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A mandatory pre-commitment system will unfairly restrict low-risk and recreational gamblers

  • The proposed default expenditure limits are evidence-based to align with recreational gambling levels, so should not restrict recreational gamblers.

  • It is proposed that a careful system be trialled to allow raising of the limits for users with demonstrated financial capacity – a further measure to avoid restricting recreational gamblers.

  • It is critical that pre-commitment is required from all users, as restricting pre-commitment only to those already harmed by gambling will stigmatise the system.

  • It is also not possible to predict which current or new poker machine users will be harmed in the future – mandatory pre-commitment will help to prevent future harms.

  • Mandatory pre-commitment is not an attack on individual freedoms – it is about empowering people to be in control when they gamble.

A mandatory pre-commitment system will encourage gamblers to seek out less regulated gambling products, eg online products

  • The Alliance is concerned about the growth in online gambling and calls for stronger regulation of online gambling products, to prevent and reduce harm.

  • The harms caused by online gambling do not represent an excuse to fail to act on the harms caused by poker machine gambling.

  • There is no evidence, here or overseas, that the introduction of mandatory gambling cards drives recreational players to other forms of gambling, including illegal online casinos.

  • Any administrative burden will be minimised by a consistent, well planned national system across Australia, with support including training for employees in the industry, to assist in its implementation and efficient administration.

  • Following initial implementation costs, there may be efficiencies for venues.

  • The Tasmanian Liquor and Gaming Commission has noted that the introduction of mandatory cashless gambling cards for poker machines will incur a one-off expense for the industry and the regulator; the Tasmanian Government in their response to the Commission’s report note: “The Government anticipates that venues will retain a greater percentage of their turnover under the new… arrangements than under the current arrangements even taking into account the costs of card-based systems.”

Such a system will be cumbersome to administer

Cashless gambling is associated with a loss of the gambler’s emotional connection to value, ie they don’t feel they are losing “real money”

  • The “tokenisation” of gambling definitely carries a risk that gamblers lose their emotional connection to value.  This is why the inevitable move to cashless gambling requires strong safeguards to be in place, through a full mandatory pre-commitment system for all poker machine users.  

There is a lack of evidence that a mandatory pre-commitment system will reduce gambling harms

Cashless gambling may facilitate money laundering

  • This is false.  There is significant evidence from Norway – the first country to introduce a full pre-commitment system – that a mandatory pre-commitment system can greatly reduce gambling harms.  Further evidence will emerge from other countries, including Australia, as full pre-commitment systems are introduced.

  • The evidence of ineffectiveness of voluntary and anonymous systems is clear, but should NOT be extrapolated to indicate lack of effectiveness of a mandatory pre-commitment system.  The failures of partial/voluntary/anonymous systems are expressly due to the fact that they are not universal and mandatory.

  • False.  In fact, the lack of mandatory cashless gambling cards facilitates criminal activity via EGMs. 

  • The NSW Crime Commission’s 2022 report on money laundering via EGMs in hotels and clubs found significant evidence of criminal activity related to EGMs, including compelling evidence that drug users are gambling on a large scale via EGMs with the proceeds of their crimes.

  • The Commission found that mandatory cashless gambling “will minimise money laundering associated with EGMs by removing anonymity and increasing traceability of EGM-related transactions”.

  • The Commission further found that “Introducing a voluntary system (where gamblers can opt to use either cash or a player card) will not address money laundering as criminals dealing with the proceeds of crime will simply use cash… hybrid player card systems could be exploited to make ‘cleaning’ easier”.

The Alliance for Gambling Reform calls on all Australian jurisdictions to introduce a requirement for mandatory, registered cashless gambling cards for use with Electronic Gaming Machines (EGMs, otherwise known as poker machines or “pokies”) in all venues that have EGMs, including hotels and clubs as well as casinos. There is compelling evidence that a mandatory cashless gambling card will help minimise the harm caused by gambling, and will have the additional benefit of addressing criminal activity related to EGMs. READ OUR POLICY.

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