Gaming Law 2025

MACAU SAR, CHINA Law and Practice Contributed by: Pedro Cortés, Lektou

Suitability assessments are conducted by the DICJ through standardised disclosure forms modelled on international practice. The review covers integrity, financial capacity, and professional qualifications, and authorisations remain subject to continuing compli- ance throughout the concession or authorisation term. The concessionaires or promoters bear the costs of verification for directors and key employees in accord- ance with their concession contracts or DICJ sched- ules, while collaborators pay an issuance or renewal fee of MOP1,500. Although no personal sanctions are provided in law, an adverse suitability finding may result in the suspen- sion or revocation of the related concessionaire’s or promoter’s approval, ensuring accountability through indirect regulatory consequence. The 2022 reform in Macau introduced updates to the definition and regulation of casino gaming premises, summarised as follows. Authorised Locations Only Gaming is now exclusively permitted in venues authorised by the Chief Executive. Approval takes into account Macau’s urban planning standards and social impact, with insights from the Specialised Gam- ing Commission to ensure community alignment. Property Ownership Requirements Casinos, together with the associated gaming equip- ment and assets, reverted to Macau SAR on 31 December 2022 – at the end of the previous conces- sions – and were placed at the disposal of the conces- sionaires as of 1 January 2023 under their new con- cession contracts, in return for the payment of rent. Pursuant to Law 16/2022 (Gaming Law), all casino gaming must be conducted in properties (hotels and resorts) owned by the concessionaires, with limited exceptions allowing temporary gaming on Macau- registered vessels or aircraft operating on designated routes outside the region. 5. Land-Based Gambling 5.1 Premises Licensing

A grace period ending on 31 December 2025 was granted for the adjustment of satellite casinos oper- ating in premises not owned by concessionaires, to ensure compliance with the new ownership and use requirements applicable to gaming areas. See 1.1 Current Outlook and Recent Changes . Regulated Casino Zones Every gaming establishment must include specific functional zones, which include designated areas for gaming, cashier and treasury operations, surveillance, storage for chips and cash, and restricted logistical spaces for employees. Modification and Closure Approvals All structural changes or closures of casino premises require prior approval from the Chief Executive. Upon concession expiry or termination, casino facilities and equipment – that are not already property of Macau SAR – may revert to government control, reinforcing regulatory oversight. Enhanced Security and Compliance Measures Casinos are required to implement rigorous sur- veillance and monitoring systems as mandated by Macau’s regulatory bodies. 6. Online Gambling 6.1 B2C Licences B2C licences are not applicable in Macau. 6.2 B2B Licences (Suppliers, Software, Etc) B2B licences are not applicable in Macau. 6.3 Affiliates The use of affiliates does not apply in Macau. 6.4 White Labels In Macau, white labels do not apply. 6.5 Technical Measures Technical measures are not applicable in this jurisdic- tion.

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