Inside Asian Gaming

December 2010 | INSIDE ASIAN GAMING 29 GLI What we’re noticing is a real convergence of technology, where we test a gaming machine for a land-based casino and it’s about game content, but the manufacturers are developing that content for multiple platforms whether it be for online, for applications on say the iPad or for smartphone gaming. Our strategy and approach to the testing is pretty much the same. The game has to play in accordance with its rules, regardless of whether it’s online or terrestrial. It’s not a big step in terms of testing an online game to testing a terrestrial game. The support platform may be different. Sometimes when we’re testing a game we find we’re getting it early in the design cycle. And we know it could be going into an online platform 12 months later. We might be testing it today for a casino now, but a few months down the line we may be asked to test it for say an iPad application or an online game application. What’s happening in the Singapore regulatory sector? As youknow, theCRA [Singapore’s Casino Regulatory Authority] must approve each test location used to test gaming equipment for the Singapore market. GLI has all its test locations in the United States approved, our locations [are] approved in Europe and we’re currently in the process of having our centre approved in Australia. So even though GLI is an approved SRTL—Singapore Recognised Test Laboratory—we can only do test procedures in those of our locations that have been CRA-approved. We are, however, adding more locations all the time. How are you positioning yourself for the expected slot regulations in the Macau market? We work very closely with regulators all around the world when they’re introducing their regulations. Regulators recognise the expertise GLI has in writing technical standards. We’re very fortunate that they engage us very early and provide us with drafts of the technical standards. We’re typically invited to comment on those technical standards. In some cases we write it [technical standards] under contract to the government involved. We talk to the regulator about what their objectives are, what their concerns are. GLI doesn’t set policy—it merely ensures that policy is reflected in the way the regulator wishes in terms of technical requirements. For example, when technical standards are published, there may be some wording that is open to interpretation. So we try to work with them [the jurisdiction] to narrow that room for interpretation. If something’s not clear, the last thing we want is for the regulator to understand it to mean one thing, the manufacturer to understand it to be something else, and the test lab something else again. That just creates a huge cost, because the manufacturer will build a product believing it’s conforming to the criteria, and then the test lab looks at it and says, ‘No that’s not the regulation’s intent’. So GLI’s first task is to look through the technical standards and understand if there’s anything at all that’s open to interpretation. We help the regulator dig deep into the text and the definitions of particular words—sometimes suggesting alternatives or seeking clarification on what they understood by a particular word or phrase. We can alsouse our experience and expertise to show them what other jurisdictions have done to resolve a particular issue or question of interpretation. What happens if the regulator wants some regulation unique to that jurisdiction? If there’s anything we believe is significantly out of step with the rest of the world—if there’s a unique requirement in there, we provide the regulator with an impact assessment. That sets out the potential downside as well as potential advantages of framing a regulation in a particular way. We say to the regulator: ‘It’s your prerogative to do it that particular way, but we would like you to consider the following impact or impacts that may have’. Then they may or may not amend it. Our concern is simply to make sure they have a well-informed decision.