Regulatory Compliance - Author Template

Author: Frances Mattias

Submission Date: 5/02/2024
Record Type: Sub Obligation
Applicable Jurisdiction:
Commonwealth ACT NSW NT ✘ QLD VIC SA TAS WA
Frequency: [Insert text here] Due Date: [Insert text here]
Core Obligation Title (if this is a sub obligation): [Insert text here]
Title: Gaming equipment

Short Description (Directional):

The casino must comply with all applicable minimum technical requirements and laws when
installing and operating gaming equipment, including card-based gaming systems, cash-redemption
terminals and jackpot systems.

Short Description (Questional):

Does the casino comply with all applicable minimum technical requirements and laws when
installing and operating gaming equipment, including card-based gaming systems, cash-redemption
terminals and jackpot systems?

Practical Guidance (Explanation – the What and the How):

Gaming equipment is regulated in Queensland by the Office of Liquor and Gaming Regulation (OLGR)
and by Queensland laws and regulations. The OLGR has published several technical requirements
which constitute minimum mandatory standards that licensed gaming venues must comply with to
ensure their gaming systems and related gaming equipment are lawful. A casino is classified as such
a venue. The following technical standards are relevant and are applicable to all casinos who
conduct or intend to conduct operations in Queensland:
 Card-Based Gaming Minimum Technical Requirements – see Tools, Office of Liquor and
Gaming Regulation: Card-Based Gaming Minimum Technical Requirements Version 1.4.1 -
This document sets out the requirements that apply to the technical evaluation of card-
based gaming systems (CBGSs) submitted for evaluation in Queensland
 Cash-Redemption Terminal Minimum Requirements – see Tools, Office of Liquor and Gaming
Regulation: Cash-Redemption Terminal Minimum Requirements Version 1.3. This document
sets out the requirements for the submission, installation and operation of cash redemption
terminals (CRTs) within the Queensland Casino, club and hotel markets
 Jackpot Systems Minimum Technical Requirements – see Tools, Office of Liquor and Gaming
Regulation: Jackpot Systems Minimum Technical Requirements Version 1.0.1. This document
sets out the principles and technical requirements pertaining to jackpot systems in
Queensland casinos and jackpot display systems

In addition to the specific requirements for the above gaming equipment and gaming systems, other
legal requirements apply to gaming equipment under Queensland laws and regulations.
Card-based gaming systems

A CBGS is a cashless gaming system that enables the electronic transfer of credits to and from a
player account for the purposes of gambling via a player, member, loyalty or other type of card. The
Card-Based Gaming Minimum Technical Requirements set out a number of requirements that must
be met in order for a casino to introduce a CBGS. These requirements are intended to ensure the
integrity and fairness of the system, enable the auditability of the system and associated equipment
and minimise the potential for harm from gambling.

A casino must submit all CBGS products intended to be used to the OLGR for evaluation and
approval. At a minimum, a submission for approval must include the following:
 the terms and conditions for card use that form the basis of the contract between the player
and the casino
 the CBGS hardware and software that delivers the system to the player and includes the
various components required to issue/validate/report various card based functions and
redemption of player funds
 the casino’s internal controls, being documented procedures for operating the CBGS and
safeguarding security of the system and players funds and entitlements
All submissions must comply with the OLGR Submission Requirements (Gaming) document (OLGR
Submission Requirements), see Tools – Office of Liquor and Gaming Regulation: Submission
Requirements Version 1.7.

Further requirements of the Card-Based Gaming Minimum Technical Requirements include the
following:
 CBGSs must only be offered in casinos by the casino operator
 a card may only be linked to a casino’s membership, player account and player loyalty
systems if the OLGR approves this. The casino must ensure that cards issued for card based
gaming are linked to systems approved for card based gaming and are not linked to other
systems such as EFTPOS

Cash-redemption terminals

A CRT is a self-service terminal that enables patrons to:

 redeem Ticket-In Ticket-Out tickets for cash
 add cash to card based gaming accounts
 withdraw cash from card based gaming accounts
 dispense funds for manual payments

Because CRTs are classified as gaming equipment, the Cash-Redemption Terminal Minimum
Requirements outline that their hardware and software must be submitted for evaluation and
approval to the OLGR prior to their installation and operation. CRT submissions must also contain
relevant user/operational manuals, service manuals and installation manuals. All submissions must
comply with the OLGR Submission Requirements when preparing its submissions. A submission to
OLGR is also required for all modifications or updates to approved CRTs.

