The Singapore government has traditionally viewed gambling as a social vice, and has regulated the sector with a heavy touch. In recent years, the government has demonstrated its continued commitment to regulate gambling in Singapore. In April 2020, it announced that it would be reconstituting the existing Casino Regulatory Authority (CRA) into a new statutory board, the Gambling Regulatory Authority (GRA). The GRA would have the mandate to regulate the entire gambling landscape in Singapore. This will enable a consolidation of resources and harmonisation in the regulatory approach across the different forms of gambling. In July 2021, the government issued a public consultation on proposed amendments to Singapore’s gambling laws (“Public Consultation”). The proposed amendments were deemed necessary due to advancements in technology that have made gambling products more accessible online, and the blurring of boundaries between gambling and gaming, given that new business models have increasingly introduced gambling elements in products that are not traditionally related to gambling (eg, chance-based loot boxes in video games). 

In March 2022, the Gambling Control Bill (GCB) and the Gambling Regulatory Authority Bill implementing the aforesaid changes were passed by parliament. Among the key changes introduced in the GCB were:

• the definition of the term "gambling", which has gone through substantial amendments and has now become much wider;
• stipulating what constitutes conducting betting, gaming and a lottery, which now includes controlling or operating a computer server located in Singapore that allows persons, whether in or outside of Singapore, to play games of chance for a prize, and a computer server wherever located that allows Singapore residents to play games of chance for a prize;
• the legalisation of terrestrial social gambling;
• the introduction of a new class licensing regime for lower-risk gambling products such as lotteries conducted to raise funds for charities, exempt charities and institutions of public character, as well as games and lotteries conducted in the course of conducting a non-gambling event, as a form of entertainment or amusement for participants attending the non-gambling event (in-person or otherwise); and
• the prescription of new offences such as proxy gambling and having a financial interest in an unlawful gambling service.

The Gambling Control Act (GCA) and the Gambling Regulatory Authority Act (GRAA) came into force on 1 August 2022 (save for Sections 137(1) and (2) which came into force on 1 June 2022). The new gambling legislation and the establishment of a new single regulator is expected to bring about a more consistent approach to decision-making in Singapore’s gambling regulatory landscape.

See 1.1 Current Outlook.

All forms of gaming, both online and offline (save for terrestrial casino gambling) in respect of games of chance, public lotteries, horse racing and betting on sporting events are generally prohibited in Singapore by the GCA, unless granted a licence by the GRA, or if covered by a class licence in respect of such gaming. 

Presently, Singapore Pools (Private) Limited (“Singapore Pools”) is the only gambling operator authorised to conduct and offer legalised non-casino gaming services, including betting on horse racing, sports betting and public lotteries. Singapore Pools is wholly owned by the Singapore Totalisator Board (STB), a statutory board under the purview of the Ministry of Finance.

Currently, class licences are available for:

• games and lotteries conducted for the purpose of various eligible objects;
• games and lotteries conducted by an education provider to promote or further research undertaken by the education provider or to encourage participation in a market survey by the education service provider in relation to eligible subject matter concerning its business;
• games and lotteries conducted by an entity to encourage participation in a market survey in relation to eligible subject matter concerning the entity’s or the entity’s client’s business;
• games and lotteries conducted primarily to promote trade in any goods or services;
• lotteries conducted to raise funds for charities, exempt charities and institutions of public character;
• games and lotteries conducted in the course of conducting a non‑gambling event, as a form of entertainment or amusement for participants attending the non‑gambling event (in-person or otherwise); and
• interactive online games of chance which are either free to play and do not consist of certain prohibited mechanics or images, or allows for the winning of prizes which may be money equivalent that are designed primarily for use in another in-game microtransaction.

The class licence in respect of mystery boxes, ie, boxes which contain an unknown prize, with a prize cap of SGD100 to make this a lower-risk gambling product, is expected to be issued in 2023.

Under Singapore law, bingo, fantasy sports and poker would be classified as games of chance and/or public lotteries, and hence would be prohibited if played for money or money equivalent, unless a licence is obtained. 

Online social gaming is prohibited under the GCA if it allows the participants to win money or other valuable consideration. 

For land-based gaming (other than terrestrial casino gambling), please see 2.1 Online Gambling. 

All forms of land-based casino gambling are generally prohibited, unless a casino licence is obtained or the activity falls under an applicable class licence. In addition, under the GCA, certain forms of land-based social gaming are now permitted. Such social gaming must:

• be conducted by an individual in premises that are either the individual’s home or another individual’s home in Singapore;
• have as participants only individuals who are members of the same family or who know each other personally;
• be substantially spontaneous, is not promoted or conducted for the private gain of any person not participating in the gambling or in the course of any business;
• be conducted so that the only way a participant can make a profit or gain any other benefit as a result of the gambling is by winning; and
• be conducted in accordance with any conditions prescribed by the legislation.

Online Gambling and Land-Based Non-Casino Gambling

The GCA – regulates all forms of gambling activities save for land-based casino operations in Singapore as well as activities outside Singapore that are targeted at Singapore residents. 

Key subsidiary legislation that have been gazetted to date are:

• Gambling Control (Trade and Other Promotional games and Lotteries – Class Licence) Order 2022 – grants a class licence in respect of games and lotteries conducted:
1. for the purpose of various eligible objects;
2. by an education provider to promote or further research undertaken by the education provider or to encourage participation in a market survey by the education service provider in relation to eligible subject matter concerning its business;
3. by an entity to encourage participation in a market survey in relation to eligible subject matter concerning the entity’s or the entity’s client’s business; and
4. games and lotteries conducted primarily to promote trade in any goods or services.
• Gambling Control (Fundraisers – Class Licence) Order 2022 – grants a class licence in respect of lotteries conducted to raise funds for charities, exempt charities and institutions of public character.
• Gambling Control (Minor Gambling – Class Licence) Order 2022 – grants a class licence in respect of games and lotteries conducted in the course of conducting a non‑gambling event, as a form of entertainment or amusement for participants attending the non‑gambling event (in-person or otherwise).
• Gambling Control (Remote Games of Chance – Class Licence) Order 2022 – grants a class licence in respect of interactive online games of chance which are either free to play and do not consist of certain prohibited mechanics or images, or allows for the winning of prizes which may be money equivalent that are designed primarily for use in another in-game microtransaction.
• Gambling Duties Act – sets out the duties and taxes payable in respect of lawful betting, gaming and lotteries (including sweepstakes) by non-casino gambling operators.

