## Regulating bodies
The GRA is the main authority involved in regulating the gambling sector in Singapore. With effect from 1 January 2025, the Singapore Police Force (“SPF”) has taken over the functions of blocking access to unlawful remote gambling services, blocking the advertising of such serv…
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## Regulating bodies
The GRA is the main authority involved in regulating the gambling sector in Singapore. With effect from 1 January 2025, the Singapore Police Force (“SPF”) has taken over the functions of blocking access to unlawful remote gambling services, blocking the advertising of such services, and blocking payment transactions relating to them. This will be further elaborated on below under “Technical Measures”.
The MSF also established the NCPG to deal with the social aspects of gambling. Beyond providing free counselling services to gambling addicts, the NCPG maintains a database of individuals who are limited and/or prevented from entering casinos and/or jackpot rooms in private clubs, and/or utilising Singapore Pools’ online betting services.
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 offence proscribed under the GCA is 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, and to arrest without warrant persons who are suspected to have committed an arrestable offence under the GCA. The SPF 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.
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.
For gambling duties, it should be noted that the Inland Revenue Authority of Singapore (“IRAS”) conducts regular reviews of clubs/societies’ gambling duties returns and their record-keeping procedures. During audit visits, the IRAS gathers information on the clubs/societies’ operations, record-keeping practices and internal controls with respect to computation of turnover and duty payable.
## Supervision by Regulator
For licensed gambling, supervision is exercised over such licensees by the GRA by imposing certain license conditions that the GRA deems necessary, such as conditions fixing the kind of gambling or betting, games of chance or lotteries involved in providing the gambling service, conditions regarding advertising, or conditions regarding the management of the gambling service etc. Approvals also need to be sought from the GRA to provide a gambling service from a certain venue, so that the venue is considered an approved gambling venue. Conditions can also be imposed by the GRA in exchange for such approval, for example, requiring a layout or design of the place or premises that ensures that no customer or member of the public can see the gambling taking place in the approved gambling venue from outside the gambling venue, or requiring access control measures for underaged individuals and excluded persons. Moreover, licensees are also required to obtain GRA’s approval for the contents of the rules to any betting, game of chance or lottery conducted. For unlicensed gambling, the GRA will act on complaints made by members of the public on gambling activities which appear to be illegal. The GRA will then take the necessary action against the operators of such gambling activities after conducting its own investigations.
For casinos, the Casino Regulatory Authority of Singapore (now GRA) had previously 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 also investigates certain types of patron disputes between casino operators and a casino patron, such as disputes as to alleged winnings, alleged losses, or the manner in which a game is conducted. A patron may request for a GRA inspector to investigate into a patron dispute. Following the GRA’s investigation, the GRA will make a decision, and if the patron or casino operator is dissatisfied with the outcome, it can appeal to the Patron Dispute Committee by completing and submitting a Reconsideration Form. The Patron Dispute Committee will then reconsider the decision, and decide whether to confirm, vary or reverse the decision of the GRA inspector. If either party is still dissatisfied with the decision of the Patron Dispute Committee, it may appeal to the GRA Board. The GRA Board will then confirm, vary or reverse the decision of the Patron Dispute Committee. Its decision is final.
Moreover, persons who are employed or who work in a casino in a managerial capacity or who are authorised to make decisions involving the exercise of discretion and which relate to the operations of a casino, or who are employed or working in a casino in a capacity relating to the conduct of gaming, the security and surveillance of the casino, or the operation or maintenance of gaming equipment, must have a “Special Employee License” to do so.
Additionally, the CCA allows only approved persons to be main shareholders, substantial shareholders, or controllers of the casino operators. The amendments introduced by the CC(A)A have now resulted in the transfer of the power to approve the main shareholders of casino operators from the GRA to the Minister of Home Affairs, since the latter is better placed to take into account whole of government considerations in deciding whether to approve divestments and acquisitions relating to main shareholders. For controllers and substantial shareholders, the relevant regulatory powers are transferred from the Minister of Home Affairs to the GRA, since these regulatory decisions relate to suitability of persons who may exert influence or control over casino operations, and hence are more appropriately undertaken by GRA.
