|
FEATURE |
This article sets out the legal framework and highlights the salient features of the laws governing casinos in Singapore.
The Laws Governing Casinos in Singapore
The legal framework governing the operation of casinos in Singapore is comprehensive and rigorous. The key legislation is the Casino Control Act (“CCA”). Besides this primary casino legislation: casinos in Singapore are governed by myriads of other regulations: Notices, Internal Codes and Directions. The subsidiary legislations governing the casinos are as follows: (i) The Casino Control (Prevention Of Money Laundering And Terrorism Financing) Regulations 2009 (“Casino AML Regulations”); (ii) The Casino Control (Surveillance) Regulations 2009; (iii) The Casino Control (Licensing of Special Employees) Regulations 2009 (“Special Employees Regulations”); (iv) Casino Control (Junkets) Regulations 2009 (“Junkets Regulations”); (v) Casino Control (“Casino Layout Regulations”); (vi) Casino Control (Gaming Equipment) Regulations 2009 (“Gaming Equipment Regulations”); (vii) Casino Control (Credit) Regulations 2010 (“Credit Regulations”); (viii) Casino Control (Advertising) Regulations 2010 (“Advertising Regulations”); (ix) Casino Control (Patron Dispute Resolution) Regulations 2009 (“Patron Dispute Resolutions”); (x) Casino Control (Casino Tax) Regulations 2010; (xi) Casino Control (Casino Licence And Fees) Regulations 2009; and (xii) Casino Control (Casino Contracts) Regulations 2010 (“Casino Contracts Regulations”).
The casinos are further regulated by various detailed Notices issued by the Casino Regulatory Authority. These are conditions imposed on a casino’s licence. The same authority also issues Directions to casinos and it prescribes Internal Control Codes. Both of these administrative requirements are confidential to the casinos concerned, hence, they are outside the scope of this article.
The regulatory authority that regulates casinos in Singapore is the Casino Regulatory Authority (“CRA”). The objectives of the CRA are to ensure that: (i) casinos in Singapore are free from criminal influence or exploitation; (ii) gaming in casinos is conducted honestly; and (iii) the casinos do not cause harm to minors, vulnerable persons and society at large.1 The main functions and duties of the CRA are to license and regulate the casinos’ operation; to approve the casino’s system of control, administrative and accounting procedure, and to advise the Minister.2
Section 40, CCA, in dis-applying ss 5(1) and (2) of the Civil Law Act, has clarified that all wagering contracts conducted by the casinos in Singapore are legally valid and enforceable. To prevent a burgeoning of casinos in Singapore, the CCA expressly limits the licensing of only two casinos for the period of 10 years (from commencement of the CCA).3 During this 10-year period, the main shareholder of the casino operator is not allowed to divest his stake in the casino operator to less than 20 per cent of the total votes or less than any other shareholder’s stake in the casino operator.4 No third party (other than the main shareholder)is allowed to acquire these stakes in the casino operator.5 Further, the main shareholder is prohibited from acquiring any stake in the other casino operator, or to participate in the management or operation of the other casino operator in Singapore during this 10-year period.6 This is to prevent one casino operator from taking over the other in Singapore. A casino operator is not allowed to transfer, mortgage, charge or otherwise encumber the casino licence except with the CRA’s approval.7
A key feature of the law governing casinos in Singapore is the rigid control over the ownership of the casino. This is to prevent the ownership of the casino from falling into wrong hands (particularly persons with questionable or undesirable background). Therefore, a casino operator is required to obtain the prior approval of the CRA before a major change relating to a casino operator occurs.8 A “major change” refers to a person becoming an Associate,9 or a change in the management or operation of a casino operator.10 If it is not within the power of the casino operator to prevent a “major change”, it should then notify CRA three days after it becomes aware of it. Further, if there is a change in the situation of the Associate, it is required to inform CRA within 14 days.11 A casino operator is required to notify CRA that a person is likely to become an Associate as soon as practicable after it is aware of the likehood.12 If CRA determines that the Associate is unsuitable (eg, not of good repute, unsound or unstable financial background or has business association with persons of dubious reputation or unsatisfactory financial resources)’13 it may require the Associate to terminate its association with the casino operator;14 failing which, CRA can direct the casino operator to terminate the relationship.15 No person shall become a substantial shareholder of a casino operator,16 a “12 per cent controller” or a “’20 per cent controller” or an “indirect controller” of a casino operator without first obtaining the approval of the Minister.17
