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Gambling Control Act

Introduction

The Gambling Control Act 2022 (GCA) is a consolidation and update of previous gambling legislation including the Betting Act 1960, the Common Gaming Houses Act 1961, the Private Lotteries Act 2011 and the Remote Gambling Act 2014. It was passed as a response to the increasing number of gambling-adjacent grey areas, such as online gambling platforms and loot box mechanics embedded in video games. The GCA also established the Gambling Regulatory Authority (GRA) to oversee gambling matters in Singapore.

Singapore’s strict stance on gambling is reflected in the GCA, which is explicit in defining lawful and unlawful gambling, prescribing harsh penalties for the latter. It establishes a low threshold required to charge someone with organizing, participating in and abetting of unlawful gambling.

Key Areas of the Gambling Control Act

The GCA defines gambling as betting, participating in a gaming activity or in a lottery. All forms of gambling are illegal by default unless it falls under the following classes:

  1. Licensed Gambling. Organisations which intend to conduct any form of gambling must apply for a license. This includes organisations conducting gambling as a bonding or cohesion activity, including fantasy sports and tombolo. Organisations must also apply for a license to own a gambling machine.
  2. Class-Licensed Gambling. Some forms of gambling are permissible under a blanket license. This includes games of chance or lotteries to promote a cause, survey or trade, fundraiser lotteries, lotteries at specific events such as fairs and dinners, and remote games of chance. Each form of class-licensed gambling has additional requirements, such as restrictions on advertising materials. These are outlined in respective Minister’s Orders.
  3. Physical Social Gambling. The GCA allows for social gambling provided it is in a participants’ home and is among family or friends only.

The GCA also makes provision for vulnerable individuals. This includes banning gambling for individuals under the age of 21, and individuals on a Singapore’s public rental housing scheme. Moreover, the GCA also establishes a low threshold required to charge someone for the organisation, participation and abetment of unlawful gambling. For instance, a person caught leaving a location hosting unlawful gambling is automatically presumed to have participated in gambling.

Remote Games of Chance

The Gambling Control (Remote Games of Chance – Class Licence) Order 2022 was passed in response to the rise of online gambling. Clear-cut cases of online gambling, such as on virtual casinos and gambling sites have always been banned. However, there are an increasing number of grey areas which blur the line between gambling and gaming. Online games which contain an element of chance may be permissible under class-licensed gambling if they have a scoring or progression system influenced by player action and are primarily for entertainment. They must also be played for a prize, which does not include ranking on leadership boards. There are two forms of remote games of chance permissible under the class license:

  • Type 1 Class License. Participating in the game must be free, promotional materials are free of specified gambling articles and complimentary tokens given to the player are non-transferrable.
  • Type 2 Class License. Prizes won from the loot boxes must not be readily monetisable, meaning the licensee or any associate cannot provide a service making the prize readily convertible to money or a money equivalent (such as cryptocurrency), and must be designed for use in in-game microtransactions.

Conclusion

The GCA has been a necessary update to Singapore’s gambling legislation to keep up with the rise of technology-facilitated gambling. Due to Singapore’s strict stance on gambling, the GCA is comparatively strict and prescriptive, with severe penalties and requirements. In particular, gaming companies or providers should closely examine and consult with local regulators or experts in determining the permissibility of their games. The GRA is also committed to continual updates to keep up with developments, such as the class-license requirements for mystery boxes, which are currently in development.

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