If a change of a kind specified by the GRA in writing to an associate of a casino operator takes place in the situation of that associate, the associate must notify the GRA of the change in writing within 14 days after it takes place, or such longer period as the GRA may allow (section 62 of the CCA).
## Enforcement against licensed operators
The GCA applies a three-tier penalty structure for gambling offences and differentiates punters, agents, and operators. Operators who flout the law face the harshest penalties, followed by agents and lastly punters. The GRA actively enforces the law to ensure that licensed operators comply with the requirements of their licenses. The GRA publishes the results of their enforcement actions in its Annual Reports which are publicly available on its website.
## Typical triggers for enforcement against unlicensed operators
The Singapore Police Force is deployed in areas in which illegal gambling activities are carried out. For instance, Singapore’s local newspaper, the Straits Times has reported instances of police patrolling areas and apprehending unlicensed service providers. Apart from police patrol, typical triggers for enforcement also include whistle blowing by disgruntled ex-employees of such operators, dissatisfied customers, or reports by family members of problem gamblers. Tip-offs from the public may also lead to police investigations.
Enforcement action taken against unlicensed operators, agents of unlicensed operators, and individuals who engage in illegal gambling
Search and seizure
Under Section 108 of the GCA, a police officer or an authorised officer may enter any premises without a warrant if there are reasonable grounds for believing gambling is or has been conducted. Upon entering the premises, the police or authorised officer may inspect and seize any document, article, or equipment.
## Arrests
Under Section 112 of the GCA, an authorised officer may arrest, without warrant, any individual who the officer reasonably believes has committed an arrestable offence under the GCA where the individual is found in or found to be escaping from certain places such as an approved gambling venue or an office storing records of gambling services. The authorised officer may also seize all gambling articles found on the individual arrested.
Technical measures
Under Section 117 of the GCA, the GRA may direct the IMDA to order an internet service provider to take reasonable steps to disable access to an online location (an access blocking order) that is used to provide a remote gambling service in contravention of section 18, that is or may be used by individuals present in Singapore to gamble in contravention of section 20(1), that contains an invitation to young persons to gamble in breach of section 34, or that is a remote gambling service advertisement published in Singapore in contravention of section 85. Before doing so, the GRA must have regard to the matters listed in section 117(2). For online locations containing invitations to young persons to gamble or remote gambling advertisements, the GRA must generally also first give the owner or operator notice to stop the activity within the prescribed period (section 117(4)).
Under Section 118 of the GCA, where the GRA is satisfied that a person is participating or has participated in unlawful remote gambling activity, it may direct MAS to give a financial institution a payment blocking order, or itself give one to a financial transaction provider involved in the transaction. Such an order may block credit, cheques or funds transfers to or from that person, or transactions using merchant category codes customarily associated with gambling. An MHA press release published 8 April 2025 stated that the GRA has blocked more than 3,800 illegal gambling websites and more than 145,000 illegal gambling transactions amounting to approximately $37 million. Since 1 January 2025, the blocking of access to unlawful remote gambling services has been carried out by the SPF (see “Regulating bodies” above).
Fines and imprisonment
Under Section 18(2) GCA, an unlicensed operator who conducts any betting operation, gaming or any lottery is liable on conviction to a fine of up to SGD 500,000 and mandatory imprisonment of up to 7 years. Where the offender is a repeat offender, the maximum fine is SGD 700,000 and maximum jail term is 10 years. Similarly, under Section 19(2) GCA, conducting any of these activities outside of an approved gambling venue will attract the same punishments.
Under Section 18(3) GCA, where the offender conducts any of betting operation, gaming or any lottery on behalf of, or in accordance with arrangements made by another (i.e. agents of unlicensed operators), the offender is liable to a fine of up to SGD 200,000 and mandatory imprisonment of up to 5 years. Where the offender is a repeat offender, the maximum fine is SGD 300,000 and maximum jail term is 7 years. Similarly, under Section 19(3), conducting any of these activities outside of an approved gambling venue will attract the same punishments. Enforcement action has been taken against such agents of unlicensed operators. For example in 2019, various individuals were convicted for facilitating illegal betting by opening agent accounts and player accounts for bets to be placed by punters. Recent examples of enforcement action taken include the following:
In August 2023, Singapore authorities conducted simultaneous raids and arrested 10 foreigners holding multiple citizenships in connection with their alleged acts of laundering the proceeds of their overseas criminal activities, including online gambling. The amount of assets surrendered to the state amounted to almost $2.8billion as of 19 November 2024.