Further, under CRA Notice 145/2/8, a casino operator is required to notify CRA on corporate matters such as change in ownership, trust or corporate structure, change in constituent documents and nominal/paid up capital.18 It must also notify CRA on changes in its financial situation (such as refinancing of debts, breach of covenants, notice of payments from banks for default in repayment of loans, repossession of assets, disposal of assets or impairment of assets, and judgment debts having material impact on the casino’s financial stability; appointment of special auditor; entering into scheme of compromise or arrangement with creditors; appointment of receiver, judicial manager or liquidator).19 Finally, a casino operator has to declare any changes in its strategic business level (such as joint venture, merger or acquisition, starting or terminating other business level such as change in the casino’s operator’s stake in joint venture, merger or acquisition).20
Under CRA Notice 145/2/9, a casino promoter has to further report to CRA on matters such as: change in key persons (eg, directors, managers, head of compliance, auditors; changes in main stakeholder’s shareholdings); material litigation, criminal investigation and changes in the financial situation of the Relevant Entity (such as casino operator’s Associates).21
A casino operator is not allowed to enter into a Controlled Contract with any party unless it has given 28 days prior notice to CRA.22 A Controlled Contract is a contract relating to the supply of goods and services for the operation of a casino with a prescribed value above $500,000. 23 Such contracts include the supply, maintenance, repair and disposal of gaming equipment; financial matters (financial services provided by financial institutions not regulated by the Monetary Authority of Singapore, supply of debt recovery services); supply of management services relating to gaming, information technology; casino security and surveillance.24 A casino operator can only deal with suppliers of gaming equipment who are approved by CRA.25
There is a group of employees employed by a casino operator to perform the key roles in the operation of a casino called Special Employees. A Special Employee is a person who: (i) is employed in a casino in a managerial capacity or who is authorised to make decisions that regulate the operations of a casino; or (ii) is employed in a casino in the following activities – conduct of gaming; movement of money/chips in casino, exchange of money/chips to patrons, counting of money/chips; security/ surveillance of casino; operation, maintenance, construction or repair of gaming equipment, and supervision of the above activities.26 There are four categories of Special Employees: Categories A, B, C1 and C2. A Category A Special Employee includes the Chief Executive Officer, Chief Financial Officer, General Counsel, Chief Technology Officer, Vice President or Director of Casino Operations, Vice President or Director of Table Games. A Category B Special Employee includes the pit manager, slot manager, cage manager, audit manager and international marketing manager. A Category C1 Special Employee includes the dealer, cage cashier, slot attendant, casino account officer, surveillance officer and table games supervisor. A Category C2 Special Employee includes slot technician, technical support personnel for surveillance equipment, slot management systems or electronic monitoring systems.27
A Special Employee must be licensed and he can only exercise the function specified in his licence.28 Each of the Special Employee’s licence is only valid for three years,29 after which he may apply for a new Special Employee licence.30 A Special Employee licence may be cancelled by CRA if there are grounds for disciplinary action (eg, licence was improperly obtained, committed an offence under CCA, contravened condition in the licence, bankruptcy or becomes an unsuitable person to hold the licence).31 A casino operator must terminate the employment of the Special Employee whose licence is cancelled within 24 hours upon CRA’s notification.32 Special Employees are not allowed to gamble in their own casino.33
A casino promoter is not allowed to change the casino layout without the approval of CRA.34 The size of the casino premises in each casino is limited to 15,000 square metres.35 This is to prevent the casino from outgrowing the other areas of the Integrated Resort approved by the authorities. All games played in a casino (excluding gaming machines), mode of play and rules for those games must be approved by CRA.36 All gaming equipment for use in a casino must be approved by CRA.37 A casino promoter can only purchase gaming machines from manufacturers and suppliers approved by CRA.38 The number of gaming machines available for gaming in each casino is limited to 2,500 per casino.39 According to s 108(1), CCA (read with reg 5, Credit Regulations), a casino promoter (or a junket promoter) is not allowed to accept a wager other than by means of money or chips, lend money, provide money or chips as part of a transaction using a credit card, extend other form of credit or wholly or partly discharge or release a debt (except with Minister’s consent) when it deals with Singapore residents (ie, Singapore citizens and Permanent Residents). Hence, as a general rule, a casino operator cannot allow a Singapore resident to purchase chips using a credit card. However, pursuant to reg 5, Credit Regulations, a casino promoter is allowed to accept payment for chips using credit cards, provide cheque-cashing facility (ie, to buy chips only), credit to patron’s deposit his cheque payable to the casino operator before it is cleared with the bank, and grant credit to a non-Singapore resident to qualify as Premium Player when dealing with a non-Singapore Resident or a Premium Player (ie, patron with deposit account exceeding $100,000, which would include a Singapore resident). Hence, a casino can grant credit to a Singaporean Premium Player to gamble.