Land-Based Casino Gambling

The Casino Control Act (CCA) – regulates the two licensed casinos in Singapore.

The key subsidiary legislation under the CCA includes:

• Casino Control (Casino Licence and Fees) Regulations 2009 (CCCLFR) – sets out the process and payable fees for operators looking to apply for a casino licence;
• the Casino Control (Casino Marketing Arrangements) Regulations 2013 – regulates the conduct of casino marketing arrangements between the two licensed casinos and the international market agent and their representatives (IMAs), as the case may be; 
• the Casino Control (Conduct of Gaming) Regulations 2009 – governs the issuance, redemption and use of chips and chip purchase vouchers, together with the conduct of table games offered at the casino;
• the Casino Control (Credit) Regulations 2010 – regulates the extension of credit for gaming in a casino by a casino operator to a casino patron who is neither a Singaporean nor a permanent resident (PR); 
• the Casino Control (Entry Levy) Regulations 2010 – imposes levies on Singaporeans and PRs who enter casinos;
• the Casino Control (Gaming Equipment) Regulations 2009 – stipulates the conditions for approval for manufacturers and suppliers of gaming machines and equipment, and the requirements for gaming machines and equipment to be complied with; 
• the Casino Control (Internal Controls) Regulations 2013 – requires the two licensed casinos to implement controls, policies, procedures and processes for the operations of a casino or operations relating to casino marketing arrangements; 
• the Casino Control (Licensing of Special Employee) Regulations 2009 – regulates the application and grant of special employee licences for various categories of such employees; and
• the Casino Control (Problem Gambling – Exclusion Orders and Visit Limits) Rules 2008 – stipulates the procedures for the application of the various exclusion orders that can be imposed on individuals.

General application

In respect of agreements by way of gaming or wagering, Section 5 of the Civil Law Act provides that all agreements by way of gaming or wagering will be null and void unless they are in respect of legalised gaming. However, contracts entered into by way of business and the making or performance of which constitutes an investment activity are deemed not to be gaming or wagering agreements. 

The term “gambling” is defined in the GCA as any of the following:

• betting;
• engaging in gaming activity; or
• participating in a lottery.

Betting is defined under the GCA as involving the payment or staking of any money or money equivalent or any thing else of value on:

• the outcome of a race, competition, sporting event or other event or process, taking place in Singapore or elsewhere;
• the likelihood of anything occurring, or not occurring, in Singapore or elsewhere; or
• whether anything is or is not true.

Engaging in gaming activity is defined under the GCA as:

• playing a game of chance for a prize; or
• playing a gaming machine.

A game of chance is in turn defined as (i) a game that involves both an element of chance and an element of skill; (ii) a game that involves an element of chance that can be eliminated by superlative skill; or (iii) a game that is presented as involving an element of chance.

A lottery is defined as an arrangement or a scheme, competition or device, which may or may not involve multiple participants, for the distribution of prizes where:

• entitlement to participate in the arrangement, scheme, competition or device depends on the payment of or giving of any money or money equivalent or anything else of value by the participant; or the attendance or other qualification of the participant, without payment; and
• the distribution depends, at any stage of the arrangement, scheme, competition or device, on an element of chance (even if the arrangement, scheme, competition or device, in some other respects, involves a genuine or purported exercise of skill).

Land-based gambling would constitute all forms of gambling that are not carried out wholly or partially by remote communication.

Online gambling would be considered as a form of remote gambling, which is defined as gambling in which a person participates by the whole or partial use of remote communication. Remote communication means communication done through the internet, telephone, television, radio or any other kind of electronic or other technology for facilitating communication. 

Online Gambling and Land-based Non-Casino Gambling

• Unlawful conduct of betting operations, gaming or lotteries, save where this was conducted on behalf of or in accordance with arrangements made by another:
1. for first time offenders, a fine not exceeding SGD500,000 and imprisonment for a term not exceeding seven years; and
2. for repeat offenders, a fine not exceeding SGD700,000 and imprisonment for a term not exceeding ten years.
• Unlawful conduct of betting operations, gaming or lotteries, where this was conducted on behalf of or in accordance with arrangements made by another: 
1. for first time offenders, a fine not exceeding SGD200,000 and imprisonment for a term not exceeding five years; and
2. for repeat offenders, a fine not exceeding SGD300,000 and imprisonment for a term not exceeding seven years.
• Conducting a betting operation, gaming or lottery outside of an approved gambling venue, save where this was conducted on behalf of or in accordance with arrangements made by another: 
1. for first time offenders, a fine not exceeding SGD500,000 and imprisonment for a term not exceeding seven years; and
2. for repeat offenders, a fine not exceeding SGD700,000 and imprisonment for a term not exceeding ten years.
• Conducting a betting operation, gaming or lottery outside of an approved gambling venue, where this was conducted on behalf of or in accordance with arrangements made by another: 
1. for first time offenders, a fine not exceeding SGD200,000 and imprisonment for a term not exceeding five years; and
2. for repeat offenders, a fine not exceeding SGD300,000 and imprisonment for a term not exceeding seven years.
• Gambling with an unlicensed gambling service provider or at an unlawful gambling place: a fine not exceeding SGD10,000 and/or imprisonment for a term not exceeding six months.
• Having a financial interest in an unlawful gambling service:
1. for first time offenders, a fine not exceeding SGD500,000 and imprisonment for a term not exceeding seven years; and
2. for repeat offenders, a fine not exceeding SGD700,000 and imprisonment for a term not exceeding ten years.
• Conducting a betting operation, gaming or lottery where the scope and manner of the betting operation, gaming or lottery has not been approved and/or contravenes the conditions in which approval has granted, save where this was conducted on behalf of or in accordance with arrangements made by another:
1. for first time offenders, a fine not exceeding SGD500,000 and imprisonment for a term not exceeding seven years; and
2. for repeat offenders, a fine not exceeding SGD700,000 and imprisonment for a term not exceeding ten years.
• Conducting a betting operation, gaming or lottery where the scope and manner of the betting operation, gaming or lottery has not been approved and/or contravenes the conditions in which approval has granted, where this was conducted on behalf of or in accordance with arrangements made by another:
1. for first time offenders, a fine not exceeding SGD200,000 and imprisonment for a term not exceeding five years; and
2. for repeat offenders, a fine not exceeding SGD300,000 and imprisonment for a term not exceeding seven years.
• Owning or occupying a place and using or allowing said place to be used as an unlawful gambling place: 
1. for first time offenders, a fine not exceeding SGD500,000 and imprisonment for a term not exceeding seven years; and
2. for repeat offenders, a fine not exceeding SGD700,000 and imprisonment for a term not exceeding ten years.
• Organising or managing any unlawful gambling place, save where this was conducted on behalf of or in accordance with arrangements made by another: 
1. for first time offenders, a fine not exceeding SGD500,000 and imprisonment for a term not exceeding seven years; and
2. for repeat offenders, a fine not exceeding SGD700,000 and imprisonment for a term not exceeding ten years.
• Organising or managing any unlawful gambling place, where this was conducted on behalf of or in accordance with arrangements made by another:
1. or first time offenders, a fine not exceeding SGD200,000 and imprisonment for a term not exceeding five years; and
2. for repeat offenders, a fine not exceeding SGD300,000 and imprisonment for a term not exceeding seven years.
• Financing an unlawful gambling place, save where this was conducted on behalf of or in accordance with arrangements made by another:

