Introduction by Croakey: Seven and Nine broadcast networks breached gambling advertising rules by showing betting promotions during major sporting events in 2021, according to a recent investigation by the Australian Communications and Media Authority.
ACMA Chair Nerida O’Loughlin said “Australians are increasingly concerned about the potentially harmful nature of gambling advertising” and the rules exist to minimise exposure to betting promotions.
The House of Representatives Standing Committee on Social Policy and Legal Affairs has begun an Inquiry into online gambling and its impacts on those experiencing gambling harm, with submissions closing 11 November.
Meanwhile, a year on from the Victorian Royal Commission into the Casino Operator and Licence, Crown Casino have some important work to do in implementing recommendations from the Commission, according to Professor of Addiction Studies and Services at Monash University Dan Lubman.
Lubman, who is also Executive Clinical Director at Turning Point reflects below on what recommendations from the Commission have been implemented and how much is yet to go.
Dan Lubman writes:
When Commissioner Ray Finkelstein delivered his findings from the Royal Commission into the Casino Operator and Licence last October, he lambasted Crown Resorts’ conduct as “disgraceful, illegal, dishonest, unethical, callous, alarming, and exploitative” and concluded Crown was unfit to hold a casino licence.
A year on, it is timely to reflect on how far we’ve come in implementing the Royal Commission’s recommendations, and how far we’ve still to go.
Oversight has been improved
The Royal Commission found that the Victorian Commission for Gambling and Liquor Reform lacked the ability to impart meaningful disciplinary action on Crown Resorts.
It recommended that the regulator be given greater access to information and that a Special Manager be appointed to oversee and investigate Crown’s operations and override decisions if necessary.
The regulator has since been split in two: the independent Victorian Gambling and Casino Control Commission, and the Victorian Liquor Commission within the Department of Justice and Community Safety. Stephen O’Bryan QC was appointed as the new Special Manager in January this year.
The first Special Manager’s activity report revealed they have been busy establishing the office and meeting with key Crown staff and board members.
While the Office of the Special Manager must regularly report to the Victorian Government, the rest of us will likely have to wait for their final report due at the end of 2023 to see whether they think Crown has done enough to redeem itself.
Anti-money laundering measures
To prevent money laundering, the Royal Commission recommended that Crown maintain only a single bank account for each patron’s transactions and enforce cashless play for all transactions of more than $1000.
These important changes have been implemented, with any casino patron wishing to gamble more than $1000 now needing to show identification and use pre-loaded, casino-issued cards to do so.
While carded play has been mandated for amounts over $1000, the Royal Commission urged that we go further and make carded play compulsory for all gambling at the casino.
It also recommended that records identifying all people entering the casino should be maintained. Notably, these anti-money laundering measures won’t apply at other gambling venues across there state where the criminal practice is also a major concern.
Mandatory pre-commitment
Another of the Royal Commission’s recommendations was for the voluntary pre-commitment system YourPlay launched in 2015 to be made mandatory for Australian residents gambling on poker machines at Melbourne Casino. This mandatory pre-commitment scheme will also prohibit poker machine play to no more than 3 hours in one sitting, 12 hours in a 24-hour period, and 36 hours in a week.
Unfortunately, while mandatory pre-commitment is better than voluntary pre-commitment, a fundamental design flaw of YourPlay currently is that players can set their time and spend limits to ‘no limit’, and those who have reached their time or spend limit can simply remove their YourPlay card and continue gambling.
Understanding of this, the Royal Commission recommended that when pre-set time or loss limits for poker machines are reached that those limits cannot be altered for 36 hours.
Importantly, limiting the mandatory nature of the pre-commitment only to poker machines and only at Melbourne Casino, means that it doesn’t apply to other forms of gambling at Melbourne Casino, or any form of gambling at hundreds of venues all over the state.
We can do better, and we need not look far for inspiration.
Tasmania has just announced a state-wide mandatory pre-commitment scheme that covers poker machines at any venue including hotels, clubs and casinos. The player card gaming scheme will also have default spending limits of $100 per day, $500 per month, and $5000 per year that can be lowered by players and increased only within certain parameters.
We need to address gambling harms across the board.
Last week’s Gambling Harm Awareness Week reminded us of the importance to call out the elephant in the room.
The fact is all forms of gambling, not just designed-to-addict poker machines, can and do cause harm.
The Royal Commission reforms are welcome, but their limited focus on Crown Casino means that even once they are fully implemented people will continue to experience gambling harms unchecked online and at hotels, pubs, and clubs right across Victoria.
Important steps
Crown Casino and the Victorian Government have started taking important steps to limit the potential for misconduct and reduce gambling-related harm to casino users.
However, recommendations yet to be acted on include limits on shareholding arrangements, a majority independent board, and expanding the functions and powers of inspectors so they can effectively monitor conduct on the casino floor and have unfettered access to all areas of the casino.
There’s still much to be done, and little more than a year left for Crown to get its house in order and become worthy of keeping its casino licence. For once, the odds are not in Crown Casino’s favour.

Professor Lubman has worked across mental health and drug treatment settings in the UK and Australia. His research is wide-ranging and includes investigating the harms associated with alcohol, drugs and gambling, the impact of alcohol and drug use on brain function, the relationship between substance use, gambling and mental disorder, as well as the development of targeted telephone, online and face-to-face intervention programs within school, primary care, mental health and drug treatment settings.
Also read this previous Croakey article: Star Sydney suspension: how do casino operators found so unfit get to keep their licences?
Finding help
Gambling help: For free 24/7 gambling support, call 1800 858 858 or contact www.gamblinghelponline.org.au
Lifeline 13 11 14 www.lifeline.org.au
Suicide Call Back Service 1300 659 467 www.suicidecallbackservice.org.au
Kids Helpline 1800 55 1800 www.kidshelpline.com.au
MensLine Australia 1300 78 99 78 www.mensline.org.au
Coronavirus Mental Wellbeing Support Service 1800 512 348
Head to Health National Phone Service (1800 595 212, www.headtohealth.gov.au)
Head to Health Adult Mental Health Centres (www.headtohealth.gov.au/supporting-yourself/adult-mental-health-centres)
QLife – phone peer support service by LGBTIQ+ peers for all ages. 3pm-midnight. 1800 184 527 or webchat www.qlife.org.au
If you are concerned about suicide, living with someone who is considering suicide or bereaved by suicide – the Suicide Call Back Service is available at 1300 659 467 or www.suicidecallbackservice.org.au.
Help with alcohol and other drugs: For 24/7 free, confidential alcohol or other drug support, contact www.counsellingonline.org.au or call the National Alcohol and Other Drug Hotline 1800 250 015 to speak to someone in your state. Click here to find out more.
See Croakey’s extensive archive of articles on the commercial determinants of health.