In November 2023, the police investigated 42 persons for suspected illegal gambling activities, where 13 of them had allegedly relinquished control of their bank accounts to illegal gambling syndicates to facilitate bank transactions linked to illegal gambling, 27 had allegedly used illegal gambling sites or applications and made transactions to bank accounts controlled by gambling syndicates, and two had allegedly subscribed to cellphone lines that were used by the gambling syndicates in their activities.
On 10 December 2023, police entered and seized S$40,200 in cash and other gambling-related items from a unit in the notorious Geylang neighbourhood. The operation led to the arrests of 21 people for suspected illegal gambling activities.
Under Section 20 of the GCA, an individual commits an offence if he gambles using an illegal gambling service or at an unlawful gambling place, and knows or ought reasonably to know that the gambling service or gambling place was illegal. The individual would be liable on conviction to a fine not exceeding $10,000 or to imprisonment for a term not exceeding 6 months or to both. Enforcement action has been taken against such individual punters under the various legislation that preceded the GCA for gambling unlawfully. Recent examples include the following:
Following gambling suppression operations conducted between 2 and 10 May 2024, SPF initiated investigations against 32 persons for their suspected involvement in illegal gambling activities. Officers from the Criminal Investigation Department froze more than 10 bank accounts that are believed to have been used to facilitate illegal gambling.
During a joint operation conducted between 21 August 2024 to 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 S$48,000, computers and other gambling paraphernalia were seized as case exhibits.
Betting: Currently, Singapore Pools is the only legal sports, lottery, and (until October 2024) horse betting operator in Singapore. Enhanced enforcement during major events The authorities will step up enforcement of the GCA during major sporting events that attract illegal betting. For example, in the run up to the 2022 World Cup in Qatar, the Ministry of Home Affairs (“MHA”) and the MSF had made a joint statement to the press that the authorities would step up enforcement efforts against unlawful gambling and problem gambling. The Singapore Police Force also conducts heightened enforcement during festive occasions such as the Chinese New Year festivities where betting and other forms of gambling are more rampant. The Singapore Police Force also publishes enforcement outcomes, including details of raids, arrests, and seizures of cash and gambling equipment on their website. From 28 December 2022 to 10 January 2023, a total of 466 people were investigated for various offences. Notably, evidence of betting paraphernalia was seized during one of the investigations. Match-fixing and coordinated efforts Match-fixing, while not a gambling activity, is closely tied to betting where bets are placed with knowledge of the pre-determined winning party. The Corrupt Practices Investigation Bureau investigates reports of corruption in traditional sports and esports. In 2015, Singaporean Rajendran S/O R.
Kurusamy was sentenced to 48 months’ imprisonment for offences relating to match-fixing activities at the 28th South East Asian Games. In the field of football, the authorities work closely with the Football Association of Singapore (“FAS”) to clamp down on match-fixing. Before the start of every season, the relevant authorities conduct briefings for officials, players and staff on what constitutes match-fixing and the consequences of it. The Singapore Premier League’s standard player contract also provides for the right of the FAS to administer lie detector tests on players. The FAS also requires its players and officials to report to their respective clubs and the authorities should they be approached by anyone intending to match-fix. In 2015, Singaporean Selvarajan s/o Letchuman was sentenced to 30 months’ imprisonment for three counts of match-fixing and cheating offences relating to the Malaysian League football match between Lions XII and Sarawak FA. General deterrence is the primary consideration in sentencing persons involved in match-fixing. This is especially so where match-fixing involves a cross-border element. When an offence became harder to detect, easier to commit, more lucrative and increasingly prevalent, the court will adjust the punishment upwards to ensure that the element of deterrence is properly maintained.