Besides casino operators, a licensed junket operator is also allowed to grant credit to a non-Singapore resident for the sole purpose of qualifying him to be a Premium Player.40 However, they are not allowed to solicit the granting of any credit to their patrons.41 In granting credit to their patrons to buy chips, a casino promoter or a licensed junket promoter is deemed to be a money lender under the Money Lenders Act. Hence, besides a casino licence, a casino promoter must also hold a money lender’s licence in Singapore.42 However, non-casino money lenders (as well as pawn brokers) are not allowed to provide money lending or pawn-broking business within the casino premises.43 Neither are ATMs (Automatic Teller Machines) allowed to operate within the casino premises.44
The CCA only permits licensed junket promoters are allowed to organise junkets for a casino in Singapore.45 All authorised junket promoters must each hold a junket promoter licence and their representatives must each hold a junket representative licence.46 No licensed junket promoter shall enter into an agreement with any unlicensed junket promoter to organise or to promote a junket.47 A casino operators must not allow any unlicensed junket promoter to operate within the casino.48 There are stringent probity requirements for an applicant to be licensed (or continue to be licensed) as a junket promoter in Singapore. A licensed junket promoter may either be an individual or a corporation. 49 In deciding whether to grant a junket promoter licence to an applicant, the CRA will consider matters such as the applicant and its Associate’s reputation, their financial soundness and stability, their experience in the casino business, their business association with third parties who are not of good reputation; whether the applicant’s directors, partners or executive officers are suitable to act in that capacity and whether the applicant or its Associate has a non-compliance record with any casino laws in Singapore or overseas.50 An applicant applying to be a licensed representative promoter has to pass almost similar probity tests.51 A junket promoter licence is not transferable and it is valid for only three years.52 A junket representative licence is also valid for three years.53
All licensed junket promoters must keep a record of every junket containing the personal identification of each junket player (which includes full name, date of birth, residential address, unique identification number eg, passport number, I/C number – passport and I/C should bear a photograph of the junket player) and other related information.54 This is not to be confused with the customer due diligence (“CDD”) or know your customer (“KYC”) information which is required when a casino opens a patron account under reg 8(1),55 Casino AML Regulations (which does not apply to a junket promoter). Hence, a licensed junket promoter is under no statutory obligation to perform a CDD on its junket players. This will be a cause for concern for banks dealing with junket promoter customers, since banks cannot rely on the fact that the junket promoter had performed its CDD on its underlying clients. All these records must be kept for no less than five years.56 The CRA continues to monitor a junket promoter’s Associate by gathering information on his reputation, financial situation and his business association with third parties who are not of good reputation. 57 The CRA will take this into consideration when renewing the junket promoter’s licence. One of the interesting duties of a casino operator is that it must give CRA the arrival report of a junket not less than one hour before the commencement of a junket in its casino.58 This gives CRA the right to prohibit any junket player who is on CRA’s “exclusion” list from gaming in the casino.
