ACCESS SYSTEMS PTY LTD
`
`Submission
`
`To
`
`The Productivity Commission Inquiry
`
`Into
`
`Australia’s Gambling Industries
`
`October 1998
`
`

`

`CONTENTS
`
`1. EXECUTIVE SUMMARY......................................................................................... 2
`
`2. INTRODUCTION ...................................................................................................... 3
`
`3. ACCESS SYSTEMS PTY LTD.................................................................................. 3
`
`4. THE MARKET........................................................................................................... 3
`
`5. THE ISSUES IDENTIFIED BY THE COMMISSION ............................................... 4
`
`0 5.1. To what extent will the new technologies change the way gambling is offered to
`people? Will it significantly open up gambling opportunities to new groups of people? 4
`5.1.1 Separation of the player’s terminal from the gaming organisation.
`4
`5.1.2. The current demographics of Internet users are very different
`5
`0 5.2 How could access be restricted to adults?
`5
`1 5.3. Security of financial transactions, the integrity of the supplier and of the game.
`5.3.1 Payment System 5
`5.3.2 Security
`6
`6
`0 5.4. Current regulatory responses
`1 5.5. How does interactive gambling differ from other home based gambling such as phone
`betting?
`7
`8
`2 5.6. How will tax be levied on the industry?
`8
`3 5.7. Should the States and Territories adopt the same legislation and tax regime?
`4 5.8. Can regulations stop non-Australian jurisdictions offering gambling products which
`do not meet Australian standards? 8
`6. PLAYER PROTECTION, SELF PROTECTION AND PLAYER CONTROL ........... 9
`
`5
`
`9
`0 6.1. Internet Gaming System Features
`9
`6.1.1 Self Control and Self Help
`1 6.2. Operator and Government Control 10
`0 6.3. Probity
`11
`
`1
`
`

`

`1. EXECUTIVE SUMMARY
`
`This submission addresses the issue of new technologies such as the Internet. Access Systems is in a strong
`position to comment on the implications of new technologies by virtue of both having a developed Internet
`gaming product and an existing customer base. The Internet on-line cash gaming and wagering market is
`already large and growing fast internationally, mainly based in non-regulated parts of the world. Australia has
`taken the lead in licensing Internet gaming, giving Australian regulators and Australian companies the
`opportunity to set high standards for the world to follow in managing and controlling gambling including its
`social consequences. This leadership decision also provides Australian companies with opportunities to take
`the international lead in developing a secure, reliable, auditable, high performance on-line cash based gaming
`and entertainment systems.
`
`The Internet opens up gambling opportunities to new groups of people and will represent the only means
`available to some. It changes the way gambling is offered because the Internet differs greatly from all other
`gambling environments in many ways. By collecting data by player for example on what games are played,
`when, how many times, for how long and with what results, Internet gambling systems are much more able to
`closely monitor and control an individual player’s activity and habits than in traditional gambling venues. For
`example the minimum betting age can be effectively controlled, by jurisdiction if required.
`
`Most Internet gaming players are a different group to typical gamblers in traditional forms of gambling. We
`conclude that much traditional gambling will be unaffected by the availability of Internet gambling and that it
`is unlikely that problem gambling will increase as a result of its growth. Resources should be set aside to
`collect and analyse the trends as well as to handle the situations identified.
`
`Properly designed, an Internet gaming platform enables secure financial transactions. An Internet gaming
`system must implement high security of its own. The system should restrict staff access to the system to what
`is necessary to run the site. Information held about a player must be held securely, and access to it only
`granted for legitimate purposes. Players must be protected against potential financial loss as a result of a
`failure of the Internet gaming system or its communications links. Players need to be assured that the games
`available at a legitimate Internet gaming site are completely fair.
`
`Australian regulators are taking the lead and breaking new ground in regulating the operation of Internet
`gaming. Thus the process involved in issuing government certification and in elucidating the features
`considered essential for an Internet gaming system is being progressed carefully. In future it will be important
`that regulatory processes are sufficiently flexible to allow gaming sites to introduce changes and new games
`without undue delays. Regulators, as a matter of good practice, will probably need to re-examine ways of
`protecting problem gamblers. This is an area in which licenced on-line Internet software provides greater and
`different opportunities on data collection, analysis and control than in traditional gambling venues.
`
`Individual States are striving to co-ordinate their regulatory and tax requirements, including taxation levels. It
`is not considered practical to change this situation. Federal and State governments should be encouraged to
`take a common approach to regulation, preferably through co-operation between states - as in the Draft
`Regulatory Model. Any change in legislative structure would delay the introduction of regulated Australian
`gaming sites. Australian governments (at whatever level) would lose revenue and control. Investment put into
`developing licenced Internet sites would be wasted while the rest of the world catches up and passes Australian
`regulatory standards and technology.
`
`There are no known practical means by which an Internet player can be prevented from gambling on an
`international site on products which do not meet Australian standards.
`
`2
`
`

