Gaming Law 2024 Comparisons

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 regulating 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, thus enabling a consolidation of resources and harmonisation in the regulatory approach across the different forms of gambling. The then current laws regulating gambling – the Betting Act, Common Gaming Houses Act, Private Lotteries Act and Remote Gambling Act – would all be repealed and replaced by a new consolidated legislation.

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).

In the wake of one of the biggest money laundering probes in Singapore in August 2023, the Singapore government has announced that they are reviewing Singapore’s anti-money laundering legislation. See 8.3 Recent or Forthcoming Changes.

On 6 August 2024, the Singapore government introduced the Casino Control (Amendment) Bill (CC(A)B) as part of a regular review to ensure that the Casino Control Act (CCA) keeps up with changes in the gambling industry. The CC(A)B was subsequently passed by parliament on 10 September 2024, but no concrete date has been set as to when the new amendments will come into effect.

See 3.7 Recent or Forthcoming Changes, 4.3 Recent or Forthcoming Changes and8.3 Recent or Forthcoming Changes.

All forms of online 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 online legalised non-casino gambling 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, has yet to be issued as of 1 October 2024.

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.

All forms of land-based non-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 gambling.

Singapore Pools is the only licensed gambling operator authorised to conduct and offer legalised land-based non-casino gambling services, including betting on horse racing, sports betting and public lotteries.

The class licences available for land-based non-casino gambling are similar to that for online gambling. The list of class licences may be referred to at 2.1 Online.

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.

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 has been gazetted to date is as follows.

• Gambling Control (Trade and Other Promotional games and Lotteries – Class Licence) Order 2022 – grants a class licence in respect of games and lotteries conducted: (i) for the purpose of various eligible objects; (ii) 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; (iii) 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 (iv) 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 CCA regulates the two licensed casinos in Singapore.

The key subsidiary legislation under the CCA includes the following.

• 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 (IMA) and their representatives, 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 – impose 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.
• 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 gambling. 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 anything 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:

• a game that involves both an element of chance and an element of skill;
• a game that involves an element of chance that can be eliminated by superlative skill; or
• 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:
1. 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. 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.
• 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:
1. a fine not exceeding SGD10,000 and/or imprisonment for a term not exceeding six months.
• Conducting gaming involving a prohibited gaming machine or using or operating such a machine for the purposes of gambling activities by another person, 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 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:
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.
• Playing a game of chance for a prize involving a prohibited/unapproved gaming machine:
1. a fine not exceeding SGD10,000 and/or imprisonment for a term not exceeding six months.
• Proxy gambling outside of a gaming machine room:
1. a fine not exceeding SGD10,000 and/or imprisonment for a term not exceeding six months.
• Supplying prohibited/unapproved gaming machines:
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 12 years.
• Gambling by underaged individuals and excluded persons:
1. for underaged individuals, a fine not exceeding SGD1,500; and
2. 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:
1. a fine not exceeding SGD300,000 and/or imprisonment for a term not exceeding six years.
• Employing an underaged individual in gambling:
1. 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.
1. for first time offenders, a fine not exceeding SGD500,000 and imprisonment for a term not exceeding four years; and
2. for repeat offenders, a fine not exceeding SGD700,000 and be imprisonment for a term not exceeding ten years.
• Providing credit for unlawful gambling:
1. for first time offenders, a fine not exceeding SGD200,000 and imprisonment for a term not exceeding four years; and
2. for repeat offenders, a fine not exceeding SGD300,000 and imprisonment for a term not exceeding seven years.
• Advertising unlawful gambling:
1. a fine not exceeding SGD20,000.

Land-Based Casino Gambling

• Operating a casino without a valid licence:
1. 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:
1. 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:
1. 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;
2. 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
3. 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:
1. 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;
2. 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
3. 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:
1. a fine not exceeding SGD1,000 as well as the amount of the entry levy payable for the overstay period.
• Proxy gambling outside casino:
1. a fine not exceeding SGD10,000 and/or imprisonment for a term not exceeding 12 months.
• Cheating in a casino game:
1. a fine not exceeding SGD150,000 and/or imprisonment for a term not exceeding seven years.