When a dispute relating to alleged winnings or losses or the manner the game was conducted arises between a casino operator and a patron, the casino operator shall endeavour to resolve the dispute amicably within seven days from when the dispute arose (“Dispute Resolution Period”).59 If both parties cannot resolve the dispute within the Dispute Resolution Period, the casino must notify the Inspector (if amount is at least $1,000) or inform the patron of his right to request for an Inspector (if the amount is less than $1,000) to investigate this dispute.60 Where the Inspector has made a decision, the party liable to pay must pay within 15 days after the Inspector’s decision.61 If a party is dissatisfied with an Inspector’s decision, it may appeal to the Patron Dispute Committee (“PDC”).62 The Party who is dissatisfied with the PDC may appeal to CRA for a final decision.63 The costs of the proceedings before the PDC shall be borne by each party. The PDC or CRA may dismiss any dispute if it considers it to be trivial, frivolous or vexatious.64
To mitigate the social ills of casino gambling in Singapore, it is mandatory for casinos to impose entry levies to discourage Singapore residents from gambling in the casinos. Thus, a casino operator imposes an entry levy of $100 for every Singapore resident to enter and to remain in the casino premises for a period of 24 hours. Alternatively, a Singapore resident may pay $2,000 for an annual membership levy to enter the casino with unlimited entries.65 All entry levies are paid to the Singapore Totalisator Board.66 The entry levies do not apply to any casino’s employee, Inspector, police officer, officer of the Centre Narcotics Bureau or Corrupt Practices Investigation Bureau, Civil Defence Officer, Inland Revenue Authority of Singapore Officer and CRA Officer.67
Besides the entry levies, there are four types of exclusion orders which bar a person from entering the casino premises. First, a casino operator may itself issue an exclusion order to bar a person from entering the casino (eg, patron found guilty of cheating the casino).68 This is perfectly legal because a person enters and remains in a casino premises only by the licence of the casino operator.69 Second, there is a voluntary exclusion order by which an applicant effectively bars himself from entering the casino.70 The casino operator is required to notify CRA of the persons under both exclusion lists.71 Third, CRA itself may issue an exclusion order to prohibit a person from entering a casino.72 Finally, the Commissioner of Police can also issue an exclusion order to prohibit a person from entering a casino.73 It is interesting to note that if an excluded person managed to illegally enter a casino to gamble, all his winnings are forfeitable.74 Besides the “excluded persons”, there is another group of persons who are also prohibited from entering a casino’s premises. These are the minors (persons below 21 years). Like “excluded persons”, all winnings by a minor in a casino are also forfeitable.75
There are strict advertisement rules restricting the advertisement of casinos in Singapore. This is part of the authorities’ efforts to avoid giving undue prominance to the casino aspect of the Integrated Resorts they have approved. Hence, a casino operator or a junket promoter is not allowed to publish or to distribute a “Casino Advertisement” in Singapore.76 A “Casino Advertisement” is any image or message which: (i) contains an inducement to visit a casino or to play any game in that casino; or (ii) promotes a casino or the playing of any game in a casino.77 The only places where a “Casino Advertisement” can be displayed are: overseas, the casino’s internet website (provided it is not primarily targeted at Singapore residents), exhibition on billboards or signboards within Changi Airport or within the tourist information centre managed by or approved by the Singapore Tourism Board or where the advertisement is directed primarily at foreign visitors in Singapore (eg, tourist information booklet). However, limited advertisements (ie, basic factual information on the casinos with no inducement or encouragement to play any game in a casino) may be distributed within certain “designated sites” (ie, official tourist sites), hotels (registered under the Hotels Act), Changi Airport and premises approved/ managed by the Singapore Tourism Board.78 Where a casino operator is interviewed or gives a media release, it must ensure that the interview or media release contains factual information only, and does not contain inducement to visit or to play any game in the casino.79
The system of internal controls and administrative and accounting procedures of a casino must be approved by CRA.80 This encompasses the entire casino operation including matters such as: accounting procedure, organisational chart, procedures for conduct and playing of games, cheque encashment, chips redemption, collection and transfer of money, storage and recording of chips, maintenance, security deposit accounts, control of keys, surveillance, controlled contracts, junket promoters and AML measures.81 We now focus on the AML control measures a casino should have.
