Gambling Legally (at Home, in Public or Online) in Singapore
In Singapore, gambling can occur in many forms, with the most popular and widely-known options being 4D, Toto, the Singapore Big Sweep, or visiting the two casinos located at the Integrated Resorts.
However, what many might be unaware of is that these are just some of the more obvious options for gambling. Under the laws put in place to regulate local gambling activity, gambling actually covers such types of activities and many more, and there is a fine line between legal and illegal gambling activity in Singapore.
While it can be fun to gamble every once in a while, there is always the risk that frequent gamblers may succumb to gambling addiction, or worse still, find themselves on the wrong side of the law for unwittingly participating in illegal gambling activity. Hence, this article will cover:
- What constitutes gambling in Singapore
- When is it legal to gamble in Singapore and what you should look out for when indulging in the occasional gamble
- Whether there is a minimum age requirement to gamble legally in Singapore
- When is it illegal to gamble in Singapore
- Tips on gambling legally in Singapore
What Does It Mean to “Gamble” in Singapore?
In Singapore, gambling is broadly defined to encompass three types of activities:
- Engaging in gaming activity; and
- Participating in a lottery.
The table below sets out the differences between the three areas, as well as some common examples of gambling activities and where they come under:
|Betting||The making or accepting of a bet, which involves either paying or staking of money or money’s worth 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.||
|Engaging in gaming activity||
||Playing slot machines at country clubs/casinos.|
|Participating in a lottery||Paying money or money’s worth to participate in arrangements, schemes or competitions for the distribution of prizes, which depend on an element of chance.||Buying 4D/TOTO; participating in lucky draws and raffles.|
Does buying loot boxes constitute gambling in Singapore?
One concern that bears highlighting, and which has come up with the increasing popularity of online games, is whether you, or your children, are unwittingly “gambling” by buying virtual loot boxes or mystery boxes in such games.
To participate, players often have to use real-world money to purchase in-game credits, which can be exchanged for loot boxes or mystery boxes. When the loot or mystery boxes are redeemed, players can receive a randomised selection of (typically rare, powerful and/or attractive) virtual items or “loot” (hence the name).
While buying loot boxes sounds like it could potentially come under the definition of “engaging in gaming activity” or “participating in a lottery”, this activity is not considered gambling. This is because players generally stand to win only virtual rewards that have no real-world value.
That said, some games may allow players to exchange their virtual loot box rewards for real-world payouts, such as by allowing players to transfer the virtual items out of the game and exchange them for money or money’s worth. In this case, buying such loot boxes would be considered gambling.
When is It Legal to Gamble in Singapore?
The general approach taken by the Singapore government is that gambling is prohibited unless licensed or exempted, whether it is conducted physically or online. This reflects the government’s overall stance that gambling as a whole is not encouraged, but certain forms of gambling are allowed so long as they take place in a controlled and safe environment.
Taking part in exempted gambling activities
The only exemption to the general ban against gambling is physical social gambling, i.e. social gambling that takes place in person. As the name “physical social gambling” suggests, a gambling activity must be both “physical” and “social” in nature to qualify as physical social gambling.
A gambling activity will be considered “physical” and “social” if it meets the following requirements:
- The gambling activity must be conducted in-person in an individual’s home. This excludes physical venues such as hotels, clubs, community centres, cafes and chalets.
- The participants must be members of the same family, or individuals who know each other personally, i.e. friends.
- The gambling activity must be non-commercial in nature. Therefore, it must not be conducted in the course of any business and must not be conducted for the private gain of a non-participant. For example, a person hosting the gambling activity at his/her house, but who is not participating, should not get a commission from the participants, or collect fees from the participants.
- Additionally, no participant should be able to obtain a benefit from the activity other than winning, such as receiving payment for participating in the game.
Social gambling would ordinarily cover casual gambling activities that are commonplace amongst many Singaporeans. These include having friends over to play mahjong at home, especially during the Chinese New Year festivities.
On the other hand, it is illegal to gamble in any public place in Singapore. Thus, even if members of the same family gather to gamble at a funeral held in a void deck, such an activity would technically be illegal as a void deck is a public place.
The requirement that the gambling activity must be conducted in an individual’s home also means that online social gambling is illegal. This is in part due to the nature of online gambling making it difficult to ascertain if the other conditions for legal social gambling (e.g. if the participants know each other personally, or if there is an arrangement for the host to receive a commission from the participants) are satisfied (more below).
Taking part in licensed gambling activities
As mentioned above, gambling would also be legal if it is licensed – in other words, if it is conducted by a licensed person/entity and if it is conducted at an approved gambling venue.
The table below lists some of the typical examples of what one might consider to be potential gambling activities in Singapore and whether they are legal:
|Gambling activity||Legal / Illegal (and why)||Punishment (if any)|
|Gambling in the two Singapore casinos (Marina Bay Sands and Resorts World Sentosa Integrated Resorts).||Legal. The two Singapore casino operators have been granted casino licences that authorise them to operate casinos legally in Singapore.||–|
|Placing bets with bookmakers*.||Legal, if bets are placed with legal bookmakers such as Singapore Pools and the Singapore Turf Club, since they are licensed gambling service providers.