See 3.5 Key Offences.

The CC(A)B was introduced to amend the CCA in order to:

• enhance the operational effectiveness of the casino regulatory regime;
• tighten the regulation of the casinos and licensees; and
• strengthen protection for vulnerable groups.

See 11.4 Recent or Forthcoming Changes.

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 Gambling (NCPG) to deal with the social aspects of gambling.

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.

Under the previous regime, the NCPG and its committees were only allowed to revoke an existing Exclusion Order or Visit Limit and subsequently impose a new Exclusion Order or Visit Limit. The CC(A)B introduced a new streamlined regime where the NCPG is allowed to immediately substitute an Exclusion Order with a Visit Limit, and vice versa. This provides more protection to the individual as compared to the current regime, where there is a period of one to two months between the revocation of the Exclusion Order or Visit Limit and the imposition of the New Exclusion Order or Visit Limit, during which the individual would not be protected by any safeguards. The NPCG also has the flexibility to substitute safeguards with more stringent ones, like a Visit Limit with an Exclusion Order, to protect the individual.

Additionally, the CC(A)B has criminalised the breach of a Family Visit Limit to bring it in line with the breach of an Exclusion Order by Law, Third Party Exclusion Order, Third Party Visit Limit and Family Exclusion Order.

The Singapore government takes a strict approach to regulating gambling.

However, the Ministry of Home Affairs (MHA) has acknowledged that a broad 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 has therefore evaluated various activities and products which it determined ought not to be classified as gambling, and has expressly carved out such activities and products from the definition of gambling. For instance, the MHA has 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 has provided for a carve-out at Section 5(2)(a) of the GCA to address this.

The CC(A)B has expanded the scope of activities that the GRA can regulate in the casinos to cover betting and lotteries. This has been done to pre-empt any future changes in the gambling landscape.

Online Gambling and Land-Based Non-casino Gambling

Various types of licences may be granted by the GRA to allow for the provision of gambling services, including but not limited to licences in respect of:

• specified kinds of gambling operations, including the conduct of betting, gaming or lotteries;
• specified types of gaming machines;
• specified types of gambling articles (other than gaming machines) or prizes; and
• specified types of customers who may engage in gambling using the gambling service authorised by the class licence. 

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).

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. As of 17 October 2023, there are no licensed IMAs in Singapore.

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 gambling 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 one-off. For example, the licence issued by the GRA to Singapore Pools under Section 54 of the GCA is effective from 25 October 2022 to 24 October 2025. It allows Singapore Pools to conduct betting operations (including betting on football, Formula One and horse races), gaming and lotteries.

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.

International market agent licences will be valid for such period as the GRA may specify in the licence, up to a maximum 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. Upon receiving an application for a licence or to renew a non-casino gambling licence, the GRA may carry out investigations or inquiries in relation to the application.

Prior to granting a licence or allowing the renewal of a licence for gambling operations under the GCA, the GRA will consider, inter alia, the following factors:

• whether the applicant, its licensees, responsible executives and/or key officers of the applicant is suitable to provide the gambling service in the application;
• whether the licensee has gambling service agents; and
• whether it is contrary to the public interest or national security of Singapore to grant the licence to the applicant.

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.

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.

With the amendments under the CC(A)B, the power to approve the main shareholders of casino operators has now been transferred from the GRA to the Minister of Home Affairs.

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 4.9 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 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 floor plans 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.

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

• 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, inter alia:

• those requiring that surveillance systems for monitoring of operations in the approved gambling venue conform to applicable standards;
• those requiring that the location and orientation of facilities and equipment for that requisite surveillance system must be as approved by the GRA; and
• those requiring access control measures for underaged individuals and excluded persons.

