What location checks could Singapore Pools add to verify users are in Singapore?

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Singapore Pools could add device location data checks, alongside its existing geofencing, to verify users are physically in Singapore.

Singapore’s Gambling Regulatory Authority requires Singapore Pools to implement measures so users can only place bets while they are in Singapore. A potential weakness involves some mobile roaming arrangements making overseas users appear to have a Singapore IP address, and a computer science professor said operators may need additional safeguards such as using device location data to confirm where users are physically located.
How the roaming loophole can affect location signals
The issue described centres on Singapore telco roaming connections, where users reportedly placed bets while travelling in places including Malaysia, Thailand, Indonesia, Japan and China. Tests during the World Cup found users in the United Kingdom and Italy could place bets when connected through Singapore mobile data roaming, even though they were overseas. The described mechanism is that some roaming traffic can be routed through Singapore, causing an overseas user to be assigned a Singapore IP address.
The specific additional location check raised publicly
Professor Chan Mun Choon of the National University of Singapore said telecommunications providers may route roaming traffic through Singapore, leading to users being assigned a Singapore IP address despite being abroad. He said operators may need additional safeguards, including using device location data to confirm the user’s actual physical location. This is the only clearly specified location-check direction discussed in the available reporting.
What Singapore Pools already uses to restrict overseas access
Singapore Pools said its online betting services are intended solely for local use and that it has geofencing measures to restrict access from overseas locations. It also stated that account holders must be Singapore residents or hold a valid Foreign Identification Number. If an account is found breaching its terms and conditions, Singapore Pools said it may freeze, suspend, terminate or close the account.
What regulators and legal experts focus on for “reasonable effectiveness”
Singapore’s regulator said any potential non-compliance would be assessed based on the relevant facts and circumstances, and that it requires Singapore Pools to ensure users can only place bets while in Singapore. Legal commentary highlighted that operators would need to show they took reasonable steps to prevent overseas betting, including location restrictions, monitoring for circumvention and taking action against breaching accounts. The core standard described was whether location measures were genuine and reasonably effective, rather than whether circumvention was technically impossible.

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What location checks could Singapore Pools add to verify users are in Singapore?

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