`

`2. INTRODUCTION
`
`Access Systems submits the following information for consideration by the Productivity
`Commission in response to the inquiry into Australia’s Gambling Industries.
`
`Our submission addresses the issue of new technologies “(such as the Internet)” referred to in
`3. (f) of the Scope of the Inquiry.
`
`Access is in the forefront of the development and use of Internet gaming software for the
`regulated gaming and wagering markets internationally. Therefore the comments made in this
`submission on the technology section of the Terms of Reference are made from practical
`experience.
`
`Access would also welcome the opportunity to demonstrate Internet gaming to the
`Commissioners involved in this inquiry and to debate the issues
`
`3. ACCESS SYSTEMS PTY LTD
`
`Access was established in 1991 and operates in Australia and Europe with headquarters in
`Sydney. The company has developed a world lead in licenced on-line Internet gaming systems.
`The Access gaming platform, called ACES, provides licenced gaming operators with a secure,
`reliable, auditable, high performance on-line cash based gaming and entertainment system and
`includes a broad range of innovative games (on screen table games, slot machines etc). The
`system includes a strong security model, isolation of sensitive data and a strong encryption
`process. The group has, to date, invested $7m on product development and employs a highly
`qualified and a skilled development team of over 35 engineers. The practical experience of the
`company with live product dates from early 1996.
`
`Access is in a strong position to comment on the implications of new technologies by virtue of
`both having a developed product and an existing customer base of substantial licenced Internet
`gaming operators in Australia and internationally. All its customers are government licenced
`operators and include two clients in Australia and a European national lottery. Access has
`worked closely with government regulators to ensure the product and the technology
`adequately fulfill the regulatory requirements. One of Access’ existing Australian customers is
`poised to become the first major licenced gaming organisation to offer worldwide cash based
`gaming on the Internet. This will result in ACES becoming a “certified” platform.
`
`4. THE MARKET
`
`The Internet is a fast growing borderless means of communication. The number of users is
`expected to increase from 100 million to 1 billion by the year 2005. The usage is doubling
`every 100 days. With the rapid development of on-line gaming, it is already possible for
`customers to gamble on the Internet. Over 150 Internet gaming and wagering sites have been
`identified worldwide. The majority of these are based in ‘tax effective’ regimes with little
`regulatory control. Already there is a leakage of Australian tax revenues from gaming to
`potentially questionable gaming operators overseas.
`
`3
`
`

`

`Recent studies published on the international turnover include estimates of the 1997 market
`which range from $450 million to $2b. (source Merrill Lynch and Frost and Sullivan ). The
`industry magazine, International Gaming and Wagering Business (IGWB), has estimated that
`the Internet gaming market would grow to a turnover of US$25.4 billion by the year 2000
`from below US$5bn currently.
`
`5. THE ISSUES IDENTIFIED BY THE COMMISSION
`
`The Commission ‘Issues Paper’ September 1998 identifies a number of matters which it
`considers should be understood and debated. The particular matters raised in the technology
`section of the paper are outlined as follows together with our comments.
`
`To what extent will the new technologies change the way gambling is
`0 5.1.
`offered to people? Will it significantly open up gambling opportunities to new groups of
`people?
`People gamble for a variety of reasons. Some of the reasons, such as the social aspects, are
`different in the Internet environment. For example the entertainment and mood created in
`casinos will not be present on a PC at home. Internet gaming makes gambling more accessible
`to new groups of people and will represent the only means available to some - especially those
`living in remote locations or housebound provided they have on line facilities. It changes the
`way gambling is offered because the Internet differs greatly from all other gambling
`environments in many ways. For example:
`
`5.1.1 Separation of the player’s terminal from the gaming organisation.
`Two of the many implications of this are:
`• After downloading the software to play, a competent programmer may try to tamper
`with it to gain advantage. Slot machines in a club are trusted to generate their own
`results whereas a PC in someone’s home cannot be so trusted. The player of a machine
`in a club will not have enough time to defeat its tamper-proofing; a player at home has
`all the time in the world, and tamper-proofing is impractical. With a well-designed
`system, the risks accruing from tampering with games software are low, and unlikely
`to cause major damage to the server site.
`• Electronic communication through public networks is sometimes unreliable and it is not
`possible to tell whether there is intrusion on the line. Systems must be designed with
`these things in mind, and it is beneficial if critical information is sent via a separate
`medium (eg. by fax).
`
`These factors and others in the on-line Internet software environment lead to security
`challenges quite different and more complex than has been faced before. Proper security
`features are vital. Software technology enables the platform to tackle this because
`Internet gambling systems are much more able to closely monitor a player’s activity and
`habits than in traditional gambling activities for example by collecting data by player on
`what games are played, when, how many times, for how long and with what results. Thus
`these systems are able to provide powerful means to monitor and control the amount a
`
`4
`
`