1. for first time offenders, a fine not exceeding SGD500,000 and imprisonment for a term not exceeding seven years; and
2. for repeat offenders, a fine not exceeding SGD700,000 and imprisonment for a term not exceeding ten years.
• Financing an unlawful gambling place, where this was conducted on behalf of or in accordance with arrangements made by another:
1. for first time offenders, a fine not exceeding SGD200,000 and imprisonment for a term not exceeding five years; and
2. for repeat offenders, a fine not exceeding SGD300,000 and imprisonment for a term not exceeding seven years.
• Being present in or entering or leaving an unlawful gambling place: a fine not exceeding SGD10,000 and/or imprisonment for a term not exceeding 6 months.
• Conducting gaming involving a prohibited gaming machine or using or operating such a machine for the purposes of gaming activities by another person, save where this was conducted on behalf of or in accordance with arrangements made by another:
• for first time offenders, a fine not exceeding SGD500,000 and imprisonment for a term not exceeding seven years; and
• for repeat offenders, a fine not exceeding SGD700,000 and imprisonment for a term not exceeding ten years.
• Conducting gaming involving a prohibited gaming machine or using or operating such a machine for the purposes of gaming activities by another person, where this was conducted on behalf of or in accordance with arrangements made by another:
• for first time offenders, a fine not exceeding SGD200,000 and imprisonment for a term not exceeding five years; and
• for repeat offenders, a fine not exceeding SGD300,000 and imprisonment for a term not exceeding seven years.
• Playing a game of chance for a prize involving a prohibited/unapproved gaming machine: a fine not exceeding SGD10,000 and/or imprisonment for a term not exceeding 6 months.
• Proxy gambling outside of a gaming machine room: a fine not exceeding SGD10,000 and/or imprisonment for a term not exceeding 6 months.
• Supplying prohibited/unapproved gaming machines:
• for first time offenders, a fine not exceeding SGD500,000 and imprisonment for a term not exceeding seven years; and
• for repeat offenders, a fine not exceeding SGD700,000 and imprisonment for a term not exceeding 12years.
• Gambling by underaged individuals and excluded persons:
• for underaged individuals, a fine not exceeding SGD1,500; and
• for excluded persons, a fine not exceeding SGD10,000 and/or imprisonment for a term not exceeding 12 months.
• Inducing an underaged individual to gamble: a fine not exceeding SGD300,000 and/or imprisonment for a term not exceeding six years.
• Employing an underaged individual in gambling: a fine not exceeding SGD300,000 and/or imprisonment for a term not exceeding six years.
• Possession of an unlawful gambling instrument at or near a place where gambling games.
• for first time offenders, a fine not exceeding SGD500,000 and imprisonment for a term not exceeding four years; and
• for repeat offenders, a fine not exceeding SGD700,000 and be imprisonment for a term not exceeding ten years.
• Providing credit for unlawful gambling: 
• for first time offenders, a fine not exceeding SGD200,000 and imprisonment for a term not exceeding four years; and
• for repeat offenders, a fine not exceeding SGD300,000 and imprisonment for a term not exceeding seven years.
• Advertising unlawful gambling: a fine not exceeding SGD20,000.

Land-Based Casino Gambling

• Operating a casino without a valid licence: a fine not exceeding SGD200,000 and in the case of a continuing offence, a fine not exceeding SGD20,000 per day or part thereof, as well as a fine of gross gaming revenues for the period of operation.
• Installing a linked jackpot arrangement: a fine not exceeding SGD200,000 and/or imprisonment for a term not exceeding five years.
• Organising or conducting a casino marketing arrangement involving the participation of any Singapore citizen or permanent resident: 
• for first time individual offenders, a fine not below SGD30,000 and not exceeding SGD300,000 and with imprisonment for a term not exceeding four years;
• for repeat individual offenders, a fine not below SGD30,000 and not exceeding SGD300,000 and with imprisonment for a term not exceeding seven years; and
• in any other case, a fine not below SGD50,000 and not exceeding SGD500,000.
• Acting as an international market agent without a valid licence: 
• for first time individual offenders, a fine not below SGD30,000 and not exceeding SGD300,000 and with imprisonment for a term not exceeding four years; 
• for repeat individual offenders, a fine not below SGD30,000 and not exceeding SGD300,000 and with imprisonment for a term not exceeding seven years; and
• in any other case, a fine not below SGD50,000 and not exceeding SGD500,000.
• Entry into a casino without paying the required entry levy or remains in the casino upon expiry of period for which an entry levy was paid: a fine not exceeding SGD1,000 as well as the amount of the entry levy payable for the overstay period.
• Proxy gambling outside casino: a fine not exceeding SGD10,000 and/or imprisonment for a term not exceeding 12 months.
• Cheating in a casino game: a fine not exceeding SGD150,000 and/or imprisonment for a term not exceeding seven years.

