Exclusion is a regulator’s order. Enforcing it is your floor.
The interdiction is the DICJ’s to grant; keeping the barred person out, catching the breach, and handling the chips on the spot is the monitoring room’s. Two different acts, two different legal effects.
The distinction the whole duty turns on
Macau is frequently described as letting a family member exclude a relative. Read against the gazette, that is not what Article 6 says: a family application must be confirmed by the person to be excluded. And exclusion is a DICJ decision, not a property ban. A patron asking to be excluded at the cage is asking for something the operator cannot itself grant — the operator applies its own ban and facilitates the statutory application. Conflating the two is the most common procedural error.
1 ·What the law provides
The DICJ Director may prohibit entry to all casinos, or only some, for up to two years, to persons who request it or who confirm an application made by a spouse, ascendant, descendant or second-degree collateral relative.
| Point | Provision | Article |
|---|---|---|
| Who administers it | The DICJ Director — a regulator interdiction, not a property-level ban | Art. 6(1) |
| Maximum duration | Two years; all casinos or only some, as applied for | Art. 6(1) |
| Third-party route | A family application has NO effect unless the person concerned confirms it | Art. 6(1) |
| Early revocation | The subject may request it at any time — but it takes effect only 30 DAYS AFTER the request | Art. 6(2) |
| Renewal | Allowed after expiry or revocation, on a new request presented or confirmed by the subject | Art. 6(4) |
2 ·Where the risk sits
The failure is almost never the order; it is the enforcement gap behind it. An interdiction the property holds but does not actually screen against is worse than none — it is a documented duty with no control behind it. Singapore's Auditor-General found 120 excluded persons entering the two casinos a combined 1,100 times while under orders; the lesson travels. A list is only as strong as the entry control that reads it, and a control is only provable if the checks are logged.
3 ·The surveillance part
This is the most purely surveillance of the RG duties. The department owns the screen at the door, the match on the floor, and the evidence trail for both. Three things have to be true on every shift: the exclusion list in use is the current one; the means of matching against it (facial recognition, ID checks, host recognition) is running and its checks are logged; and the responsible officer who must sign a chip seizure is identified and reachable. That last one is quietly operational — a legal step stalls at 3am if nobody knows who signs.
4 ·When an excluded person plays anyway
Three consequences attach, and they are routinely conflated.
Winnings revert to the Region — net of losses
Prizes and other gaming benefits won by an interdicted person revert to the Macao SAR after deduction of the respective losses, as do the concessionaire's revenues from that play, on the same net basis. The 2018 amendment introduced the net-of-losses wording; the earlier “amounts bet” reading no longer applies.
Chips can be seized on the spot
A DICJ inspector may make a cautious seizure of chips or gaming benefits held. The seizure record must be signed by the inspector, by the casino's responsible officer and by the interdicted person; the items are held in the casino's main treasury and returned once the decision is final — unless declared reverted to the SAR.
Any referral for help needs consent
Where there are grounded indications of gambling addiction disorder, the DICJ may share personal data with the IAS and request intervention — only with the person's consent (Art. 16-B). Consent precedes the data movement; see Data protection in RG.
5 ·Cadence & timing
| When | What |
|---|---|
| Continuous | Screen entry and floor against the current interdiction list; log the checks. |
| Per shift | Confirm the list is up to date and the responsible officer for seizures is on call. |
| Per incident | On a breach: contain, seize with the record signed by all three parties, hold in treasury. |
| On revocation | Diarise the 30-day delay — the person is not clear to enter until it elapses. |
6 ·The correct pathway
- Load the current DICJ interdiction list into the screening system; verify it is the live version each shift.
- Match at entry and on the floor; log every check so the control is provable, hit or no hit.
- On a match, contain discreetly and confirm identity before acting.
- If play has occurred, effect the Art. 11-A seizure — record signed by the inspector, the responsible officer and the subject; hold chips in the main treasury.
- Apply the reversion (net of losses) through the proper channel; do not settle winnings to the patron.
- On a revocation notice, hold enforcement until the 30-day delay elapses, then update the list.
7 ·Sources
- 1.Exclusion on request — duration, family route, confirmation — Law 10/2012 Art. 6(1), as republished by Law 17/2018, BO 52/2018, 27 Dec 2018Max 2 years · all or some casinos · spouse, ascendant, descendant or 2nd-degree collateral · the subject must request or confirm
- 2.Revocation, notification and renewal — Law 10/2012 Art. 6(2)–(4), BO 52/2018Revocation effective 30 days after the request · applicant notified · renewal on a new request presented or confirmed by the subject
- 3.Reversion of prizes and concessionaire revenues — Law 10/2012 Art. 11(1), BO 52/2018Both revert to the Macao SAR after deduction of the respective losses
- 4.Cautious seizure of chips — Law 10/2012 Art. 11-A, BO 52/2018Seizure record signed by the inspector, the casino's responsible officer and the interdicted person · chips held in the casino's main treasury
- 5.IAS intervention requires the person’s consent — Law 10/2012 Art. 16-B, BO 52/2018
- 6.Singapore enforcement-gap benchmark — Auditor-General's Office FY2025/26 report, as reported 15–16 Jul 2026120 excluded persons entered a combined 1,100 times while under orders
Legal provisions are VERIFIED against the Boletim Oficial. Risk framing, the surveillance responsibilities, the cadence and the pathway are Surveillance Intelligence Asia's own analysis, graded separately from the cited record.