As expected, Japan’s draft regulations have shown the industry will be strictly regulated, however, they also set the tone for a conservative and formal casino floor with a stress on a clean image in keeping with mores in Japanese society.
The draft regulations issued by the Japan Casino Regulatory Commission (JCRC) a couple of weeks ago have become the subject of detailed study by those most concerned with IR development.
Many analysts are reaching the conclusion that these draft regulations represent a major step forward in clarifying the national government’s intentions, though many vital subjects have still been left unaddressed.
The scope of the topics covered in the draft regulations, however, is very wide, making generalizations difficult. The draft is a shopping basket of different items, not really focusing on a united theme.
It is also offered only in the Japanese language (in spite of the fact that most of the operators are likely to come from overseas), reflecting the fact that even in an industry that is supposed to be focused on foreign businesses and foreign tourists, Japan is still an inward looking market.
At any rate, despite the lack of effort to make themselves understood, the JCRC’s documents are garnering attention because of the operators’ urgent need to understand what they entail.
Here we will look briefly at what we have learned about the casino floor, and what we can further surmise.
One of the key issues has been the permitted physical size of the casinos. It was determined several years ago during the legislative phase that the maximum size of the casino floor would be set at 3 percent of the total area of the IR, but it wasn’t clear exactly what this meant.
The draft regulations partially answer this crucial question for IR design. We learn in reasonable detail what counts as the “casino floor” and what doesn’t.
Specifically, the facilities that do NOT count toward the 3 percent limit include stairways, elevators, hallways, bathrooms, smoking rooms, the complaints desk, art exhibition spaces, the problem gambling information room, and even the casino cashier areas.
What is not addressed, however, is the other side of the equation—not the 3 percent but the 100 percent. In other words, what qualifies as the total area of the IR? For example, are car parking lots allowed to be included in the IR’s total area? What about harbors for yachts, etc.? The regulations are silent about these issues.
Still, one does get the sense that even if Japan’s regulations may be strict in some areas, it may be relatively lax on just how to interpret the “3 percent rule.”
On the other hand, inflexibility seems to be the approach when it comes to the games themselves. As we have noted previously, the regulations specify nine types of games authorized for the casino floors, including slot machines, baccarat, poker, and roulette.
The draft goes into further detail. For example, under the heading of poker, the games will be limited to eight specific varieties: Caribbean Stud, Three Cards, Texas Hold’em, Texas Hold’em Bonus, Mississippi Stud, Let It Ride, Omaha Poker, and Poker Tournament.
Players will be banned from offering tips to dealers.
The machine regulations specify that the average customer “refund rate” will be more than 90 percent and less than 100 percent of the money ventured.
Presumably these gaming rules will evolve over time, but the JCRC clearly wants to keep tight reins on which games may be played at Japanese casinos, and how much money is lost by the average patron.
A further point worthy of note is that both the JCRC draft regulations and a stream of comments from local government officials make it clear that the casinos in Japan IRs will be nearly obsessed with presenting a clean, high-class public image.
For example, even at this early juncture the JCRC draft relations go into some degree of detail about the responsibility to maintain “good manners and a clean environment.” This includes such guidance as the “prohibition of installation of photographs, decorations, and other equipment that may harm good manners and a clean environment.”
The local governments, too, have been talking about maintaining strict dress codes for use of the casino facilities.
One suspects that their mental images of casinos may come largely from James Bond movies, and of course they want to combat the accusations from anti-casino critics that the IRs will present a threat to public morals.