China
Overview
In mainland China, all forms of gambling, including online casinos and offshore sites, are prohibited; exceptions are only two state lotteries (Welfare Lottery and Sports Lottery). Since March 1, 2021, a new corpus delicti has been in effect for organizing the participation of Chinese citizens in foreign gambling, which has significantly increased responsibility for "junkets," affiliates and payment intermediaries. In parallel, the authorities are campaigning against cross-border gambling, restricting travel to "black" gambling destinations and regularly reporting on the repatriation of suspects from Southeast Asian countries.
Legal framework and general logic of prohibition
Penal Code (Art. 303) and Amendment XI
The basic prohibition and responsibility for organizing/participating in gambling are enshrined in Art. 303 of the Criminal Code of the PRC. Amendment XI (Criminal Law Amendment XI, adopted in December 2020 and entered into force on March 1, 2021) added a separate composition: organization of the participation of Chinese citizens in gambling outside the country (including online and offshore schemes), with increased sanctions on a "large scale" and other aggravating circumstances.
Exceptions: State lotteries only
The only allowed verticals are China Welfare Lottery and China Sports Lottery, which are regulated separately and are not considered "gambling" in the sense of a criminal ban. There is no licensing of private casinos or online casinos on the mainland.
Geographical reservations
Macau is a separate jurisdiction (SAR) where casinos are legal; however, on the mainland (including Hainan, etc.) casinos are prohibited. Attempts to use Macau/overseas venues to engage mainland citizens fall under the "overseas gambling" line-up of Amendment XI.
Online mode and enforcement
Total online gambling ban
Online casinos, poker/slots, skin betting and any bets outside of goslotery are illegal. Judicial practice on the "disguise" of gambling (for example, for e-sports) leads to real terms for the organizers.
Priority per cross border
In 2024, the Supreme People's Court confirmed the course towards tough sentences in cases of cross-border gambling, focusing on organizers and "repeaters."
"Black lists" of tourist destinations
The Ministry of Culture and Tourism has introduced and is expanding a "blacklist" of foreign tourist destinations seen involving Chinese citizens in gambling; travel restrictions apply to such destinations.
Cooperation with foreign agencies
Mass repatriations of suspects from Cambodia, the Philippines and other countries where offshore online operations operate are periodically reported; Chinese departments publicly emphasize that any kind of online/foreign gambling is illegal for Chinese citizens.
Payments, "underground banking" and laundering
Offshore operators have historically relied on shadow acquiring networks ("running points"), cryptocurrency and underground banking to circumvent capital controls. Regulators treat such schemes as subsidiary criminal activity (facilitation) to cross-border gambling and/or laundering. International reports record the relationship between offshore gambling, shadow settlements and other crimes (fraud, trafficking).
Risks to business and affiliates
1. Criminal liability for "involvement in foreign gambling." Any activity that purposefully attracts Chinese citizens to games outside the mainland (advertising, lead generation, referral funnels, junkets, payment routing) falls under Amendment XI.
2. Content risks. Promotion of poker/casino content in China (applications, social networks) has already been blocked before; platforms remove such materials.
3. Payment risks. Assistance in transferring funds to/from offshore casinos is considered as assistance to the crime; attention to crypto and pseudo-variable schemes is increased.
4. Transcordon operations. The vector for joint raids and repatriations creates a high extraterritorial vulnerability for personnel and partners in Southeast Asia.
What remains legal: lotteries
It is possible to work on the mainland only within the framework of state lotteries (Welfare and Sports Lottery) - as a technological contractor/supplier, in strict accordance with contracts and regulations. Any private casino initiatives (including online) are not possible.
Compliance checklist (high-level)
No mainland targeting for casino/betting/poker (interface language, domains, ASO/SEO, advertising, influencer promo).
Block payment routes (MCC, aggregators, P2P schemes) related to offshore gambling; monitor cryptocurrency bridges.
UGC moderation: remove referral links, mirrors and training materials on bypassing locks.
Southeast risk management: exclude operations/personnel that can be interpreted as "involving PRC citizens"; consider "blacklists" of directions.
If you are a lottery contractor: act strictly under a contract with government agencies, store compliance logs and prepare audit trails.
Perspective
The course towards zero tolerance for gambling on the mainland looks stable: the criminal framework (Article 303 + Amendment XI), "black lists" of directions and proactive international operations form a consistently high legal risk for offshore operators, affiliates and payment intermediaries. The only predictable channel is goslotherei in narrow technological roles.
Terms
Cross-border gambling - the involvement of Chinese citizens in gambling outside the mainland (including online/offshore), a separate corpus delicti from 2021.
Blacklist of destinations - a list of foreign tourist locations seen engaging in gambling; they are subject to restrictions on outbound tourism.
Welfare/Sports Lottery - state lotteries in mainland China that do not fall under the criminal ban on gambling.