See 3.5 Key Offences.

The GCA is a relatively new piece of legislation, having repealed the Common Gaming Houses Act, the Betting Act, the Remote Gambling Act 2014 (RGA) and the Private Lotteries Act. Additional subsidiary legislation under the GCA is expected to be enacted in due course to introduce further class licences and/or to replace the various subsidiary legislation that were enacted under the said repealed legislation.

The GRA is the main authority involved in regulating the gambling sector in Singapore.

The Ministry of Social and Family Development (MSF) also established the National Council for Problem Gaming (NCPG) to deal with the social aspects of gambling. Beyond providing free counselling services to gambling addicts, the NCPG maintains a database of individuals who are limited and/or prevented from entering casinos and/or jackpot rooms in private clubs, and/or utilising Singapore Pools’ online betting services.

The Singapore Police Force may also prohibit a person from entering or remaining on any casino premises by a written exclusion order given to the person, as well as ban a person from entering and remaining in all gaming machine rooms, and/or engaging in general remote gambling by a written notice given to the person and the NCPG.

The Singapore government takes a strict approach to regulating gambling. The legislation is prescriptive and is generally drafted in broad language to provide the authorities with flexibility in terms of the gambling activities they wish to take enforcement action against.

In the Public Consultation, the Ministry of Home Affairs (MHA) acknowledged that the proposed broader definition of what constitutes gambling may result in activities or products which the MHA may have no intention of treating as gambling activities or products falling within the definition of gambling. The MHA therefore evaluated various activities and products which it determined ought not to be classified as gambling, and expressly carved out such activities and products from the definition of gambling. For instance, the MHA recognised that investments in financial products already regulated by the Monetary Authority of Singapore (MAS) through other legislation should not be treated as gambling products, and introduced a carve-out provision in Section 5(2)(a) of the GCA to address this.

The licensing regimes under the previous gambling legislation which were repealed and replaced by the Gambling Control Act (GCA) are no longer applicable. The new licensing regime under the GCA is set out in 4.4 Types of Licences. 

Online Gambling and Land-based Non-Casino Gambling

The GRA has the power to grant various licences to allow for the provision of gambling services, including but not limited to licences in respect of:

• specified kinds of gambling;
• specified kinds of betting operations, conduct of gaming or conduct of lotteries;
• gambling, or betting operations, conduct of gaming or conduct of lotteries, undertaken in or in connection with specified types of gambling venues;
• facilities of a specified nature, or adapted or presented in a specified way, and used for purposes of gambling;
• specified types of gaming machines; and
• specified types of gambling articles (other than gaming machines) or prizes.

Class licences are also available for various activities as set out at 2.1 Online.

Land-Based Casino Gambling

• Casinos may only be built on sites designated by the Minister. Only the owners of such designated sites, or a person nominated by the owner, may then apply to the GRA for a casino licence. Only two casino licences have been granted in Singapore to-date – to the operators of each of the casinos at the Marina Bay Sands (MBS) and Resorts World Sentosa (RWS). These casinos had at inception enjoyed an exclusivity period of 10 years, ie, the government would not grant more than 2 casino licences within 10 years. This exclusivity period has since been extended to 31 December 2030. Earlier in 2022, RWS and MBS were granted the renewal of their licences until February and April 2025 respectively.
• Casino operators must apply for special employee licences on behalf of various categories of individuals that they wish to employ in their operations. These include employees who perform senior managerial or other executive functions, or whose role has a significant influence over the casino operations, or who provide technical support services relating to the maintenance, rectification or repair of gaming equipment in the casino premises.
• IMAs looking to enter into casino marketing arrangements with casino operators must apply for an international market agent licence, or an international market agent representative licence if such agents use representatives for their marketing operations. 

The GCA does not prescribe restrictions on the number of licences that may be granted. However, Section 46(1) of the CCA stipulates that only two casino licences are to be in force at any particular time, at least until 31 December 2030.

Given the strong anti-gambling stance adopted by the Singapore government, the prospect of licences being awarded to gambling operators that are not related to, or endorsed by, the Singapore government to conduct commercial gaming operations for an extended period is extremely low.

Online Gambling and Land-based Non-Casino Gambling

The GCA does not prescribe the duration of licences for online gambling and land-based non-casino gambling. Such duration appears to be based on the nature of the gambling activity that is licensed – eg, whether it is recurrent or a one-off. 

Land-Based Casino Gambling

Casino operations

Pursuant to the CCCLFR, a casino licence is valid for three years, or a shorter term if the GRA is of the opinion that the term of three years is not appropriate. Casino operators may apply to renew their licence for further periods, under Section 49B of the CCA and the CCCLFR. 

Similarly, special employee licences granted in respect of certain categories of employees of the casinos are valid for three years.

For international market agent licences, they will be valid for such period as the GRA may specify in the licence, up to a maximum duration of three years.

Online Gambling and Land-based Non-Casino Gambling

Applications for licences for betting, gaming and lotteries are to be made in the form prescribed by the GRA. At present, the GRA has not set out details on the application process, but it is likely that such details will be provided by March 2023.

For operators who have a licence to conduct betting, gaming and lottery operations, they are further required to obtain the GRA’s approval for:

• the contents of the rules of any betting, game of chance or lottery conducted;
• any gaming machine, game used in a gaming machine, and peripheral equipment for a gaming machine; and
• any place or premises to be used in connection with providing gambling service.

For more details, see 5.1 Premises Licensing.

For the various class licences, the licensee will have to fulfil various conditions prescribed by the various subsidiary legislation on class licences.

Land-Based Casino Gambling

Casino operations

The CCCLFR sets out the process and payable fees for operators looking to apply for a casino licence. Every application shall be submitted electronically via the GRA’s website and accompanied by:

• an application fee;
• such documents as the GRA may specify evidencing the applicant’s ownership of the designated site;
• the disclosure of corporate or individual information in the form provided by the GRA for the applicant and such associates of the applicant as the GRA may specify; and
• such other documents as the GRA may require from the operator to determine its application. 