Cash Transaction Report (“CTR”) and Suspicious Transaction Report (“STR”)
As we have seen in the first part of this article, casinos are vulnerable to money laundering. The key regulation in controlling money laundering in a casino in Singapore is the Casino AML Regulations. As we have seen in the discussion earlier, casinos are cash-intensive businesses and cash is a favourite medium of laundering because of the anonymity it provides to the money launderers. Hence, one of the key features of AML controls in the Casino AML Regulations is the Cash Transaction Reporting (“CTR”). A casino operator must report each cash transaction of $10,000 or more to CRA within 15 days after the transaction has taken place (a copy of the CTR to be given to CRA).82 Cash is defined as “currency notes and coins”.83 Hence, cheque-encashment, wire transfers, travellers cheques and cashier’s orders will not be caught under a CTR. What will be reportable under a CTR is a patron’s cash transaction involving “cash-in” or “cash-out” of $10,000 or more in a single transaction or in multiple cash transactions (within 24 hours). 84 If a patron decides to avoid a CTR by buying $30,000 worth of chips separately four times within the same day, he may be caught under this “multiple transaction” rule. The term “cash-in” refers to the receipt of cash paid by the patron to the casino promoter: (i) in exchange for chips; (ii) deposit of cash to be credited into the patron’s account; (iii) cash received in settlement of debt owed by the patron to casino operator or for the redemption of cheque held by the casino operator; (iv) cash inserted into a gaming machine.85 The term “cash out” refers to the payout of cash by the casino operator to or on behalf of the patron and this includes: (i) cash paid by the casino operator to redeem the chips; (ii) cash paid upon withdrawal made from the patron’s account; and (iii) cash paid by the casino operator as winnings. 86 It is interesting to note that jackpot winnings are not reportable under CTR.Besides a CTR, a casino must also lodge a Suspicious Transaction Report (“STR”) with the STRO (copy extended to CRA).87
Prohibited transactions
It is well documented that a money launderer often visits a casino not to gamble but to “wash” his dirty money. He uses the casino like a money changer or a bank. Hence, another tool of money laundering control used in the Casino AML Regulations is to prohibit a casino operator from allowing a patron to convert his money from one form to another without being used for gaming. This would include receiving cash from wire transfer without being used for gaming or cashing of cheques without gaming.88 Under such circumstances, the money launderer is treating the casino like a bank. A casino operator is also prohibited from receiving any money for which the purpose or ownership cannot be ascertained within seven days because they would be considered suspicious transactions.89 Both these transactions are red flags of money laundering. A casino operator should consider lodging a STR because of these red flags. A casino operator must also take all appropriate steps to ensure that there are no “loan-sharks” operating within the casino premises.90 Some of these “loan-sharks” may be funded by triads or any other criminal syndicates or unlicensed junkets.
