Singapore’s recent proposed change to its Casino Control Act (CCA) is a “timely amendment,” notes Tier 1 gaming lawyer Lau Kok Keng, indicating that the move “reflects a continuing commitment by the government towards maintaining a robust regulatory framework for legalized casinos in Singapore”.
In response to AGB inquiries, the Partner and Head of Gaming Law Practice at Rajah & Tann Singapore LLP, indicate that the updates are aimed at plugging gaps in the current framework “which have been created due to advancements in technology and changes to the way gambling and casino operations are or may in the future be carried out”.
When announcing the proposed updates at the bill’s first reading, authorities indicated that they wanted to future proof Singapore’s casino sector.
This includes allowing the Gaming Regulatory Authority (GRA) to regulate all other forms of gambling offered in casinos, expanding its oversight beyond just games of chance to betting and lotteries.
“The effect of such an amendment would potentially open the door for future betting and lotteries to be offered within casinos, perhaps within the context of collaborative tie-ups between the casinos and Singapore Pools, although it is uncertain if this will ever take place,” notes the gaming law expert.
Authorities were clear to note earlier this month that there are no current plans to introduce betting and lotteries within casinos.
Sports betting and lotteries are currently operated in Singapore under Singapore Pools, allowing football and motor racing betting, horse racing, 4D, TOTO and Singapore Sweep Lottery.
Focus on operators
Other future proofing measures are also to be introduced, allowing the GRA’s Evaluation Panel to take into account “future industry standards and market demands”.
Lau Kok Keng indicates this is not likely in response to regional competition, but “is instead likely to be motivated by the primary benefits behind considering not just prevailing […] but also future market demand and industry standards,” meaning “the evaluation panel can assess whether an integrated resort will remain relevant and competitive in the long term, as well as whether the resort is positioned to capitalize on anticipated industry shifts and stay ahead of competition”.
This can also help ensure integrated resort operators “will be in position to comply with anticipated regulations and industry practices, reducing the risk of subsequent costly adjustments or unexpected legal issues”.
Information sharing and future liability
One major shift is legislating that casino operators (COs) will be able to directly share personal information on patrons without the patron’s consent.
This “allows the casino operators to take quicker action at their end” in regards to information which could be pertinent to combat money laundering, terrorism financing and proliferation financing risks. The current framework is “operationally inefficient” as all such information exchanges had to be facilitated by the GRA.
The changes also mean that “casino operators are liable to disciplinary action if they contravene their obligation to disclose risk information as required by the GRA’s written notice […] and/or disclose risk information received or accessed under this section to other persons, unless lawfully required to do so”.
Casino operators, under the newly proposed framework, can also be found liable for regulatory breaches even after their licenses have lapsed, if the action occurred before the lapse.
“This move applies not only to casino operators, but also to special employees, international market agents and international market agent representatives,” highlights the gaming law expert. This extended liability period already applied to “other non-casino gambling licensees regulated under the GCA (Gambling Control Act). Hence this amendment is also another move to bring the CCA (Casino Control Act) in line with the GCA in this regard”.
Oversight and protection
While many of the updates focus on expanding possibilities, authorities are also aiming to crack down on cheating, improving the Casino Control Act to cover scenarios not previously envisioned in 2012.
One such move is to label an offense withdrawing bets after the result of a game is known. According to reports cited by the lawyer, 10 people were investigated for this activity between 2010 and 2023. “To avoid the police having to use offenses in other laws to deal with such cheating cases, the proposed amendment right-places this offense under the CCA,” notes the expert.
And while crime at Singapore’s casinos has historically been low (at just 137 reported cases in 2023, or 0.2 percent of all reported crime cases), “the move to take steps to establish new offenses under the law to deter casino-related crime thereby further protects the integrity of gaming operations”.
Virtual instruments and crypto?
Also looking ahead, authorities are aiming to allow the introduction of new wagering instruments, namely virtual credits.
This, notes the expert, could help improve both operational efficiency and the player experience, reducing transaction costs caused and potential fraud linked to fiat.
“Nonetheless, it should also be pointed out that […] these new wagering instruments will only be introduced should the GRA assess them to be suitable. As such, there is unlikely to be an immediate move towards crypto adoption, though this change certainly does signal the recognition of the benefits that such virtual credits can bring”.
While cryptocurrency is not currently considered legal tender in Singapore, it can be used as an alternative means of payment and it appears to be open to crypto use – evidenced by changes in April by the Monetary Authority of Singapore (which regulates crypto) focused on digital payment token (DPT) service providers.
Given its continual evaluation of the gaming framework, Singapore is likely to continue to adjust legislation and regulations to ensure its strict compliance with Financial Action Task Force (FATF) standards, promoting a healthy and vibrant gaming industry in the Merlion city.
