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Introduction
The passage of the Act for Development of Specified Complex Tourist Facilities Areas (the Act), which legalises gambling to be operated by licensed private entities in certain designated locations within Japan, which was passed in 2018, has garnered strong interest domestically and internationally, as it allows licensed private entities to operate a 'complex tourist facilities area', more commonly referred to as an 'integrated resort' (IR), which by definition under the Act shall include a casino (Article 2 of the Act). As described further in Section II, although the Japanese Penal Code (Act No. 45 of 1907) generally prohibits any form of gambling, which to date has only been allowed in connection with public sports and lottery, the Act explicitly legalises gambling in a certain designated area by excluding the application of the Penal Code.2
While there is no IR established or casino licence issued at the time of writing, the process is currently underway for the establishment of the first IR and casino in Japan. Below are some of the key features that should be of interest to those who are considering entering into the Japanese casino market, and also brief guidance on which types of business would require licensing or certification, what sort of policies and agreements are necessary for the implementation of an IR and the effective date regarding the various portions of the Act.
