The Macau authorities issued – during the period from May 9, 2016, to April 16 this year – a total of 71 verbal cautions to casino patrons for their alleged violation of an instruction banning use of telephones while at any of the city’s gaming tables, the city’s gaming regulator told GGRAsia in a written reply. A majority of the warnings – 49 in total – were issued between January 1 and April 9 this year, added the Gaming Inspection and Coordination Bureau in its email.
The tableside telephone ban had come into effect on May 9, 2016. Steve Wynn, chairman of Macau casino operator Wynn Macau Ltd, said shortly after the government’s announcement – made several days before the ban was imposed – that it meant an end in the Macau market to betting via telephone. Such activity is also known in the industry as ‘proxy’ betting because of the use of a person or ‘proxy’, physically present at the gaming table but making a bet as per telephoned instructions, on behalf of someone outside the casino.
Prior to May 2016, Macau VIP clients could use their phones at the casino table while gambling, provided that they had registered for that purpose.
The gaming bureau – also known by its Portuguese acronym DICJ – said, in its reply to our enquiry on the number of people warned on tableside phone use since its May 2016 instruction: “Since those patrons that received verbal cautions usually stop using the phone once being reminded, no irregularities were detected in their play afterwards.”
The bureau added: “Since the banning of phone usage at gaming tables on May 9 last year until now, among the alleged violations detected by DICJ, none of them have irregularities that we have to further pass to the Judiciary Police for follow-up action.”
Earlier voluntary ban
In October 2014, long before the bureau instruction, GGRAsia had learned that at least one Macau operator – Sands China Ltd – had told its Macau junket partners that proxy betting would no longer be tolerated.
An industry source with knowledge of the matter told us at the time the move was connected to the firm’s “leadership role on compliance-related matters in general”.
One problem with telephone betting, say several gaming lawyers spoken to by GGRAsia, is that the practice risks creating a loophole regarding the “know your customer” protocol. Such a protocol is encouraged under best international practices on tackling the threat of money laundering.
Shortly after Sands China’s reported moratorium on telephone betting, it was rumoured that another Macau casino operator – concerned about regulatory risk associated with anti-money laundering rules – had also imposed a voluntary ban.
In a May 2016 note, Daiwa had estimated – based it said on conversations with junkets and other industry participants – that Macau market telephone betting grew about 15 percent year-on-year in 2015, to account for approximately 20 percent of junket gaming volume in Macau that year, compared to 8 percent to 10 percent in 2014.
Even after Macau’s official ban on use of telephones at tableside came into effect in May 2016, there were rumours of telephone use at gaming tables.
In April this year, Macau’s Judiciary Police arrested seven mainland Chinese men over their alleged involvement in what the police termed illegal betting worth US$1.3 million, by gamblers from China making use of the social messaging service WeChat. It is thought the suspects arranged for gamblers to place their bets on the results of some actual VIP baccarat games in the city’s casinos.
But Tam Weng Keong, a Judiciary Police spokesman, told GGRAsia at the time: “So far, we haven’t found any signs of a collaboration between these suspects and the local junkets.”
At the time of the May 2016 instruction on use of telephones at tableside, the gaming bureau didn’t clarify what sanction might be imposed, and on whom, were the instruction not heeded.
Under Macau Law No. 16/2001 there is a prohibition on “interactive gaming,” which is defined as entering in and participating in a game using a telecommunications device. But legal opinion has been divided on the topic of whether someone outside the casino – albeit giving instructions on the telephone to someone who is at the gaming table – could be said to be “participating” in a game.
Live video streaming of Macau VIP room games for the purposes of allowing people outside to bet on games has always been considered a prohibited activity in the Macau casino market.
Any violation against the gaming bureau’s ban on use of telephones at Macau gaming tables could under certain circumstances lead to the risk of a person or persons being charged with the crime of illegal gambling, said Kwok Chi Chung, president of the Association of Gaming and Entertainment Promoters, when asked by GGRAsia about the gaming bureau’s warnings to some gamblers. Mr Kwok was – from 2003 and until his retirement in August 2010 – the first head of the Judiciary Police force’s gaming-related and economic crimes investigation unit.
Regarding the specific matter of junket room proxy betting, Mr Kwok told us: “From what I heard, the licensed junkets here – especially the big ones – have been compliant with the Macau authorities’ ban [against tableside telephone use],” He added: “For the big junkets in particular, they don’t need to rely on proxy betting for making profits,” he added.
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”I don’t see this project [Lisboeta Macau] will just go for the existing market clientele. The clientele I’m going for is… family [travellers]. This is a four-star resort and the pricing will be benchmarked against other four-star hotels in Cotai.”
Director of Macau Theme Park and Resort