In one case, the Court concluded that the appropriate sentence for an offence of bribing players, referees, other football officials or any other persons in order to fix football matches at the FIFA World Cup level committed by a fairly seasoned match-fixer is 3½ years’ imprisonment. The Court also stated that in the case of fixing a domestic league football match, the appropriate sentence would be 1½ years’ imprisonment: see Ding Si Yang v Public Prosecutor and another appeal [2015] 2 SLR 229. Internationally, Interpol’s Match-Fixing Task Force reported a marked increase in online betting related to match-fixing schemes during COVID where match-fixers took advantage of COVID-19 restrictions to exploit the betting and sports industry. Interpol detects potential match-fixing and issues a Purple Notice to its 194 member countries, of which Singapore is a member. The International Betting Integrity Association reported 90 alerts of suspicious betting to the relevant authorities in the second quarter of 2024, concerning 8 sports, across 25 countries and five continents. This amount is 3% less than the 93 alerts in the first quarter of 2024 and an increase of 80% when compared to the 2023 second quarter total of 50 alerts. Match-fixing can also exist in eSports. The Straits Times reported that several professional gamers in Singapore had been banned for match-fixing and betting against their own team in a regional tournament held in 2020.
In May 2023, the Singaporean Valorant team captain was sentenced to 4 months in jail for accepting a bribe to purposely lose an e-sports match in which he was playing and for placing bets against his own team on an illegal gambling website. Other enforcement actions On 13 August 2023, the Singapore Police Force arrested a man suspected of acting as an illegal bookmaker, together with two other men suspected of placing bets with him. Cash, phones, and a tablet were seized. Between 30 October 2024 to 10 November 2024, the Singapore Police Force raided multiple locations in Singapore, and cash amounting to more than $43,000, mobile phones, and horse betting paraphernalia were seized. This was the first major operation against illegal horse betting activities following the closure of the Singapore Turf Club on 5 October 2024. 73 people, consisting of 70 men and three women aged between 52 and 93, were investigated for their suspected involvement in such activities, believed to be in various roles such as illegal bookmakers, runners and punters.
Bingo: Lower-risk gambling Generally, bingo games are likely to be perceived as lower risk gambling particularly if they are only conducted in a social context. Moreover, if the bingo game is conducted for specific purposes, it is likely that class licences will be available to allow such games to be held. Under the Gambling Control (Trade and Other Promotional Games and Lotteries — Class Licence) Order 2022, the provider of a game of chance does not require a licence for certain games of chance. These are games of chance that are cause-related, survey-related, and for trade promotion. With respect to cause-related games of chance, class licences are available where the game is organised by government authorities to promote national and public objectives. With respect to survey-related games of chance, class licences are also available where the game is organised by education providers such as tertiary and private education institutions. With respect to trade promotion, class licences are available where a game of Bingo is carried out primarily to promote trade in any goods or services and where entitlement to play is free, or the right to play or is dependent on the purchase of any goods or services being promoted.
However, in each of these scenarios, the game must abide by various conditions such as avoiding the use of gambling articles (e.g. dominoes, mah-jong tiles etc.), ensuring information on the determination of prize winners is made publicly available, and not offering goods or services to a winner who by reason of his or her age would not be permitted under the law to purchase such goods or services. Bingo as a form of social gambling It should be noted that as explained above, physical social gambling that is conducted in residential premises among family members and friends on a substantially spontaneous basis and not conducted for private gain or in the course of any business has been legalized under the GCA. However, due to difficulties with enforcement, online social gambling has not been offered a similar exemption under the GCA. Bingo conducted by clubs and societies Previously, under the Private Lotteries Act, clubs and societies could apply for permits to conduct private lotteries such as bingo games, and permits were granted to such clubs and societies for the conduct of such private lotteries. With the GCA repealing the Private Lotteries Act, the transitional provisions in the GCA apply.
The GCA provides that for clubs and societies who have been granted permits to conduct such private lotteries prior to the repeal of the Private Lotteries Act, such a permit is to continue to be in force as if it were a licence granted under the GCA for the conduct of a lottery, until that permit expires or is otherwise revoked. Once such permit expires, the clubs and societies will need to apply for a fresh licence under the GCA, as it is unlikely that such Bingo games would fall under the scope of social gambling, or any of the other class licences.
