HKD 25m junket deposit: concessionaire not liable after Law 16/2022 (TUI 55/2022): Status, Rulings and What It Means for Players

What this case is about

TUI Processo 55/2022 is a Macau Court of Final Appeal (Tribunal de Última Instância) judgment on whether a casino concessionaire must repay money a player deposited with a junket promoter.

A depositor, named only as "A", sued the concessionaire "B" and the gaming promoter "C" in 2019. The case sits within a small group of Macau refund litigation matters.

The depositor lost HKD 25,000,000 (MOP 25,750,000) in a VIP room in 2015 and claimed it back with interest from 13 October 2015. The legal route was solidary liability of the concessionaire under art. 29 of Administrative Regulation 6/2002, as interpreted by art. 63 of Law 16/2022, the 2022 junket law.

Who is covered

The case concerns players who deposit funds with junket promoters in Macau casinos. The depositor here deposited in 2015, and the ruling applies Law 16/2022 to that deposit.

It does not cover ordinary casino play. Liability of the concessionaire depends on what happened to the money deposited with the promoter, which is set out below.

Is there a payout?

No payout exists in this case for players from the casino. The depositor won judgment of HKD 25,000,000 against the promoter only, and the claim against the concessionaire was dismissed. The record shows no class fund, no claim process and no payment by the concessionaire.

The promoter judgment dates from the first instance on 2 February 2021 and was confirmed. The record does not show whether the promoter has paid anything.

What the court decided

As of 14 November 2026 the case is decided, with status judgment. The first-instance court (TJB) ruled on 2 February 2021 (CV1-19-0003-CAO), and the appeal court (TSI) decided on 4 November 2021 (TSI 563/2021).

On 10 October 2025 the Court of Final Appeal dismissed the appeal. Judge José Maria Dias Azedo reported, sitting with Song Man Lei and Choi Mou Pan.

The court applied art. 63 of Law 16/2022 as an interpretive norm. The concessionaire is solidarily liable only where the funds or chips deposited with the promoter were used or won in casino games, and that was not proven here. Costs of 15 UC were ordered.

A second judgment applied the same rule. Proc. 125/2022, decided on 31 October 2025, covered deposits of HKD 3 million, HKD 10.5 million and HKD 2 million (HKD 15.5 million across three depositors) made in September 2015, and the appeal was dismissed.

Why it matters

The judgments mark a retreat from the 2021 to 2022 line, when art. 29 of RA 6/2002 made the concessionaire liable to third parties for its registered promoters' activity (TUI 45/2019, 19 November 2021). They also mark the end of the Suncity and Dore deposit litigation wave.

For players, the practical result is narrower recourse against the casino. Our guide on whether you can get gambling losses back compares what courts have ordered in other countries.

Questions people ask

Can a Macau casino be made to repay a junket deposit?

Only in narrow cases. Since Law 16/2022 art. 63, the concessionaire is liable only if the deposited funds or chips were used or won in casino games, as the Court of Final Appeal held on 10 October 2025.

Who has to pay the HKD 25 million?

The judgment of HKD 25,000,000 runs against the promoter only. The claim against the concessionaire was dismissed, and the record does not show payment by the promoter.

What did Law 16/2022 change?

Besides the interpretive norm in art. 63, the law banned junket revenue-sharing and capped promoters to one concessionaire, according to the court record.

Related cases

• A v Dore Entretenimento Sociedade Unipessoal Limitada and Wynn Resorts (Macau) S.A., Processo 45/2019, is the judgment of 19 November 2021 that read art. 29 RA 6/2002 as making the concessionaire solidarily liable for its registered promoters' activity.
• A v B (gaming promoter) and C (concessionaire) covers Processos 205/2020, 34/2020, 46/2020 and 185/2020 and is a decided judgment.