On 5 June 2023, the Singapore government announced that horse racing in Singapore would come to an end with the final horse race event being the 100th Grand Singapore Gold Cup taking place on 5 October 2024. The land on which the Singapore Turf Club’s Kranji race course sits will be handed back to the government in March 2027. Notwithstanding this, betting with Singapore Pools on overseas horse races will continue to be allowed.

Please see 4.4 Types of Licences on the available licences.

Under the GCA, there are no specific licences or class licences 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.

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.

There is no applicable information in this jurisdiction.

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 gambling 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.

See 1.1 Current Outlook and Recent Changes and 3.7 Recent or Forthcoming Legislative Changes.

The GCA allows for certain types of lower-risk gambling services to be offered under a class licence regime. Under a class licence regime, there is no need to apply for a licence from GRA. 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.

The MSF works with the NCPG and the GRA to reduce the harms caused by problem 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 GRA. The GRA conducts regular inspections and audits to ensure that the responsible gambling programme at each casino is implemented effectively.

The GRA has also set out certain RG measures in order to minimise the harms of social gambling, which include:

• a pre-commitment programme that enables patrons to set limits on their gambling expenditure or period of continuous gambling;
• mandatory training for the operator’s employees to identify and assist any patron with signs of gambling related problems;
• the provision of responsible gambling materials at the operator’s premise;
• assistance to patrons who seek help on RG matters or display signs of problem gambling; and
• patron education and help services.

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.
• The Commissioner of Police may also prohibit a person from entering or remaining on any casino premises by a written exclusion order given to the person.
• The GRA may also issue an exclusion order to a person (either orally or in writing) to prohibit the person from entering or remaining on any casino premises in such circumstances as the order may specify.
• 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.
• The Commissioner of Police may ban a person from engaging in general remote gambling by a written notice given to the person and NCPG ‒ the NCPG can also issue exclusion orders for general remote gambling.
• Availability of blocking access orders and payment blocking orders (see 6.5 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.

Offline Gambling (Requirements Imposed on Singapore Pools)

• Training employees on responsible gambling measures. 
• Player education and assistance on responsible gambling.
• Displaying responsible gambling messages and information on seeking assistance with problem gambling.
• Regular review of the responsible gambling programme.

From November 2022, the GCA mandated that private clubs with jackpot machines would have to implement responsible gambling measures such as:

• having a responsible gambling programme;
• providing patron education and assistance; and
• ensuring documentation of responsible gambling activities.

Singapore does not have a single consolidated piece of legislation that deals with all anti-money laundering and countering the financing of terrorism (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 2009 – 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 2002 – 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 1992 (CDSA) – provides for confiscation orders to be made to deprive offenders of benefits accrued from serious criminal conduct, including gambling-related offences; and
• MAS Notices 626, PSN01 and PSN02, regarding the Prevention of Money Laundering and Countering the Financing of Terrorism, issued pursuant to Section 16 of the Financial Services and Markets Act 2022 (FSMA) – set out due diligence measures that banks and payment service providers (including digital payment token service providers) should take to monitor for, and report, suspicious transactions.

Singapore’s existing AML rules cover real estate professionals, financial institutions, registered businesses and single family offices, as well as precious stone and metal dealers, among others. For financial institutions such as banks, the MAS requires them to conduct rigorous KYC processes when accounts are opened, and to perform customer due diligence for transactions, as part of Singapore’s defence against money laundering and terrorism financing.

If the customers’ behaviour is suspicious, financial institutions are required to notify the Suspicious Transaction Reporting Office. For example, if customers refuse to provide relevant information or intentionally provides false or misleading information to circumvent the checks, the institutions will have to file suspicious transaction reports (STR). Failing to file an STR is an offence.

Following one of the biggest money laundering probes in Singapore in August 2023, which involved at least ten foreign nationals and more than SGD2.8 billion in assets that were seized or issued with prohibition of disposal orders, changes have been made to Singapore’s anti-money laundering legislation.

