Inside Asian Gaming

December 2010 | INSIDE ASIAN GAMING 19 S ingapore set the bar very high in terms of probity standards for casino junket agents wishing to operate from the city-state’s casinos. With such tough rules, how easy will it be for the Lion City to authorise junkets, even if there’s a political will among lawmakers to do so? Singapore’s Casino Regulatory Authority (CRA) confirmed recently that an unspecified number of junket agents had applied to operate out of Resorts World Sentosa, Genting Singapore’s integrated resort. Analysts suggest as many as 20 agents initially applied. According to reports in the Singapore media, at least half of them— following a lengthy background check of about nine months—have moved on to the interview stage, which could take several more months. That leaves the possibility of some junket applicants being licensed before the end of the first quarter 2011. The 29 pages of probity requirements for junkets as set out in the Casino Control (Junkets) Regulations 2009 and the supporting application forms include a requirement for applicants to list all assets, foreign and domestic bank accounts and business activities for the 15 years prior to their application. In Macau, there’s a widely held view that it’s quite easy to get a junket licence. There, the licences are issuedon a roombasis, rather than on a junket-by-junket basis. Industry sources say the individual named on the room licence (as required under local rules) is rarely the ‘controlling mind’—to use a phrase from English commercial law—of the business. The real boss or bosses are other parties usually from the junket investor or consolidator that feeds that particular room and others with players. Could a parallel system evolve in Singapore, i.e. where the entity and persons holding the junket licence are passed as fit, but the ‘controlling mind’ remains elsewhere? It would potentially be very hard to prove or disprove outside influence, just as it is very hard to prove or disprove the claims that there are proxy junkets already operating out of Singapore. Proxy junkets allegedly operate by getting a junket front person to check in money representing himself to the casino management as a direct premium player. The ‘front’ then shares the chips with ‘friends’ who happen to be customers of that junket. This ambiguity regarding ultimate control of junkets and the difficulty in policing the junket system is precisely why Singapore drew up such tough regulations in the first place. The junket regulations were either designed effectively to outlaw junkets without stating it as a policy in so many words, or they were designed to introduce (perhaps for domestic political reasons) an illusion of control and absolute certainty in relation to regulating junkets, when in fact no such certainty is possible. The CRA’s job in this context is quite straightforward. It simply has to implement the relevant criteria and checks demanded by lawmakers to the best of its ability. If the CRA makes all the necessary background checks and finds no objections to the issuing of one or more junket licences, would the Singapore government still be able to make a political decision that keeps the door closed to junkets at RWS, or would it be bound by the CRA findings? Given that the deliberations of the CRA vetting procedure are not themselves made public, lawmakers could theoretically still exercise ultimate The Illusion of Lawmaker Control Could Singapore allow junkets to operate at its casinos? Policy Outlook Casino Regulatory Authority of Singapore Chief Executive T. Raja Kumar