Dear Attorney,

I hope this letter finds you in great health and high spirits.

I am reaching out to seek your expertise on a concern related to an invitation I received to be featured in an upcoming report titled “iGaming Fraud Report 2025: An In-Depth Analysis of Gambling Fraud Attack Types, Key Security Trends Powered by AI, and a Spotlight on Leading Anti-Fraud Companies in the Industry.” This publication aims to provide comprehensive insights into fraud prevention in the gambling sector, including a focus on anti-fraud measures, technological advancements, and the prominent contributors in this space. My law firm has been identified as a potential leader in the anti-fraud domain, and they are proposing to highlight our work in this field through a double-page spread in the report.

Given the nature of this opportunity and the potential implications of participation, I would like to understand the legal considerations surrounding this matter. Specifically, I am seeking guidance on the following:

Compliance with Philippine Laws on Gambling and Anti-Fraud Practices: How might participation in such a publication align with or potentially conflict with local gambling regulations and anti-fraud laws in the Philippines?
Ethical Implications for Legal Professionals: Are there specific ethical guidelines for Philippine lawyers that I should be aware of before consenting to this feature? Could my firm’s inclusion in such a publication create any perceptions of bias or promotional misconduct?
Defamation and Liability Concerns: What measures should I take to mitigate risks of defamation or liability associated with my firm being publicly positioned as an authority in this sensitive area?

I value your comprehensive understanding of both Philippine laws and international best practices and would deeply appreciate your analysis of this matter. Kindly provide an exhaustive overview of the relevant legal framework, ethical considerations, and potential risks associated with this undertaking.

Thank you for your time and expertise. I look forward to your insights.

Yours sincerely,
A Concerned Professional

Legal and Regulatory Framework: Anti-Fraud Measures in the iGaming Industry

In the Philippines, gambling activities and their regulation fall under the jurisdiction of several government agencies, notably the Philippine Amusement and Gaming Corporation (PAGCOR) and the Anti-Money Laundering Council (AMLC). As the iGaming industry continues to grow, these regulatory bodies have implemented measures to address fraud, promote transparency, and ensure compliance with both local and international standards.

1. Philippine Laws Governing Gambling and Fraud Prevention

A. The Anti-Money Laundering Act of 2001 (Republic Act No. 9160, as amended)

Under RA 9160, gambling operators and related businesses are classified as covered persons. This means they are obligated to adhere to stringent anti-money laundering (AML) protocols, including customer due diligence, reporting of suspicious transactions, and record-keeping. Participation in an anti-fraud initiative aligns with the legislative goals of curbing illicit activities but must strictly avoid divulging confidential information or appearing to endorse any specific commercial entity.

B. Presidential Decree No. 1602 (Penalizing Illegal Gambling)

This decree defines and penalizes illegal gambling activities, emphasizing that any involvement in gambling must comply with existing licensing and operational standards. Law firms that position themselves as anti-fraud leaders must ensure their messaging does not inadvertently associate them with unlicensed or questionable operators.

C. Data Privacy Act of 2012 (Republic Act No. 10173)

The Data Privacy Act mandates the lawful handling of personal information. Any participation in public reports should avoid the unauthorized disclosure of sensitive data that could expose the firm to liability.

2. Ethical Guidelines for Lawyers

A. The Code of Professional Responsibility and Accountability

The recently updated Code emphasizes integrity, accountability, and the avoidance of conflicts of interest. Rule 3.04 underscores that lawyers must not engage in advertising or solicitation that could mislead the public or undermine the dignity of the profession. Inclusion in the report should be framed as a factual acknowledgment of expertise, avoiding promotional overtones.

B. Avoiding Conflicts of Interest

Lawyers must ensure that their public statements or affiliations do not create conflicts with their client base. For instance, representing gambling operators while publicly advocating for anti-fraud measures might create an appearance of conflicting loyalties.

3. International Considerations: Cross-Border Implications

The iGaming industry often operates across jurisdictions, requiring Philippine firms to consider international standards, such as the General Data Protection Regulation (GDPR) in Europe, which governs data privacy, and the Financial Action Task Force (FATF) recommendations on combating money laundering and terrorist financing.

4. Risk Mitigation Strategies

A. Drafting a Comprehensive Engagement Letter

Before participating in the publication, draft an agreement outlining the scope, purpose, and limitations of your inclusion. Ensure the agreement explicitly states that the feature does not constitute an endorsement or partnership.

B. Reviewing Content for Accuracy and Compliance

Carefully vet the content of the double-page spread for any potentially defamatory statements or inaccuracies that could expose your firm to reputational or legal risks.

C. Seeking Prior Approvals

Obtain clearance from PAGCOR or the AMLC if the feature discusses regulated activities or practices, ensuring compliance with national standards.

D. Establishing a Crisis Management Plan

Anticipate potential controversies that may arise from public scrutiny of the report. Develop a communication strategy to address queries from clients, regulators, and the media.

Conclusion

While participation in the iGaming Fraud Report 2025 presents a valuable opportunity to showcase your firm’s expertise, careful consideration of the legal, ethical, and reputational implications is essential. By adhering to Philippine laws, international standards, and professional ethics, you can navigate this endeavor effectively while upholding the integrity of your practice.

Should you wish to discuss this matter further, please do not hesitate to reach out.

Yours sincerely,
[Your Name]
[Your Position]