On 1 August 2022, Singapore officially inaugurated a new gambling regulator, the Gambling Regulatory Authority (GRA), replacing the former Casino Regulatory Authority (CRA) and bringing all of the sovereign state’s gambling regulations under a single entity. In this special piece compiled for Inside Asian Gaming, the GRA explains its core mission and why it is better positioned to provide effective and detailed regulation of Singapore’s various gaming activities.
Gambling regulation in Singapore was previously overseen by multiple agencies such as the Casino Regulatory Authority (CRA), the Ministry of Home Affairs HQ, the Singapore Police Force and the Singapore Totalisator Board. There were various pieces of gambling-related legislation, such as the Betting Act, Common Gaming Houses Act, Private Lotteries Act and Remote Gambling Act. These acts had been enacted at different junctures over more than half a century to regulate different types and modalities of gambling.
In recent years, two emerging trends have had a significant impact on the gambling landscape:
- Technology has changed the way people gamble, by making gambling accessible anywhere and anytime.
- Boundaries between gambling and gaming have blurred, which may normalize gambling behaviour, if left unchecked.
To keep pace with the evolving gambling landscape, Singapore’s non-casino gambling laws were consolidated under one omnibus Act titled the Gambling Control Act (GC Act). The Betting Act, Common Gaming Houses Act, Private Lotteries Act and Remote Gambling Act were repealed.
The Gambling Regulatory Authority of Singapore Act (GRA Act) was also passed to reconstitute the CRA as the GRA, which would regulate the entire gambling landscape in Singapore. As regulator, the GRA works with the Ministry of Social and Family Development and the National Council on Problem Gambling (NCPG) to protect Singaporeans from the harms of gambling, while the Singapore Police Force (SPF) will continue to enforce against illegal gambling activities.
As the single regulator for all forms of gambling, GRA pools and optimizes resources and expertise in keeping up with technological and global trends. It can now respond more effectively to emerging products and adopt a more holistic and coherent approach towards gambling policies and issues.
For example, CRA has built up extensive experience in regulating gaming machines in the casinos over the last 14 years. The knowledge and regulatory acumen acquired will enable GRA to regulate gaming machine rooms in private clubs more efficiently and effectively, where the operation of these machines presents similar risks.
The GC Act and the GRA Act were passed in Parliament on 11 March 2022 and took effect on 1 August 2022.
On top of regulating the casinos, GRA, which has about 180 officers currently, now oversees the licensing regime for non-casino gambling services in Singapore such as Lotteries and Betting, Gaming Machine Rooms in private clubs, Tombola in private clubs and Gambling in private bodies.
In addition, a new class license regime was introduced under the GC Act to regulate lower-risk gambling activities such as remote games of chance designed as part of interactive games that are primarily for entertainment, as well as trade promotion lotteries and games of chance. A class license regime differs from a licensing regime in that an operator does not need to apply for a license from GRA to provide such lower-risk gambling activities. The class-licensed operator can conduct the activity as long as all conditions specified in the class license order are met.
The GC Act allows social gambling among family and friends in homes. However, this allowance for social gambling in homes will not be extended to online platforms, given the practical difficulties in establishing the relationship of individuals in the online context, whether an online gambling activity is really social gambling among family and friends. The SPF will take enforcement action against criminal syndicates that seek to exploit this exemption to conduct illegal gambling activities.
As explained earlier, an emerging technological trend is the blurring of the boundary between gambling and gaming, such as loot boxes in video games, which are increasingly popular. Singapore’s approach is to strike a balance between leisure and entertainment, and safeguard against gambling inducement. In this regard, the GC Act does not consider loot boxes as gambling as long as these loot boxes do not contain prizes that are money, money equivalent or anything else of real-world value.
On the other hand, remote games of chance with loot boxes which give out money, money equivalent, or anything else of real-world value would constitute gambling and are prohibited, unless they comply with the conditions stipulated in the Gambling Control (Remote Games of Chance – Class License) Order.
GRA will continue to adopt a risk-based approach to regulation and advance our mission of protecting the people of Singapore by keeping gambling honest and free of criminal influence, and minimizing the harm from gambling.
PENALTIES
The GC Act applies a three-tier penalty structure for unlawful gambling offenses (both online and physical), which differentiates between punters, agents and operators. The highest penalties will be imposed on operators, as their culpability is highest, followed by agents and then punters. Penalties for unlawful gambling will be enhanced, to send a strong deterrent signal to criminal syndicates. Proxy gambling in casinos and gaming machine rooms have also been made criminal offences.
The GC Act makes it a criminal offense for under-aged individuals to gamble, regardless of whether with licensed or unlawful operators, and for under-aged individuals to enter gambling areas – except where entry checks are not required, such as at Singapore Pools’ physical outlets. These outlets are open areas with easy access, and under-aged individuals may unknowingly enter without the intention to gamble.
Similar to how it is currently an offense for excluded individuals to enter and gamble in the casinos, the GC Act also makes it an offense for excluded individuals to enter and gamble across all online platforms and physical locations where NCPG exclusions are applicable, namely gaming machine rooms and the Singapore Pools’ online gambling platform. This does not apply to individuals under Self Exclusion, to avoid deterring individuals from applying for this exclusion.
REGULATING SINGAPORE’S CASINOS
Under the Casino Control Act (CCA), an International Market Agent (IMA) needs to be licensed by GRA before it can perform casino marketing arrangements in or with respect to any casino of which the casino operator has given its endorsement. There is currently no licensed IMA in Singapore.
The casinos were always envisaged as a relatively small component of a large and diversified integrated resort (IR) development that would contribute significantly to Singapore’s tourism industry and economy.
GRA works closely with other economic agencies such as the Singapore Tourism Board and the Ministry of Trade and Industry to ensure the broader tourism and economic objectives.
An example of this approach is reflected in the amendments made to the CCA in 2012 where:
- A new section 45A was introduced in the CCA for the Minister responsible for tourism development and promotion to appoint an Evaluation Panel which will provide an independent opinion to GRA on the ability of the IR operators to fulfill their economic obligations; and
- Section 45 of the CCA was amended to allow GRA to take into account IR operators’ ability to maintain, promote and develop the IRs as compelling tourist destinations when assessing applications to grant or renew casino licenses.
As part of GRA’s supervisory efforts, we monitor the suitability of the two casino operators to hold their casino licenses on an ongoing basis. The suitability criteria are set out in Section 45 of the CCA and in the Casino Control (Casino License and Fees) Regulations 2009. They include, among others, the applicant’s financial background; the applicant’s business associates, which in the opinion of the Authority must be of good repute with regard to character, honesty and integrity and not have undesirable or unsatisfactory financial resources; and the applicant’s track record of compliance with the legal and regulatory requirements applicable to it, whether in relation to casino gaming or otherwise and whether in Singapore or elsewhere.
The GRA also has a range of regulatory levers under the CCA to address areas of regulatory concern. These include issuing Directions and Notices, issuing letters of censure, imposing financial penalties and varying license conditions.
For more information on the GRA visit www.gra.gov.sg.
