Brimming with Eastern Promise

It might be volatile but the Asian market is full of opportunities, says Susan O’Leary

It might be volatile but the Asian market is full of opportunities, says Susan O’Leary


Blink and you may miss it. There is no status quo when it comes to the gambling market in Asia, in particular the online sector. During 2018 and the start of 2019 we have witnessed many changes in the Asian gambling market.

While the opportunities are aplenty, so too are the ancillary volatility and associated risks. Businesses are finding it hard to plan ahead and decide if an investment in a particular market is worth it. Risk versus reward assessments are hard to predict, and with regulatory changes happening globally, Brexit and other factors, businesses are under significant pressure to diversify investment strategy.

The Asian gambling market is certainly appealing but is it worth the risk and potential damage to businesses facing many markets?


A round-up of recent developments in Asia demonstrates the region’s volatility:

  • The Chinese government has a renewed interest in activity with a direct effect rippling all over Asia, including in Macau, visa crackdowns, ATM withdrawal limits and cash card limits.
  • In the Philippines, the position alters depending on the mood of the president. At the time of writing POGO, the online arm of the Duterteendorsed gambling regulator PAGCOR, had 57 licensees. First Cagayan has retreated, with PAGCOR taking the helm for foreign facing operators and suppliers. The cap on licences and associated costs as well as the air of uncertainty is leading many of those establishing in other parts of Asia back underground.
  • In Singapore, it is unlikely the gambling licensing regime will change any time soon.
  • Japan is also moving forward slowly.
  • There is potential positive change in Cambodia, where online gambling is legal if the operator holds a retail licence, with its own nuances.
  • The Indian market is promising and there are steady rumblings towards legalisation.

One thing is certain: the position is different in many Asian countries and ever-changing. What operators and service providers need is consistency and stability, but this is unlikely to be achieved in this market any time soon. It is a vast region in which consumers have an appetite for gambling and technology. Overall, online gambling is prohibited (albeit not explicitly) or grey.

The decision to enter a new market should never be taken lightly and it is important that businesses do their homework. Asia is complex: it is a patchwork of markets, each with different rules, requirements and expectations. Businesses must understand these subtleties and ensure full compliance in each if they are to establish themselves in the region for the long term.

The size of Asia, the popularity of gambling products among consumers, and lawmakers’ interest in licensing and regulation combine to present a very attractive opportunity. Operators and suppliers must proceed with caution, though, as the market is still finding its feet when it comes to remote businesses and there are plenty of pitfalls for those looking to get in on the action.

Things can change overnight: Playtech’s profit warning and decrease in EBITDA was reportedly due to a decline in profits in Asia. If Playtech, with all its vast experience, couldn’t avoid being impacted, it is a serious warning for others.


As the Asian market environment changes so frequently, it is wise to adopt internationally recognised standards and best-practice procedures. This way, even if the position changes post-entry, the business will have been acting as appropriately as possible. This also ensures the business maintains its standards adopted in regulated parts of the world and mitigates potential sanctions from other regulators.

Operators and suppliers should educate themselves on the financial structures in place in each market and whether they meet the needs of their businesses. They should familiarise themselves with the main financial institutions and learn whether they are international, national or local. They should also understand the antimoney laundering protocols they have in place and whether they provide sufficient protection.

We also recommend that operators and suppliers assess the stability of the country’s currency, as well as the process of repatriating funds. Businesses want to be able to withdraw profits from accounts held in that region to others located elsewhere, but different countries have different rules, processes and procedures.

It is also worth researching player preferences in the market you are looking to enter. Consider the popularity of market-specific games: rummy is the game of choice in India; mahjong is popular in China, while pachinko is huge in Japan.

Punters in some countries like to wager on their mobile devices, while others prefer to go to landbased bookmakers to place their bets.


Clearly, with any new and emerging market, the key to success lies in balancing the risk/reward factor. Operators and suppliers should only take on risks they are comfortable with and must always keep in mind how entering one jurisdiction can affect their licensing status in another.

Widespread regulation is coming to Asia, then, but it will undoubtedly take time. The good news is opportunities are there for the taking – if operators and suppliers take the right approach.


The Alderney Gambling Control Commission (AGCC) is a global-facing regulator. It permits its licensees to operate under one licence anywhere it is legal to do so and is actively involved in the International Association of Gaming Regulators (IAGR), working to harmonise global standards. By working with an established regulator, businesses can properly prepare themselves for launch in Asia. 

The AGCC has long-standing relationships with regulators and stakeholders across the continent, as well as with local operators and suppliers. This means it can explain what measures are required to be compliant in each market, and what businesses can expect once live. 

The AGCC has licensed and continues to license many Asian-facing businesses and Asian operators can now obtain an AGCC license from any country via the AGCC’s new Category 1 Associate Certificate B2C – the only licence of its type in the world.

Written by
Alderney eGambling