RESOURCES

Comments on the Draft Circular on the Regulations on Online Gambling Payment Services

This legal advisory from Geronimo Law offers policy recommendations to strengthen the Draft Circular on the Regulations on Online Gambling Payment Services for stronger compliance rules for PSPs and online casino payments. Authored by Atty. Russell Stanley Geronimo, founder and managing lawyer of Geronimo Law.

Download file here

What's Inside?

A legal critique of the ADB cap, fixed time windows, and payment service provider-led restrictions, showing how these fail to prevent real financial harm among low-income users of Philippine online gambling platforms.

Detailed policy reforms that replace one-size-fits-all rules, including how using KYC levels & more can help set safer limits for online gambling payments ensuring platforms support responsible gambling laws in the Philippines.

Clear, system-level reforms for gambling payment services including credit disablement, etc., critical for curbing high-risk activity in the growing online gambling PH market

Legal fixes to strengthen BSP regulation oversight, require stricter oversight of e-wallets and gambling platforms, aiming to align gambling laws in the Philippines with public health goals and financial integrity.

Stronger rules. Safer platforms. Smarter regulation.

Download our legal recommendations to improve BSP’s online gambling safeguards. Contact Geronimo Law for policy advisory or compliance implementation support.

Get in touch with us Download report

Frequently Asked Questions

This section addresses common concerns raised by businesses, legal teams, and finance professionals looking for clarity on complex issues. If you’re seeking practical answers or a better understanding of key concepts, you’ll find helpful insights here.

What is this advisory about?

This is a formal legal comment on the BSP’s proposed regulations for online gambling-linked payments (Draft Circular on the Regulations on Online Gambling Payment Services). It highlights weaknesses in the current draft and recommends enforceable measures to protect financially vulnerable users.

Who is this for?

This paper is for regulators, policy developers, PSPs, e-wallet providers, legal teams, and fintech compliance officers preparing for tighter digital gambling controls.

Why are these recommendations important?

Without strong safeguards, gambling-linked payments can lead to debt, addiction, and financial instability — especially for the poor. This paper proposes guardrails that are both evidence-based and implementable.

Geronimo Law is a full-service firm.