SINGAPORE Law and Practice Contributed by: Lim Chong Kin, Drew & Napier LLC
• public order and national interest; • the treatment of theme and content; and • the evaluation of impact. Gambling, Loot Boxes, In-Game purchases Games that feature specific in-game purchases could potentially fall under the scope of the GCA. Under the GCA, “gambling” is defined as the act of betting, playing a game of chance for a prize or playing a gaming machine, and participating in a lottery. In Singapore, only social gambling, gambling with licensed operators and jackpot gambling in private clubs are allowed. Online gambling is currently prohibited in Singapore, unless licensed or exempted. Persons who offer interactive games of chance that are played for a prize and are conducted in Singapore, or can be accessed by or delivered to players physically in Singapore, may fall under Type 1 or 2 Class Licences under the Under the Gambling Control (Remote Games of Chance – Class Licence) Order 2022 (GCO) and be subject to conditions subsequent of the class licences. Class licensees who contravene any of the con - ditions subsequent may be liable for regulatory sanctions by the Gambling Regulatory Authority (GRA). Games that fall under the Type 1 Class Licence are free of charge and must not involve the use, design elements or mechanics of prohibited games specified in the First Schedule of the GCO, nor the image of gambling articles speci - fied in the Second Schedule of the GCO. Conditions subsequent of the Type 1 Class Licence include ensuring that promotional mate - rials are free of specified gambling articles, and that complimentary tokens given to players to play the game are consumable and restricted to
unique use by each individual player and cannot be transferred to any other person. Games that fall under the Type 2 Class Licence provide prizes that are not money, may be won or acquired from in-game microtransactions or by playing the game, and are designed primarily for use in the same or related interactive games. Conditions subsequent of the Type 2 Class Licence include taking all reasonably practi - cable steps to not provide any service making any prize, feature or complimentary token given by the licensee readily convertible into money or money equivalent, or anything else of value, except for use in in-game microtransactions in the same or related interactive games. Chance-based loot boxes (as long as there are no in-game monetisation facilities) are not currently regulated under the GCA as a form of gambling, as long as there are no in-game monetisation features. 9.2 Regulatory Bodies The regulatory body overseeing the classifica - tion, import, distribution and public exhibition of video games in Singapore is the IMDA. Insofar as the games feature content that involves regu - lated subject matter under the GCA, the GRA will be the regulatory body. On a non-exhaustive basis, the enforcement powers of the relevant regulatory bodies include the following. • Under Section 11(1) of the FA, the IMDA is empowered to take regulatory action against licensees for contravention of a condition of their licence or an offence under the FA (such as importing, distributing or publicly exhibit - ing video games in Singapore in the course of
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