The main shareholders of the respective casino operators are not allowed, without GRA’s prior approval, to divest any part of their stake for a period of ten years such that their stake becomes less than 20% of the total votes attached to all voting shares in the casino operator, or is equal to or less than the percentage of the total votes attached to the stake of any other stakeholder in the casino operator. Furthermore, no person other than the main shareholder may, without GRA’s prior approval, acquire any stake in the casino operator to the extent that after acquisition, the percentage of the total votes attached to that person in the casino operator is equal to or more than 20% of the total votes attached to all voting shares in the casino operator, and is equal to or more than the percentage of the total votes attached to the main shareholder’s stake in the casino operator. In addition, the main shareholder of each casino operator in Singapore is not allowed to acquire or hold any stake, or participate in the management or operation, or enter into any agreement for the management or operation, of the other casino operator in Singapore. 

Neither the GCA nor the CCA prescribes any timescale for applications for licences, exemptions and/or permits to be made. These applications are likely to be evaluated on a case-by-case basis, and the timelines would likely vary for each application.

There are currently no prescribed application fees for licences issued by the GRA in respect of online gambling and land-based non-casino gambling. 

For an application for a land-based casino licence, the fees are as follows.

• Casino licence:
1. application fee – SGD1,100; and
2. licence fee – SGD24 million per annum.
• Renewal of a casino licence:
1. application fee – SGD850; and
2. licence fee – SGD24 million per annum.
• Application to redefine casino boundaries: SGD270.

For an application for a casino special employee licence, the fees vary based on which category the employee falls under:

• Category A (senior management) – SGD400 (fresh application), SGD350 (renewal);
• Category B (middle management) – SGD320 (fresh application), SGD300 (renewal);
• Category C1 (operations personnel) – SGD270 (fresh application), SGD240 (renewal); and
• Category C2 (technical support services) – SGD270 (fresh application), SGD240 (renewal).       

For an application for an international market agent licence, the fees are SGD670 for a fresh application and SGD550 for a renewal. For an application for an international market agent representative licence, the fees are SGD320 for a fresh application and SGD300 for a renewal. 

See 4.8 Application Fees.

Casino Operations

The boundaries of any casino premises are defined by the casino licence issued by the GRA. The GRA may occasionally redefine the boundaries of the casino premises on its own accord or on the application of the casino operator.

The casino operator must also ensure that the casino layout complies with the requirements prescribed by the GRA and notify the GRA before altering the casino layout. The Casino Control (Casino Layout) Regulations 2009 sets out the detailed requirements for a casino operator to adhere to, which will include submitting a casino layout plan to the GRA comprising detailed floorplans and a description of how the gaming areas will be clearly demarcated from ancillary areas.

Non-Casino Operations

For operators who have a licence to conduct betting, gaming and lottery operations, they are further required to obtain the GRA’s approval for a place or premises which the licensee will use in connection with providing the licensed gambling service. The application will be made in the form and manner to be prescribed by the GRA, and must state:

• the name, the residential or business address of each proprietor of the place or premises;
• the name and address of the premises;
• whether the person applying for approval is a licensee or an applicant for a licence;
• whether the written permission or authorisation required by the Planning Act 1998 for the development of the premises has been granted or deemed granted;
• where any part of the gambling service to be provided at the place or premises involves gaming machines: 
1. the location of the gaming machine room within the place or premises; and
2. the number of gaming machines intended to be installed in the gaming machine room;
• the hours of gambling proposed at the place or premises;
• any prescribed particulars and information; and
• such other additional information that the Authority may require in order to decide on the particular application.

In determining whether any place or premises can be an approved gambling venue, GRA would consider the following factors:

• the desirability of the proposed gambling venue in maintaining the cultural interest and social wellbeing of the community in the area concerned;
• the level of criminal activity in the vicinity of the proposed gambling venue; and
• whether it is otherwise contrary to the public interest for the approval to be granted to the applicant.

In granting a gambling venue approval to any licensee, the GRA may impose such conditions as the GRA deems fit, such as:

• conditions requiring a layout or design of the place or premises that ensures that no customer or member of the public can see the gambling taking place in the approved gambling venue from outside the gambling venue;
• conditions requiring that any requisite surveillance system for monitoring and surveillance of operations in the approved gambling venue must conform to standards;
• conditions requiring that the location and orientation of facilities and equipment for that requisite surveillance system must be as approved by the GRA; and 
• conditions requiring access control measures for underaged individuals and excluded persons.

Please see 3.7 Pending Legislation.

Please see 4.3 Types of Licences on the available licences.

Under the GCA, there are no specific licenses or class licenses available for B2B services. It is likely that B2B services may be provided, as long as such services do not fall within any of the offences prescribed under the GCA, and if the provision of such services does not amount to an abetment of any offences under the GCA.

In this regard, Section 8(4) of the GCA provides that a person would not be considered as assisting in the conduct of gaming (which is an offence under Section 8(1) and (3) of the GCA) merely because one is, inter alia, providing “relevant electronic services” such as telecommunications services or internet access services. Section 8(4) of the GCA is non-exhaustive as to the list of activities that would not be considered to be assisting in conducting a gambling activity. Therefore, it is possible that providers of support services for gambling operations can bring themselves within this Section and not be considered to be “conducting gaming” by providing such services, although this would ultimately depend on the exact services being provided. It is unlikely that legitimate service providers such as those who licence software or provide technical IT support services will be the target of enforcement action.   

Under Section 8(3) of the GCA, it is an offence for any person, such as agents or runners, to assist in gambling operations in accordance with arrangements made by someone else. 

Under Section 21 of the GCA, it is an offence to have a financial interest in unlawful gambling. Financial interest in a gambling service means an entitlement to receive:

• any of the income from the gambling service; or
• a percentage or share from:
1. any amount of any bet received, negotiated or accepted;
2. any amount wagered on a game of chance conducted or to be conducted; or
3. any amount of money or money equivalent paid or given by the participants of a lottery conducted or to be conducted, in the course of providing the gambling service.

