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On August 14, MyDataJapan submitted public comments on the Ministry of Internal Affairs and Communications’ “Draft Interim Summary of Issues by the Study Group on Measures to Deter Access to Online Casinos.”

The comments make the following points:

  • The policy of properly assessing the importance of secrecy of communications and the adverse effects of blocking, and conducting verification in 4 stages (necessity and effectiveness / permissibility / basis for implementation / legal framework), is reasonable. However, the comments point out that (1) and (2) are not currently satisfied, so devoting space to (3) and (4) is premature and “overly eager.”
  • Examples of implementation in other countries do not justify implementation in Japan (the EU has stringent personal-data protection; the United States has strong freedom of expression; and in Japan, secrecy of communications is fundamental).
  • The comments note that alternatives to blocking, such as restricting credit-card payments and arresting those involved, have not yet been sufficiently exhausted.
  • Even now, online casinos can easily accept payments in Japanese yen through referral sites such as “Top 20 Popular Overseas Online Casino Sites.”
  • The comments question the effectiveness of blocking and point out that it can be easily circumvented using VPNs and smartphone privacy-protection features.
  • The comments support the draft summary’s view that the legally protected interest underlying the offense of gambling alone would have difficulty justifying an infringement of secrecy of communications.
  • Regarding the serious harm caused by gambling addiction, the comments argue that fundamental measures, such as reviewing pachinko, pachislot, and publicly operated gambling, should come first.
  • The comments criticize “outflow of national wealth” as a rationale, arguing that it amounts to saying “pay a domestic house rather than an overseas house” and cannot justify infringing secrecy of communications.
  • The comments point out that it is unnatural to sound the alarm only over online casinos while casino introduction is being planned under the Integrated Resort Promotion Act.
  • The comments warn that permitting “exceptional blocking without a rationale” risks making blocking the response to all illegal and harmful information in the future, significantly changing the Internet environment.

These are the points we made.

As usual, this was made possible by the tremendous efforts of the MyDataJapan Public Policy Committee (chaired by Ryoji Mori) and everyone else involved.

For details, please see https://mydatajapan.org/documents/public_comments/pc2025-8-14/.

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