`

`player bets -and may also limit a player’s gambling in other ways, such as the length of
`time they wish the system to permit them to gamble (say, 10 hours per week).
`
`Internet gaming systems can thus provide protection against the factors described above.
`
`5.1.2. The current demographics of Internet users are very different
`Internet gaming players are a different group to those of typical gamblers in traditional
`forms of gambling. Access understands that most problem gambling occurs with poker
`machines played by the less well off in society. If this is the case, we consider that these
`are the least likely to have access to home computing and the Internet. This indicates a
`relatively low level of transfer of gambling from traditional venues to the Internet - from
`which one may conclude that Internet gaming is likely to be in addition to existing
`gambling, rather than replacing it in part.
`
`We conclude that much traditional gambling will be unaffected by the availability of
`Internet gaming and that it is unlikely that problem gambling will increase as a result of its
`growth.
`
`No one really knows what effect Internet gambling will have. A properly designed licenced
`system gathers huge quantities of raw data automatically, as a standard part of an Internet
`gaming system, so it will be a relatively minor step to develop software to analyse this data and
`search for patterns of behavior within prudent limits on privacy. Planning should be put in
`place early to select and analyse data gathered on real Internet gambling activity. Access would
`be interested in assisting in this area, with the prospect of using these patterns to identify
`possible problem gamblers in live systems.
`
`0 5.2 How could access be restricted to adults?
`
` The age of each player can be checked as part of the registration process, and only players
`verified as adults allowed to bet for cash or receive winnings. The minimum betting age can
`be specified per jurisdiction - so if a jurisdiction demands players be over 21 before they can
`bet, it can be enforced.
` Each player’s residential address can be checked during registration. This address can be
`compared against addresses for credit card accounts and that supplied for posting winnings
`cheques. Addresses can also be compared against independent sources such as the electoral
`roll. The system can be configured to only allow players from nominated locations (country
`and/or state) to bet and to exclude players from barred locations.
` A gaming operator may themself exclude a particular player. They may do this at the player’s
`request, at the government’s request (as stipulated in the Draft Regulatory Model and
`subsequent regulatory regimes - such as in Queensland), or done by the operator for some
`other reason.
`
`1 5.3.
`game.
`
`Security of financial transactions, the integrity of the supplier and of the
`
`5.3.1 Payment System
`Properly designed, Internet gaming software enables secure financial transactions. The
`primary method is the use of an electronic purse which has to be funded prior to the player
`5
`
`