New offences have been introduced under the CDSA to further emphasise the need for public vigilance and responsible behaviour in financial dealings. With effect from 8 February 2024, the CDSA has been amended to introduce (i) new offences involving rash and negligent money laundering, penalising individuals who proceed with suspicious transactions without conducting adequate inquiries; and (ii) an offence targeting individuals who assist others in retaining criminal proceeds through financial transactions.

The Computer Misuse Act 1993 has also been amended with effect from 8 February 2024, introducing new offences (i) targeting Singpass users who disclose their Singpass credentials to other persons knowing, or having reasonable grounds to know, that such disclosure is to facilitate the commission of an offence; and (ii) targeting individuals who obtain, supply, or make available another person’s Singpass credentials for an illegitimate purpose.

To further combat the threat of money laundering, terrorism financing and proliferation financing, the MAS launched the Collaborative Sharing of Money Laundering/Terrorism Financing Information and Cases (COSMIC) on 1 April 2024, the first centralised digital platform to facilitate sharing of customer information among prescribed financial institutions (FIs). Participant FIs will be able to securely exchange information on COSMIC of customers who exhibit potential for financial crime, if the stipulated thresholds are met. Under the CC(A)B, casino operators will be required to share information of patrons directly with other casino operators, allowing them to overcome personal data protection restrictions and facilitate quicker action for the prevention and detection of money laundering and other criminal conduct.

On 18 October 2024, the MAS issued guidelines for use by prescribed financial institutions of the COSMIC platform. Key requirements include establishing robust internal policies for training staff, ensuring timely requests and disclosures of risk information, and documenting processes to avoid tipping-off relevant parties. Institutions must conduct risk assessments upon receiving information and maintain stringent record-keeping practices. The guidelines emphasise the importance of information accuracy, security and compliance with related regulations. Additionally, institutions should implement controls for accessing platform information and manage outsourced services effectively. Regular audits and compliance checks are encouraged to ensure adherence to these guidelines.

On 6 August 2024, the Anti-Money Laundering and Other Matters Bill (the “AML Bill”) was passed in parliament. The AML Bill seeks to:

• enhance the ability of government agencies to pursue and prosecute money laundering offences;
• clarify and improve processes for dealing with seized or restrained properties linked to suspected criminal activities; and
• align the framework for AML/CFT for casino operators with the international Financial Action Task Force standards, to better prevent and detect money laundering.

The AML Bill has also amended the CCA to require customer due diligence checks for cash deposits of SGD4,000 or more in a customer’s account, reducing the current threshold from SGD5,000.

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. Unlawful gambling advertisements may also be reported to the GRA via an online feedback form.

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 “Non-Casino 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, which 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, which prohibit 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, which sets out guidelines on gambling-related marketing communications;
• the ASAS SCAP, which sets out general principles and guidelines that all advertisements appearing in Singapore should follow; and
• the IMDA’s Internet Code of Practice (ICP), which 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. This applies to advertising of unlawful gambling in or from Singapore or from outside Singapore to persons situated in Singapore.
• Under Section 87(1) of the GCA, the GRA may order a person who advertises any unlawful gambling to (i) stop the advertising with immediate effect; (ii) take reasonable and necessary measures to remove the advertisements that have already been published in Singapore; and (iii) publish a corrective advertisement in a manner specified by the GRA.

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 ASAS SCAP, the ASAS is empowered to ask an advertiser to (i) amend or withdraw any advertisement that, in ASAS’ opinion, is contrary to the SCAP; and (ii) withhold such advertisement until it has been modified or, where ASAS has requested further information so as to decide whether an advertisement is contrary to the SCAP, pending receiving such information and a decision.
• Under the IMDA’s ICP, the IMDA may impose sanctions, including fines, on internet content providers that contravene the ICP.

There are no recent or forthcoming changes.

Casinos 

The CCA governs the acquisition and disposal of shares in the casino operators, and allows only approved persons to be main shareholders, substantial shareholders, or controllers of the casino operators.

