The CGC envisions a future in which the RG Framework for local gaming lounges and horseracing is deepened so that resident patrons are better able to access the information, support and other resources that they need to minimize or deal effectively with gaming/gambling-related harm. By Damian Martinez, journalist at G&M News.
Can you elaborate on how the amendments to the Casino Gaming Act in 2021 have positioned Jamaica to attract foreign investment and bolster economic growth?
The 2021 amendments to the Casino Gaming Act enhanced Jamaica’s ability to attract foreign investment in the form of the construction of integrated resort developments by adjusting the barriers to entry. In particular, the required room count for approval of an Integrated Resort Development (IRD) was reduced from 2,000 new hotel rooms to 1,000 new hotel rooms, including rooms which were already under construction at the time of the application. The practical effect of this amendment was to make it possible for projects which are already underway to be approved as IRDs, instead of requiring new builds, as was the case prior to the amendment. The amendment also required 500 of the 1,000 new rooms to be luxury hotel rooms that include facilities, furnishing, amenities and décor that are superior to other accommodation at the hotel, thereby enhancing the product required to be offered by the IRD.
What is the overarching vision for the Casino Gaming Commission, particularly as Jamaica transitions into hosting its first major casinos?
The vision of the CGC is for Jamaica’s casino gaming industry to be the best regionally in compliance, public confidence and profitability; regulated, facilitated and enabled by an innovative, technology-driven employer of choice. If we realize that vision, then ultimately, we would have executed the mission of enabling a viable and reputable casino gaming industry by balancing the interests of providers, consumers, the general public, and the Government.
With the announcement of the first integrated resort development project in Hanover, what are the CGC’s immediate priorities in ensuring a smooth rollout of Jamaica’s casino gaming sector?
We are focused on ensuring that we are ready to receive the first licensing application, and that all stakeholders are aligned to make the commencement of operations of the first casino as seamless as possible. This covers everything, from guaranteeing that we are adequately resourced internally to ensuring that our legislative framework is complete and is sound based on international standards. We also must establish that there is alignment with other stakeholders in the Government of Jamaica who are critical to the onboarding and operational processes of the casino and confirming that we collaborate effectively with the prospective licensee to eliminate bottlenecks where they exist and achieve mutual clarity around processes and expectations.
Your recent paper Implementing an Effective Framework for Securing Player Health in a Tourist Casino User Population – the Jamaican Experiment emphasized embedding responsible gaming practices into the regulatory framework. What are the key pillars of Jamaica’s approach to responsible gaming?
The CGC believes that the nexus for balancing the rights, expectations and obligations of operators of casinos and IRDs, and patrons is a Social Responsibility model that centers transparent decision making aligned with broader societal expectations in furtherance of sustainability for all stakeholders. We believe sustainability is the ultimate goal of all stakeholders in the industry, and we see our role as marshalling the attitudes and resources of the operator of the IRD and the casino to create an environment in which casino patrons are aware of the risks of participating in casino gaming and are able to engage in an informed way in a transparent environment. We also believe that a successful RG model should pay significant regard to the body of research evidence on best practices to prevent harms, including with respect to the connection between marketing strategies and gambling behaviors, while being adapted to the relevant local cultural and legal dictates. I can mention four principles to our RG strategy. The core principle of our RG Framework is that casino patrons, potential patrons and those with responsibility for underage or vulnerable people should have access to data that helps them make informed choices about their gaming and wider gambling choices. The aim is to ensure that patrons of the casino and IRD understand the risks associated with casino gaming and gambling in general and know where to seek help and support if their gaming or that of a family member or associate begins to or has become problematic. The second principle is that the casino operator (and by extension, the IRD operator) has a clear responsibility to minimize gambling-related harm. The framework requires that the casino operator’s commitment to the welfare of its patrons is demonstrated in its internal controls, which must, at a minimum, provide for responsible advertising of casino gaming; the procedures and guidelines to identify and trace any casino patron who is or might be experiencing gambling-related harm; clear and detailed procedures and guidelines with respect to the availability of information, treatment, and counselling services or intervention services to those patrons who might face problems caused by gaming, including displaying responsible gaming messages and information on seeking assistance with problem gambling. Also, they should deliver the operation of an on-demand support program for casino patrons and other guests of the IRD who are affected by gambling-related harms while at the IRD, including through education on suicide and self-harm intervention strategies