Gaming

Since 2002, our lawyers have been actively involved in representing and advising clients in the gaming industry. We have arguably the most experienced gaming law practice in Singapore and in the region, in view of our role as legal counsel to the only legalised lottery, gaming and betting operator in Singapore. We have, through our work, acquired a good practical understanding of various lottery, gaming and betting operations and products, and are able to apply that domain knowledge to the work products that we generate.

WITHIN THIS PRACTICE

Practice areas

Legal advisory work

We have advised on the legal and regulatory aspects of product conception, product development, devising of game rules, setting up of betting accounts and e-payment procedures, product launch, product distribution (including regulatory restrictions on retail outlet operations), prize claims and disputes over prize entitlements. We have also rendered legal support work such as the listing of casino operations, vetting of leases, IT contracts, distributorship and supplier contracts, intellectual property issues, online banking issues, tax issues, consultancy contracts, sponsorship contracts and dispute resolution.

We have assisted in the provision of gaming services over multiple platforms including over the internet and through mobile phones. The unique contracts and business models in this sector is familiar territory for our team, and we have crafted betting data centre agreements, mobile betting payment fulfilment contracts.

In addition, we work with foreign and offshore private gaming operators, including a UK based casino, a cruise ship casino and international gaming operators who offer online casinos, lotteries and sports betting products. We have helped companies desiring to enter the gaming industry undertake due diligence, feasibility studies, regulatory analysis, enlisting back-end and front-line operational support, dealing with contractual relationships with gaming vendors, and preparing/vetting supplier contracts.

Drafting of rules and laws

Uniquely, we have also advised on the drafting of local gaming legislation, and have helped establish the legal framework governing legalised sports betting in Singapore. For example, in 2002, we advised the state operator on the implementation of a legalised betting system for the FIFA World Cup 2002 matches. This was the first time Singapore had allowed legalised betting on foreign football matches. Following from this breakthrough, we then helped set up the legal infrastructure for betting on foreign football leagues (starting with the English Premier League and then gradually extending to the Italian, Spanish, German and all other professional football leagues around the world), and international competitions like the UEFA Championships and Copa America, and international friendly matches. This involved us drafting the exemptions under the Betting Act, advising on intellectual property issues relating to use by bookmakers of fixture lists, statistics and 3rd party commercial rights, drafting rules for participation in betting, review prize structures and claim procedures, reviewing regulatory compliance issues, advising on rollout implementation issues, and reviewing game rules for each bet type on offer.

We also helped set up the legal infrastructure relating to account betting. This involved negotiating with banks and payment service providers for facilitating betting through accounts created with the bookmaker and linked to the customer’s nominated bank accounts, drafting terms and conditions for account betting, and resolving transactional matters, including live betting and prize claim issues.

In 2008, when Singapore hosted the first Formula 1 night race, we helped set up the legal infrastructure for betting on Formula 1 races. This extended beyond the Singapore Grand Prix to all races on the F1 Circuit.

Regulatory and licensing

We have advised social clubs on jackpot machine licensing, had worked with various interested bidders in relation to the Singapore Integrated Resorts tender for the Marina Bay and Sentosa sites, and had advised on gaming and sports betting advertising regulations for various Asia Pacific jurisdictions. We had also advised a state operator on the implementation of responsible gaming policies and know-your-customer principles in compliance with anti-money laundering policies.

Gaming litigation

We advised a gambler who had lost a significant sum of money through gambling at one of the two Integrated Resorts in Singapore of his recourse against the casino for failing in its duties under the Code of Practice for Responsible Gambling. We successfully defended a state lottery operator against claims for prize monies brought by a punter on multiple scratch and win lottery cards. We also acted for a gaming operator in taking enforcement action against spoof websites and domain name squatters, and in advising on claims by a UK organization seeking license fees for the use of football fixture lists.

OTHER DEALS

Other gaming law related work we have done include the following:

Advising on the applicability of gaming laws and regulations governing offshore gaming operations
Advising an Asian horse racing club on commingling arrangements with the Singapore Turf Club
Advising on regulatory aspects of establishing an Asian football competition by a state lottery operator
Structuring legal documentation and terms of participation for on-line betting, on-line casino and on-line betting exchange services
Advising on incorporation issues and shareholder issues in international gaming ventures and related regulatory concerns
Advising an overseas horse racing club on regulatory issues relating to the broadcast of horse races in Singapore
Advising an underwriter on the listing of the Genting casino in Malaysia
Advising on a reverse takeover of a Singapore-listed company through the injection of a Macau casino business into the Singapore-listed company
Advising on gaming licence application processes in overseas jurisdictions such as Gibraltar, Vanuatu, Aldernay, Malta, Antigua/Barbuda, Kahnawake (Canada) and the Philippines
Advising on acquisitions of and joint ventures with foreign lottery and betting operations
Advising on licensing and regulatory compliance issues under the Casino Control Act
Advising online payment service providers on Singapore law requirements