Collateral Damage: How Regulatory Shifts in the Philippines’ POGO Crackdown Exposed Foreign Workers to Unintended Risk

From 2023 to 2024, the Philippine government launched an aggressive campaign to shut down POGOs (Philippine Offshore Gaming Operators), citing connections to cybercrime, human trafficking, and labour violations. While the decision was widely praised, its implementation exposed serious risks, especially for foreign workers who had followed the law and ended up as victims of the policy.

A turning point came in July 2024, when President Ferdinand R. Marcos Jr. publicly questioned the continued existence of POGOs. In his third State of the Nation Address, he stated, “Starting today, all POGOs are banned.” The statement immediately drew public attention. He described POGOs as hubs of fraud, money laundering, human trafficking, and even murder. He emphasised the state's duty to safeguard national security, enforce the law, and protect its citizens.

This momentum intensified with a statement from Senator Risa Hontiveros, a key figure in investigating human trafficking cases linked to POGOs, who declared: “To all POGOs, legal or illegal, goodbye.” Her words became symbolic of a strong political stance, but they also blurred the line between legal and illegal operators. This narrative may have pushed authorities to act without clearly distinguishing between those who were compliant and those who were not.

Soon after, Executive Order No. 74 was issued, mandating that all POGOs cease operations by December 31, 2024. The EO cited findings from the Department of Finance that the social and criminal costs of POGOs far outweighed their economic benefits. In November 2024, the Bureau of Immigration released a list of over 8,000 foreign nationals, mostly holders of 9(g) work visas from PAGCOR-licensed companies. These individuals were ordered to downgrade their visas, complete immigration procedures, and exit the Philippines by December 31, 2024.

According to the document, they were considered to have failed to downgrade their visas before the October 15 deadline. However, in reality, many had followed the proper procedures. Some had already downgraded and exited the country on time, while others downgraded early and stayed temporarily under valid tourist visas. Still, they were included in the ALO list along with actual violators. This created administrative chaos and undermined the credibility of an immigration system that should be fair and evidence-based.

More concerning was the fact that the ALO document was never officially published through government channels. There was no public announcement, no posting on official websites, and no individual notifications. Instead, the list began spreading informally via WhatsApp messages, moving from one person to another without clear context or verifiable authority. Such a distribution process is highly inappropriate for a document affecting the legal status of thousands, creating the risk of social stigma, data misuse, and the spread of misinformation. It was as if the fate of thousands was being decided by a PDF forwarded in group chats, rather than through lawful procedures.

The consequences were severe. People who had followed legal procedures were suddenly labeled as unable to return to the Philippines. Even for transit purposes, their status became uncertain. Although the ALO is administrative in nature, its impact is substantial. There was no official notice, no removal mechanism, and no clear support channel. Many tried contacting the Bureau of Immigration via email but received no clear response. Those who were fortunate enough to get a reply were told the only recommended option was to hire a local Filipino lawyer accredited by the Bureau of Immigration to help prepare and submit the necessary documents. Although not mandatory, the involvement of a lawyer was clearly advised in official responses. The required documents were simple: a petition letter to the Commissioner and a copy of the passport. However, no clear information was provided regarding the timeline or potential costs.

Even more confusingly, requests for delisting could only be submitted in person at the Bureau of Immigration headquarters in Intramuros, Manila. There was no online form, no email option, and no way to file from abroad. Even formal requests submitted through legal channels like the Freedom of Information (FOI) system failed to produce meaningful results. One example was a public request submitted by L. Huang on FOI.gov.ph, asking about the reasons for being placed on the ALO and requesting permission to return and retrieve personal belongings and pets. The request was marked as received but remained pending for months without a response. This highlights how difficult it was to access legal clarity and administrative rights, even when using official pathways.

This meant that even if someone had legally exited the country, they still had to physically return to Manila to file for name removal. The problem was that it was unclear whether they were even allowed to re-enter. Airlines were likely to deny boarding due to their ALO status. As a result, individuals found themselves trapped in an absurd situation: blacklisted, unable to return, and unable to fix the issue because the only available remedy was located in the very country that had denied them entry.

The lack of clarity began with the absence of any official announcement when the ALO was implemented. In fact, the public first learned about it through a TikTok video uploaded on December 12, 2024, by an account called “Xiao Annie,” likely an agent. The video showed long lines at an immigration office with overlay text: “ALO just came out, but no official memo yet. Please wait.” In the next clip, the video read: “This is for those who haven’t downgraded their 9(g) visas.” A third video showed a government building with a caption: “Message me directly if you want help processing.”

