Mr. David Hickson:

I thank the committee for the invitation to outline the Gaming and Leisure Association of Ireland’s recommendations and observations on the heads of the gambling control Bill.

The Gaming and Leisure Association of Ireland is a trade association made up of nine private member gaming clubs and online operators. Our members have all signed up to a voluntary code of practice, maintain the best available consumer protection standards and work on an ongoing and positive basis with anti-money laundering authorities, problem gambling experts and the Garda Síochána. Our members enforce strict age verification mechanisms, undertake customer due diligence and player tracking. Our staff are trained to implement responsible gambling policies and identify problem gambling, as well as to offer self-help information to customers when necessary.

Private member card clubs are deemed designated bodies under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010. As such, they are obliged to register with the anti-money laundering unit in the Department of Justice and Equality and must appoint a money laundering reporting officer. The association has developed its own responsible gambling guidelines and literature which shows our commitment to providing our casino services in our communities in a responsible and sustainable manner. I would be happy to circulate this to the committee if it believes it would be helpful to its work.

For the past several years the association has worked with the Government to achieve and implement a workable regulatory regime for our sector. Existing legislation is not fit for purpose and major regulatory gaps exist. Given that gambling services can now be accessed on a 24-7 basis via the Internet on computers, tablets and smart phones, we believe prohibition as a regulatory tool is no longer tenable.

Accordingly, there is a clear need for a fully regulated gambling sector in Ireland and we welcome the parameters around which the proposed legislation is seeking to structure our industry. The legislation before us has the potential to put in place a strong legal framework and, with the right adjustments, will allow for responsible growth in the form of jobs and Exchequer contributions, as well as curtail criminal activity in the sector and protect the most vulnerable from the risks associated with gambling. With a well regulated and sustainable operating environment in place, we believe there is the potential to create a further 500 jobs in the casino industry over a short period; the possibility of generating heretofore untapped tourism streams; and the opportunity to provide gambling in a safe, secure and sophisticated environment. Based on our working knowledge of the industry and drawing on the experience of other regulated jurisdictions, we would like to make the following recommendations. I will then invite questions about both the current sector and its future potential.

A transitional arrangement must be put in place for existing private member gaming clubs so as to allow them to continue to operate and plan for future operations before, during and after the legislation and licensing process are put in place. We welcome the proposed creation of the Office for Gambling Control Ireland, OGCI, but recommend that this regulator be unencumbered by political interference or the appearance of it. Accordingly, "sole authority for the licensing of gambling" and "exclusive authority to grant, renew, revoke and revise any licence" should rest with a regulator with an expertise in the industry rather than the Minister of the day. This regulator must also be supported by adequate and effective enforcement mechanisms that will underpin the legislation from day one.

As profit margins in the casino sector are far lower than many assume, the proposed duration of a casino licence of ten years needs to be lengthened to 15 years so as to enable operators to secure a return on the initial investment required to establish a casino. There is a very modest limit proposed on gaming machines in casinos - 15 gaming tables and 25 machines. Currently, there are approximately 5,600 gaming machines in 57 licensed gaming arcades around the country, with approximately an additional 20,000 in unlicensed venues. Gaming machines are popular, but to make them commercially viable, a ratio of 2:1 will limit operators to higher stakes machines. A higher ratio of 5:1 would encourage operators to provide lower stakes machines also. Therefore, the multiplier regarding the number of gaming machines permitted in a licensed casino should be increased from two to five. We estimate that such an increase would still ensure less than 1% of the gaming machine population post-regulation would be housed in licensed casino venues.

An appropriate taxation level for all forms of gambling is a key component of the success of this regulation in order to prevent the proliferation of black market operators and provide business continuity for those of us operating compliant and regulated clubs. Equally, a taxation structure is required to facilitate the establishment of smaller venues in less populated areas.

All gambling services distribution methods - online or offline, casino, slot machines or sports betting - must be treated in an equitable manner with respect to regulation, licensing conditions and fees, taxation, player protection and supervision. The proposed restriction on opening hours for casinos must be amended in recognition of the fact that land-based casino operators compete directly with their 24/7 online competitors. We welcome the provision for alcohol licences in casinos but recommend that the same restrictions also apply to other gambling service providers. Rules applying to advertising and gambling should apply to all sectors equally. Remote gambling should be established in a manner that incentivises online operators to establish in Ireland, thereby creating a "hub" similar to that in Malta and the Isle of Man and potentially creating up to 5,000 jobs.

The GLAI is very grateful for the opportunity to appear before the committee and for its time in considering the points we have made. We look forward to working with it and the Government in the coming months and years to implement workable, long-term legislation to regulate an industry that has long been in existence in this country and crying out for sensible reform.