Stricter regulations on deposits and increased limitations on gaming promoters’ activities in the last four years reflect a shared vision between China’s and Macau’s governments to turn the city into a tourist destination increasingly reliant on mass-market revenues rather than the VIP junket-driven segment, a study by University of Macau researchers argues.
However, the study sent to AGB argues that achieving this objective requires a balanced approach to joint liability for concessionaires, one that encourages meaningful oversight of junket activities while avoiding excessive liability for actions beyond their control.
Gaming revenue generated by mass market baccarat reached MOP137.9 billion ($17.2 billion) last year, surpassing the levels recorded in the pre-pandemic full year of 2019, according to data from the Gaming Inspection and Coordination Bureau (DICJ).
In contrast, VIP baccarat gaming revenue totaled MOP54.7 billion ($6.8 billion), accounting for 40 percent of 2019 levels and making up 24 percent of the total GGR figure for 2024.
A recent study by João Ilhão Moreira and Yudi Zhou, professors at the Faculty of Law at the University of Macau, examines the changing liability landscape within Macau’s gaming industry since 2021, particularly focusing on the joint liability of casinos in deposit disputes involving junket operators.
Junkets serve as intermediaries that attract high-rolling VIP players and have historically provided complex financial services, including the deposit of cash and chips. However, high-profile cases of embezzlement and insolvency, such as the incidents involving Suncity and Dore, have raised important questions about civil liability for lost deposits.
The study highlights recent court rulings from Macau, particularly those by the Court of Final Appeal, and discusses the legislative reforms that have emerged in response to these challenges.
Macau’s legal framework now imposes joint liability on casino concessionaires for the actions of junket operators, marking a significant shift aimed at enhancing accountability, with the introduction of Macau’s Gaming Law (Law No. 16/2022) representing a critical moment in the regulation of this sector.
This law prohibits junkets from independently offering deposit services and establishes a clear framework for joint liability for casinos unless they can demonstrate diligent oversight. The law also criminalizes unlawful deposit-taking, enforcing stricter regulatory measures to combat financial misconduct.
Seismic changes

According to Moreira and Zhou, the legislative changes have led to a reduction in the autonomy of junkets, as they can no longer independently provide deposit services, with this limitation increasing their dependency on casinos for managing patron funds.
Moreover, the updated law clarifies that casinos are jointly liable for administrative fines and civil liabilities arising from junket activities conducted within their premises, unless they can prove proper oversight.
‘This underscores the need for robust monitoring mechanisms and places a significant compliance burden on concessionaires to mitigate risks’, the research highlights.
Recent guidance has also clarified the conditions under which deposits made to junkets qualify as activities conducted in a casino, helping to resolve numerous disputes related to these transactions.
‘This clarification reduces ambiguity surrounding concessionaire liability and incentivizes greater oversight of junket activities. The reforms aim to alleviate the financial risks for concessionaires associated with ongoing disputes regarding deposits not returned by gaming promoters’ the research details.
The evolving regulatory landscape has significant implications for both casinos and junket operators.
The new regulations aim to enhance transparency and accountability, aligning Macau’s gaming industry with broader governmental goals to transition toward a more mass-market tourism model.
As Macau seeks to transform its gaming sector, the findings from Moreira and Zhou emphasize the need for a carefully calibrated approach to joint liability.
By encouraging casinos to exercise meaningful oversight of junket operations without overburdening them with liability for actions beyond their control, the region aims to create a safer and more transparent gaming environment.
‘Ultimately, the stricter regulations on deposits within Macau’s gaming industry, coupled with increased limitations on gaming promoters’ activities, reflect a shared vision between China’s and Macau’s governments for a transformed gaming sector’, the researchers added.
‘These efforts aim to align Macau’s gaming industry with the broader goal of becoming a tourist destination increasingly reliant on mass-market revenues rather than the VIP junket-driven segment.’