The narration claimed that the list was targeting POGO workers who had not downgraded their visas. However, many people on the list had already met all requirements and exited the country legally. This information did not come from a legal institution or official channel, but from a TikTok intermediary offering help for a fee. That is how many people first discovered they were on the list not from official letters or embassy coordination, but from shaky videos edited with pink fonts and emojis.

The distinction between political messaging and administrative execution is critical. When public statements are overly assertive without technical explanation, enforcement bodies may interpret them as permission to act indiscriminately. For many compliant foreign workers, this led to being swept into a system that no longer differentiated between violations and procedural compliance.

The fallout revealed deeper weaknesses in the regulatory system: minimal communication, no available appeals process, and serious consequences for those who had followed the law. Many affected foreign workers only discovered their ALO status when trying to re-enter the country or after receiving viral WhatsApp messages. Most were not criminals or overstayers. They had downgraded their visas, obtained exit clearances, and left before the deadline. Yet there was no official notice, no clear appeals process, and no guidance on how to restore their status.

This raises broader questions about non-financial risk management in regulated industries such as iGaming. Regulatory risk is often discussed in terms of license revocation or economic impact. But when a government acts too quickly, without proper procedural safeguards, human loss becomes the blind spot.

In cross-border sectors like online gaming, the effects can spill over into other countries. Individuals affected by vague administrative listings may face entry bans, damaged reputations, visa denials, and psychological distress. Many left the Philippines with clean immigration records, only to later learn they had been blacklisted without explanation.

To prevent similar chaos in the future, several principles must be adopted:

• Transparent criteria for inclusion in administrative lists such as the ALO

• Clear separation between violations and legal employment records

• A documented and scheduled removal or appeals process

• Multilingual communication for foreign workers

• Public messaging that is strong but procedurally fair

The shutdown of POGOs in the Philippines is both a political milestone and a hard lesson. Political declarations can inspire action, but when execution fails, institutional trust suffers.

Communication is crucial. When statements like “To all POGOs, legal or illegal, goodbye” are made without clear boundaries, the impact can strike the wrong targets. Law-abiding workers become victims, and institutional credibility erodes.

This is not a critique of anti-crime campaigns or an attempt to diminish the findings of Senate investigations. The shutdown of illegal operations and the rescue of trafficking victims are essential. But the law must be enforced in a way that does not harm those who comply.

For policymakers in Southeast Asia and globally, this case is a sharp reminder that regulatory risk is not only about companies or capital. It also involves a human dimension that is often overlooked. When systems fail to distinguish between violators and those who follow the rules, the impact goes beyond administrative inconvenience. It becomes a structural failure that damages institutional credibility. From a risk management perspective, this reflects the absence of mitigation for non-financial risks such as reputational damage, stakeholder trust erosion, and disruption of global labour mobility. This case shows that public policy must be designed with a holistic approach, where compliance is not only praised in rhetoric, but also guaranteed through due process.

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References

1. Bureau of Immigration Philippines. ALO_20BOC-2024-01, Visa Cancellation No. BOC-2024-132, Order to Leave No. BOC-2024-21. Issued 22 November 2024. (Unofficially circulated via WhatsApp)

2. Hontiveros, Risa. “To all POGOs legal or illegal goodbye.” Facebook Post, 22 July 2024

3. Marcos Jr., Ferdinand. State of the Nation Address (SONA). July 2024. https://pbbm.com.ph/2024-state-of-the-nation-address/

4. Wikipedia. “Philippine Offshore Gaming Operator.” https://en.wikipedia.org/wiki/Philippine_offshore_gaming_operator

5. Asia Gaming Brief. “PH Senate panel to hold its last POGO hearing next week.” https://agbrief.com/news/philippines/22/11/2024/ph-senate-panel-to-hold-its-last-pogo-hearing-next-week/

6. TikTok testimonies and video documentation relating to the ALO (archived October to December 2024). Some content created or shared by labor agents

7. Asia Gaming Brief. “Philippine Senate passes Anti-POGO Act of 2025 on final reading.” https://agbrief.com/news/philippines/09/06/2025/philippine-senate-passes-anti-pogo-act-of-2025-on-final-reading/

8. PNA. “Marcos gets loudest applause in SONA 2024 with POGO ban.” https://www.pna.gov.ph/articles/1244137

9. Freedom of Information Philippines. Inquiry Regarding ALO Listing and Request to Return to the Philippines. Submitted by L. Huang on 19 March 2025. https://www.foi.gov.ph/requests/agen/OP-379375180757

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Romario Nugraha has experience in risk operations in the online gaming sector across Southeast Asia. With direct exposure to compliance processes and regulatory impacts in day-to-day operations, he offers a grounded perspective on the challenges faced by industry workers in evolving legal environments.

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