Differences between Macau, Hong Kong and mainland China

Macau: licensed casinos under new, stricter model

Concessions and timing. In December 2022-January 2023, six incambents signed 10-year concessions: the validity period is from January 1, 2023 to December 31, 2032. Maximum - six concessionaires; extensions beyond term are limited.

Reform of junkets. Law No. 16/2022 "on game promoters" turned the VIP model: prohibition of revenue-share, fixed commission ~ 1.25% of rolling-chip and work of the junket with only one concessionaire; a separate law of 2024 allows lending only to concessionaires.

"Satellite Casinos." After the changes of 2022, satellite casinos should come under the direct ownership of concessionaires - in fact, they will be liquidated/absorbed by the end of 2025, which leads to market consolidation.

Enforcement and de-risking. Measures against illegal exchangers and shadow currency networks have been tightened, interaction with Beijing has intensified; in parallel, the center of China is promoting a course towards diversifying the Macau economy (more non-gaming investments under new concessions).

Bottom line for Macau. Casinos are legal, but the "rules of the game" have become much stricter: less space for VIP intermediaries, more for a transparent mass segment and non-gaming projects.

Hong Kong: State monopoly on betting and lottery

Market model. The only legal bookmaker/lottery operator is Hong Kong Jockey Club: Horse Racing and Football Betting + Mark Six Lottery. Acceptance of bets is possible at the box office, by phone and online - exclusively at HKJC. There are no private licenses for iGaming.

Practice and RG. HKJC publishes its own responsible game standards and lottery/payout rules (for example, the collection time for Mark Six winnings is 60 days).

Bottom line for Hong Kong. Any online casinos/bookmakers outside of HKJC are outlawed. The market is compact, "clean" and almost unregulated gray area within the territory.

Mainland China: Total ban on private gambling + state lotteries

Legal only: State "Welfare Lottery" and "Sports Lottery." Private casinos/bookmakers and online gambling are prohibited; exceptions - only for two special regions (Macau and Hong Kong) under the "one country, two systems" framework.

Enforcement. Campaigns against cross-border online are large-scale: in 2024, the PRC Ministry of Internal Affairs reported the destruction of> 4,500 illegal platforms and tens of thousands of cases. Hainan did not become "Asian Las Vegas": the ban on gambling and horse racing was officially confirmed.

Bottom line for the mainland. Any attempts to target players from the PRC with private casinos/online services are a high legal risk zone, including blocking, criminal cases and payment bans.

Key differences on one page

What it means for business

1. Operators/investors.

Macau: bet on "mass premium," hotel/event-non-gaming and partnerships with concessionaires; The VIP model through junkets is narrow and strictly regulated.

Hong Kong: B2C online not possible outside HKJC; B2B niches (responsible play, risk analytics, infrastructure) are possible.

Mainland: direct B2C online - "red zone"; only relevant for B2B according to local laws (data, payments, RG technologies not for gambling).

2. Marketing and payments.

In Macau - maximum transparency of sources of funds and rejection of gray currency channels; increased compliance reduces risk.

In Hong Kong - any creatives/activations are only possible within the HKJC perimeter.

In China, offshore targeting and payment rounds lead to criminal risks and confiscations.

3. Strategy 2025-2032.

Macau: live according to the logic of concessions (investments in non-gaming, VIP control, "clean" financial flows).

Hong Kong: looking at partnerships with HKJC or sports ecosystems around it (responsible betting, data analytics).

Mainland: landmark - lotteries and non-gambling services; no B2C online attempts.

Models of three jurisdictions are three different responses to the same demand. Macau retains the casino as a core, but under strict rules and with a course of diversification. Hong Kong relies on one operator and the highest control. Mainland China leaves only goslotherei and does not tolerate private gambling, especially online. Understanding these boundaries is key to a legal and sustainable strategy in the region.