Following what has been a fascinating period for the Asian gambling market, we spoke to Lau Kok Keng, Head of Intellectual Property, Sports & Gaming, Rajah & Tan Singapore, who provided insights into a myriad of key narratives from the continent – including the downfall of the Thai bill.
In a two-part series, he also revealed the market to keep a key eye on when it comes to opportunity as the region continues on a path of transformation.
iGaming Expert: Can you tell us what you have made of the pausing of the Thai Entertainment Complexes Bill for integrated resorts in Thailand, and what can other emerging markets learn from this?
Lau Kok Keng: The pausing of the Thai Entertainment Complexes Bill is a textbook example of how political instability, public opposition, and insufficient groundwork can derail even the best intentioned and positioned legislative efforts.
Despite Thailand’s clear economic motivations – such as boosting tourism, creating jobs, and stemming the outflow of revenue from illegal gambling – the process was hampered by a lack of public consensus, vocal resistance from religious and civic groups and opposition politicians, and doubts about the government’s ability to implement robust regulatory and social safeguards. The government’s own admission that more time was needed for public education and consensus-building underscores the importance of a properly planned, phased and consultative approach to transformative legislation.
Thailand’s experience is a cautionary tale from which emerging markets can learn several key lessons:
- Public Engagement is Essential: Early, transparent and sustained widespread public consultation is critical to building legitimacy and addressing public concerns. It would also counter attempts by opposition political parties seeking to capitalize on public anxiety about the social and moral risks of casino legalization, to frame the government’s push for entertainment complexes as a reckless disregard for the democratic process and public opinion, and as an indication of the ruling party’s inability to govern effectively on divisive issues.
- Regulatory Clarity and Credibility: A detailed, credible, and stable regulatory framework must be in place before moving forward.
- Political Stability: Contentious reforms require a stable government with a clear mandate. The opposition politicians must place the country’s interests above their own and support reforms which benefit the country.
- Social Safeguards: Demonstrating a credible plan to manage social risks (problem gambling, crime, money laundering) is non-negotiable. It should be at the forefront of any move to introduce legalized casinos.
- Commitment to Executing a Long-Term Vision: Policymakers must show investors and the public that they are committed to executing their policies and fulfilling their commitments to implementing a strong responsible gambling framework, and that such policies will not be subject to sudden reversals or political interference, let alone disruptions arising from military coups.
iGX: How challenging is it for new markets to convert grey to regulated as they develop their framework?
LKK: Converting a grey (i.e. unregulated or semi-legal) market to a fully regulated one is fraught with challenges. The most significant hurdles include:
- Entrenched Illegal Operators: Illegal gambling is often deeply rooted, with established criminal networks and significant vested financial (and even political) interests. Legalisation does not automatically displace these operators unless accompanied by strong enforcement and incentives for players to migrate to legal channels.
- Regulatory Capacity: New markets often lack the institutional experience and resources to design, implement and enforce a robust regulatory regime, especially in areas like anti-money laundering, responsible gambling, and consumer protection. The political will to do so may also be lacking, which is by far the bigger problem. If this problem can be overcome, then new markets can always learn and seek a helping hand on a Government-to-Government level from established jurisdictions, but they must be willing to adapt policies as their markets mature.
- Public Perception: There is often widespread scepticism about the government’s ability to control social harms, and a lack of trust in new regulatory bodies. There is a need to break out of this mindset, but this is often easier said than done.
- Transition Costs: Moving from grey to regulated requires significant investment in technology, compliance and training, both for operators and regulators.
- Political and Social Resistance: Legalisation efforts can be derailed by political instability, religious opposition, or public anxiety about social costs. Just look at Thailand.
iGX: Which Asian market do you believe will be the next to emerge as a hub for iGaming, given the potential of the region?
LKK: The Philippines has long been a regional leader in iGaming, but its future is now clouded by political uncertainty. Thailand, while showing potential, is still some way off due to legislative delays and public opposition. Vietnam and Cambodia have active land-based gaming sectors but face regulatory and reputational challenges for iGaming, not to mention political pressure from certain bigger countries eager to protect their citizens from the ills of online gambling.
The market with the most potential to emerge as the next iGaming hub is likely to be Vietnam or, if reforms progress, Thailand. Vietnam has shown a willingness to experiment with regulated online betting and has a growing tech-savvy gaming population. The sky’s the limit for Thailand if it can overcome its current political situation and put in place the right legislative and regulatory environment. It has the market scale, tourism appeal, infrastructure and digital penetration to become a major player in the iGaming market.
Outside of ASEAN, the UAE is also a market to watch, given its recent moves towards legalisation and its ambition to become a global tourism and entertainment hub, but it is still in the very early stages. Its legal system (a combination of civil and Shariah laws), religious and cultural environment, lack of political will to promote gambling, and economic model which is not dependent on gambling as a source of revenue are all factors which work against the UAE in this regard.
iGX: What have you made of President Marcos’ recent statements in the Philippines on the potential shutting down of the online gambling industry and how optimistic are you for the future of iGaming in the Philippines?
President Marcos’ statements about potentially shutting down the online gambling industry in the Philippines reflect growing concerns about crime, money laundering, and social harm associated with the sector. Like Cambodia, the Philippines government has faced international pressure (particularly from certain large countries) and domestic criticism over the negative repercussions of having POGOs, including human trafficking and scams.
While POGOs have contributed to the economy, their association with criminal activity became a political liability. The future of iGaming in the Philippines is therefore uncertain. If the government opts for a blanket ban, it could drive the industry underground or offshore, losing both tax revenue and regulatory control.
That itself is a safeguard against an outright and complete ban. Instead, a better solution would be for the government to tighten regulations, improve enforcement, and focus on attracting reputable and well-regulated operators. Just look at how Singapore has regulated its gambling industry – land and online.
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