Jurisdiction - Singapore
Singapore – Regulator Gives Guidance On What Social Games Escape Remote Gambling Regulatory Controls.

3 February, 2015


Legal News & Analysis – Asia Pacific – Singapore  Regulatory & Compliance


A Singapore regulator has set out new guidance explaining in more detail the type of games that do not fall subject to tight regulatory controls on remote gambling that exist in the country.


The Media Development Authority (MDA) said it was providing clarification on the issue after some businesses in the gaming industry had raised concerns about whether “social games” are in scope of the new regulatory regime.


The guidance was issued as the Ministry of Home Affairs in Singapore announced that the Remote Gambling Act, passed by the country’s parliament in October 2014, will take effect from 2 February 2015.


Under the Remote Gambling Act, companies that organise, manage or supervise remote gambling services and make them available to Singapore consumers face fines of up to SGD 500k (USD 400k) unless they are authorised to provide such services.


Remote gambling services will now be licensed in accordance with strict conditions set out under the Act which was passed in response to the Singapore government’s concerns about the relationship between online and mobile gambling and crime and social problems.


Licensed operators under the new regime will only be able to accept bets on sports events and run lotteries, although the scope of activities permitted could be extended by the Singapore government. However, the restrictions have left some in the gaming industry wondering whether the provision of certain games to consumers in Singapore falls foul of the new regulatory framework.


However, the MDA said it wanted to clarify the issue. In a statement it said: “The Act does not cover games which do not, as part of the game design, enable players to receive money or money’s worth consequent to the outcome of that game”.


An example of games that do not fall subject to the general ban on remote gambling include those that do not allow consumers playing the game to win “money or real-word merchandise which can be exchanged for money”, it said.


Other games that allow players to buy or trade game credits or tokens, or buy, gain or exchange “game enhancement features” such as weapons or skills, or which involving ranking players, are also not subject to the new framework, providing there is no facility that sees those aspects of the game converted to or rewarded with money or merchandise exchangeable for money, the MDA said.


The MDA said it had also received queries about games where players at the top of leaderboards or who win tournaments win “real-word prizes”. It said that the Remote Gambling Act “does not prohibit mechanisms to reward players for their skill, provided that these are not within casino-style games or are not used as a means of facilitating syndicated criminal activity.”


The MDA said it the Act “will not impede the development of legitimate social media gaming businesses” and that it would “continue working with the gaming industry to ensure its continued growth and development”.


Gambling law expert Bryan Tan of Pinsent Masons MPillay said the MDA’s statement would provide useful guidance to gaming providers based in Singapore and those providing their services to consumers in Singapore from overseas.


“There has been a big uproar from the social gaming industry about the Remote Gambling Act,” Tan said. “The MDA’s clarification is welcome as the original language about the scope of the Act was unclear and the parliamentary speeches seemed to suggest that social games were not included, however the position seemed to be put less than unequivocally then, leading to uncertainty.”


Pinsent Msaons MPillay


For further information, please contact:


Antoinette Jucker, Partner, Pinsent Masons

[email protected]


Susan Biddle, Pinsent Masons

[email protected]

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