Is time required to ensure compliance (other than reviewing the terms and conditions)?
For organizations running prize promotions that qualify under any of the exemptions in the Remote Gambling (Exempt Persons) Order 2015 (as discussed in the section regarding competitions based on chance) there is a standard condition that at least 4 weeks before any advertisement giving publicity to, or otherwise promoting or that is intended to promote, the lottery is published, certain details must be given to the Head of the Specialized Crime Policy Branch, Criminal Investigation Department, of the Singapore Police Force. These details include the name and address of the business organization providing a remote gambling service for individuals to participate in the customer lottery, the arrangements for the lottery and the prizes and manner of their allocation, together with copies of the communications given to or to be given to the customers or to the general public.
In respect of exempt prize promotions under the Common Gaming Houses (Exemption) Notifications (as discussed in the Prize draws section), the following details must be disclosed on printed publicity material:
The methodology of the promotion;
The details of the prizes to be distributed and their manner of distribution; and
If the winners are determined solely or partly by a draw, the time, date and place of the draw.
Copies of the above information must be freely available to all participants and 2 copies must be sent to the Head, Gambling Suppression Branch, Criminal Investigation Department, by AR registered post (a postal service which provides proof of receipt) at least 4 weeks prior to the launch of the promotion.
Importantly please note that applying to the MHA for a permit or exemption to carry out a prize promotion can be a time-consuming process depending on the type of permit or exemption being applied for. According to the Singapore Police Force website, the normal processing time for an application for a private lotteries permit is approximately 2 months from the receipt of the application and the necessary supporting documents. General applications for exemptions under the RGA and the CGHA may take up to approximately 1 month to process. For a certificate of exemption under the RGA (referenced above in question 8), the Ministry of Home Affairs has stated that it would generally take between 9 to 12 months to evaluate and assess such applications.
Furthermore, please allow for additional time as specific conditions may be imposed on the organization on the granting of a permit to run the prize promotion.