`

`being able to play, and into which winnings are paid. Funding of this purse can be by
`transfer from credit card, Secure Electronic Transactions (SET), Bill Payee (B-Pay),
`electronic cash (Digicash), Pre-Paid Cards, cheques and direct credit.
`
`5.3.2 Security
`Security features, of diverse types, are by far the most important parts of an Internet
`gaming system - because without them no site can run without unacceptable risk. Security
`measures can be classed according to the type of protection they afford to players. Among
`the most important are the following:
`• Protection from ’hackers’. The Internet is an open, global network which
`provides little protection for communications between users and Web sites, and
`little protection to sites themselves. An Internet gaming system must implement
`high security of its own, to protect communications with players and to defend the
`site, especially player data, against ’hackers’ (using firewalls, encryption of data in
`the database, access control, and numerous other steps).
`• Protection from gaming organisation staff. The system should restrict staff
`access to the system to what is necessary to run the site. Dual authorisation is
`important for sensitive tasks. Some tasks may be performed by both Government
`and gaming organisation staff, and need to be authorised accordingly.
`• Player privacy. Information held about a player must be held securely, and access
`to it only granted for legitimate purposes. Only operators involved in customer
`support will generally be able to view the information about a particular player on
`request.
`• Protection from disaster at site. Players must be protected against potential
`financial loss as a result of a failure of the Internet gaming system. Relevant steps
`include duplication of site hardware (especially of the database), storing of data
`off-site in real time, and adequate procedures to minimise the chance of such a
`failure. (Access has first hand experience of a system failure leading to loss of
`game data and player balances at a Caribbean Internet gaming site.)
`• Player Fairness. Players need to be assured that the games available at a legitimate
`Internet gaming site are completely fair. There are a number of aspects to this: that
`the odds of winning are as they should be, that the odds are displayed, the rules and
`behaviour of the games are clear, that all other players are treated in the same
`manner, and so on. This is achieved in several ways, including providing adequate
`information to the player when playing, and providing government regulators with
`the ability to verify game behaviour and the statistical distribution of game results.
`
`Current regulatory responses
`0 5.4.
` Australian regulators are taking the lead and breaking new ground in regulating the operation
`of Internet gaming. Since the draft regulatory model was published in May 1997, the states and
`territories have done extensive work on the practical aspects of specific legislation, regulation
`and technical requirements. Access has been working on a day to day basis with agencies for
`over 12 months now. Whilst the process involved in issuing government certification and in
`elucidating the features considered essential for an Internet gaming system has been lengthy
`
`6
`
`

`

`(and therefore occasionally frustrating), it has been encouraging that high standards have been
`adopted.
`
` Apart from the government regulatory bodies, experienced testing houses such as BMM
`(Bellamy, Miller and Moneypenny) and GGS (Global Gaming Systems) have been involved,
`along with audit and security experts such as Ernst & Young and Deloittes.
`
` The draft regulatory model has promoted a new level of openness between the states and
`territories resulting in the sharing of information and more common standards. Whilst there are
`some different perspectives between the jurisdictions, these are largely specific to
`implementation rather than intent. All the jurisdictions and the operators we have dealt with
`show a very high level of responsibility on both the social and technical aspects of Internet
`gaming.
`
` The Internet is a fast-moving environment, where users expect new developments to occur
`very rapidly and where new technology becomes available at a dizzying pace. It will be
`important, then, that regulatory regimes are sufficiently flexible to allow gaming sites to
`introduce changes and new games without undue delays. This probably requires changes to
`existing processes for approving new games (say, slot machines).
`
` To date, the responsibility regulators have taken most seriously is player fairness. This is a
`developing area due to the many aspects of Internet gaming which existing principles do not
`cover – for example multi-player games.
`
` Regulators, as a matter of good practice, will probably need to place more emphasis on aspects
`other than player fairness - especially protecting problem gamblers. This is an area in which
`licenced on-line Internet software provides greater and different opportunities to take steps to
`identify and limit problem gambling. As has been mentioned elsewhere in this document,
`Internet gaming systems facilitate player protection steps (including self-protection) which are
`not possible in other gambling environments. Some further detail is given under item 6 of this
`submission. However it is important to avoid setting technical goals which are impossible to
`achieve and to realise that, as with physical gaming and wagering venues, watertight, infallible
`security is impossible. Access is putting further thought into these issues.
`
` An example is the potential for regulation to require site operators to provide adequate self
`control and assistance to control the amount and the time use in gaming. Operators would be
`able to provide to players messages about how long they have been playing and possibly to
`give hints that it is perhaps time to stop.
`
`How does interactive gambling differ from other home based gambling
`1 5.5.
`such as phone betting?
` The key difference is indicated by the name used for this new form of gambling: it is
`interactive. Phone betting offers a purely functional mechanism for the placing of bets, and has
`no entertainment value of its own. Interactive gambling offers its own entertainment.
`
` Virtually all other types of commercial betting available from the home have their outcomes
`determined by events which occur at a pre-determined time (eg. the running of a horse race, or
`
`7
`
`