Illegal, if bets are placed with private bookmakers or “bookies” (e.g. private bookmakers who accept horse racing bets or 4D / Toto bets) who are not licensed to provide gambling services.
|Upon conviction, the offender (i.e. a person who had placed bets with “bookies”) is liable to a maximum fine of $10,000, imprisonment for up to 6 months or both.|
*Bookmakers are people who facilitate gambling activity. They often set the odds, accept bets, place bets and pay out the winnings on behalf of their customers.
Taking part in online gambling
Online gambling – like its physical counterpart – is also illegal in Singapore, unless it is licensed or exempted. However, there are some differences between the approaches taken towards physical and online gambling.
Due to the ease of conducting illegal gambling activities online, the Singapore government pays particular attention to regulating the online gambling space. Such regulations include blocking:
- Illegal online gambling websites;
- Advertisements for these websites; as well as
- The payment services linked to illegal online gambling.
The police also have enforcement powers to curtail illegal online gambling activities happening in Singapore.
In line with this tougher stance towards online gambling, the exemptions and licensing regime also apply slightly differently. For one, the exemption for physical social gambling does not apply to online gambling. Using the same example above, if you have friends over to play mahjong at home over Chinese New Year, but are playing mahjong on your mobile devices, you are technically participating in an illegal gambling activity.
With regard to the licensing regime, Singapore Pools is the only gambling service provider licensed to offer legal online gambling services in Singapore. Hence, while placing bets with Singapore Pools online is legal, you would be falling afoul of the law if you place bets on third-party gambling websites.
Is There a Minimum Age Requirement to Gamble Legally in Singapore?
The minimum age to gamble in Singapore is 21 years old. This is except for gambling with Singapore Pools, which sets a lower minimum age of 18 years old for its products and outlets. However, there is no minimum age for participating in physical social gambling.
There are a number of offences relating to under-aged gambling, which are summarised in the table below. To clarify, “under-aged individuals” refer to individuals under 18 years old for Singapore Pools’ products and outlets, and under 21 years old for all other types of gambling activities:
|Gambling activity||Punishment (if any)|
|Offences committed by the under-aged individual him/herself|
|Gambling.||Upon conviction, the offender is liable to a maximum fine of $1,500.|
|Entering gambling areas (e.g. when an under-aged person enters a slot machine room in a country club).|
|Opening gambling accounts with Singapore Pools.|
|Offences committed by other persons in relation to the under-aged individual|
|Gambling with under-aged individuals (except in cases of physical social gambling), e.g. accepting a bet from an under-aged individual.||Upon conviction, the offender is liable to a maximum fine of $300,000, imprisonment for up to 6 years or both.|
|Inducing under-aged individuals to engage in gambling (except in cases of physical social gambling).|
|Employing individuals below 21 years old to conduct gambling.|
When is It Illegal to Gamble in Singapore?
The main forms of illegal gambling activities covered earlier were:
- Social gambling in public places;
- Online gambling, including online social gambling (other than with Singapore Pools); and
- Placing bets with unlicensed gambling service providers.
Where illegal gambling activities are carried out from a certain place or premises, this place is referred to as an “unlawful gambling place”. There are various offences associated with unlawful gambling places that you should be aware of:
|Offence||Punishment (if any)|
|As an owner or occupier of a place, you use or allow the place to be used as an unlawful gambling place.||Upon conviction, the offender is liable to a maximum fine of $500,000 and to imprisonment for up to 7 years.
A repeat offender shall be liable upon conviction to a maximum fine of $700,000 and to imprisonment for up to 10 years.
|Organising, managing, or assisting in organising or managing an unlawful gambling place.|
|Providing financing for an unlawful gambling place.|
|Being found in, or being caught entering or leaving an unlawful gambling place.||Upon conviction, the offender is liable to a maximum fine of $10,000, imprisonment for up to 6 months or both.|
Tips on Gambling Legally in Singapore
To ensure that you stay on the safe side of the law while engaging in the odd gambling activity, you should keep the following pointers in mind:
- When indulging in social gambling among family members and friends, make sure to do it only in person, and at one of the participants’ homes. It is also important to ensure that the gambling is truly social in nature, as opposed to being commercial – a good rule of thumb is that the only thing the participants should be taking away from the gambling is their winnings and nothing else.
- When participating in other forms of gambling, be sure to gamble only with licensed gambling service providers. Since it may be tricky to identify at a glance whether a gambling service provider is licensed or not, you should do your research beforehand to be sure. Alternatively, the safe bet is to stick to gambling with the commonly known “official” sources, such as the Singapore Pools and the casinos.
- If you are running an establishment where it would be possible for patrons to gamble (e.g. if you are running a space with private rooms that individuals can book and gather to do activities), you should set clear rules on what kinds of activities can and cannot be done, and conduct periodic checks where convenient. This is to ensure that you do not inadvertently get involved in any of the offences relating to unlawful gambling places.
Apart from the fine line between legal and illegal forms of gambling activity, there are a host of gambling-related offences that you should avoid committing unwittingly. If you have been charged with a gambling-related offence in Singapore, you may wish to consult a criminal defence lawyer for assistance in navigating the criminal justice process and advice on any available legal defences you may have in relation to the offence.
In the event that you wish to plead guilty to the charge, the lawyer can also advise you on any mitigating factors you can rely on, and present arguments on an appropriate sentence on your behalf, to help achieve the best possible outcome for your case.
You may get in touch with experienced criminal defence lawyers in Singapore here.
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