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Report of the Law Reform Committee on Online Gaming and Singapore

to.50 Currently, “Pok3d” operating from Cyprus is one of the few virtual worlds offering purely gambling activities. 51


Note on terminology


In the past, legislators and the judiciary have used the word “gaming” to refer to

“gambling”. While some literature may use the words “gambling” and “gaming” interchangeably, in general, this occurs when referring to offline gambling and they usually occur in older materials. In recent years, legislators in many jurisdictions have begun using the word “gambling” in statutes to make sure that there are no mistakes as to the subject matter they are referring to, and to be more accurate and precise.


With the advent of the Internet, there has been a tendency for the word “online”

to be added in front of almost any word to refer to the networked or Internet version of whatever is the subject matter. So today we have online music, online videos, online news and so on. However, the usage of “online gaming” in many jurisdictions has been confined to referring to the types of “games of skill” referred to above and not to mean online gambling. When referring to gambling on the Internet, the norm has been to use the phrase “online gambling” so that the latter is not a subset of online gaming. Hence, the two definitions refer to mutually distinct subject matters. However, Singapore laws

have not drawn such a clear distinction as yet.


Singapore Legal/Regulatory Landscape


The regulatory regime in Singapore on gambling is currently antiquated and

may not cover all the permutations and types of online gaming or online gambling activities, whether operated out of or conducted within Singapore. With the opening of the Integrated Resorts (“IRs”) and the casinos in Singapore, the government’s policy on gambling and regulatory laws has been updated to include licensing requirements and gambling controls on their operation.52 One area that the government will probably have to look at beyond the IRs will be the regulation or prohibition of online gambling

activities, but in order to do so, we need to understand the current state of affairs.


See generally, Yee Fen Lim, Cyberspace Law: Commentaries and Materials (Oxford University Press, Melbourne, 2nd Ed, 2007) at Ch 2 on “Jurisdiction”.

51 52

See http://www.pok3d.com/.

See the responses given by the Ministry of Trade and Industry (MTI) on the Singapore Integrated Resorts website at http://integratedresorts.com.sg/gov/.


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