`

`a lotto draw). Interactive gambling offers real-time games, with results generated for each
`player on request. This provides a much faster bet-play cycle As in all gaming, the player has
`to make a conscious decision to stop.
`
` A further aspect of the interactiveness of this form of gambling is the degree to which it is
`similar to other computer-based games - which are very popular among teenagers and younger
`children. That is, the step from these games to gambling is considerably narrowed, so measures
`to prevent under-age Internet gambling must be much stronger. Gaming organisations (and
`system developers such as Access) are developing more exciting games - which is likely to
`reduce this distinction still further. Clear guidelines need to be developed setting an acceptable
`standard.
`
`How will tax be levied on the industry?
`2 5.6.
` The extensive data gathering, reporting and operator control features of the ACES on-line
`gambling software provide excellent capability to account for taxation purposes.
`
`Should the States and Territories adopt the same legislation and tax
`
`3 5.7.
`regime?
` Australia is at the forefront of regulated Internet gaming at the moment. It is to the nation’s
`advantage that high international standards are set for the world to follow and tax revenues
`from the gaming industry are sustained as the world moves to Internet gaming and wagering.
`
` All gaming taxation and regulation in Australia is currently firmly the responsibilities of the
`states and territories. Some states are more advanced than others with the introduction of
`legislation and regulation for Internet gaming. The states appear to be co-operating
`successfully via the Draft Regulatory Model process, and it seems likely that the key aspects of
`legislation, regulation and taxation will be handled consistently across the country. Any
`change in legislative structure would delay the introduction of Australian licenced Internet
`gaming, to the advantage of operators overseas. That is, it may delay the introduction of
`regulated Australian gaming sites for an extended period. In the interim, development work
`and investment put into developing licenced Internet sites would be wasted while the rest of
`the world catches up and passes Australian regulatory standards and technology, and
`Australians will gamble at overseas sites. Australian governments (at whatever level) will
`consequently lose revenue and control.
`
` Current physical gaming operators may be concerned about additional competition from
`Internet gaming. It must be recognised that Internet gambling is already available and in use
`from over 150 sites. Attempts to stop the tide will only lead to Australia losing tax revenue
`and being left behind technically. Any recommendation that has this effect would have to be
`based on detailed and factual evidence and powerful logic including an explanation of how
`Internet gambling on international sites is to be prevented.
`
` Federal and State governments are being encouraged to take a common approach to
`regulation, through co-operation between states - as in the Draft Regulatory Model.
`
`Can regulations stop non-Australian jurisdictions offering gambling
`4 5.8.
`products which do not meet Australian standards?
`
`8
`
`

`

`The simple answer is ‘NO’. The open nature of the Internet makes it impractical to prevent
`users from accessing whatever Internet sites they wish, so if Internet gambling sites exist
`somewhere in the world, then players will be able to bet at them. The steps needed to prevent
`them are such that no government is likely to give serious consideration to the legislation
`required or the means needed to enforce it. In any case, the possible preventative steps are
`unlikely to be particularly effective.
`
`6. PLAYER PROTECTION, SELF PROTECTION AND PLAYER CONTROL
`
`The Terms of Reference indicate a concern over the broader questions of player protection and
`self protection and player control. This section discusses the ways in which players can be
`protected from the potential risks and potential dangers associated with Internet gaming. It
`concentrates on the technical and control steps which can be taken.
`
`Much has been said about the potential problems that Internet gaming may cause, and most of
`this document enumerates ways of dealing with such problems. On the other hand many of the
`problems already prevalent in traditional forms of gambling are far more easily
`controlled with the new Internet medium. For example, all of a player's bets are recorded,
`making it much easier to set and enforce limits on how much money a player can lose -
`something which is very difficult in existing betting venues where players can bet anonymously.
`
`The factors involved in player protection can be grouped into three broad types as follows:
`•
`
`Internet Gaming System: the main hardware and software system which runs an Internet
`gaming site, and which is responsible for all of the automated player protection measures.
`• Operator Control System: the supporting regimes, systems, procedures, codes of
`conducts and so on that a gaming organisation needs in order to operate a regulated
`Internet gaming site. This includes physical security (cameras, restricted access, etc.), the
`vetting of prospective employees, accounting systems, payment systems, operational
`procedures and so on.
`• Probity: reassuring the player that he or she is dealing with reputable, trustworthy,
`reliable gaming operators and suppliers, which is achieved by the authorised government
`body granting them an official licence to conduct the business.
`
`0 6.1.
`
`Internet Gaming System Features
`
`
`
` 6.1.1 Self Control and Self Help
` A player must identify themself (log in) whenever they visit an Internet gaming site. This
`makes it possible to control the activity of the player in several ways, the most powerful
`of which is to stop the player exceeding certain betting and play criteria they have
`previously set for themself (ie. bet limits).
`
` 6.1.2. Bet limits.
`These allow a player to control the amount they can bet. A well-designed system will
`support several types of limits: loss limit for a time period (eg. $50 per week), purse top-
`up limits (to restrict the amount of money a player can transfer into their account - eg.
`9
`
`

