Macau’s casino industry is a cornerstone of its tourism and economic model, and gaming credit plays a pivotal role within that system. Since most gaming patrons come from Mainland China, where strict capital controls apply, the growing reliance on credit for high-value players, combined with cross-border enforcement risks, makes the design and supervision of gaming credit a central legal, regulatory and operational issue.

The regulatory framework for the granting and collection of credit in the casino gaming industry has undergone significant reform with the introduction of Law No. 7/2024 (“Legal Regime for the Granting of Credit for Games of Chance in Casinos”), which entered into force on August 1 2024. This statute replaces Law No. 5/2004 and evidences the Macau Government’s policy of centralizing credit operations in casino concessionaires, while substantially curtailing the role of junket operators.

A move from independent lending

Under Law No. 5/2004, licensed junket operators (officially “gaming promoters”) were authorized to extend credit to patrons in their own name, provided an authorization contract had been executed with a casino concessionaire. In practice, this regime allowed junkets to operate as independent lenders, bearing the credit risk and undertaking responsibility for debt collection. The enforceability of such gaming debts is expressly recognized under Macau law, as Article 1171 of the Macau Civil Code classifies debts arising from compliant gaming credit agreements as civil obligations.

Law No. 7/2024 abolishes this model and reserves the exclusive right to grant gaming credit to casino concessionaires. Junkets are now confined to acting as agents or representatives of concessionaires and can no longer function as autonomous lenders. Pursuant to Article 3, the credit relationship is only between the concessionaire, as lender and the patron, as borrower. In line with Article 16 of Law No. 16/2022, junkets may receive commissions solely for introducing high-roller clients. Representation agreements between concessionaires and junkets are subject to prior approval by the Secretary for Economy and Finance (Article 7.4, Law No. 7/2024). Concessionaires must implement robust credit risk management systems, maintain detailed transactional records and create mechanisms for handling customer complaints (Article 8, Law No. 7/2024).

Cross-border challenges

Because many high-value patrons do not hold substantial assets in Macau, the practical challenge lies less in obtaining a favorable judgment than in securing its recognition and enforcement in jurisdictions where those patrons’ assets are located. Some neighboring jurisdictions have traditionally upheld the enforceability of gaming debts arising from compliant credit arrangements. In Wynn Resorts (Macau) S.A. v Poh Yang Hong, the High Court of Malaysia recognized a Macau judgment requiring a patron to repay HK$33m (US$4.2m) in gaming debt. However, the Federal Court’s 2025 decision in Dato’ Ting Ching Lee v NagaCorp Ltd marked a decisive shift, holding that gambling-related credit facilities are unenforceable because they contravene Malaysian public policy. The court dismissed a claim to recover US$1.5m in casino debt, characterizing such arrangements as “composite gambling contracts” inseparable from wagering itself. This precedent may significantly impede the direct recovery of gaming credit in Malaysia, even where the underlying obligations are valid and enforceable under Macau law.

The contrast between Macau’s permissive approach to the enforceability of gaming credit and Malaysia’s restrictive stance underscores the importance of conflict-of-law considerations for cross-border debt recovery. While Macau law treats gaming credit as a legitimate civil obligation when extended under a compliant regime, foreign courts may refuse recognition or enforcement on public policy grounds. For concessionaires and their agents, this divergence necessitates careful structuring of credit arrangements and strategic selection of jurisdictions for enforcement. It also heightens the importance of due diligence on patrons’ connections to jurisdictions that adopt a restrictive view of gambling debts.

Within Macau, the shift from junket-driven credit to concessionaire-controlled lending has several implications. First, it consolidates financial and regulatory risk within entities that are already subject to close supervision by the Gaming Inspection and Coordination Bureau and other authorities. Second, it diminishes the opacity historically associated with junket operations, particularly in relation to informal credit practices and offshore collection. 

Third, by tying credit more closely to licensed concessionaires, the regime is likely to strengthen anti-money laundering and responsible gambling controls, given the enhanced obligations on risk management, record-keeping and complaints handling.

A decisive long-term step

For junket operators, the new framework fundamentally alters their business model. Their role is now limited to client introduction and ancillary services, with revenue derived from commissions or fees rather than interest margins on credit. This has reduced the attractiveness of the junket business and accelerated the ongoing consolidation of the VIP sector. At the same time, it has encouraged the development of more transparent partnership models between concessionaires and high-end travel or entertainment service providers.

In sum, Law No. 7/2024 represents a decisive step in Macau’s long-term strategy to place the extension and enforcement of gaming credit squarely under the purview of casino concessionaires. By excluding junkets from the role of independent lenders and strengthening oversight of credit practices, the new regime seeks to enhance regulatory control, mitigate financial and reputational risk, and align Macau’s casinos with evolving international expectations on compliance and public policy. At the same time, divergent approaches in neighboring jurisdictions, exemplified in Malaysia, highlight the continuing challenges of cross-border enforcement and the need for sophisticated, jurisdiction-sensitive credit strategies.