ATM Positioning

It is crucial that members are hyper-diligent when considering the appropriateness of their ATM positioning in relation to the proximity of their gaming floors, as there has been an enhanced inspection focus on gaming compliance in recent months by the regulator. 

These audits have continued through the holiday period and recent meetings with the regulator indicate this frequency and focus will remain for the foreseeable future.

Positions which may have traditionally been considered compliant are now being challenged by the regulator, with numerous penalties being issued. 

Members are reminded that ATMs should be positioned in an area which is entirely separate to the gaming floor and, where possible, at a suitable distance away from gaming room entrances. If ATMs are positioned within airlocks, separate rooms, or alcoves which are only accessible from a gaming area meaning they cannot be accessed without at some point first going through a gaming floor, they are non-compliant and considered an egregious breach of the legislation. 

Particularly in light of recent unfavourable media coverage regarding the industry, members are encouraged to be risk averse, leaning towards a conservative approach and best practice in their gaming operations at all times.

The regulator has also advised that when testing compliance with the legislation, an aggravating factor includes the ability to see an ATM from a gaming machine. This is not a specific requirement within the legislation and is merely a component of the test for the resulting compliance action which may be taken.

ClubsNSW continues to engage with the regulator to ensure a prompt understanding of their areas of focus, and evolving interpretations of legislation.

For more information, please email Luke Bucciarelli.