1. What are the benefits of RBR to an applicant?
Efficiency: A comprehensive risk-based approach allows the AGCO to focus its time, attention and resources on high risk or problem applications. This leads to a more efficient use of government resources and allows the registration of lower risk applicants to be processed more quickly. Personal interviews and in-depth investigations will no longer be conducted as a rule, but only where issues or concerns exist. This will mean a simpler process in particular for renewal applicants with a history of good conduct.
Consistency: All gaming-related applications will go through a similar risk assessment process, irrespective of registration type. This ensures consistency, transparency and fairness for all applicants.
Focused investigations: Where required, in-depth investigations on higher risk applicants may be more focused and targeted on specific concerns. This will improve the efficiency of the process, optimize the use of investigatory resources and improve overall turnaround times.
2. Will registrations be processed faster under RBR?
On average, turnaround times are expected to improve. Lower risk applicants will undergo a more simplified and streamlined registration process, which will result in a shorter turnaround time for their applications.
The primary beneficiaries of the new streamlined process will be those renewing their registrations. Registrants with no compliance issues or any other adverse material changes to their circumstances (e.g. criminal conviction, bankruptcy filing) over the past four years of their registration will normally be renewed without undergoing an in-depth investigation.
In particular, suppliers and commercial gaming employees with a history of good conduct should experience shorter turnaround times under RBR. Interviews will no longer be conducted as a rule with these registrants every four years, but based on a risk assessment, and investigations, where requested, will be better focused and targeted on specific concerns.
Lottery sector registrants and charitable gaming assistants will not see much change in the processing of their applications. A risk-based approach to reviewing their applications is already in effect for these individuals, in that in-depth investigations and interviews are now only conducted where concerns or issues are identified as part of an initial risk assessment.
3. Is there any potential negative impact on the integrity of gaming by streamlining the due diligence and decision making process in this manner?
No. Standard background checks will be conducted on each and every applicant, and a risk assessment performed. Only those who have been deemed lower risk after the first phase of the review may be issued a registration without undergoing any further investigation. Typically, these will be registrants with a history in the gaming industry, who are renewing their registrations and have had no compliance issues or any other adverse material changes to their circumstances (e.g. criminal conviction, bankruptcy filing) over the previous years of their registration.
4. I submitted my application prior to September 12, 2011. Will it be reviewed under the new RBR process?
No. Only those applications submitted with the revised application forms after September 12, 2011 will be reviewed under RBR.
5. Will I be able to provide input to the AGCO regarding any of their concerns before a risk designation is made or conditions imposed?
If you are asked to undergo an interview, this simply means that some additional information is needed from you in order to determine your eligibility for registration under the Gaming Control Act, 1992. The Registrar will only propose not to issue a gaming registration where the applicant’s personal or financial history indicates that he/she is likely not to perform his/her duties in accordance with the law and in the public interest.
6. Will registration fees be affected by RBR?
No. The registration fees have not changed
7. How will AGCO monitor this program to ensure it’s working properly, and make changes?
A full audit of the RBR program will be carried out one year after implementation to provide an analysis of the program, address potential issues and make any necessary revisions to procedures and policies.
8. Why are “exempts” (those working for or supplying a gaming facility but not required to be registered) not included in RBR?
“Exempts” are already considered low risk by the nature of their status under the Gaming Control Act, 1992. In addition, as “exempts” they are not officially considered registrants.
9. Why will RBR not apply to lottery retailers and break open ticket sellers in September 2011 like the other registrant categories?
It was decided that, due to the large volume of registrants in these categories, implementation of RBR for lottery retailers and break open ticket sellers will follow in 2012. In any event, a risk-based approach to reviewing their applications is already in effect for these applicants, in that in-depth investigations and interviews are now only conducted where concerns or issues are identified as part of an initial risk assessment. RBR will simply formalize and standardize the process better across all registration categories.