Singapore’s Remote Gambling Act, passed after its second reading, now means that the entire spectrum of remote gambling activities in the country will be criminalized. The restrictions are extremely broad and will be felt by operators, agents, brokers, service providers, advertising networks, payment processors, financial institutions, ISPs – and, of course players, says Matt Pollins, international technology and media lawyer at Olswang in Singapore.
There will be a licensing regime, but the Minister’s speeches during the Parliamentary session indicate that there are only a couple of real candidates – Singapore Pools and Singapore Turf Club. In the Minister’s own words: “The entity has to be based in Singapore so as to aid the enforcement of the exemption conditions. The exempt operator has to be a not-for-profit entity which contributes to public, social and charitable purposes in Singapore”.
Even when the licenses are handed out, casino-type games will not be permitted, so Singapore customers will have no legitimate options available to play online casino games. In addition, the licenses will come with some heavy conditions.
It does not matter whether the services are hosted or based in Singapore or abroad. By providing a remote gambling service with a "Singapore customer link", operators are subject to the rules, wherever in the world they are based operators based overseas will be required to make operational changes to comply. These include informing prospective customers that Singapore law prohibits the provision of the service to Singapore-based users, updating their terms and conditions and taking "such other measures as far as reasonably practicable to ensure that the service did not, or could not reasonably have, a Singapore-customer link". It is not yet clear whether geoblocking will be a minimum requirement.
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