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Choppy Seas for Cruise Line Gamblers

5 February 2002

In today's third installment in my series dealing with casino gambling aboard cruise ships in international waters, I will investigate the gambling guidelines of the International Council of Cruise Lines (ICCL) that were enacted by the organization in December of 1999 to establish specific procedures for onboard casino operations.

First of all, the ICCL's description of itself:

The ICCL is a Washington, D.C.-based industry trade association that represents the interests of 17 passenger cruise lines in the North American cruise market and more than five dozen cruise line suppliers. ICCL member lines operate 95 vessels that call upon major ports in the United States and abroad. These vessels carry more than five million passengers each year and account for approximately 90 percent of the North American passenger cruise line industry.

Keep in mind that the ICCL is not an unbiased, outside "watch dog" group. Therefore, as we review the guidelines as they pertain to the equipment, conduct of games, internal controls, and customer service for casinos on cruise ships, remember that the rules are formulated from within and not mandated from an outside regulatory body.

The ICCL lists the following three goals of the guidelines:

  • To provide reasonable rules by which all gambling onboard member vessels is conducted to ensure fair and professional gaming to the highest level of integrity to the player.
  • To provide internal controls upon which passengers can rely to assure them that the gambling is operated with the utmost integrity.
  • To provide a form of entertainment for passengers which is responsive to the customers' requests.

Internal controls can be misleading in the context of cruise ship gambling. For example, all riverboat casino license holders in the state of Illinois are required to publish internal controls manuals. Copies of each of the property's internal procedures must be submitted to the Illinois Gaming Board for review, inspection, and enforcement. Which begs the question: What outside agency reviews the internal controls of ICCL?

Now, let's take a look at each of the guidelines. I will present each of them as they are printed by the ICCL, followed by a brief analysis of what they REALLY mean.

FACILITIES AND EQUIPMENT

What it says: All equipment purchased and installed on cruise vessels will meet the regulatory standards of the Nevada Gaming Control Board or other licensed jurisdiction for payback and internal software.

What it means: A vague guideline that requires all electronic gaming devices (slot and video poker machines) that are placed in cruise line casinos be purchased from an approved supplier as designated by any licensed gaming jurisdiction. So what? All this says is that cruise lines can't buy the machines from clandestine operations. Furthermore, payback percentages and internal software vary greatly from jurisdiction to jurisdiction. They're just giving themselves license to install machines with the tightest payback percentages if they so desire.

Another thought: Once the machines are delivered and installed, are there any safeguards in place to PRESERVE the regulatory safeguards for payback and internal software?

Investigators from the Illinois Gaming Board seal all electronic gaming devices in place at riverboat casino destinations in Illinois. The casino owner cannot access the internal software unless a member of the gaming board is present. With no higher authority to answer to, cruise line operators have no reason to ensure fair payback percentages.

Next week: Rules of play, internal controls, and customer service.

John G. Brokopp

John G. Brokopp's gaming column appears in Chicago Sun Times (Chicago, Illinois), The Times (Northwest Indiana), The Quad City Times (Davenport, Iowa), The Courier News (Elgin, Illinois), The Gazette (Southwest Suburban Chicago) and Senior Wire (Denver, CO). He's also a regular contributor to The Colorado Gambler, Midwest Gaming & Travel, Casino Player and Strictly Slots. John possesses 28 years of experience as a professional handicapper, publicist, freelance writer, and casino gaming correspondent. He is also the author of two very popular books, The Insider’s Guide to Internet Gambling and Thrifty Gambling.

Books by John G. Brokopp:

> More Books By John G. Brokopp

John G. Brokopp
John G. Brokopp's gaming column appears in Chicago Sun Times (Chicago, Illinois), The Times (Northwest Indiana), The Quad City Times (Davenport, Iowa), The Courier News (Elgin, Illinois), The Gazette (Southwest Suburban Chicago) and Senior Wire (Denver, CO). He's also a regular contributor to The Colorado Gambler, Midwest Gaming & Travel, Casino Player and Strictly Slots. John possesses 28 years of experience as a professional handicapper, publicist, freelance writer, and casino gaming correspondent. He is also the author of two very popular books, The Insider’s Guide to Internet Gambling and Thrifty Gambling.

Books by John G. Brokopp:

> More Books By John G. Brokopp