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 GRA, or, where this is not applicable, notify the GRA 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 GRA, able to exercise significant influence over the management or operation of the casino business of the casino operator), the associate must notify the GRA 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 GRA 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.

However, as mentioned above at 6.3 Affiliates, 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.

The CC(A)B, which was passed by parliament on 10 September 2024, seeks to transfer powers related to the approval of associated divestments and acquisitions by the main shareholders of the respective casino operators from the GRA to the Minister for Home Affairs. This is because the Minister would be better placed than the GRA to take into account whole-of-government considerations in deciding whether or not to approve divestments and acquisitions relating to main shareholdings. 

The GRA is empowered under the GCA and CCA to mete out regulatory sanctions against casino operators and licensed gambling service providers for regulatory contraventions or non-compliances (eg, breach of licence conditions), including financial penalties, suspension or revocation of licences, issuance of directions for the rectification of the contravention or non-compliance.

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 offences proscribed under the GCA are 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;
• seize gambling winnings from underaged individuals or persons who are excluded or banned from participating in gambling activities; and
• arrest without warrant persons who are suspected to have committed an arrestable offence under the GCA.

Notably, under the CC(A)B, the power to approve associated divestments and acquisitions has been transferred from the GRA to the Minister for Home Affairs (see 10.4 Recent or Forthcoming Changes). On the other hand, the power to approve persons as controllers and substantial shareholders or to exempt them from any requirement under the CCA has now been transferred from the Minister for Home Affairs to the GRA. However, appeals against the GRA’s decisions can be submitted to the Minister for Home Affairs.

See also 6.5 Technical Measures in respect of the IMDA’s powers to issue access blocking orders and the powers of the 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.

Regulatory contraventions or non-compliances are enforced by the GRA, and such enforcement actions are typically published by the GRA.

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.

For larger-scale illegal gambling operations, the authorities have conducted raids on these operations, seizing equipment and other property, freezing assets, arresting individuals and charging them under the relevant gambling laws. Recent examples include the following.

• Arising from gambling suppression operations conducted between 2 and 10 May 2024, the SPF initiated investigations against 32 persons for their suspected involvement in illegal gambling activities. Officers from the Criminal Investigation Department froze more than ten bank accounts that were believed to have been used to facilitate illegal gambling.
• During a joint operation conducted between 21 August 2024 and 22 August 2024, simultaneous raids were conducted in various locations across Singapore, resulting in the arrest of 16 persons for suspected involvement in illegal gambling activities. During the operation, cash amounting to more than SGD48,000, computers and other gambling paraphernalia were seized as case exhibits.

The authorities have also been quick to issue blocking orders against remote gambling websites. An MHA press release published on 12 June 2024 stated that the GRA has blocked more than 3,400 illegal gambling websites, over 260 bank accounts and more than SGD36 million in payments linked to illegal remote gambling services.

Financial penalties are imposed and enforced as a criminal sanction on offenders, as discussed in 3.5 Key Offences. Financial penalties may also be imposed by the GRA on casino operators or licensed gambling service providers for regulatory breaches pursuant to its enforcement powers, as discussed in 11.1 Powers.

The amendments introduced by the CC(A)B regarding financial penalties allow the GRA to implement the following relating to after a licence is cancelled/surrendered/expired/invalid (as applicable) (see also 11.4 Recent or Forthcoming Changes):

• to continue proceedings and impose financial penalties on casino operators even after their licence is cancelled, surrendered or expired;
• to continue proceedings and impose financial penalties on special employees despite their licence becoming invalid; and
• to establish regulations for financial penalties against former licensed international market agents and their representatives.

The changes correspond to 11.1 Powers.

To future-proof the regulatory regime, the CC(A)B empowers the GRA to do the following.