Under Section 85 of the GCA, it is an offence to advertise unlawful gambling. 

There is no applicable information in this jurisdiction.

See 1.1 Current Outlook and 3.7 Pending Legislation.

Subsidiary legislation relating to class licences to be issued under the GCA are being progressively released. Currently, the class licence conditions for six class licences have been released. The class licence in respect of mystery boxes remains unreleased.

Under Section 117 of the GCA, an authorised government officer may notify the operator of an online location that unlawfully provides a remote gambling service or that promotes remote gambling to cease its unlawful activities within 14 days. If this is not complied with, the officer may then direct the Infocomm Media Development Authority (“IMDA”) to order an internet service provider to block access to that particular website.

Under Section 118 of the GCA, authorised officers may also block payment transactions by persons participating in unlawful remote gaming activity, by directing the MAS (which regulates the banking industry in Singapore) to issue payment blocking orders to the financial institution or financial transaction providers involved in the transaction. 

The MSF works with the NCPG to reduce the harms caused by problem gambling in Singapore, through implementing preventive measures through public education, imposing social safeguards, and providing help services for problem gamblers and their families. The MSF also works with the GRA to implement social safeguards to minimise the harm of all forms of gambling in Singapore.

The Responsible Gambling Code of Practice (RGCP) was introduced in 2007 by the NCPG to minimise the potential harm gambling poses. Key measures in the RGCP include the provision of information about the risks of gambling, the availability of help services, and training of frontline and management staff to assist customers who show signs of problem gambling. A Responsible Gambling Forum was also established in June 2013 to promote a shared commitment and understanding towards responsible gambling.

The CRA (now the GRA) had released a Responsible Gambling Code for Casinos. Pursuant to the Casino Control (Responsible Gambling) Regulations 2013, casino operators must implement a responsible gambling programme approved by the CRA. The GRA conducts regular inspections and audits to ensure that the responsible gambling programme at each casino is implemented effectively.

The recent changes are that the newly established GRA now works with the MSF and the NCPG to establish responsible gambling measures.

The key gambling management tools are as follows.

Casinos

• Mandating that casinos implement a responsible gambling programme approved by the GRA.
• Imposing casino entry levies for Singapore citizens and PRs.
• Imposing a minimum age requirement of 21 years for casino entry.
• Mechanisms to limit or exclude persons from entering casinos managed by the NCPG.
• Regulations on casino advertising and promotions.

Online Gambling

• Imposing a minimum age of 21 years to create a remote betting account with Singapore Pools.
• Mechanisms to limit or exclude persons from using Singapore Pools' remote gambling platform.
• Mechanisms for patron-imposed loss limits on Singapore Pools’ remote gambling platform. 
• Mandating that Singapore Pools must implement a responsible remote gambling programme.
• Requiring all advertising and promotional materials to be approved by the MSF.
• Availability of blocking access orders and payment blocking orders (see 6.6 Technical Measures)

Private Clubs with Jackpot Machine Rooms

• Imposing a minimum age of 21 years for entry into jackpot machine rooms.
• Mechanisms to limit or exclude persons from entering jackpot-machine rooms.
• Restrictions on entry – only members of a club with membership terms of at least one year can enter the jackpot machine room, and no guests are allowed.
• Prohibition on promotions.

• Prohibition on the presence of ATMs, credit card or other electronic funds transfer facilities in jackpot machine rooms.
• Regular outreach programmes and broadcast of advertisements on local media by the NCPG to educate the public on the ills of gambling.
• Prohibitions on Singapore Premier League clubs from having jackpot operations from 31 October 2022 onwards. 

Singapore does not have a single consolidated piece of legislation that deals with all AML/CFT issues; rather, they are dealt with in various industry-specific legislation/guidelines, including: 

• the CCA – Section 139 requires casino operators to engage in customer due diligence measures to detect and prevent money laundering and the financing of terrorism;
• the Casino Control (Prevention of Money Laundering and Terrorism Financing) Regulations – sets out the various AML obligations of the casinos; 

• the Organised Crime Act 2015 – provides for the making of financial reporting orders, organised crime prevention orders, disqualification orders and orders for the confiscation of gains derived from organised crime activity;
• the Terrorism (Suppression of Financing) Act – allows for warrants to be issued for seizure and forfeiture of terrorist property;
• the Corruption, Drug Trafficking and other Serious Crimes (Confiscation of Benefits) Act – provides for confiscation orders to be made to deprive offenders of benefits accrued from serious criminal conduct, including gambling-related offences; and
• MAS Notice 626, the Prevention of Money Laundering and Countering the Financing of Terrorism, issued pursuant to Section 27B of the Monetary Authority of Singapore Act – sets out due diligence measures that banks should take to monitor for, and report, suspicious transactions.

There are no recent or forthcoming changes which are of relevance or applicability to the gambling industry.

See 8.1 AML Legislation.

In general, the Advertising Standards Authority of Singapore (ASAS) promotes ethical advertising in Singapore, and regulates the advertising industry through the Singapore Code of Advertising Practice (SCAP).

As regards gambling, all forms of advertising and promotion relating to licensed gambling are prohibited unless otherwise approved by the GRA.

Land-Based Casino Advertisements

The GRA regulates the publication or distribution of casino advertisements or carrying out of casino promotion. Prior approval has to be obtained from the GRA, and the casino advertisement must be publicised, distributed or carried out in the manner approved by the GRA.

Under paragraph 2.5 (a) of the SCAP, an advertisement means any form of commercial communication for any goods or services, regardless of the medium used, including advertising claims on packs, labels and point of sale material.

Non-Casino Gambling Advertisements

The GCA defines a “gambling advertisement” to mean any information or material that gives publicity to, or otherwise promotes or is intended to promote:

• a particular gambling service;
• gambling services in general;
• the whole or part of a trade mark relating to a gambling service;
• a domain name or URL of a particular gambling service, betting operation, game of chance or lottery; and
• any words that are closely associated with a particular gambling service, betting operation, game of chance or lottery (whether also closely associated with other kinds of services or products).

Remote Gambling Advertisements

See above on “Gambling Advertisements”.

