A junket operator in Macau earned not a share of a player's losses, but commission on their turnover — CPA logic, just written into law instead of an advertiser contract. Between 2021 and 2024, the model nearly disappeared: the two largest operators were arrested, the licensed market shrank from 235 companies to under three dozen, and the law banned revenue-share and shifted player credit to the casino itself.
A junket operator was a middleman in Macau's gaming market who earned commission on the turnover of the player he brought in. In incentive structure, this is almost identical to a CPA affiliate deal in iGaming: the middleman brings in the client, the operator pays for the volume he delivers. The difference is that in Macau, this model was regulated by law for decades, not by a contract between operator and partner. When the regulator decided that the risk of concentration in the hands of a few middlemen had become unacceptable, it effectively eliminated junkets as a category. Here's how this CPA-style model worked in the gaming industry, what broke it, and what's worth keeping in mind for anyone building CPA and RevShare programs in iGaming today.
What a junket operator was
A junket brought a high-roller — usually from Hong Kong or mainland China — into a Macau casino's VIP room and earned commission on that player's turnover, not on the casino's winnings. The player bet not with ordinary chips but with rolling chips: these couldn't be cashed out or exchanged for money, only replayed. The total value of chips sold to the player was the base for calculating the junket's commission — pure agency logic, where the middleman takes on acquisition and service while the operator pays for the volume that passed through him.
From 2009 until the 2022–2023 reform, junket commission was capped by law at 1.25% of that turnover, with the casino withholding a further 5% of the commission as tax (Macau Business). Until 2023, some casinos paid junkets not a fixed commission but a 40–50% share of their own revenue instead — almost a literal RevShare; it was this scheme that the new law later banned.
The difference in the bottom two rows explains why the model ultimately didn't survive in its original form: in an online CPA vs. RevShare setup, the operator is always responsible for a player's solvency, while in Macau the middleman carried that risk for decades. That arrangement ultimately cost the market half its participants.
Why credit to players became the model's weak point
A junket didn't just bring in players — it extended them credit using its own money: the credit was interest-free, short-term, and revolving, with the debt offset against the commission the casino owed the junket. The risk of non-repayment sat with the middleman. But when a VIP-room cashier at Dore Entertainment inside Wynn Macau stole client funds in 2015, Macau's highest court ruled in November 2021 that the casino was jointly liable alongside the junket (GGRAsia), and in May 2022 extended that principle to nine more similar cases.
For any program where a partner holds a client's balance or extends credit under its own name, this isn't an abstract risk: an agency agreement formally separates liability, but Macau's court ruled otherwise. That's worth keeping in mind for the affiliate industry generally, not just for gaming. For more on why verbal agreements and agency arrangements between an operator and a partner tend to hold up poorly in a dispute, see our piece on the economics of trust in affiliate marketing.
Why the model collapsed: one partner, a quarter of the market
On the night of November 27, 2021, Alvin Chau, founder of Suncity, was detained in Macau. Four days later, the company closed all its VIP rooms without waiting for a verdict.
Estimates of Suncity's share of the junket market vary — from a quarter to nearly half the segment, depending on methodology. But the scale itself, where one partner's exit could collapse a quarter of the industry, is a structural concentration risk regardless of the exact figure. In January 2022, Levo Chan, head of the second-largest operator, Tak Chun, was arrested for similar reasons, and the 2022 list of licensed promoters turned out to be nearly half the length of the previous year's.
What the courts established
The charges against Chau included 289 counts. On January 18, 2023, the court of first instance sentenced him to 18 years, finding him guilty on 162 of them — for fraud, illegal betting, and organizing a criminal syndicate (Hong Kong Free Press). The court of second instance increased the forfeiture amount to nearly HK$25 billion in October 2023, and the Court of Final Appeal rejected his appeal and upheld the sentence in full on July 3, 2024 (Inside Asian Gaming).
At the heart of the case was a ledger the group kept in parallel to the official one — so-called "under the table" bets, with revenue hidden from both the casino and the regulator. For the affiliate industry, there's a direct, if uncomfortable, parallel here: a discrepancy between what a partner reports and their actual turnover is exactly what eventually makes a regulator or a platform lose trust in an entire model of working with middlemen.
Levo Chan's Tak Chun case followed a similar path: the court of first instance handed down 14 years, the appellate court reduced it to 13, and on November 28, 2024, the highest court upheld that sentence (Inside Asian Gaming). This is an account of public court rulings, not legal advice, and not a judgment of any individual beyond what the court itself established.
New rules: one operator, commission under control
Since January 1, 2023, a new junket law has been in force in Macau: an operator may work with only one casino concessionaire at a time, rather than several at once as before (AGB). A revenue share with the casino is banned as a form of commission, while the fixed 1.25% ceiling remains in place. Since August 1, 2024, another change has applied: only the casino itself, not the junket, can extend credit to a player (GGRAsia).
In effect, the regulator applied the same toolkit typically used to defuse middleman concentration risk in any industry: channel exclusivity, a ceiling on the rate of reward, and shifting liability for the riskiest element of the deal — credit — onto the operator itself. A similar shift toward consolidation and tighter requirements for middlemen played out, for instance, in Curaçao's licensing regime too: there, mass sublicensing was likewise replaced with direct licensing of operators under a single regulator, though the causes and mechanics were different.
The number of licensed junkets has fallen by multiples compared with the early-2010s peak: the market went from several hundred companies to a few dozen over a little more than a decade, and the number actually operating remains well below the formal license cap year after year.
What this means for CPA and RevShare programs in iGaming
A junket wasn't literally the ancestor of an online affiliate. But a few parallels from this history are worth keeping in mind for anyone building affiliate programs today.
A gap between a partner's reporting and their actual traffic is the same vulnerable spot Chau's case rested on. Online, this also tends to surface sooner or later, and the fallout is usually broader than the loss of one account. Volume concentrated on one large partner carries the same structural risk that played out in Macau, where one person's exit nearly collapsed a quarter of the industry — only the source of the threat differs. Credit risk or access to a player's balance that a partner takes on doesn't always stay the partner's risk alone: Macau's court, in the Dore Entertainment case, extended liability to the platform itself, even though the theft was committed by the middleman's own employee. And channel exclusivity, which in online affiliate programs is usually a matter of agreement between the parties, can at some point become a regulatory requirement rather than an operator's option, as it did in Macau.
This is a business-model comparison by analogy, not compliance or legal advice: specific decisions about the structure of affiliate agreements, handling credit risk, or liability for an affiliate's actions should be checked with a lawyer against the regulations that actually apply in your jurisdiction.
Frequently asked questions
Bottom line
If your affiliate program has a top partner with a disproportionate share of traffic, access to player balances, or credit exposure to a client, it's worth checking that against exactly what broke the junket market in Macau — before a regulator or payment partner does it for you. Concrete next steps: audit key partners' reporting for discrepancies, reassess how much traffic share is safe to concentrate on a single channel, and review who actually carries the credit and reputational risk in the chain.