Casino: Generally strict enforcement The authorities tightly regulate casino gambling in Singapore through strict law, tough enforcement, and public education. The GRA is the main regulator of the gambling industry. To future proof the regulatory regime, the amendments made to the CCA by the CC(A)A allow any thing to be prescribed as a casino chip. With effect from 21 September 2026, “casino chip” means any token used instead of money for the purpose of casino gambling, and includes any voucher or other instrument that has a fixed dollar wagering value and anything prescribed as a casino chip, and the Casino Control (Prescribed Casino Chips) Regulations 2026 prescribe electronic credits in a casino operator’s cashless wagering system as casino chips. Regulation of betting and lottery in casinos With effect from 21 September 2026, “casino gambling” under the CCA includes betting and lotteries conducted by a casino operator within the casino premises, so the GRA regulates these under the CCA. However, there are currently no plans to allow casinos to carry out betting and lotteries. Licence (land-based casino) All forms of land-based casino gambling are generally prohibited, unless a casino licence is obtained.
Under Section 43 of the CCA, it is an offence to operate a casino without a valid casino licence in force. If found guilty of an offence, the offender will face a fine of up to SGD 500,000 (for first offence)/ SGD 700,000 (for second or subsequent offence), or to imprisonment up to 7 years (for first offence)/ 10 years (for second or subsequent offence) or to both, and a further fine of up to SGD 50,000 (for first offence)/ SGD 70,000 (for second or subsequent offence) for every day that the operator continues to operate the casino following the conviction. In addition, under Section 100 of the CCA, a licensed casino operator must obtain approval from the GRA for each of the specific games that are played in the Casino, including their mode of play and game rules. Under section 45(4) of the CCA, as amended by the CC(A)A, the GRA may also consider: (a) whether the casino operator conducts its business (including business outside Singapore or unrelated to casino operations) in a manner which is unethical or will bring discredit to casino gambling in Singapore; and (b) whether there has been a systemic deficiency or failure in the applicant’s internal controls or corporate governance. A casino operator that is no longer a suitable person having regard to the matters in section 45 may be subject to disciplinary action (section 54(1)).
Moreover, under the CC(A)A amendments, disciplinary proceedings started against a casino operator may continue, and the GRA may issue a letter of censure or impose a financial penalty, despite the cancellation, surrender or expiry of the casino licence (section 54(11)); the same applies to special employees (section 93(7)). Notably, this already applies to other gambling licensees regulated under Section 89 of the GCA (thus bringing CCA in line with the GCA in this regard) and ensures licensees do not avoid punishment for failing regulatory requirements, despite their licences lapsing. Anti-money laundering regulations (land-based casinos) Licensed casino operators are required to conduct customer due diligence and record-keeping in accordance with the Casino Control (Prevention of Money Laundering, Terrorism Financing and Proliferation Financing) Regulations 2009. Casino operators must identify and verify the identity of every patron who seeks to open a patron account, and continually monitor all existing accounts. Casino operators must also exercise additional diligence and keep sufficient records where large sums of money are deposited into an account. In addition, heightened safeguards must be observed when dealing with higher-risk patrons, including obtaining prior approval from senior management before establishing transactions with the patron, and conducting enhanced monitoring of the transactions.
Casino operators are also required to conduct an independent audit at least once annually. Failure to observe these requirements can result in the cancellation or suspension of the casino licence. One recent action taken by the GRA against an operator in December 2023 was the imposition of a S$2.25 million financial penalty on Resorts World at Sentosa Pte. Ltd. (“RWS”). Between December 2016 and December 2019, RWS failed to perform customer due diligence checks prescribed by the CCA and the Casino Control (Prevention of Money Laundering and Terrorism Financing) Regulations 2009 (“PMLTF Regulations”). RWS did not establish the identify of third parties who wished to make cash deposits into the accounts of RWS’s patrons, did not record the identifying information, and did not verify these identities using reliable and independent sources as required by the PMLTF Regulations. GRA also cancelled the special employee licence of one of the employees involved in the breaches. Moreover, under the new section 139A(12) of the CCA, casino operators are liable to disciplinary action if they contravene their obligation to disclose risk information as required by the GRA’s written notice (relating to the sharing of information of patrons between casino operators, for the purposes of tackling money laundering, terrorism financing and proliferation financing) and/or disclose risk information received or accessed under this section to other persons, unless lawfully required to do so.
