A STUDY THAT looked into the difference in key areas of regulated and unregulated online platforms in hosting online cockfighting or esabong showed that Facebook– despite a nationwide ban on esabong– is being actively used in promoting this banned esabong.
The Fourth Wall, a Filipino-focused sociocultural research firm, said “our audit findings confirm that several unregulated gambling platforms, including JOLIBET and OKEBET, still host esabong events years after the ban,” Business Mirror cited the report.
Fourth Wall said these games are sometimes “gated” by account registration but remain openly promoted, indicating ongoing demand and the “resilience” of illegal operators.
The study indicated that esabong agents use dedicated groups and private messages to invite players to ongoing events.
“This direct recruitment bypasses official channels, helping illegal operators maintain a steady inflow of players despite the prohibition,” it noted.
‘[R]ecent enforcement actions and raids against illegal online gaming hubs, employing coordinated use of payment controls alongside police operations, amplified disruption efforts by choking the revenue pipelines that sustain offshore and unlicensed platforms.’
MARKET EXPANDING
With the market expanding and enforcement actions ongoing, the research firm said it examined how regulated and unregulated platforms differ in key operational areas—game offerings, promotions, affiliate structure, payment channels, KYC (know your customer), trust and safety, among others.
These differences, it noted, reveal not just “contrasting” business models, but also “varying levels” of player protection.
As to the number of games, the firm said regulated platforms have a “smaller” game catalog because each new title must pass the Philippine Amusement and Gaming Corp.’s (Pagcor) approval process.
“Games are audited for fairness and delivered by licensed providers, which may give players greater assurance about outcome legitimacy,” it said.
Some unregulated platforms feature game titles not found in regulated sites. However, this larger catalog includes several games that are not verified by third-party auditors, with some showing signs of being fake or manipulated.
HIGH-VALUE BONUSES
In terms of promotions, players involved in unregulated online gambling would usually encounter “higher-value bonuses” of up to 108 percent when joining unregulated platforms, with new player promos, cashbacks, and rebates that outpace regulated competitors.
The research said these offers are often marketed “frequently and prominently” to attract and retain users.
In regulated online gambling, platforms still offer sign-up bonuses and occasional rebates, but the “frequency and size of these promotions are limited” up to 10 percent to 40 percent online.
“Its aim is to support responsible play and limit high-risk spending,” the study read.
HIGHLY LUCRATIVE
Affiliate programs run by many unregulated operators offer “highly lucrative” affiliate programs, sometimes offering 45 to 65 percent of gross gaming revenue to attract agents.
The study said the marketing rules appear “less restrictive and less transparent, facilitating possible aggressive recruitment and promotion.”
Affiliate programs of regulated sites “clearly describe” how the interested affiliate will qualify and how he/she will be paid, such as 747’s offer for websites.
On the Know Your Customer (KYC) process, the study said it is “minimal or entirely absent” in unregulated platforms.
For one, there is no Pagcor pop-up verifying the player’s eligibility, making it possible for players, including those under the legal age, to register.
In addition, these platforms only require “a little more than a phone number or email, and there is no verification at the end.”
“This level of anonymity may enable re-entry by banned or at-risk individuals,” the firm noted.
STRICTER PROTOCOLS
Regulated platforms follow “stricter” protocols. Before a player can proceed, a Pagcor-branded pop-up appears to confirm that players complied with eligibility requirements and are not among those prohibited from playing under its regulations.
Regulated platforms also ask for basic details such as name, email, and contact number when registering an account.
Afterwards, these platforms verify identity with valid government IDs, age checks, and sometimes cross-checks with e-wallet registration details.
“These measures are designed to block underage access and enhance player accountability,” the research firm said.
PAYMENT CHANNELS
Payment channels in unregulated platforms, the report noted, are “lower-friction” —players can use GCash, Maya, QRPH, cryptocurrencies, and bank transfers with no transaction limits.
This “ease of movement,” it said, may make them appealing, but it can also be used for money laundering and high-volume spending without restrictions.
Payment systems in regulated platforms support popular e-wallets and banks but limit transactions to comply with anti-money laundering and responsible gambling policies.
CIRCULAR ON EGAMBLING
The draft Circular by the Bangko Sentral ng Pilipinas to tighten rules on mobile wallets underscores why regulated non-bank electronic money issuers should be retained as key enforcement tool rather than be disconnected from the gambling- related transactions, said PlaySafe Alliance Ph.
Alliance spokesman Mike Defensor said mobile wallets provide Know Your Client (KYC) data and transaction trails that enable authorities to trace flows, link accounts to suspected operator networks, and build cases that would be far harder to assemble if payments reverted to cash or unregulated channels.
Defensor noted that the BSP’s draft measures – including stronger identity verification, daily limits and mandatory monitoring for gambling related activity – create the legal and technical scaffolding needed for wallets to flag and block illicit transfers promptly.
He argued that the ability to freeze or temporarily restrict suspect e wallet accounts, when exercised under clear due process rules, can stop funds in transit and prevent rapid dispersion or laundering that often frustrates subsequent investigations.
Defensor said recent enforcement actions and raids against illegal online gaming hubs, employing coordinated use of payment controls alongside police operations, amplified disruption efforts by choking the revenue pipelines that sustain offshore and unlicensed platforms.
PERVERSE EFFECTS OF BAN
Defensor cautioned that a total ban or unilateral disconnection of mobile wallets could produce perverse effects, driving bettors and operators toward cash couriers or emerging digital payment channels that are harder for domestic regulators to monitor and interdict.
He recommended that policymakers emphasize calibrated measures – stronger KYC, transaction thresholds, pattern based monitoring and mandated reporting – so wallets remain both convenient for consumers and ally for licensed e-gaming platforms.
The inclusion of built in consumer protection tools in wallet rules, such as self exclusion, voluntary spending caps and mandatory warnings, arguing these reduce harm while preserving the wallets’ investigative value.
He highlighted the global dimension, noting many illicit operators route funds through cross border payment arrangements and that retained, regulated wallets make it easier to cooperate with foreign counterparts and international AML mechanisms.
Defensor also called on regulators to publish clear protocols for when and how freezes are applied, including oversight, appeal mechanisms and data privacy safeguards, to maintain public trust while enabling rapid enforcement.
He acknowledged legitimate concerns that wallets can lower the friction of funding bets, and he advocated parallel measures to target operator behavior – penalties for facilitation, restrictions on in app promotional links, and tougher licensing checks – paired with payment controls.
Preserving regulated mobile wallets under stronger, well defined guardrails offers the best chance to reduce the prevalence of unlicensed online gambling by making illicit revenue streams traceable, interruptible and prosecutable while protecting ordinary users.
The PlaySafe Alliance, composed of 20 founding members, has earlier expressed its full support to BSP’s proposed Circular seeking to regulate online gambling payment services.
Defensor’s group of gov’t licensed operators is also advocating actively for strictest regulations on online gambling as part of their commitment for responsible gaming.