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Report of the Law Reform Committee on Online Gaming and Singapore

control and supervise because of the sheer number of machines to check and the ease in which the odds can be changed with just a small change in one line of the programming code. It is for this reason that many do not consider them as lotteries and would class them as casino-style games.


Legal position


In many jurisdictions, lotteries are made expressly legal by statutes and

regulations although the usual prohibitions on minors purchasing lotteries apply. For example, in the US,6 42 of the 50 states and the District of Columbia allow lotteries.7 In some states, archaic laws make it a crime to possess an out-of-state lottery ticket although these laws are rarely enforced.8 Some countries and states like New York have laws that declare cross-border lotteries illegal. So when an out-of-state Internet lottery operator accepts lottery purchases from customers from a state with prohibitions against selling lottery tickets, it would likely be violating the local law. 9


In some jurisdictions, regulations specifically allow offline lottery tickets to be

sold online such as the BoysTown lotteries in Australia,10

while in other jurisdictions

such as California, charities are expressly prohibited from selling raffle tickets online.


Some online lottery operations specifically limit their sales to local residents

w h e r e a s o t h e r s d e l i b e r a t e l y c a s t t h e n e t w i d e r . F o r e x a m p l e , t h e L o t t e r y o f F i n l a n d , attempts to restrict its players to locals by requiring players to have a Veikkaus Oy,11

Finnish bank account and the website is entirely in Finnish with the exception of one page entitled “Finnish lottery for Finns” which explains the background and rationale

for the gambling setup in Finland.



At the other end of the spectrum, the website http://www.interlotto.com/ allows

players to play the major official national and state lotteries from around the world. A player can choose from the Australian Lotto, to the USA Powerball, to the Japan Jumbo Draw. If there are specific limitations to any of these, there will be disclaimers


See generally, Yee Fen Lim, “Internet Gambling – the US Perspective” (1998) 1 No 8 Internet Law Bulletin 114.


Ie Arizona, California, Colorado, Connecticut, Delaware, Florida, Georgia, Idaho, Illinois, Indiana, Iowa, Kansas, Kentucky, Louisiana, Maine, Maryland, Massachusetts, Michigan, Minnesota, Missouri, Montana, Nebraska, New Hampshire, New Jersey, New Mexico, New York, North Carolina, North Dakota, Ohio, Oklahoma, Oregon, Pennsylvania, Rhode Island, South Carolina, South Dakota, Tennessee, Texas, Vermont, Virginia, Washington, West Virginia, Wisconsin, District of Columbia, Virgin Islands, Commonwealth of the Northern Mariana Islands, and Puerto Rico.

8 9 10 11 12

See, eg, RI GEN LAWS § 11-19-4 (2003); NJ STAT ANN § 2C:37-6 (2003). See Yee Fen Lim, “Internet Gambling – the US Perspective” (1998) 1 No 8 Internet Law Bulletin 114. See https://www.boystown.com.au/cgi-bin/db2www/94D5C789/BT0005.ndm/Login?Environment=. See http://www.veikkaus.fi. See https://www.veikkaus.fi/info/yritys/english.html.


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