Customer Due Diligence
The key to combating money laundering is to know your customer by performing CDD. Therefore, a casino operator must perform CDD measures when: (i) a patron opens an account with the casino operator; (ii) a patron enters into a cash transaction involving $10,000 or more in a single transaction with the casino; (iii) deposits $5,000 or more in a single transaction into a deposit account; (iv) it has reasonable suspicion of money laundering or terrorism financing; or (v) it has doubts over the veracity or adequacy of the information previously obtained from the patron.91 This means that a casino operator need not perform CDD on a walk-in patron who: (i) enters into a cash transaction below $10,000; or (ii) enters into a non-cash transaction (eg, banker’s draft or traveller’s cheque) above $10,000. A casino operator must establish the identity of each of its patron before opening a patron account by obtaining the following four sets of information: (i) patron’s identifying information (this would include his full name and, date of birth, residential address, contact number, nationality, identification number ie, identity card number, passport number, taxpayer identification number) and signature; (ii) the amount of initial deposit into the patron account; (iii) the date the patron account is opened and (iv) the name and signature of casino’s employee who opened the account.92 Before a patron account is opened, a casino operator must not only identify the identity of the patron, it must also verify the identity of the patron. This should be done using reliable and independent sources (eg, identity cards, passports).93 A casino operator is not allowed to debit or withdraw from the patron account without a licensed Special Employee having had a face-to-face meeting at the casino premises with the patron.94
Besides identifying and verifying the identity of the patron, a casino operator is required to identify and verify the identity of the beneficial owner of the patron account.95 This poses a greater challenge for a casino operator because most of the time the casino operator may not know of the existence of a beneficial owner. However, it is necessary to know this because the money deposited into the patron account may belong to a money launderer (the beneficial owner). Also, a casino operator must identify and verify the identity of the patron who carries out a cash transaction of $10,000 or more.96 Where a single deposit of $10,000 or more is deposited into a patron account in a single transaction, the casino operator must identify and verify the identity of the depositor and keep a record of all the deposit particulars.97 A casino operator must also monitor the transactions in each patron account to ascertain whether the transactions are consistent with the patron’s income profile and his source of funds to detect any suspicious transactions.98 Besides monitoring, a casino operator must also review the adequacy of the information obtained on the patron and beneficial owner of the patron account.99
PEP Patrons and Incomplete CDD
A casino operator must perform enhanced CDD (“Enhanced CDD”) when dealing with a Politically Exposed Person (“PEP”) patron because he is considered “high-risk”.100
A PEP is an individual who is or has been entrusted with a prominent public function in Singapore or in a foreign country. The term “prominent foreign function” includes the role held by a head of state, a head of government, a government minister, a senior civil servant, a senior judicial or military official, a senior executive of a state-owned corporation or a senior official of a political party. 101 A PEP includes such individual’s immediate family members and close associates.102 A PEP is considered “high risk” because of the powers he/she possesses to benefit from corrupt practices within his/her country. How should PEP patrons be handled? All casino operators should: (i) have established internal policies, procedures and controls in place to determine if a patron is a PEP; (ii) require prior approval from an employee holding senior management or executive position before dealing with, or continuing to deal with a PEP; (iii) establish the source of wealth (what economic activities that generate such wealth) and source of funds (where are the assets now); and (iv) perform enhanced monitoring. 103If a casino operator is: (i) unable to complete the CDD measures on a patron; or (ii) a patron is unable or unwilling to provide the information requested or if he decides not to proceed with opening the patron account or if he decides to withdraw the cash transaction or deposit, the casino operator should not proceed with the opening of the patron account or proceed with any of the above transactions.104 If necessary, the casino operator should lodge a STR with a copy extended to CRA.105
Internal Policies, Procedures and Controls and Training
This has been discussed in the first part of this article printed in the Singapore Law Gazette November 2010 issue.
The legal framework regulating casinos in Singapore is now in place. There are now myriads of laws and regulations closely regulating and controlling the casinos’ operations in Singapore. The challenge ahead lies in the administration of the casinos by CRA to ensure that they operate within a controlled, healthy environment envisaged under the CCA while at the same time using the casinos to boost tourism in Singapore. This is the delicate balance Singapore hopes to achieve.
Tan Sin Liang*
SL Tan & Co
E-mail: [email protected]
The author’s area of practice is in compliance regulatory laws relating to financial institutions
Notes
4. Section 42(1)(a), CCA. [Return]
5. Section 42(1)(b), CCA. [Return]
6. Section 42(2), CCA. [Return]
8. Section 61(2)(a), CCA. [Return]
9. The term “Associate”) is defined in s 3, CCA to refer to: [Return]
(a) a person who holds or will hold any relevant financial interest (ie, share capital in the casino operators business and entitlement to income from the business), or will be entitled to exercise any relevant power (ie, power to participate in any directorial, managerial or executive decision or to appoint such persons) in a casino operator’s business, and by that interest or power, he is able or will be able to exercise a significant influence over the management or operation of that casino business; and
(b) a person who holds or will hold any relevant position (ie directors, manager or secretary and other executive position) in the casino operator’s business.