CRTs are not intended to completely replace cashiers but rather assist with the processing of venue
based transactions by offering patrons a self-service option. Thus, the casino must continue to
provide cashier services even if operating CRTs.

Further requirements of the Cash-Redemption Terminal Minimum Requirements include the

following:
  the integration of EFT or ATM services into CRTs is not permitted in all Queensland casinos
 a CRT must only perform approved and legitimate transactions when dispensing cash,
accepting tickets, dispensing funds for manual payments or transferring funds to/from
player CBGS account. These transactions at the CRT must be sanctioned by the monitoring
system, and relevant data reported back to the monitoring system for record keeping. The
monitoring system is a computer system tasked with monitoring operation of gaming
equipment within the venue
 the CRT manufacturers must ensure that all equipment complies with relevant product and
electrical safety statutory requirements under the Queensland State and Commonwealth
laws

Jackpot systems

Simply put, a jackpot is another name for a “prize”. A jackpot system is a gaming system. A gaming
system refers to any type of computer based wagering, jackpot or prize awarding system as a whole.
The Jackpot Systems Minimum Technical Requirements outline that, at the broadest level, a gaming
system accepts bets and gives a chance of winning a prize and then awards a prize. The predominant
example of this is a linked jackpot arrangement comprising of electronic gaming machines. An
electronic gaming machine is a “Slot Machine” or “Poker Machine”. Such machines internally offer a
range of prizes/jackpots but may also be a part of a linked jackpot arrangement. A linked jackpot
arrangement is an arrangement under which 2 or more gaming machines are linked to a device
recording a winning result or other event resulting in an amount, part of an amount, or something
else, being won by a player.

All gaming systems, which includes jackpot systems, must be submitted to OLGR for evaluation and
approval. All submissions must comply with the OLGR Submission Requirements as well as with the
submission requirements outlined in section 4 of the Jackpot Systems Minimum Technical
Requirements.

Further requirements of the Jackpot Systems Minimum Technical Requirements include, but are not
limited to, the following:
 gaming system operators must have adequate controls and safeguards in place to ensure
the integrity of the system and its operation
 each jackpot system must be fully auditable
 the number of authentication and checks concerning a jackpot or win must be in reasonable
proportion to the level of operating risk
 the gaming system operator’s internal controls and procedures must ensure adequate
protection is provided to minimise the risk of fraud
 all jackpot display systems must meet the minimum requirements set out in section 17 of
the Jackpot Systems Minimum Technical Requirements. A jackpot display system is any
device which publicly displays jackpot artwork, such as a computer screen, plasma screen,
LCD screen or LED display

Other requirements relating to gaming equipment

There are several legal requirements additional to those discussed above that a casino operating
gaming equipment at their premises must comply with. These requirements apply to all gaming
equipment, irrespective of whether it is a CBGS, CRT, jackpot system or anything else. Specifically:
 all gaming equipment in a casino must be of a high standard of manufacture and must be
maintained in good order and condition
  in a hotel-casino, gaming equipment may only be maintained or exhibited in the
casino and nowhere else on the premises
 gaming equipment in a gaming area within a casino must not be maintained, exhibited,
brought into or removed from the gaming area, unless the equipment:
o has been approved by the Chief Executive of the OLGR (the Chief Executive)
o is required for the conduct of gaming
o has an identification number or symbol authorised by the Chief Executive
permanently affixed to it or permanently imprinted, impressed or engraved on it
o is under the exclusive control of the casino operator or the operator’s agents or
employees; and
o is brought into or removed from the gaming area at times authorised for that
purpose by the Chief Executive or at other times when prior notice has been given to
and written approval granted by an inspector
 the casino operator must ensure the number of gaming machines in the casino does not
exceed a limit fixed for the casino by the Minister for Liquor and Gaming (the Minister)
 the casino operator must accurately maintain a written inventory of gaming equipment used
or for use in the casino
 the casino operator must not, without the Chief Executive’s consent, destroy gaming
equipment or part with the physical possession of gaming equipment
 the casino operator must not permit a person to repair or maintain gaming equipment
unless the Chief Executive has approved of the person for that purpose
 gaming equipment in the casino must not be an annoyance due to the location of the
gaming equipment, the noise generated by the operation of the equipment or for any other
reason
 gaming equipment must not convey or exhibit:
o any false, misleading, rude or offensive message; or
o excessive or unnecessary advertising
 gaming equipment must be installed at the casino in a way that:
o permits the cleaning and maintenance of the equipment
o does not restrict access to fire exists; and
o does not restrict the use of things provided on the premises for safety and security
purposes

