Minimising gambling harm and preventing crime in casinos
The NICC requires both casinos in NSW to take active measures to raise compliance standards and deal with the serious misconduct uncovered by recent inquiries.
Casino risks
Casinos pose risks that are specific to their operational environment such as gambling harm and money laundering. These risks can be complex and require sophisticated supervision. Casinos must employ stringent control measures that target these issues and address the concerns identified in the Bergin and Bell inquiries.
Gambling harm
Casinos operate 24/7 gaming and hospitality environments with an emphasis on incentivising high rollers and return patrons. In this environment, the risks of alcohol and gambling harm can be exacerbated by:
- irresponsible service of alcohol
- irresponsible conduct of gambling
- improper use of VIP incentives and rewards
- improper advertising and/or promotions.
Casinos must provide safe spaces for patrons and staff by embedding gambling harm minimisation as a central component of their operations and culture. Casinos need to conduct their business in a way that fosters and promotes responsible gambling and make sure this objective is communicated to all staff. Casinos must establish the training and systems to recognise risky or problematic gambling behaviours and take action to assist patrons experiencing gambling harm.
Money laundering
Casinos move money into and out of the casino environment, including across international borders. They provide gaming accounts to fund gaming activity, including setting up accounts where funds can be deposited, exchanging chips and cash through a cage facility, and utilising cashless card or ticket technology. Casinos have been implicated in high risk junket operations which involve bringing overseas high rollers to a casino and the facilitation of third-party transactions. Because of the risks of money laundering, junkets are now banned in NSW casinos.
Casinos must employ multi-layered know your customer programs and have strict processes in place to manage the conduct of financial transactions that could potentially breach Australian and international currency laws, for example when:
- facilitating currency transfers
- setting up front money accounts
- conducting cage exchanges.
Other risks casinos must mitigate include:
- Entry of excluded people (including casino-initiated exclusions or NSW Police exclusions of criminals).
- Entry of self-excluded people.
- Entry of minors.
- Suitability and probity of casino close associates such as casino directors, executives.
- Licensing and integrity of casino special employees.
- Business dealings with retailers and contracted casino suppliers who have criminal associations.
- Loan sharking and providers of illegal debt facilities.
- Misconduct in gaming services and game play.
- Misconduct of patrons and/or casino employees such as:
- improper destruction or theft of gaming chips
- property damage
- theft
- drug use.
Key control measures
The NICC imposes extensive control measures that are contained within internal control manuals (ICMs). The ICMs provide a comprehensive framework that seeks to limit the infiltration of criminal activity within a casino, minimise the potential for gambling harm, and maximise a casino's compliance and accountability.
The NICC is also working with casinos and stakeholders to improve electronic surveillance methods and adopt new ways to address the risks and challenges of modern casino environments.
The NICC’s ICMs impose strict controls to minimise gambling harm and ensure patrons are protected. These controls include requirements covering:
- timed play
- breaks in play
- responsible conduct of gambling officers
- training required of responsible conduct of gambling officers
- schedule for the presence of supervisors in gaming rooms
- register to record the actions taken by managers when an issue is reported
- structured systems for staff to conduct welfare checks
- identified situations where increased welfare checks and patron interactions is required
- a self-exclusion register and process for ensuring excluded players cannot gain entry to the casino.
Casinos must identify all patrons to prevent the infiltration of minors, known criminals, and excluded individuals. They must also ensure gaming patrons can verify their source of funds. Know your customer programs include layered screening processes such as identification and background checks, facial recognition technology, patron risk ratings, and other security protocols to confirm patron identity and obtain visibility of patron behaviour while they are on the casino premises.
Casinos are bound by a breach reporting protocol. When breach or a suspected breach is detected, they must report it to the NICC, as soon as reasonable. To ensure the integrity of casino licence holders, close associates and casino special employees must report changes to their financial and legal circumstances and to their contact details within 14 days.
The NICC facilitates extensive probity and assurance assessments to oversee certain people connected with a casino's ownership, management, and operation:
- casino close associates
- casino special employees
- people engaged in controlled contracts
- liquor licence holders at the casino.
Along with a stringent licensing regime, these checks ensure people who are involved with the ownership, management and operation of a casino meet the suitability requirements for their roles and are not themselves criminals or associated with known criminals.
The NICC conducts regular casino inspections and investigations and works with Liquor & Gaming NSW and NSW Police to investigate potential breaches. Where wrongdoing is found, the NICC will decide whether to take a remedial or disciplinary approach, or to refer a matter to another regulator or law enforcement agency. The NICC also conducts scheduled and adhoc inquiries and, where necessary, can amend a casino’s licence conditions, instruct casinos to comply, and utilise a range of financial penalties.
Both casinos are moving towards fully cashless gaming (by August 2024) which will provide a direct means of monitoring a patron's source of funds and limiting the opportunity for money laundering or terrorism financing. The introduction of cashless gaming will also allow patrons and the casinos to monitor gaming activity and implement intervention strategies such as setting time and spend limits. These measures are not only used by staff involved in the conduct of gaming, but are an integral part of wider staff training and the development of a culture where responsible gambling is recognised as an essential component of casino operations.