In Southeast Asia, online illegal gambling and other transnational crimes have seen a surge in recent years. As quoted by the Organized Crime and Corruption Reporting Project (OCCRP) from the UN Office on Drugs and Crime (UNODC), tens of thousands of people are estimated to have been trafficked and forced to work as scammers in transnational criminal activities (Shenawy, 2025). In this regard, Southeast Asia has become a connected criminal ecosystem, where both perpetrators and victims are citizens of the region’s member states.
The cross-border nature of these crimes poses a significant threat to the region. Addressing these issues necessitates collaboration and coordination among regional states. However, the quality of coordination and collaboration within ASEAN itself remains hampered by high levels of suspicion and competition (UNICRI & TIJ, 2021). Generally, even when ASEAN member states have ratified agreements, they appear reluctant to implement them (UNICRI & TIJ, 2021).
Southeast Asian governments have responded unevenly to this challenge. While some countries completely ban gambling, others embrace it within strict regulatory frameworks, and still others tolerate it for economic investment. These conflicting norms create governance gaps, allowing transnational syndicates to flourish beneath the surface. This article aims to discuss the social realities that have emerged in Southeast Asia and how they influence the dynamics of transnational crime in the region.
Conceptual Framework
Constructivism posits that reality is collectively constructed through social interaction, and conversely, individuals are shaped by this constructed reality (Berger & Luckmann, 1966). This perspective highlights the role of state and non-state actors in criminalizing illegal gambling and international crimes as threats to a nation’s morality, social life, and stability. These efforts then lead to the formation of international agreements, such as the ASEAN Plan of Action Against Trafficking in Persons, Especially Women and Children (APA). According to constructivism, the adoption of such agreements depends on one crucial factor: how states and their prevailing norms can accept a consensus regarding these issues.
A Crisis Fueled by Desperation—and Loopholes
Online illegal gambling is one of the serious security threats gaining traction in Southeast Asian society. According to Indonesia’s Minister of Communication and Information, Budie Arie Setia, the number of online gambling players in Indonesia alone has reached 4 million people (Ramalan, 2024). Typically, the negative impacts of online gambling are viewed through the adverse effects experienced by the players and/or their families, both physically and materially. However, in a broader context, online gambling can serve as a gateway to human trafficking activities.
The Director-General of Immigration (2024), Silmy Karim, stated that between 2020 and 2023, Indonesian representatives in Southeast Asia handled 2,434 cases of online fraud. The fraud schemes varied, ranging from fake investments, money laundering, love scams, and fake job offers, such as online gambling administrators. Based on accounts from victims who managed to escape, they were initially lured by promising jobs, then sold and forced to work as online gambling administrators, sex workers, and scammers. Furthermore, they were highly vulnerable to other crimes, such as organ trafficking and human trafficking.
Liberal state policies, low living costs, and generally low tax rates have led several countries, such as Cambodia and the Philippines, to become operational bases for these criminal syndicates (De Leon, 2024). In this context, investors, primarily from China, see significant profit potential from Philippine Offshore Gaming Operators (POGO) and the Sihanoukville area in Cambodia. So, why do people fall into such scams, and why are Southeast Asian countries divided into victim-origin and victim-destination countries?
In this case, economic motives, such as limited job opportunities, are not the sole reason. Instead, poverty and poor government governance are driving factors for individuals to seek opportunities to work abroad. Take Indonesia, for example. The labor issues in Indonesia, as summarized by the Center of Economic and Law Studies (Celios), include: 1) real wage formulations in the Job Creation Law that are too low; 2) age discrimination as a requirement for job applications; 3) massive layoffs (PHK) and the replacement of permanent employees with interns or outsourced workers; 4) unfulfilled severance pay and outstanding wages; 5) increasingly limited formal job opportunities; 6) additional layoff risks due to trade wars; 7) high youth unemployment; and 8) increasingly fierce labor competition. This summary illustrates how Indonesian society is not merely facing competition among individuals, but also a structure that does not allow all members of society to have equal opportunities.
In this regard, the government, as an agent, plays a significant role in shaping a suffocating social reality for its citizens, both through the creation of regulations that cause these problems and through their neglect. This contrasts with developed countries, which generally have more structured and strict labor policies. Assuming that developed countries possess more advanced economic policies and capabilities, coupled with testimonies from other migrant workers, a public perception emerges that they will earn higher wages by working abroad.
Three Normative Paths: Gambling in ASEAN
Within the ASEAN context, this article categorizes member states into three groups: those that completely prohibit gambling, those that legalize gambling with strict regulations, and those that legalize gambling with relatively lenient regulations.
