The Myanmar government legalized casinos through a gambling law passed last year. The law does not allow Myanmar citizens to visit or gamble in casinos and further guidelines on regulations are forthcoming. Some foreign investors have expressed interest in developing casinos in Myanmar, especially in border areas and tourist destinations where casinos have historically operated. The casino market potential in Myanmar is seen as high, but online gambling remains illegal. The document discusses questions around suitable locations, target clientele from neighboring countries, investment levels, and regulation of casinos being constructed along the Chinese border.

1. Myanmar - Casino business - latest update
1. The government last year passed a law legalizing casinos. Are there
any further details? Ban on locals/minimum investments/zones etc
Myanmar Gambling Law (“MGL”) came into force on 7 May 2019. We
understand that further implementing rules and guidelines in connection
with the MGL will be announced soon.
The MGL does not allow Myanmar citizens to visit and/or gamble in
casinos. The MGL is silent on aspects such as capital requirements and
other related compliances, and we understand that subsequent
notifications specifying operational guidelines will be announced soon.
2. How you seen any foreign investor interest in the country from the
casino industry?
Myanmar has a long history of horse racing and betting since colonial
era. Notwithstanding the official ban on operation of casino under the
Gambling Law 1986, we understand from information available in
public domain that some casinos operate in border areas such as
Myawaddy of Kayin State, Mong La of Shan State and Tha Htay Island
of Taninthayi Region which attract significant number of tourists.
The MGL has legalized the establishment and operation of casino
subject to specific requirements laid by the Union Government. We
have received queries and we are aware that certain foreign investors
are interested in setting-up and operation of casinos in Myanmar.
3. Where would the most interest be in terms of locations?
Historically, most of casinos are located in border areas. In our view most
of the tourist destinations in Myanmar will be suitable for casinos. We
recommend having a continuous watch on the market.
Once we are engaged, we will be pleased to assist with identification and
screening of local partners in relation to identification of suitable
sites/locations.
4. How much potential is there in the market?
We certainly do see potential in this market. Certainly the first-mover
advantage in this sector can also be considered.]
5. Who is likely to be the main clientele base for casinos in Myanmar
(Thais, Chinese VIP/mass)

2. We can expect potential clienteles from all neighboring countries. Myanmar
is a popular tourist destination and is visited by tourist from all around
the globe.
6. There does appear to be a flurry of casino construction, almost like
Sihanoukville, in the north along the Chinese border. Is there any
effort to rein that in?
The Ministry of Home Affairs may issue rules, terms and conditions as
required with the consent of the Union government in order to
implement the MGL. Nevertheless, we are not aware of any particular
restrictions imposed on foreign investors.
7. Is there any chance of legal online gambling there?
The MGL is silent on activities involving online gambling. Having said so,
we understand that the position of the Union Government appears
currently negative in relation to allowing online gambling. Please also
note that the MGL forbids the public from all forms of solicitation or
collection of stakes for gambling, gambling or being present in a
Gambling-house, run and manage unlicensed lotteries or other games
similar to lotteries and acquire financial benefits to provide aid in any
manner to carry out such activities.
8. In terms of investment levels, what kind of size of resort would be
profitable/suitable in Myanmar?
The investment level will depend upon several factors. Once engaged, we
are available to assist with preparing a market entry memorandum
capturing advice inter alia on regulatory, compliance and contractual
matters. If required, we will be pleased to collaborate with a local
financial advisor to assist with inputs from a financial feasibility
perspective.
Please do not hesitate to contact the author Dr. Oliver Massmann under
omassmann@duanemorris.com. Dr. Oliver Massmann is the General Director of Duane Morris
Vietnam LLC, Member to the Supervisory Board of PetroVietnam Insurance JSC and the only
foreign lawyer presenting in Vietnamese language to members of the NATIONAL ASSEMBLY
OF VIETNAM.