Cruise Ship Gambling Guidelines

My investigative series dealing with the unregulated world of casino gambling aboard cruise ships continues today with another look at the gambling guidelines enacted in 1999 by the International Council of Cruise Lines. The ICCL is a Washington, D.C.-based industry trade association that represents the interests of 17 passenger cruise lines and a variety of cruise industry suppliers.

Last week I examined the guidelines regarding facilities and equipment. Today I'll take a look at the rules of play and internal controls.

RULES OF PLAY

What the guidelines say: Each line will provide a gaming guide setting forth the rules of play for their casino. These rules of play shall generally follow those established for casinos in Nevada, New Jersey, or England. These house rules will also be made available in every casino. Each member line will post at every gaming table minimum and maximum betting limits for each game. Only adults are allowed to play the slots or the tables.

What it means: Virtually nothing as far as the best interests of the players are concerned. It just gives the cruise lines the right to create rules hostile to players if they so choose. Some casinos in Nevada and New Jersey have some pretty bad rules. I don't know about England. Wording like "shall generally follow" opens up a lot of leeway. Making the rules available and posting minimum/maximum bets at table games are givens. There is such lack of precision that even "adult" is undefined in terms of age.

INTERNAL CONTROLS

What the guidelines say: All shipboard gambling operations will be inspected by each member line's internal audit department on a regular basis, not to exceed 12 months.

All casinos will have detailed internal control procedures concerning the cash and coin counts, casino cage procedures, and other processes, similar to licensed jurisdictions.

Each line will employ some form of surveillance to assure operations are fair and equitable for all parties.

Each line will separate the operation of the casino from the financial aspects of the casino as clearly as possible including specific duties for cashiers and table gaming staff.

What it means: Having the gambling operations inspected from within is meaningless. An outside, independent auditor or watchdog is an absolute necessity to ensure integrity. And doing the inspection a minimum of once a year? Come on! I don't call that "on a regular basis." As for providing controls concerning cash and coin, that's strictly for the protection of the cruise line, not the players. Then there's the issue of security. Requiring "some form" of surveillance is about as vague as it gets.

In other words, no matter how you look at it, there's no percentage in doing any kind of serious gambling aboard a vacation cruise ship.

Next week: Customer service and player's clubs.