Total Prohibition: Indonesia and Brunei
In Indonesia, all forms of gambling are regulated by the Criminal Code (KUHP) and the ITE Law. While Article 303 paragraph (3) of the KUHP defines gambling, it does not explicitly define online gambling. Meanwhile, under the ITE Law, gambling is considered a criminal offense, punishable by a maximum of 6 years imprisonment and/or a fine of up to IDR 1,000,000,000.00 (one billion rupiah) (Aidah & Pratama, 2023). However, before Law No. 7 of 1974 on the Regulation of Gambling was issued, Indonesia had legalized certain forms of gambling, such as the Lotre Dana Harapan and Lotre Pekan Olahraga dan Ketangkasan (Porkas). These policies were issued to fund state needs. Throughout their existence, these legalized gambling practices drew numerous complaints, especially from the Muslim community in Indonesia. In accordance with Indonesia’s state ideology, Pancasila, Indonesia believes in the existence of the One Supreme God. Therefore, the reason Indonesia now prohibits gambling is because it is seen as an act that violates religious and moral norms, and damages Pancasila’s moral foundation. For similar reasons, namely the implementation of Sharia law, gambling is also fully prohibited in Brunei Darussalam, regulated by the Common Gaming Houses Act (Chapter 28) (Trisista, 2024).
Strict Regulation: Singapore
In the second category, Singapore represents a country that legalizes gambling with strict regulations. Similar to Indonesia, gambling has fundamentally been a long-standing practice in Singaporean society. Over time, gambling in Singapore has evolved from merely lottery games to world-class casinos (Agoncillo, 2024). Although the presence of gambling has also sparked debate, similar to Indonesia, the Singaporean government has chosen to continue and develop gambling practices in Singapore by focusing on protecting civil society from the negative impacts of gambling itself. Marina Bay Sands and Resorts World Sentosa embody the balance of the gambling industry in Singapore. In this context, the societal norms rejecting gambling are not entirely disregarded by Singapore. With a series of strict requirements, as outlined in the Betting Act (1960) and the Remote Gambling Act (2014), Singapore has formulated policies that do not completely prohibit gambling but also consider the protection of its civil society and state from its dangers.
Lenient Zones: The Golden Triangle Special Economic Zone (GTSEZ), Laos
Although gambling is dangerous, especially for vulnerable populations (read: the poor), many ASEAN member states, in reality, serve as operational bases for transnational criminal syndicates. As mentioned earlier, the Philippines and Cambodia are part of Southeast Asia’s largest illegal gambling operational bases. However, on a broader scale, the Golden Triangle Special Economic Zone (GTSEZ) in Bokeo, Laos, has become an operational base for various transnational crimes (Kennedy & Southern, 2022). In developing the GTSEZ, the Laotian government collaborated with Zhao Wei, a Chinese casino boss who has invested over a billion dollars in the zone (Kennedy & Southern, 2022). Through this investment, Zhao Wei, along with his syndicate, the King Romans Group, took control of the GTSEZ. As a result of this cooperation, the Laotian government cannot enforce its own laws and must abide by the laws established by the King Romans Group.
Laos is a landlocked country, which hinders its potential for international trade due to its limited integration with regional and international trade systems (Intracen, 2011). Consequently, Laos adopted a market-based economic system. This article argues that to boost its economic power, Laos leveraged the market demand for the gambling industry, the GTSEZ, and the opportunities presented by the King Romans Group. In this regard, Laos is operating with a “land-linked” vision.
ASEAN’s Institutional Deadlock
ASEAN is an organization that operates based on consensus and state preferences to maintain national sovereignty and the principle of non-interference (Sundram, 2024). This long-held norm by ASEAN has been challenged by various issues within the bloc, including illegal gambling and transnational crime. In the case of human trafficking, research by Renshaw (2016) shows that international agreements formed by Southeast Asian countries to address transnational crimes, such as human trafficking, lack strong legitimacy. In a situation where ASEAN countries are divided into criminal operational bases and victim-contributing countries, the interests of each nation diverge.
This is where constructivist insights become crucial: ASEAN’s paralysis isn’t just about capacity, but also about conflicting social constructions of threat and morality. In countries like Indonesia, gambling is seen as a religious and moral transgression. In Singapore, it’s viewed as a manageable risk. In Laos, it’s a source of national income. Without shared norms, collective action remains elusive.
Furthermore, international legal instruments, such as the Trafficking in Persons Protocol and the Trafficking Victims Protection Act (TVPA), which are generally based on Western assumptions, do not align with the social realities of transnational criminal practices in Southeast Asia. For instance, coercion is a primary indicator of human trafficking. However, in Southeast Asia, many victims choose to migrate under false pretenses, driven by poverty and disinformation, rather than overt physical coercion. This reality is rarely acknowledged in policy frameworks and further complicates regional responses.
Toward Normative Convergence?
As quoted through Renshaw (2016), both the Trafficking in Persons Protocol and the Trafficking Victims Protection Act (TVPA) consider coercion as the distinguishing factor between human trafficking and migration practices. In this regard, these policies assume that victims are coerced and have no choice in their movement from their country of origin to their destination. This formulation does not align with the social reality where most victims of human trafficking are victims of fake job scams who consciously choose to go to the destination country. In this case, the victims are actually the victims of poverty and their country’s structural problems.
Moreover, the differing visions held by each country lead to varied responses to the dynamics of illegal gambling and transnational crime in the region. Therefore, what is currently lacking in the ASEAN region is not just regulatory alignment, but also a shared normative understanding of what constitutes a threat.
There are no easy solutions. However, acknowledging the social and normative fragmentation at the heart of this crisis is the first step. Regional coordination cannot rely solely on consensus—it must confront the realities of structural inequality, moral pluralism, and economic desperation. Until ASEAN finds a way to resolve its internal contradictions, transnational crime will remain one step ahead.
