COMMENT
During my time as Professional Development Manager at ClubsNSW, I was constantly advocating for clubs to diversify their revenue streams, to reduce and eventually remove the reliance on poker machine profits. And I still do today as an independent industry consultant.
The Anti-Pokie sentiment within the community is building to a point where, any sensible club and pub must be developing long-term strategic plans, where pokies represent a reduced percentage of both turnover and profit.
As long as pokies are a legal form of entertainment, like wagering, people will choose to entertain themselves as they wish. The critical issue here, right now, is the push to muddy the waters with combining the two perceived problems of Problem Gambling and Money Laundering. These are two completely separate issues.
If the public, led by a well-meaning but biased media, actually read the reports available (like the 2022 Crimes Commission Report) they would find the scale of money laundering in clubs and pubs is very low, compared to other industries. The Finding #5 states: “Using EGMs to clean large quantities of dirty money is high risk and inefficient. Accordingly, while it is occurring, it is not widespread.”
Large gaming venues are at most risk of money laundering and also reduced income with the introduction of a Cashless Gaming Card and spending limits. However, small clubs are more at risk of falling over if their gaming revenue is dramatically reduced. Should large clubs have different controls to the smaller, low risk venues? Is anyone asking these questions?
The industry has long been governed by the Anti Money Laundering and Counter Terrorism Financing (AML/CTF) Act 2006, with all venues with 16 EGMs or more being required to have an AML/CTF Program, train all their staff (and directors on boards) in monitoring and managing gaming activities to ensure minimising potential money laundering activity. Annual reports to AUSTRAC are due at the end of March.
This, in addition to all staff involved in gaming being mandated to hold their Responsible Conduct of Gaming (RCG) qualification (in NSW and similar in other states), which must be refreshed every five (5) Years. Smart venues also do Police Checks on all their employees, with particular focus on those working in gaming.
Harm minimisation for problem gamblers, who constitute only two (2) per cent of the adult population, is a separate and vexed issue that a Cashless Gaming card, with a daily limit would probably go a long way to help. Most people, who are not regular club or pub patrons, do not know that there are many safety mechanisms already in place to address problem gambling, including staff training through programs like
ClubSAFE and BetSafe, and the Multi-Venue Self Exclusion (MVSE) Program, developed by ClubsNSW and shared across the country with clubs and pubs, to facilitate better management of people who wish to self-exclude from gaming venues.
ClubsNSW has already launched its Gaming Code of Practice to address many of the issues raised by the anti-gaming lobby, to commence on 1 July 2023. The Code includes realistic approaches to implementation, including consideration of venue size, and adding Third Party Exclusions to be approved to allow family to intervene where a serious problem exists.
Would a Cashless Gaming Card provide any real benefit in minimising play for problem gamblers? Too many difficult questions are yet to be asked to find a suitable mechanism to help reduce money laundering and problem gambling, but two things are certain in my mind.
One: We must rely on the data to inform the decisions, not emotion and;
Two: Clubs and pubs must prepare for a future with reduced cashflow and profits from gaming.
For more information contact Ron Browne, Managing consultant, Extrapreneur Services 0414 633 423 ron@extrapreneurservices.com.au
(An extended version of this column first appeared in Club Management on January 30.)