• Regulate betting and lotteries in the casinos, in addition to games of chance: this expanded mandate is to pre-empt any future changes in the gambling landscape, although there are currently no plans to allow casinos to carry out betting and lotteries.
• Approve gaming software independent of gaming hardware: this allows the GRA to approve gaming software only, eg, software for deployment on mobile devices such as tablets.
• Expand the definition of “casino chips”: this new definition would include both instruments that have fixed and non-fixed dollar wagering value, allowing for new wagering instruments (eg, virtual credits) to be used in the future.

Other key changes introduced by the CC(A)B include the following.

• In the continuing assessing of a casino operator’s suitability to hold a casino licence, the GRA will take into account additional considerations of whether the casino operator conducted business in a manner which is unethical or will bring discredit to casino gambling in Singapore; and whether the casino operator has poor corporate governance practices or weak internal controls.
• The GRA is now empowered to take disciplinary action against licensees (ie, casino operators, special employees, international market agents and international market agent representatives) for regulatory breaches even after their licences have lapsed. Notably, this already applies to other gambling licensees regulated under Section 89 of the GCA (thus bringing the CCA in line with the GCA in this regard) and ensures licensees do not avoid punishment for failing regulatory requirements, despite their licenses lapsing.
• Currently, it is an offence for persons who are excluded from casinos to enter, remain or take part in gambling in a casino. However, to prosecute such persons, GRA has to prove that the excluded person was aware of their exclusion status when they entered the casino, which can be hard to prove. Hence, to address this, the CC(A)B has now provided that an excluded person would be liable for entering, remaining or taking part in gambling on casino premises if they know or ought reasonably to know that they are an excluded person.
• Three new offences have been introduced.
1. It is an offence to withdraw bets after the result of the game is known: subject to a fine not exceeding SGD150,000 or to imprisonment for a term not exceeding seven years, or both.
2. It is an offence to use a device to record non-card games: if convicted of this offence, (i) an individual shall be liable to a fine not exceeding SGD150,000 or to imprisonment for a term not exceeding seven years, or both, while (ii) a corporation shall be liable to a fine not exceeding SGD300,000.
3. It is an offence to destroy or falsify key documents required to be produced under the CCA: subject to a fine not exceeding SGD100,000 or to imprisonment for a term not exceeding two years, or both.

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 operator 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 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% is payable on the 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% is payable 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 applicable information in this jurisdiction.

See 4.4 Types of Licences on the types of licences, which also applies to individuals. Regarding the casino special employee licence under Section 80 of the CCA, there are four categories of employee licences, as set out in the First Schedule of the Casino Control (Licensing of Special Employees) Regulations 2009 (see 4.9 Application Fees).

See also 4.5 Availability of Licences, and 4.6 Duration of Licences.

See 4.7 Application Requirements, 4.8 Application Timing and 4.9 Application Fees.

See 4.9 Application Fees.

The GCA sets out conditions to be complied with for licences, class licences, gambling venue approval and gaming machines. For example, for the various class licences as set out in 6.6 Recent or Forthcoming Changes, the licensee will have to fulfil various conditions prescribed by the various subsidiary legislation on class licences. As for conditions imposed by the GRA in granting a gambling venue approval to any licensee, some of these conditions are set out in 5.1 Premises Licensing. These conditions may also be modified by GRA. Breach of such licence conditions could lead to sanctions, including financial penalties, suspension or revocation of licences, and issuance of directions for the rectification of the contravention or non-compliance.

In so far as a natural person is licensed as a gambling service provider, they may be subject to regulatory sanctions imposed by GRA for regulatory non-compliances or contraventions, as discussed in 11.1 Powers.

In addition, if a person is licensed as a special employee or international market agent representative for a casino operator, they may be subject to individual sanctions imposed by the GRA for any misconduct, including but not limited to financial penalties and suspension/revocation of licences.

Please refer to 3.7 Recent or Forthcoming Legislative Changes, 4.3 Recent or Forthcoming Changes and 8.3 Recent or Forthcoming Changes regarding the CC(A)B, since the amendments cover both natural persons and corporations.