New DICJ Instruction on Electronic Table Games

LEKTOU GAMING LAW ALERT

New DICJ Instruction on Electronic Table Games

Since the liberalization of the gaming industry, the Dealer Operated Electronic Table Game (“DETG”) assumed an important and decisive role in the Macau gaming market.

Until now, there were no technical standards covering these particular gaming products (hardware and software).

Taking into consideration the development and increasing importance of this type of gaming product, Macau Gaming Inspection and Coordination Bureau (“DICJ”), decided to advance with a new set of “credible technical standards for DETG” named DETG Technical Standards.

Following the issuance of the Technical Standards, DICJ published, on 6 December 2017, guidelines: Instruction no.1/2017 on “Macau Dealer Operated Electronic Table Game (“DETG”) Technical Standards Version 1.0” (“Instruction”).

In DICJ words the main purpose of these guidelines is to unify the technical requirements for the approval by DICJ of DETG. The relevant tests reports and certificates must be in accordance with the guidelines with the purpose of improving “fairness, transparency, so as to enhance the positive image of the gaming industry in Macau”.

The most relevant provisions of the Instruction are the following:

(1) Commencement, Effectiveness and Enforcement -

Instruction’s enactment date is 1 January 2018 (“Commencement Date”) but effectiveness date is postponed to 30 June 2018 in order to allow manufacturers to implement the new standards imposed under the Instruction (“Grace period”);

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After 1 July 2018, all DETG, which approval process has been submitted to DICJ, shall be tested and certified by one of the authorized laboratories1.

DETG that do not comply with DEGT Standards by 12:00 noon of 31 December 2019 will have to be disconnected and permanently withdrawn from operation.

(2) Grace Period operation -

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During this period DICJ will accept applications for approval of DETG’s that are compliant with DETG Technical Standards Version 1.0 or GLI25 Dealer Controlled Electronic Table Games; For all DETG’s approved at Commencement Date but upgraded with any hardware or software materially2 changing the operation, fairness, security, reliability or auditability of the upgraded product will be treated as a new application, i.e. as requiring new approval. In such case the upgraded product will have to fully comply with DETG Technical Standards Version 1.0.

(3) “Grandfather Period” operation -

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Instruction sets out a Grandfather Period from 1 July 2018 and 31 December 2019 (both inclusive); During this period all gaming concessionaires (or sub concessionaires) are required to submit a report detailing its developments withdrawing from operation or converting DETG’s to fully comply with DETG Technical Standards Version 1.0 (“Updating Reports”); The Updating Reports shall be filed with DICJ no more than 30 days after the end of each six months period, commencing on 30 June 2018; The Updating Reports shall advise how many DETG have been withdrawn permanently from operation or converted to fully compliant during the relevant period, total DETG’s withdrawn from operation during Grandfather Period and total non-compliant DEGT’s at reporting date. Each Updating Report must also contain an itemized schedule with serial numbers of all withdrawn or converted DETG’s;

According to Instruction’s Annex I the authorized laboratories are: 1. BMM International Pty Ltd (BMM); 2.

Gaming Laboratories International (GLI); 3. Technical Systems Testing (TST); 4. Enex TestLab; 5. Slovenia Institutes of Quality and Metrology (SIQ); 6. QALab Pty Ltd; 7. Eclipse Compliance Testing.

2 Material changes (if any) will be considered on a binding basis by DICJ following any submissions made by authorized EGM manufacturers.

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Gaming concessionaires (or sub concessionaires) must use their best efforts to achieve at least a 40% conversion rate by 12:00 noon on 31 December 2018.

Grandfather Period will not be extended.

For more information, kindly contact Pedro CortĂŠs (cortes@lektou.com) or Ă“scar Alberto Madureira (madureira@lektou.com)