The Hon. Rauff Hakeem, Attorney-at-Law

¶ 01 Hon. Presiding Member, listening to Hon. Wijesiri Basnayake, one sees a government ever ready to “take the bitter pill on the sly.” This government has often done just that.

¶ 02 During the Premadasa era, when Joe Sim came, our JVP friends shouted, “The Chinese are coming to gamble—chase them out!” In the Mahinda Rajapaksa era, when James Packer came, they cried, “The white man is coming to gamble—chase him out!” Today, the same people are quietly swallowing the pill and dressing it up with new words like “responsible gambling.” As a devout Muslim, I must first note Islam’s categorical prohibition of gambling. It is a grave sin because wealth must arise from lawful exchange of value. Gambling stirs enmity, distracts from prayer, and leads to ruin and family discord.

¶ 03 That said, being practical: regulation done right can raise standards, bring investment and jobs. Done wrong, it entrenches opacity and turns casinos into conduits for underground banking. This Bill, as drafted, tilts the wrong way. I pointed this out in the Committee on Public Finance.

¶ 04 Sri Lanka is a current‑account convertible economy under IMF Article VIII. We should not restrict current international payments and transfers, including gambling‑related services, except with IMF approval. Operator margins are service charges; player wins/losses are current transfers. Therefore, payments must be enabled through formal, supervised financial channels—not illegal ones.

¶ 05 We have binding AML/CFT obligations under FATF, with a mutual evaluation in 2025. Remaining off the grey list requires effective controls for high‑risk sectors like casinos. A cash‑centric model will fail. Clause 22 channels gambling transactions to currency or card at a main cash desk subject only to FTRA and FEA. There is: - No requirement to settle medium/large transactions through authorized dealer banks, - No ban on large foreign‑currency cash pay‑ins or cash‑outs, - No mandatory player accounts, - No statutory CTR/STR thresholds.

¶ 06 This invites hawala/undiyal: cash‑in, chips, side settlement, cash‑out—off the banking radar. The Bill is silent on junkets/VIP promoters, historically central to illicit flows. There is no licensing class, fit‑and‑proper joint liability, or ban on deposit‑taking by promoters.

¶ 07 Border rules allow bringing/taking any amount with declarations only at US$15,000 (total FX) and US$10,000 (currency notes). Declarations alone do not control downstream use. Without bank‑rail mandates inside casinos, this becomes a pretext for cash FX recycling and corruption at the cage.

¶ 08 Peers show the way: - Singapore: CTRs over SGD 10,000 cash in/out; CDD thresholds lowered to SGD 4,000; strong data‑sharing and enforcement. - UK: strict Money Laundering Regulations for casinos. - USA: CTRs under the Bank Secrecy Act. - Macau: post‑reform, junkets curtailed; joint liability; revenue sharing barred; tight credit; cap on promoters—targeting illegal deposit‑taking and underground banking.

¶ 09 We should promote gambling tourism as an IMF‑consistent current‑account service, but not as “cash in/cash out in FX notes at the front desk.” Promotion must mean frictionless bank‑channel settlement with tight AML/CFT safeguards. This Bill locks in the opposite. I table a detailed proposal to import these guardrails.

¶ 10 Even current investors express doubt. Melco Resorts’ 2024 Annual Report states: “if public opinion or policymakers adopt more restrictive views, we could face challenges in maintaining our licence or expanding operations.” They have a willing partner in office now—those who once chased Joe Sim and James Packer now welcome them—yet doubts persist.

¶ 11 Another point: sports betting must also be squarely brought under this law. Cricket is vital to us. The Morning of 18.08.2025 reports an ex‑Sri Lankan cricketer banned by the ICC for betting. Sri Lanka Cricket sometimes allows betting entities to sponsor franchise leagues like the LPL, saying the ICC has approved them—yet these are betting entities. Whether by ICC or SLC, all must be under proper monitoring and regulation.

¶ 12 Whatever said and done, I congratulate the Government for deciding to take the bitter pill. As I said, they do it on the sly, but they have now proven it again—rebranding it as “responsible gambling.”

¶ 13 Thank you.