10. Section 61(1), CCA. [Return]
11. Section 62(1), CCA. [Return]
12. Section 63(2), CCA. [Return]
13. Section 63(4), CCA. [Return]
14. Section 63(3), CCA. [Return]
15. Section 63(7), CCA. [Return]
16. Section 65(1), CCA “Substantial Shareholder” has same meaning in s 81 of Cos Act (ie, interest in share of company with attached value not less than 5 per cent of total voting shares). [Return]
17. A “12 per cent Controller” means a person who, alone or together with his associates; (i) holds or has interests in two per cent or more but less than 20 per cent of the total number of issued shares in a casino operator; or (ii) is in the position to control voting power of 12 per cent or more but less than 20 per cent in a casino operator. A “20 per cent Controller’ means a person who, alone or together with his associates: (i) holds or has interests in 20 per cent or more of the total number of issued shares in a casino operator; or (ii) is in a position to control voting power of 20 per cent or more in a casino operator. An “indirect controller” means any person, acting alone or together with another person, and whether with or without holding shares or controlling voting power in a casino operator: (i) in accordance with whose directions, instructions or wishes the director of the casino operator are accustomed or under an obligation, whether formal or informal, to act; or (ii) who is in a position to determine the policy of the casino operator. [Return]
18. Paragraph 1.1, 1st sch CRA 145/2/8. [Return]
19. Paragraph 1.2, 1st sch CRA 145/2/8. [Return]
20. Paragraph 1.3, 1st sch CR5A 145/2/8. [Return]
21. Part A, 1st sch CRA 145/2/9, Paras 2, 3, 4 & 6. [Return]
23. Section 72(1), CCA; reg 7, Casino Contract Regulations. [Return]
24. The Schedule, Controlled Contracts Regulations. [Return]
25. Regulation 6, Controlled Contracts Regulations. [Return]
27. 1st sch., Special Employees Regulations. [Return]
29. Regulation 11, Special Employees Regulations. [Return]
31. Section 93(1), CCA. [Return]
32. Section 96(1), CCA. [Return]
34. Section 99, CCA, Regs 7 and 9, Layout Regulations. [Return]
35. Regulation 3, Layout Regulations. [Return]
36. Section 100, CCA. [Return]
37. Section 102(2), CCA. [Return]
38. Section 103, CCA. [Return]
39. Regulation 11(1), Gaming Equipment Regulation. [Return]
40. Regulation 5(2), Credit Regulations. [Return]
42. Section 108(9), CCA. [Return]
43. Paragraph 5, CRA 145/2/7. [Return]
44. Section 109(1), CCA. [Return]
45. Section 110(1), CCA. [Return]
46. Regulation 3, Junket Regulations. [Return]
47. Section 110(3), CCA. [Return]
48. Regulation 5, Junket Regulations. [Return]
52. Ibid, reg 16 and 17. [Return]
55. The “Identifying Information” required under reg 8(2) are (eg, individual full name (alias), date of birth, residential address, contact number, nationality identification number (I/c, passport, taxpayer identification number). [Return]
57. Ibid, reg 34(2), (9). [Return]
59. Regulation 3, Patron Dispute Regulations. [Return]
65. Section116(1), CCA. [Return]
66. Section116(2), CCA. [Return]
67. Section116(5), CCA. [Return]
68. Section 120(1), CCA. [Return]
69. Section 115, CCA. [Return]
70. Section 120(2), CCA. [Return]
71. Section 120(3), CCA. [Return]
72. Section 121, CCA. [Return]
73. Section 122, CCA. [Return]
74. Section 128(2), CCA. [Return]
76. Regulation 3, Advertisement Regulations. [Return]
80. Section 138, CCA. [Return]
81. Sections 139, CCA. [Return]
82. Regulation 3, Casino AML Regs. [Return]
90. Section 129(1)(b), CCA. [Return]
97.Ibid, reg 12(1)(2). [Return]
100. Ibid, reg 14(1). [Return]
101. Ibid, reg 14(3). [Return]