and protocols; a training program for staff of the casino and the wider IRD that promotes responsible gaming, with training activities that are tailored to include job-relevant information, a training schedule that contemplates training both at recruitment and repeatedly over the course of an employee’s engagement at the IRD or casino, and regular evaluation and revision of the training program to reflect current best practices; and systems for preventing underage or other vulnerable individuals from participating in any gambling or sports betting at casinos, loitering in the gaming area of a casino, or from gaining access to online, mobile, or in-room gambling opportunities. In addition, they should provide exclusion systems for patrons experiencing gambling-related harms; options available for advance limit-setting; systems available for patrons to provide other information to facilitate the monitoring and mindfulness of play over a period of time; and regular review and accreditation of the responsible gambling program to ensure consistency and alignment with international best practice. As a corollary to the second principle, our framework imposes an obligation on the operator of the IRD to practice responsible advertising in relation to the casino and events of the casino, as well as collaborate with the casino operator to ensure that staff of the IRD who are likely to come into frequent contact with patrons receive basic training to enable them to identify the signs of existing or emerging gambling-related harm, and direct patrons to available resources for additional support as needed. The third principle of our framework is based on collaboration to build knowledge around the causes of gambling-related harm and approaches to detect, prevent or minimize it. We have operationalized that collaboration by establishing relationships with subject matter experts and other regulators around the world to facilitate access of the CGC and its licensees to up-to-date data around responsible gaming practices and metrics around the world, and to enable auditing of local RG practices and standards against the CGC’s minimum requirements and international best practice. Fourthly, our framework includes specific Advertising Guidelines which are designed to ensure that marketing communications in relation to casino gaming are socially responsible, with particular regard to the need to protect children, young persons and other vulnerable persons from being harmed or exploited. Importantly, these Advertising Guidelines prohibit the publication of advertisements in respect of casinos and casino gaming by local newspaper, television or radio, or using billboards or other public signage in Jamaica; limit online advertisements to the website and social media accounts of the casino and IRD, and stipulate that the number of advertisements promoted per day will not be excessive, and that no advertisement in respect of a casino or casino gaming may exceed 10 seconds in length; prohibit misleading advertising; and prohibit inducements to gamble, such as welcome offers, or offers of bonus or free bets except through direct advertising and marketing (such as via emails, texts, and phone calls), and only after receiving active player consent. Also, the Guidelines require inclusion of a warning against compulsive or pathological gambling, as well as a reference to the support program provided by the casino being advertised; and prohibit endorsements by persons or characters whose example is likely to be followed by a child or young person, or who has a strong appeal to children and young persons, such as social media influencers, sportspersons, performing artistes and celebrities or popular personalities. Ideally, the CGC envisions a future in which the RG Framework for local gaming lounges and horseracing is deepened so that resident patrons are better able to access the information, support and other resources that they need to minimize or deal effectively with gaming/gambling-related harm. In particular, the CGC would like to see the gaming landscape in Jamaica evolve to the point where there is collaboration among local betting, gaming and horseracing regulators and their respective licensees, as well as with other local stakeholders with whom the CGC is cultivating relationships, with a view to enhancing effectiveness in minimizing the risk and indicia of gambling-related harm for both residents and visitors to Jamaica.
What are the biggest challenges and opportunities you foresee during this transformative period for Jamaica’s gaming industry?
The Commission is excited to welcome the first casino operator, as is the Government of Jamaica as a whole. While we believe that we are adequately prepared to commence casino operations and that our standards and requirements are consistent with international best practice and should therefore be navigated easily by the prospective licensee, we do anticipate that there will be teething pains and a learning curve, as tends to be the case with any new venture. We are mindful that onboarding and regulating our first licensee will test our mettle as a new regulator and we are committed to working closely with the prospective licensee and other stakeholders as we navigate the challenges that may arise either during the onboarding process or thereafter. We are happy that casino gaming will add a new dimension to our tourism product and are even more excited about what this enhanced product will mean for our island economy. We look forward to deepening our relationships with the prospective licensee, other international regulators and other local and international stakeholders as we seek to ensure that this adventure only highlights everything that is good about Jamaica as a destination for tourism and business generally.
