China

Mainland China's gambling regime remains a comprehensive prohibition under Criminal Law Art. 303, with the two state lotteries as the sole lawful exception. This cycle's material development sits in the adjacent financial-instrument layer rather than in gambling law itself: PBOC-led Notice No.42 (February 2026) closes a crypto and stablecoin settlement channel that had been used to route offshore gambling wagers, while cross-border enforcement against gambling continues to escalate through coordinated action with State Councilor-level campaign reaffirmation and international law-enforcement cooperation. The state lottery system, at approximately CNY 628 billion in 2025 sales, underscores the fiscal stakes behind maintaining the state monopoly against private and offshore competition.

Market entry is not viable for private gambling. No offshore service model can be made defensible where it serves mainland Chinese demand, because solicitation, payments and traffic reaching the mainland engage Art. 303 and accomplice liability. Reputable-operator exits and POGO contraction increase residual counterparty risk for any structure with CN exposure.

Payment risk is central, not ancillary. PBOC, SAFE, the Ministry of Public Security and other departments coordinate to sever gambling-related financial chains; 2,800+ gambling payment platforms have been shut since 2020. Pao Fen / Dai Shou local collection networks, USDT on-ramps, mirror merchants and underground banking are the primary architectures used to serve Chinese demand — all indefensible. No payment rail is permitted for gambling.

Marketing of private gambling to mainland Chinese consumers is banned and criminally exposed. Advertising assistance to gambling operations engages Art. 287-2 (assisting information-network criminal activity) alongside the Advertising Law. Chinese-language offshore marketing, sponsorship targeting Chinese audiences, affiliate traffic and social/platform distribution all carry accomplice-liability risk.

App stores, social platforms and e-commerce marketplaces in mainland China prohibit gambling distribution; in June 2018 all online poker applications were banned and removed from app stores, with poker promotion forbidden across WeChat and Weibo. China-facing affiliate, CDN, DNS and hosting infrastructure carries accomplice-liability exposure.

Fujian provincial courts delivered first-instance verdicts on 13 October 2026 against a Myanmar-border (Kokang) crime family that ran illegal casinos and scam compounds targeting Chinese nationals. The group's leader received a death sentence, three defendants received life imprisonment, and 55 further defendants received prison terms of up to 24 years. The verdicts were reported via Xinhua through secondary press coverage (agbrief.com); no direct court document was retrieved. This action continues the multi-year Strike-Hard enforcement campaign against cross-border gambling and scam syndicates based in enabler regions along China's periphery. A capital-punishment outcome against syndicate leadership reflects continued maximum-severity enforcement under the standing sanction ceiling available to Chinese courts for organised illegal gambling and associated scam operations. The action targets unlicensed organisers operating from outside mainland China's jurisdiction but reaching Chinese nationals, rather than any licensed or quasi-licensed domestic participant, since no such licensed commercial gambling sector exists within the prohibition architecture.

Default outlook is negative for liberalisation and increasing for enforcement intensity. There is no credible consultation, pilot reform or liberalisation signal on a 12-36 month horizon. SPC directives and MPS operations point to intensification, not relaxation. State-lottery expansion (record sales of RMB623.49bn in 2024) is the only growth signal and does not open any private pathway.