Casino Advertisements

A casino advertisement is defined in the Casino Control (Advertising) Regulations 2010 as anything that:

• contains any express or implied inducement, suggestion or request to visit any casino;
• expressly or impliedly leads to, induces, urges, promotes or encourages the playing of any game in any casino; or 
• is designed to publicise or to promote the casino or the playing of any game in the casino.

The key legal, regulatory and licensing provisions in Singapore that are relevant to the gambling industry are:

• Division 3 of Part 6 of the GCA sets out the offence of advertising unlawful gambling, the applicable defences, and corrective measures that can be taken relating to unlawful gambling advertisements;
• The Casino Control (Advertising) Regulations 2010 prohibits the publication and distribution of casino advertisements and promotions unless specific approval is obtained from the GRA;
• The ASAS Advisory on Gambling Advertisements and Promotions sets out guidelines on gambling-related marketing communications; and
• The IMDA's Internet Code of Practice (ICP) sets out guidelines regarding advertising on the internet.

See 9.3 Key Legal, Regulatory and Licensing Provisions.

The sanctions and penalties for infringing advertising regulations are dealt with in the following legislation/guidelines.

Penalties for Breaching GCA Provisions

• Under Section 85(2) of the GCA, a person who advertises any unlawful gambling shall be liable on conviction to a fine not exceeding SGD20,000.

Penalties for Breaching Casino Advertising Regulations

• Casino operators will face disciplinary action under Section 54 of the CCA, which may result in cancellation or suspension of a casino licence, variation of the terms of a casino licence or the imposition of a financial penalty. 
• Licensed IMAs will face disciplinary action under the Casino Control (Casino Marketing Arrangements) Regulations 2013.

Other Penalties

• Under the ASAS Advisory on Gambling Advertisements and Promotions, the ASAS is empowered to (i) request its members to sanction parties that violate the SCAP or the Gambling Advisory, including the withdrawal of facilities, rights or services from parties concerned; and (ii) publish details of the outcome of any investigation and name those who are in breach of the SCAP or the Gambling Advisory.
• Under the IMDA's ICP, the IMDA may impose sanctions, including fines, on internet content providers that contravene the ICP.

The recent changes are that the GRA now regulates all forms of advertising and promotion relating to licensed gambling.

Casinos 

An acquisition or change of control of a casino operator would be considered a “major change” under Section 61(1) of the CCA. A casino operator must ensure that such a change takes place only with the prior approval in writing of the CRA, or, where this is not applicable, notify the CRA in writing of such a change within three days of becoming aware of the change.

If there is a change in the situation of an associate of the casino operator (where such an associate is, in the opinion of the CRA, able to exercise significant influence over the management or operation of the casino business of the casino operator), the associate must notify the CRA of the change in writing within 14 days after it takes place.

Non-casino Gambling Companies

The GCA does not provide for disclosure requirements for non-casino gambling companies, although such requirements may be contained in the licences or approvals granted to such companies.

Casinos 

The CCA prescribes two corporate control triggers that will require the corporate shareholder to obtain the approval of the Minister before effecting any changes of corporate control:

• where a person becomes a substantial shareholder of the casino operator or enters into any agreement or arrangement to control voting shares of an aggregate of 5% or more of the total voting shares in the casino operator; and
• where a person becomes a 12% controller, 20% controller, or an indirect controller of the casino operator.

Non-casino Gambling Companies

The GCA does not provide for a similar change of corporate control trigger for non-casino gambling companies.

Casinos 

If there is an acquisition or change of control concerning investors who are not substantial shareholders of a casino operator, it would be considered a “minor change” under Section 61(1) of the CCA. The casino operator must notify the CRA in writing of such a change within 14 days of becoming aware that the change has occurred.

Non-casino Gambling Companies

The GCA does not provide for similar requirements pertaining to passive investors in the case of non-casino gambling companies.

The GCA vests the SPF and compliance officers appointed by the GRA with various enforcement powers, including the power to enter (by force, if necessary) and search premises where unlawful gambling and/or other gambling-related offence proscribed under the GCA is suspected to have taken place, seize and retain any equipment, documents, or other things that may serve as evidence of the relevant offence, require persons suspected to have committed an offence to furnish evidence of their identity, records, documents or any other information, and to arrest without warrant persons who are suspected to have committed an arrestable offence under the GCA.

See also 6.6 Technical Measures in respect of the IMDA’s powers to issue access blocking orders and the powers of MAS to issue payment blocking orders.

In the case of casinos, the CCA confers GRA inspectors with broad powers to enforce the provisions of the CCA, such as: 

• requiring persons suspected to have committed an offence to furnish evidence of their identity, records, documents or any other information; 
• arresting without warrant persons who are suspected to have committed an arrestable offence under the CCA; and 
• entering without notice any premises of a casino operator to investigate any offence or contravention of the CCA, search the premises and take possession of anything that may be connected to the commission of the offence or contravention.

Offences under the GCA are dealt with in the same way as other criminal offences ie, through initial investigations, followed by the crafting of charges against the persons suspected of committing the offence, the giving of the green light by the Attorney-General’s Chambers to proceed with the institution of criminal proceedings, and the criminal trial itself. While there has been no reported enforcement action taken under the GCA as yet, there is unlikely to be any difference with how enforcement action has been taken by the authorities previously under the various repealed gaming legislation or under the CCA.

For larger-scale illegal gambling operations, the authorities have conducted raids on these operations, seizing equipment, arresting individuals and charging them under the relevant gambling laws. For example, on 17 July 2022, the SPF conducted a simultaneous raid across several locations in Singapore, and arrested 29 persons for their suspected involvement in providing unlawful remote gambling services.

The authorities have also been quick to issue blocking orders against remote gambling websites. Immediately after the RGA came into force, popular betting websites were blocked. The MHA had announced that the list of websites to be blocked for flouting the RGA will be regularly reviewed, but details will be kept confidential. Enforcement action has also been taken against people who have organised online poker games and helped to distribute the winnings amongst the participants; see, for example, Public Prosecutor v Choo Yi Neng, Costner [2021] SGMC 50. The MAS has also issued payment blocking orders to financial institutions to ensure that no funds are provided to, or accepted from, certain bank accounts.