Additionally, the Anti-Money Laundering and Other Matters Act 2024 (passed in Parliament on 6 August 2024) has, amongst others, aligned the framework for anti-money laundering/ countering the financing of terrorism for casino operators with the international Financial Action Task Force standards, to better prevent and detect money laundering. Enforcement and public reports (land-based casino) The GRA takes active steps in enforcing the various legislation on casino operators in Singapore. Regulatory contraventions or non-compliances are enforced by the GRA, and the GRA publishes the outcome of its enforcement actions in its annual reports which are publicly available. For instance, the GRA has published the one-month suspension of the licence of Ceylon Sports Club consequent to the latter’s failure to comply with the requirements under Section 88(1)(a)(i) of the GCA for the screening and registration of persons and preventing the entry of excluded persons. Problem gambling (land-based casinos) The NCPG maintains a register of persons who are excluded from gambling activities at the Casinos in Singapore, or who are subjected to a visit limit restricting the number of visits which can be made to the casinos in Singapore each month. Prior to the introduction of the amendments to the CCA made by the CC(A)A, in order to prosecute such excluded persons, GRA has to prove that the excluded person was aware of his exclusion status when he entered the casino, which can be hard to prove.
To address this, with effect from 21 September 2026, the amended CCA makes an excluded person liable for entering, remaining or taking part in gambling on casino premises if it is proven that he knows, or ought reasonably to know that he was an excluded person. The breach of a family visit limit has also been made an offence. The MSF works closely with the NCPG and provides a range of public education, social safeguards, and remedial actions to target problem gambling. Online casinos Online casinos are strictly prohibited in Singapore, and are unlawful to begin with. Thus far, no licences have been granted by the GRA for the provision of any online casinos, and none is expected to be granted in the foreseeable future. White label casinos White label casinos – where a third party operates a casino under another entity’s licence or brand—are not a feature of Singapore’s tightly controlled casino regime. The CCA stipulates that only the designated and licensed operators may run casino operations, and the licensing regime does not provide for white label arrangements. As set out in the Overview section, there are only two casino licences in force, and these are not transferable or sub-licensable to third parties. The regulatory framework does not recognise or permit white label casino operations. All casino activities must be directly operated and controlled by the licensed entities, subject to the GRA’s direct supervision.
Any attempt to operate a casino without a valid licence, including through a white label arrangement, would be considered illegal and subject to severe enforcement action. This includes substantial fines, imprisonment, and the seizure of assets.
Lottery: As mentioned above, currently, Singapore Pools is the only legal sports, lottery, and (until October 2024) horse betting operator in Singapore. Licence Any person who wishes to conduct any public or private lottery operations would need to be licensed by the GRA. Currently, the Singapore Pools is the only entity which has been issued a licence by the GRA to provide public lottery services in Singapore. Under Section 69 of the GCA, a licensed lottery operator is required to obtain the approval of the GRA of the lottery and the content of the rules of that lottery. Conducting a lottery without a licence is an offence under Section 18 of the GCA. A party who is found guilty of a first-time offence faces a fine of up to SGD 500,000 and imprisonment of up to 7 years. A repeat offender may face a fine of up to SGD 700,000 and imprisonment of up to 10 years. Punters/ Participants Section 20 GCA makes it an offence for any person to gamble with an unlawful gambling service provider. This thus applies to individuals who participate in unlicensed lotteries. A person convicted faces a fine of up to SGD 10,000, imprisonment for up to six months, or both. In recent police operations, individuals who gambled using illegal lottery websites or mobile applications have been investigated and charged under this section. For example, in May 2024, two individuals were charged in court for gambling with an unlawful gambling service provider under this section.
