0

V. MISCELLANEOUS PROVISIONS

The Regulatory Framework for Offenses and Penalties for Licensed Land-Based

Casinos shall repeal previous issuances, the provisions of which are inconsistent With the same.

: This framework shall apply to all pending cases decided upon its approval.

Any prior infractions or offenses committed before its effectivity shall not be carried

over or counted to determine repeated violations.

The penalty cycle applicable to each Licensee shall be renewed every three (3) years, reckoning from the date of approval of this framework by the PAGCOR Board of Directors.

For this purpose, the computation of repeat offenses, escalation of penalties, and related monitoring shall reset at the start of each new penalty cycle.

PAGCOR REGULATORY FRAMEWORK OF OFFENSES AND (LICENSED LAND-BASED CASINOS) DEVELOPMENT DEPARTMENT GAMING LICENSING AND PENALTIES Page No Rev. No. Effectivity Page 31 of 31 AUG 1 3 2025 0

ANNEXES

LIST OF FORMS

Corrective Action Order Notice to Show Cause Notice of Imposition of Penalty Name of Form Form No. 2 3 1

LLBC - RP Form 1

Page No. Page 1 of 2

PAGCOR NOTICE TO SHOW CAUSE Revision No. Form No. Effectivity GLDD- 1677 AUG 13 2025 0

Date:

RP Docket No:

Based Casino: Licensed Land.

Address:

Reference:

SECTION A.NATURE OF INCIDENT

Date: Time:

2 Place:

3 Factual

Details:

SECTION B. OFFENSE AND PENALTY

Offense Penalty

LLBC - RP Notice to Show Cause 1|Page

LLBC - RP Form 1

Page No. Page 2 of 2

PAGCO NOTICE TO SHOW CAUSE Form No. Effectivity Revision No GLDD --1677 AUG 13 2025 0

SECTION C. SHOW CAUSE

Pursuant to the Regulatory Framework for Offenses and Penalties (Licensed Land-Based Casinos), this document formally notifies the Licensee of the alleged violation(s) committed. The Licensee is required to submit a written reply within ten (10) business days from receipt of this Notice. Failure to comply shall be construed as a waiver of the Licensee's right to be heard, in which case PAGCOR shall proceed to render a decision based solely on the available records and evidence

In accordance with the prescribed process under the framework, PAGCOR shall issue a decision on the matter within ninety (90) calendar days from receipt of the Licensee's written reply, or in the absence thereof, from the lapse of the prescribed period for submission.

MA.VINA CLAUDETTE P.OCA Assistant Vice President

ACKNOWLEDGEMENT RECEIPT (To be filled out by the authorized signatory of Licensee)

By:

Printed Name: Position Title: Signature: Date:

LLBC - RP Notice to Show Cause 2|Page

LLBC - RP Form 2

Page No. Page 1 of 1 NOTICE OF IMPOSITION OF PENALTY Form No. GLDD -1676

PAGCOR Effectivity Revision No AUG 13 2025 0

Date: RP Docket No:

Licensee: Address:

Reference:

SECTION A.VIOLATION

SECTION B.PENALTY

Particulars: Total Amount Due Due Date 15 days upon receipt of NIP

We shall appreciate the settlement of the total amount due on or before due date to Landbank of the Philippines with the following account details:

Account Name Account Number PAGCOR OPEX Fund C/A No.3402-1036-70

SECTION C.REMINDERS

M The Licensee may file a Motion for Reconsideration within fifteen (15) days from receipt of this Notice

provided the total penalty imposed has been paid under protest.

2 Payment will only be considered upon GLDD's receipt of the bank validated deposit slip or issued

Official Receipt.

MA.VINA CLAUDETTE P.OCA Assistant Vice President

CC:AVP,CMED-IR

ACKNOWLEDGEMENT RECEIPT(To be filled out by the authorized signatory of Licensee/Gaming Operator

By:

Position Title: Printed Name: Signature: Date:

LLBC - RP Notice of Imposition of Penalty 1|Page

LLBC - RP Form 3

PAGCOR CORRECTIVE ACTION ORDER Form No. Page No. Revision No. Effectivity GLDD - 1675 Page 1 of 1 AUG 1 3 2025 0

Date: RP Docket No:

Licensee: Address:

Reference:

SECTION A.BASIS OF ORDER

0 First-time minor violation involving operational practice

0 Accessory penalty.

D Others:

SECTION B.INSTRUCTION(S

SECTION C.NON-COMPLIANCE WARNING

imposition of further regulatory sanctions, including but not limited to monetary penalties, suspension of Failure to comply with this Corrective Action Order within the prescribed timeline may result in the

operations, or other regulatory actions deemed appropriate.

MA. VINA CLAUDETTE P. OCA Assistant Vice President

CC: AVP,CMED-IR

ACKNOWLEDGEMENT RECEIPT (To be filled out by the authorized signatory of Licensee/Gaming Operator

By:

Printed Name: Position Title: Date: Signature:

LLBC - RP Corrective Action Order 1|Page

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