The casino should also refer to the Australian/New Zealand Gaming Machine National Standard
2022, see Tools – Australasian Gaming Council: Australian/New Zealand Gaming Machine National
Standard 2022. These standards are considered national best practice and aim to ensure that gaming
machines, games and related equipment are fair, secure, auditable and minimise any potential for
harm to players.

Control Action:

The casino must:

 ensure compliance with all minimum technical requirements and laws applicable to CBGSs,
CRTs and jackpot systems, as well as the installation and operation of gaming equipment in
general
 comply with the OLGR Submission Requirements when submitting requests to the OLGR for
approval of CBGSs, CRTs and jackpot systems
 only install gaming equipment at the premises if it is of a high standard of manufacture, is in
the gaming area only, meets any limits fixed for the amount of gaming equipment by the
Minister, is not an annoyance and does not convey or exhibit any false, misleading, rude or
offensive message or excessive or unnecessary advertising
  maintain all gaming equipment in good order and condition
 ensure gaming equipment does not restrict the access to fire exists or to the use of things on
the premises provided for safety and security

Consequence:

A failure by a casino operator to ensure that all gaming equipment in a casino is of a high standard of
manufacture and is maintained in good order and condition is an offence which may result in a
pecuniary penalty of up to $15,480.
(Casino Control Act 1982 (Qld) s 62(1))

If the casino possesses, maintains or exhibits gaming equipment anywhere on the premises of a
hotel-casino complex other than in the casino, then this is an offence which may result in a
pecuniary penalty of up to $7,740.
(Casino Control Act 1982 (Qld) s 62(2))

Any person who possesses, maintains or exhibits any gaming equipment in a casino gaming area, or
brings into or removes from the gaming area any equipment that:
 has not been approved by the Chief Executive
 is not necessary for the conduct of gaming
 does not have an identification number or symbol permanently affixed or imprinted on it
 is not under the exclusive control of the casino operator or the operator’s agents or
employees; and
 is brought into or removed from the gaming area at times that are not authorised for that
purpose by the Chief Executive or an inspector
commits an offence which may result in a pecuniary penalty of up to $6,192.
(Casino Control Act 1982 (Qld) s 62(3))

If a casino operator permits a person to repair or maintain gaming equipment without the Chief
Executive’s approval of the person for the purpose of repairing gaming equipment, then they may be
found guilty of an offence and face a pecuniary penalty of up to $6,192.
(Casino Control Act 1982 (Qld) s 62(21))

If a casino operator does any of the following:

 fails to ensure that the number of gaming machines in the casino does not exceed a limit
fixed for the casino by the Minister
 fails to keep and at all times maintain an accurate written inventory of gaming equipment
used or for use in the casino; or
 without the Chief Executive’s consent, destroys gaming equipment or permanently parts
with the physical possession of gaming equipment
then they may be found guilty of an offence and face a pecuniary penalty of up to $30,960 for each
of the above actions.
(Casino Control Act 1982 (Qld) s 62(6), 62(19), 62(20))

Tools:

Office of Liquor and Gaming Regulation: Card-Based Gaming Minimum Technical Requirements
Version 1.4.1

Office of Liquor and Gaming Regulation: Cash-Redemption Terminal Minimum Requirements Version
1.3
Office of Liquor and Gaming Regulation: Jackpot Systems Minimum Technical Requirements Version
1.0.1

Office of Liquor and Gaming Regulation: Submission Requirements Version 1.7

Australasian Gaming Council: Australian/New Zealand Gaming Machine National Standard 2022

Compliance Source:

Casino Control Act 1982 (Qld) s 62

Gaming Machine Act 1991 (Qld) ss 9, 187, 228, Sch 2

Gaming Machine Regulation 2002 (Qld) reg 14

Definitions:

[Insert text here]