Gaming Law 2025

AUSTRALIA Law and Practice Contributed by: Jamie Nettleton, Samuel Gauci and James Dommett, Addisons

Court hearings took place in June 2025. In these hearings, the court heard, among other matters, argu- ments by the parties in relation to the AUD400 million penalty being sought by AUSTRAC. The Star Entities claimed that the imposition of this penalty would force the Star Entities into insolvency and indicated that the penalty should not exceed AUD100 million. A decision is set to be handed by the Federal Court of Australia. Entain proceedings As noted in the foregoing, on 16 December 2024, AUSTRAC commenced civil penalty proceedings in the Federal Court against Entain Group Pty Ltd. AUS- TRAC is alleging serious and systemic non-compli- ance with the AML/CTF Laws, including that Entain failed to develop and maintain a compliant AML pro- gramme, and did not conduct appropriate checks on 17 customers deemed high-risk. It has been reported that AUSTRAC and Entain are conducting mediation to resolve the matter. Further, it was reported that, in August 2025, AUSTRAC amend- ed the statement of claim to remove various claims made against Entain, which had alleged that it had failed to comply with obligations applicable to a remit- tance provider. The case is ongoing. Mounties proceedings On 30 July 2025, AUSTRAC commenced Federal Court civil penalty proceedings against Mounties, alleging breaches of the AML/CTF Laws including a failure to adopt and maintain a compliant AML/CTF programme. A case management hearing is sched- uled for 3 December 2025. Casino Reviews in Victoria, Western Australia, NSW and Queensland – Updates Victoria The Victorian Gambling and Casino Control Commis- sion (VGCCC) concluded, in its decision published on 26 March 2024, that Crown Melbourne had returned to suitability to hold the licence to operate the casino in Melbourne, and that it was in the public interest that the Crown Melbourne casino licence remain in force. Western Australia The Office of the Independent Monitor and the Western Australian gaming regulator, the Gaming and Wager-

ing Commission (GWA), conducted a final assessment of Crown Perth’s implementation of its remediation plan. The outcome of this assessment was that, on 8 July 2025, the Racing and Gaming Minister deter- mined that no punitive action would be taken against Crown Perth and that it was suitable to continue to hold a casino gaming licence. With effect from 1 August 2025, Paul Steel, who was the Independent Monitor of Crown Perth, was appointed to the GWA to support ongoing supervision of Crown Perth. New South Wales The Star The report of Adam Bell SC published on 30 August 2024 (the “Bell 2 Report”), following a second inde- pendent inquiry into the operations and remediation of The Star in Sydney as required by the NSW Inde- pendent Casino Commission (NICC), found that The Star continued to not be suitable to be concerned in or associated with the management and operation of The Star Sydney Casino. The Bell 2 Report acknowledged that there had been substantial reform of The Star; however, the Bell 2 Report concluded that The Star remained unsuitable. Subsequently, the NICC imposed a pecuniary penalty of AUD15 million against The Star and confirmed that the casino licence would remain suspended. The term of the special manager appointed to super- vise The Star’s operations has been extended to 31 March 2026 (the NICC had initially extended the term to 31 March 2025 following the Bell 2 Report). Upon extending the term of the special manager, the NICC confirmed that The Star had accepted that the special manager should remain in place for a further six-month period to 31 March 2026, during which time The Star would continue its remediation and imple- ment measures to secure its finances. The NICC con- tinues to monitor The Star’s operations. Crown Casino In April 2024, the NICC determined that Crown Syd- ney was suitable to retain its NSW restricted gaming licence. Further, it was noted that a new regulatory

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