Financial penalties are imposed and enforced as a criminal sanction on offenders. A sentencing range is prescribed in the applicable legislation for the quantum of financial penalties to be imposed for different types of offences (see 3.5 Key Offences), and the exact quantum of the financial penalty imposed on the offender is calibrated by the Court taking into account the factual matrix of the case, including any applicable aggravating or mitigating factors. 

Where a corporation, unincorporated association, or partnership is found to have committed an offence proscribed under the GCA, the officers, members, partners or individuals involved in the management of the corporation may be personally liable for the same offence as the corporation in circumstances where such officers or individuals are involved in the commission of the offence by the corporation, or had otherwise failed to take reasonable steps to prevent the commission of such offence when they ought to have done so.

With the enactment of the GCA, physical social gambling that is conducted in residential premises among family members and friends on a substantially spontaneous basis and not conducted for private gain or in the course of any business has been explicitly legalised under the GCA. However, due to difficulties with enforcement, online social gambling has not been offered a similar exemption under the GCA.

The esports market in Singapore has been burgeoning in recent years, with revenue of esports in Singapore projected to grow at a compound rate of 10.36% annually from 2022 to 2027 and with user penetration expected to grow from 21.5% in 2022 to 28.5% in 2027. This has attracted increasing investments and sparked growth in the number of esports and gaming start-ups in Singapore. Singapore has hosted various esports tournaments in 2022, such as the Icons Global Championship, and hosted the inaugural Global Esports Games in December 2021. Moreover, the Global Esports Federation is headquartered in Singapore and currently has over 100 member federations.

However, the gambling landscape in Singapore has not kept pace with the growth in the esports sector. At present, Singapore Pools does not offer bets for esports events, and there are seemingly no plans to do so. Based on the present definition of gambling in the legislation, unlicensed betting on the outcome of esports events is prohibited, although participation in esports events is unlikely to amount to gambling.

Most fantasy sports games involve a significant element of chance, and hence would be considered as games of chance under the GCA. Prima facie, if players stand a chance to win money or money’s worth or anything else of value, then such games would be prohibited by the GCA. However, such games will not be considered as gambling as long as there are no in-game monetisation facilities that allow players to exchange the virtual prizes for real-world payouts. 

At present, there do not appear to be any plans by the regulatory bodies to specifically address the legality of fantasy sports games. 

There is no applicable information in this jurisdiction.

Singapore does not regulate blockchain as the underlying enabling technology, but instead focuses its regulatory efforts on the uses of blockchain technologies, eg, digital tokens and digital payments. 

• On 4 January 2019, the Payment Services (Amendment) Bill was passed in parliament to introduce amendments to the Payment Services Act 2019 (PSA). Among such amendments include the empowerment of the MAS to impose user protection measures on digital payment tokens (DPT) service providers. This new power has a broad scope to facilitate the swift responses by the MAS to evolving issues arising out of the DPT landscape. 
• The Court of Appeal in Singapore delivered a landmark judgment in Quoine Pte Ltd v B2C2 Ltd [2020] SGCA(I) 2, where the Court found that a contract is formed between buyers and sellers when a trade is executed on a digital token exchange. It was held that even though the contracts between the buyer and seller were smart contracts, ordinary contractual principles such as the doctrine of unilateral mistake and equitable mistake at common law are nevertheless applicable subject to incremental adjustments being made in order to suit the context of algorithmic trading.
• In September 2021, the MAS embarked on a regulatory crackdown against Binance, the world’s largest cryptocurrency exchange, for carrying on unlicensed payment services in breach of the PSA. This is consistent with the larger regulatory backlash and scrutiny against the operations of Binance by regulators in various other jurisdictions. 
• In yet another judgment that is the first of its kind in Singapore, the High Court in CLM v CLN and others [2022] SGHC 46 granted a proprietary injunction and a worldwide freezing injunction prohibiting persons unknown from dealing with, disposing of, or diminishing the value of stolen cryptocurrency assets.

Casinos

Casino tax is payable on the casino operators’ gross gaming revenue (GGR). As of 1 March 2022, the casino tax structure has been revised to a tiered tax structure with a ten-year moratorium period, as follows.

• Premium gaming: Tier 1 – first SGD2.4 billion of GGR of the IR, tax rate of 8%; Tier 2 – GGR of the integrated resort (IR) in excess of SGD2.4 billion, tax rate 12%.
• Mass gaming: Tier 1 – first SGD3.1 billion of GGR of the IR, tax rate of 18%; Tier 2 – GGR of the IR in excess of SGD3.1 billion, tax rate of 22%.

However, the above tiered tax structure applies only if the casino operators meets its investment commitments to expand and enhance the IR; failing which, a flat tax rate of 12% or 22% will apply on the GGR derived from premium gaming and non-premium gaming respectively.

Non-casino Gambling Activities

Taxes on non-casino gambling activities are now prescribed under the Gambling Duties Act 2022. The taxes payable on non-casino gambling activities are as follows. 

• Sports and horse betting – a 25% duty is payable on the gross betting profit generated from the bets received in connection with horse racing and sports betting less the goods and services tax (GST) payable on such bets.
• Other totalisator bets (excluding sports and horse betting) – a 30% duty is payable on the gross amount of all monies wagered or staked in all such bets.
• Other general bets, such as pari-mutuel betting and credit/cash betting (excluding sports and horse betting and totalisator bets) – a 30% duty is payable on the payable on the gross amount of all monies wagered or staked in all such bets.
• Sweepstakes, lucky draws or raffles, or any other lottery (excluding trade promotion lotteries) – a duty of 30% total amount of money paid or agreed to be paid into the prize pool for the sweepstake, lucky draw or raffle or other lottery (as the case may be). 
• Gaming machines (including jackpot machines or fruit machines) – a duty of 9.5% on the gross amount of all money or money equivalent wagered or staked in the relevant period by every player of any such gaming machine in order to play the gaming machine. 

There is no anticipated reform in the near future given the recent enactment of the Gambling Control Act and the Gambling Regulatory Authority Act, both of which came into force on 1 August 2022.