Inside Asian Gaming

August 2016 inside asian gaming 29 Rules of the game To accomplish that, however, two things are still required. One is that compliance with the new rules is supervised and enforced; preferably, that the level of such compliance is made public for the benefit of all industry stakeholders. Secondly, but no less important, is that Macau truly embraces its role as a regional leader by requiring its operators to follow no lesser standards when engaging in gaming abroad than the ones it requires of them at home. In a context where players and funds regularly flow between casinos and VIP rooms located in multiple jurisdictions across the region, Macau can no longer ignore the significant risk that the practices it prohibits within its borders may easily be replicated in more lenient regulatory frameworks. The State of Nevada, being a leader itself, has long understood that regulating foreign gaming is crucial to the success of its own policies. Thus, it requires that Nevada licensees operating overseas report their activities and conduct themselves in accordance with the standards of honesty and integrity required of them stateside. Failure to do so may result in the imposition of a fine and, ultimately, in the revocation of their gaming licenses. The new rules give an important step in the right direction by requiring a casino concessionaire to conduct enhanced Customer Due Diligence when transferring gaming funds to its overseas group companies. This obligation derives from the (almost unreadable) provisions of article 17, which also determine that casino concessionaires are ultimately responsible for the compliance of CDD obligations by their group companies, wherever they operate. Despite its clumsily worded good intentions, article 17 still falls short of what is required, especially by leaving out of its reach the overseas operations of Macau junkets. The recent cyber-theft of the Bangladesh central bank, the proceeds of which have allegedly found its way back into the system through Macau junkets operating in Manila’s casinos, are a harsh reminder of the risk. Macau must actively promote good practices across the region. By doing so, it will be protecting the reputation of its concessionaires and licensees which is ultimately its own. At the same time, it should be ensuring that its policies will be effectively implemented rather than ignored outside its borders. It seems a big task for such a small region, but Macau may no longer shy away from its role. And that is the burden of a leader. “Soon after the Instructions were enacted, industry sources voiced their concerns over the excessive costs that the implementation of these measures would entail, particularly at a time when operators are already under the pressure of declining gaming revenues. I have to disagree with such views.”