Inside Asian Gaming

2020 年 5月 IAG JAPAN 67 be made at the outset was that Macau needed to adopt a regulatory regime for the industry which would meet at least the minimum expectations and requirements of likely bidders for new concessions. The concession system itself was foreign to most bidders. In October 2001, the omnibus gaming law, 16/2001, was adopted, and was closely followed by Regulation 6/2002, which provided for oversight of junket operators and their licensing. The regulation did not come into force until 2004; the delay was intended to give junkets the opportunity to organize themselves to be compliant. In particular, licensing was dependent upon a junket either being a natural person, or exclusively owned by natural persons. This was intended to facilitate transparency, and to prevent the public flotation of shares in incorporated junkets. Licensing of junkets, which takes account of their “suitability” to conduct the business, is merely a threshold requirement for a junket to do business with a Macau gaming concessionaire. Once licensed, a junket must enter into a written contract with each concessionaire with which it plans to work. These contracts have evolved over time as the responsibilities imposed upon junkets under other legislation have increased, such as AML reporting and credit law. Moreover, the obligations imposed on concessionaires have also increased, particularly in complying with mandated Minimum Internal Control Requirements. By licensing a junket operator, the regulator is not warranting that the operator is fit for purpose; that is a matter for each concessionaire to determine through its own inquiries. Concessionaires have a strong interest in ensuring that their contracted junket operators comply with their legal obligations for two primary reasons. First, they may be held jointly liable with the junket operator for any wrongdoing that occurs on casino premises. Secondly, all of the gaming concessionaires are publicly traded and listed Suncity Group has emerged as Macau’s dominant VIP leader サンシティグループがマカオのVIPの最有力企業として浮上してきた コラムニスト