Syndicate lottery service provider Under Section 21 of the GCA, a syndicate lottery service provider which buys lottery tickets for both local and foreign customers for an unlawful lottery service would be committing an offence if the service provider has a financial interest in the lottery service, and knows or has reasonable cause to suspect that the lottery service is unlawful. A financial interest includes the receiving of any 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. A syndicate lottery service provider who commits a first-time offence faces a fine of up to SGD 500,000 and a jail term of up to 7 years. A repeat offender faces a fine of up to SGD 700,000 and a jail term of up to 10 years. Enforcement action has been taken against the providers and members of such syndicate lotteries under the now repealed Common Gaming Houses Act, which had provided for lower penalties. Such syndicate lottery providers now face higher penalties under the GCA.
Poker, whether played online or in person, is tightly regulated under the GCA. All forms of gambling – including poker – are prohibited unless specifically licensed or exempted. Under Section 18 of the GCA, convicted organisers/agents could face fines of up to SGD500,000 and mandatory imprisonment of up to 7 years for serious offences (for first offenders) and fines of up to SGD700,000 and mandatory imprisonment of up to 10 years (for repeat offenders). Under Section 20 of the GCA, punters/participants who are convicted for gambling with an unlawful service provider could face fines of up to SGD10,000 and/or imprisonment up to 6 months. Enforcement action has been taken against people who have organised online poker games and helped to distribute the winnings amongst the participants; see, for example, Public Prosecutor v Choo Yi Neng, Costner [2021] SGMC 50. Enforcement action has also been taken against people who have created mobile applications for online poker games; see, for example, Koo Kah Yee v Public Prosecutor [2021] 3 SLR 1440. The Singapore Police Force actively investigates and clamps down on illegal poker games. The Singapore Police Force publishes the outcomes on their investigations on their website which is publicly accessible. In October 2021, the police conducted an enforcement check on a shophouse unit along Norris Road and arrested two men who were suspected to have organised illegal gambling activities for nine other men in the unit.
Gambling-related paraphernalia such as poker cards were found and seized for investigations. Enhanced enforcement during major events The Singapore Police Force conducts heightened enforcement during festive occasions such as the Chinese New Year festivities where illegal gambling is more rampant. The Singapore Police Force also publishes the findings of their investigations on their website. From 28 December 2022 to 10 January 2023, a total of 466 people were investigated for various offenses.
Skill games: As mentioned above, in general, games of skill are not prohibited under Singapore’s gambling laws. However, activities such as fantasy sports, loot boxes, skins betting, and secondary markets for virtual currencies contain an element of chance and the providers of such activities would need to ensure compliance with Singapore’s gaming laws. Class Licence There are class licenses available for online games of chance to exempt the aforesaid activities from being considered as unlawful gambling provided that certain conditions are met. The RGC Order 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. Type 1 class licence games are games which are free to play and which are not prohibited under Schedule One of the RGC Order. These games are subject to two conditions. First, publicity materials must not make reference to any gambling article specified in 2nd Schedule of the RGC Order. Second, any complimentary token awarded to a player to play or continue to play the game must be restricted to the unique use of that individual player only, and must be non-transferable to others. Type 2 class licence games are games which are excluded from a type 1 class licence and which may or may not be free to play.
These games are such that a prize may be won or a game feature may be unlocked in a randomised or partially randomised manner during gameplay. Prizes awarded must not be money, must only be won in the game, and must primarily be used in another in-game microtransaction in the same game or in another related game. These games are subject to the condition that the game provider must take all reasonably practicable steps to make sure that it does not also provide a service where any prize won can be converted into money or money equivalent. To address the blurring boundaries between gambling and gaming, the MHA had proposed to introduce a prize cap of SGD 100 for, among others, mystery boxes (i.e., boxes which contain an unknown prize). The regulatory intent is to address the inducement effect of high-value prizes, without increasing the regulatory burden on operators. With effect from 1 March 2024, prizes for games offered at amusement centres and fun fairs (such as claw machines and arcade games) must be under SGD 100 in value, and cash, cash equivalents, credit, merchant vouchers and coupons may not be offered as prizes. However, to date, the class licence for mystery boxes has not been issued. Separately, MHA and the GRA are drafting regulations on blind boxes, which will also cover trading card packs (see “Regulatory Horizon” below). Fantasy sports Most fantasy sports games involve a significant element of chance, and hence would be considered as games of chance under the GCA. Prima facie, if players stand a chance to win money or money’s worth or anything else of value, then such games would be prohibited by the GCA.
