The NSW Government established the Independent Panel on Gaming Reform as part of its commitment to gaming reform in NSW and to oversee an expanded cashless gaming trial.
Clubs, hotels and gaming machine technology providers were invited to participate in the cashless gaming trial in September 2023.
The primary practical objective of the trial is to ensure any cashless gaming rollout is feasible without unduly impacting industry, whilst also minimising gambling harm and money laundering risks.
Specifically, the trial objectives are to:
Examine the feasibility and acceptance of implementing cashless gaming technologies in all clubs and hotels in NSW and in doing so to gain insights from the technology on:
The Independent Panel has established minimum requirements for applicants wanting to take part in the cashless gaming trial. These include:
A digital payment platform (i.e., digital wallet) OR
A cashless player card AND/OR
Approved by the Independent Panel based on an assessment of the minimum technical requirements AND
Preferably able to interface with any approved gaming machine or system regardless of the manufacturer or venue.
Customer due diligence, including Know Your Customer (KYC), procedures as required by the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 and the Anti‑Money Laundering and Counter‑Terrorism Financing Rules Instrument 2007 (No. 1)
Mechanisms to ensure that players hold only one account per cashless product
Mechanisms to ensure that the movement of funds to and from the technology is from a verified source (an Australian bank account or linked debit card)
Mechanisms to ensure that any cash top-ups of a cashless product are limited to $1,000 per day
Mechanisms to ensure that the movement of funds to and from the technology to gaming machine/s is fully trackable
Ability to make tracked player data available to Liquor & Gaming NSW (L&GNSW) and law enforcement agencies immediately on request.
C1.
Effective risk assessment and management systems in place that identify risks, establishes and maintains controls designed to mitigate these risks, and monitors these controls to ensure they are effective
C2.
An incident management and response plan detailing the actions to be taken in the event of a cyber- attack, major outage, or significant disruption to the system.
C3.
A list of the roles and responsibilities of all parties that are contracted or subcontracted to provide services connected to or in association with the cashless gaming technology solution
C4.
Contemporary information security practices including technological controls to ensure player funds and information cannot be accessed or used by third parties
C5.
Deployment of a robust digital financial system that is PCI DSS compliant to ensure integrity and security of payment transactions and/or storage of funds
C6.
Assurances that all data collection, storage, security, use, disclosure, access and correction of information associated with the cashless gaming technology (including gaming systems, payment systems, cloud storage etc) comply with the relevant provisions from the Privacy Act 1988 (Cth) including the Australian Privacy Principles and the Gaming Machines Act 2001
C7.
The ability to provide the Panel or the regulator with high level system architecture documentation outlining the flow of information, data storage and governance
C8.
Data and privacy rules to ensure player data cannot be unlawfully accessed or shared, used for target marketing or other strategies intended to encourage or increase gambling
C9.
The ability to provide authorised researchers with secure and de-identified player data with consent for the purpose of the trial evaluation
C10.
A decommissioning plan that includes archiving of project information but does not preclude access to the data set for researchers.
D1.
Prohibiting minors from accessing or using the technology
D2.
Ensuring players actively provide or opt-out of an individual daily deposit limit immediately prior to making their first deposit of funds
D3.
Providing players with customisable gambling spend and time limit options using the technology, allow players to immediately decrease their set limits and require a delay of at least 24 hours for players wanting to increase their limits. Gaming machine play using the technology will be disabled when limits are surpassed
D4.
Providing players with real-time access to easily interpretable play information summaries using the technology
D5.
The ability to interface with external systems to verify individuals excluded from the trial venue/s and prevent them from using the technology to fund gaming machine play
D6.
The ability for players to self-exclude (six months or more) or ‘take-a-break’ (24 hours minimum) from the trial venue/s using the technology
D7.
Information about NSW GambleAware support services, including direct links and contact details
D8.
Preventing the use of credit (i.e. credit cards) to fund the technology
D9.
Ensuring players actively choose to deposit funds into the technology (i.e., no automatic top-ups), no default to transfer entire gaming wallet, no pre-set or suggested transfer amounts (e.g. no anchors).
D10.
Maximum gaming balance limit of $5,000, top-up limit of $500, and payout limit of $5,000 that can be directly credited to the wallet. Prize amounts exceeding $5,000 either quarantined for a minimum of 24 hours or transferred to the player’s bank account
D11.
Ensuring players actively choose what to do with prize money if it exceeds $500 but is $5,000 or less (i.e., quarantine funds, withdraw to bank account, continue playing)
D12.
Providing for a delay in accessing additional funds to mirror breaks in play associated with leaving gaming areas to obtain funds from ATMs
A NSW club or hotel where a cashless gaming technology is to be trialled must:
Acknowledge that the Government cannot be held liable for any decreases in revenue or disruptions to standard operations resulting from industry’s participation in the cashless trial
The trial is a hybrid model, that is, gaming machines in the venue and the cashless payment technologies being trialled may still accept cash. The technologies need to ensure that any cash top-ups are limited to $1,000 per day however this limit does not apply to other forms of payment.
Applications from technology providers and licensed venues closed on Friday 13 October 2023.
The Independent Panel has assessed each application against the minimum requirements for the trial as set out above and approved a mix of venues that represent an appropriate balance of venue types, sizes, locations and demographics.
All applicants have been notified in writing of the outcome of their submission.
For more information please contact the Panel Secretariat at ipforgaming@liquorandgaming.nsw.gov.au