`

`$100 per week), and individual bet limits (eg. maximum bet $5 - to stop a player losing
`everything in their account in one bet). A player can reduce any limit at any time, but can
`only increase a limit by applying to the gaming operator (who can then institute checks
`to verify the player is not a problem gambler). Bet limits are effective on the Internet, but
`not practical in most traditional forms of gambling.
`
` 6.1.3. Self-exclusion.
`A player can bar themself from the Internet gaming site at any time. They will then no
`longer be able to bet at the site. The steps a player must take to remove such a self-
`exclusion are a policy matter for the gaming organisation - but may include whatever
`checks an operator feels are necessary to verify that the player is not a problem gambler.
`This is another control which is more effective on the Internet than in the physical world:
`a player may request to be barred from a casino, but this cannot be said to be reliable and
`nor does it work for all types of gambling.
`
` 6.1.4. Player history.
`Systems must keepa history of all the games played and financial transactions made by
`each player. These records are kept at a detailed level and are available on demand to the
`player. This gives each player a much more accurate and complete picture of their
`gambling than is available from other forms of gambling. Players who may have a
`problem may thus identify it earlier.
`
` 6.1.5. Identify gambling sites.
`There are a number of Internet services (eg. “Net Nanny”) which allow Web sites to
`identify what sort of site they are and what activities they offer. Parents can then use this
`special software to deny their children access to all sites in particular categories. All
`gambling sites should register themselves as such with these services.
`
` 6.1.6. Problem gambler sites.
`Direct links to Web sites for problem gamblers can (and should) be prominently
`displayed in gaming sites. Players can thus get help more conveniently and more
`immediately than with other forms of gambling. The Web can provide considerable
`anonymity when using such sites, which may mean gamblers are less reluctant to use
`them than contacting a problem gambling organisation by phone or in person.
`
`
`
` 6.1.7. Email support.
`The gaming organisation can provide prompt e-mail support, and any player with a
`problem should be encouraged to ask them for help if they need it. Operators should be
`alert to players with potential problems.
`
`Operator and Government Control
`1 6.2.
`In addition to providing players with the ability to put controls on their own betting, the
`gaming system must allow operators (and, indirectly, governments) to restrict the activities of
`players and would-be players in accordance with the law and regulations.
`
`10
`
`

`

`The Internet Gaming System automatically handles nearly all player interactions, but the
`running of an Internet gaming site involves a wide variety of other activities. A gaming
`organisation must have a well-trained, professional staff, comprehensive operational
`procedures, suitable physical premises, and various other supporting systems (to perform
`accounting, financial reconciliation and similar administrative tasks). Most of these activities
`are involved in the offering of other types of gambling (especially products with significant
`dependence on technology - such as networks of slot machines), but the importance of such
`control systems is perhaps less visible in Internet gaming, since the main Internet Gaming
`System appears to take care of everything.
`
`The key features a system requires are:
`• Strict registration processes. Most of the other controls discussed in this document
`depend on being able to reliably identify each player, via a login process. This, however,
`relies on making sure the information each player gives about themself is accurate, which
`demands strong registration processes. ACES supports a multi-level registration process
`which, for example, allows a player with on-line registration to bet for small amounts of
`money; that only a player who has independently verified their age can receive any
`winnings (and then only by cheque) but that a 100-point check is required for large bet
`amounts or any transactions that would attract Austrac (money laundering prevention
`agency) attention.
`• Auditability. Aside from being able to run smoothly day by day, an Internet gaming
`system must record sufficient information to be able to satisfy requests in the future to
`recall it. Purposes for which this is necessary include:
`À Report money laundering activity. Aside from all other reasons, a record must be
`kept of all of each player’s financial transactions to facilitate reporting to AUSTRAC
`of any activity which may be associated with money laundering.
`À Dispute resolution. Sufficient information must be recorded about everything a
`player does in order to deal effectively with any dispute or query the player may have.
`An operator also needs a range of inquiries to permit this information to be viewed.
`
`Probity
`0 6.3.
`