However, such games will not be considered as gambling as long as there are no in-game monetisation facilities that allow players to exchange the virtual prizes for real-world pay-outs, assuming the game falls within the scope of the RGC Order. At present, there do not appear to be any plans by the regulatory bodies to specifically address the legality of fantasy sports games. Loot Boxes Games containing loot boxes would be considered a game of chance, since the loot box is a chance-based element. Depending on the game mechanics, the game may fall within the scope of the RGC Order and may be able to fall under a class license. Skins betting Skins betting or skin gambling, is the use of virtual cosmetic in-game items as virtual currency to bet on the outcome of professional matches or on other games of chance. Skin betting could potentially count as “engaging in a gambling activity” as a form of betting. Under Section 5 of the GCA, betting means the making or accepting of a bet, which involves the payment or staking of any money, money equivalent or any thing else of value on the outcome of a race, competition, sporting event or other event, the likelihood of anything occurring or not occurring, or whether anything is or is not true. Hence, as skins are likely to be regarded as “any thing else of value” (and may in some cases be money equivalent under section 14 of the GCA), betting with skins is likely to constitute betting. As of present, there has not been a case dealing with this issue. Hence, there is some risk underlying skin betting and the conducting of a skin betting service.
Any person who wishes to conduct any betting operations would need to be licensed by the GRA. Currently, the Singapore Pools is the only entity which has been issued a licence by the GRA to provide betting services in Singapore. Skins betting is not offered by Singapore Pools. Conducting a betting operation without a licence is an offence under Section 18 of the GCA. A party who is found guilty of a first-time offence faces a fine of up to SGD 500,000 and imprisonment of up to 7 years. A repeat offender may face a fine of up to SGD 700,000 and imprisonment of up to 10 years. That said, at present, we are not aware of any enforcement action which has been taken by the Singapore authorities against operators of fantasy sports betting, skins betting or games containing loot boxes.
Software/B2B: Under the GCA, there are no specific licenses or class licenses available for the provision of gambling related 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. Such services would have to involve the provision of technical support rather than being operational in nature. In this regard, Section 8(4) of the GCA provides that a person would not be considered as assisting in the conduct of gaming (within the meaning of section 8 of the GCA, the unlicensed conduct of which is an offence under section 18 of the GCA) merely because one is, inter alia, providing “relevant electronic services” such as telecommunications services or internet access services. Section 8(4) of the GCA is non-exhaustive as to the list of activities that would not be considered to be assisting in conducting a gambling activity. Therefore, it is possible that providers of support services for gambling operations can bring themselves within this Section and not be considered to be “conducting gaming” by providing such services, although this would ultimately depend on the exact services being provided.
It is unlikely that legitimate service providers such as those who license software or provide technical IT support services to online gambling operators based outside Singapore with no Singaporean customer base will be the target of enforcement action. To date, there have been no reported enforcement actions or prosecutions specifically targeting B2B gambling service providers (such as software suppliers or technical support firms) under the GCA, provided their activities do not cross into operational involvement or abetment of unlawful gambling. Under the CCA, manufacturers of gaming machines and gaming programs for use in a casino, and providers of testing equipment for gaming equipment, may apply to be approved by the GRA (section 103A); suppliers act as authorised suppliers notified by an approved manufacturer. Gaming machines and gaming programs must also comply with prescribed technical standards and other requirements (Section 103(1)(b)). The GRA is authorised to take regulatory action against casino suppliers for breaches of licence conditions, including financial penalties, suspension or revocation of licences, and issuance of directions for the rectification of the contravention or non-compliance. However, a review of GRA’s website on “Enforcement Actions”, which is where public enforcement actions would be listed if they are made public, do not include any enforcement actions against B2B suppliers.
This could be because minor or administrative enforcement actions may not be publicly available and could be resolved directly between the GRA and the supplier, particularly if they do not involve criminal conduct or significant breaches that warrant public attention.
