Inside Asian Gaming

INSIDE ASIAN GAMING | May 2011 22 incorrect.” But the gaming law expert stresses the DICJ is being consistent and following international standards. “This approach that a machine version of a table game is a derivative is not a unique view of the world. The state of Victoria in Australia has operated under a similar regime for years. It is certainly defensible as a method of bet placement or settlement. Electronic table games do not use random number generators. They use the same mechanics and rules as the approved table version of the game. The presence of a dealer is part of those mechanics,” adds the source. The supply industry source asks if that is the case, why did the DICJ previously allow more generous pay outs on electronic games—specifically on fully automated sic bo products? This source argues that’s evidence that until now the DICJ had accepted the principle that automated electronic games were a special case— neither a slot nor a table game. “I think it would be tremendously helpful if the DICJ could have a department dealing directly with the suppliers of slots and electronic games.” “On the one hand the DICJ is asking laboratories testing machines for the Macau market to work on the basis of a minimum 85% return to player [RTP]. That’s happening even if technically and legally there’s no regulated minimum RTP for slots in the Macau market. But on the other hand the DICJ is now imposing table level pay outs on some of those previously compliant sic bo games,” says the supply industry source. “For instance, with the ‘three of a kind’ prizes—from three‘ones’up to three‘sixes’— most [ ] machines in the market have until now been operating at 190-1 [odds]. That gives a pay back to the players of 87.96%. That’s slightly in advance of the minimum 85% for machines. But when you go down to 150-1, the pay back [to players] is 69.44%. That’s below the regulated pay back for a machine. So if someone only ever played the ‘three of a kind’ bet, they would be totally disadvantaged on a sic bo machine regulated as a live table,” adds the supply industry insider. But the gaming law expert rejects this assertion. “Firstly, to my knowledge there is no 85% (whether minimum or absolute) RTP ‘requirement’ for slots in Macau. Even if that were the case, until there is a regulation for electronic games in Macau, there is no restriction on concessionaires dialling up whatever RTP they like, once machines have been made operational. It is competition that prevents the RTP being set lower than might otherwise have been the case. Secondly, I am at a loss to understand the relevance of an 85% RTP on slots to ‘RTP’ on an electronic table game. The two concepts are to me different,” says the expert. “The odds on a table game, whether electronic or dealer-controlled, are determined by the game mechanics, which are comparatively simple, since there is a much more limited number of independent variables—for example three dice in sic bo. “On a slot, the game algorithms determine game volatility and RTP [return to player]. RTP Is set over an extended game cycle—possibly millions of games. An electronic table game can’t work that way. Sic bo depends on how the actual (not virtual) dice fall, which is a result of a mechanical shaker, or wobble plate. Likewise with roulette, the wheel is not driven by a device known and tested as an RNG [random number generator]. It’s the mechanical operation which determines the game outcome,” states the gaming law expert. “In a slot machine, the frequency and size of wins is written into the game software, albeit that if you played maybe a million games you might get an overall RTP of say 85%, if that is what has been programmed.” New terms of engagement The supplier suggests potential gaming law conflicts can be been avoided if channels of communication between the manufacturers and the Macau regulator were improved. “I think it would be tremendously helpful if the DICJ could have a department dealing directly with the suppliers of slots and electronic games,” says the insider. “If suppliers have a newmachine coming out now, they’re afraid to put it out. The biggest problem is that the suppliers are not allowed to talk through issues directly with the regulator,” claims the supplier source. “The suppliers have to raise issues via the concessionaires. But the concessionaires may not always have as much detailed knowledge about the products as the suppliers themselves.” Other suppliers say privately that even if their views are clearly and accurately represented to the Macau regulator, they are nervous that those views will be interpreted by the DICJ as a challenge to officials and that this will set back the approvals of their products. They say operators share this nervousness. This could be partly a cultural problem. In Chinese and Macanese culture, it’s arguably difficult to question the view of a person in authority without it seeming like an attempt to make them lose face. Officials inside the DICJ are also extraordinarily sensitive to the fact that many people in the outside world (especially the Anglo-Saxon part of the outside world) think Macau has historically been at best lax and at worst Stacked odds—players are the losers under the DICJ’s ruling Cover Story