Singapore Gambling — Distribution and platforms: Can we ship through apps and platforms?

## Infrastructure Gambling venues are required to install appropriate surveillance systems which comply with the Gambling Control (General) Regulations. Licensees must take all reasonable measures to ensure that the surveillance system is installed and kept operational at all times unless it is under maintenance or repair. Licensees are also required to keep a recording made by the surveillance system for up to 28 days. Gambling operators are also required to apply to the GRA for approval of any game, game rules and gaming machine used in the course of the gambling operation under the GCA. Casinos are also required to install appropriate surveillance systems which comply with the Casino Control (Surveillance) Regulations. A casino operator is not allowed to conduct any operations on casino premises until there is a GRA-approved surveillance plan for those casino premises and there is a casino surveillance system which is installed, operated and maintained for those casino premises in accordance with the GRA-approved surveillance plan. The GRA may conduct inspections and the casino operator must immediately provide a copy of any recorded image or video recording by the casino surveillance system to the inspector upon request. They must also answer any questions and provide information regarding the recorded image or video recording as the inspector may consider necessary or keep the copy of any recorded image or video recording by the casino surveillance system as the inspector may require. The GRA may keep the copy any recorded image or video recording provided to the inspector by the casino operator. The GRA is also empowered to install, operate and maintain its own equipment with the capability to observe, monitor and record activities within and in the immediate vicinity of any casino premises. The installed equipment will be considered under the control of the GRA. ## Integrations The Casino Control (Problem Gambling --- Exclusion Orders and Visit Limits) Rules 2008 provides that the Ministry of Social and Family Development (“MSF”) and the National Council on Problem Gambling (“NCPG”) work together with the GRA to maintain an exclusion database for casinos. The NCPG and the MSF also require operators to implement responsible gambling programs. Finally, the establishment of the GRA as the single regulator for all forms of gambling in Singapore is intended to allow the Government to respond more effectively to emerging technological and gambling trends, and take a more holistic and integrated approach to gambling policies. ## Software certification The GRA mandates that all gambling related systems and software deployed in Singapore must be secure, reliable and auditable in order to ensure honest gaming. The GRA sets out a list of approved testing laboratories (Approved Test Service Providers) that conduct tests on and certify casino gaming equipment (and software). The GRA also prescribes various technical standards that gambling related systems should comply with, including (among others) technical standards for the software involved in: Cashless wagering systems Client-server systems Electronic card shufflers and electronic card shoes Electronic gaming machines Progressives Third party add-on games and game systems Slot management systems EGM-based community games