Liquor & Gaming NSW has confirmed it is actively enforcing the state’s new gaming harm minimisation requirements, with inspectors visiting 528 hotels and clubs across NSW in July and August 2024 alone. For club operations managers and venue owners, this is a clear signal: the compliance obligations that came into force earlier this year are not theoretical, and enforcement activity is already underway.
What’s Being Checked
The compliance blitz focused on four specific areas that venues with gaming machines were required to implement from 1 July and 1 September 2024:
- Gambling incident registers — a documented, monthly-reviewed record of potential or actual gambling harm identified on-site, required since 1 July 2024
- Responsible Gaming Officers (RGOs) — mandatory for hotels and clubs with more than 20 gaming machine entitlements, also from 1 July 2024
- Gaming Plans of Management (GPOM) — a formal plan, required from 1 September 2024 and updated at least annually, that staff must be able to demonstrate they’re actually following, not just filing away
- ATM signage requirements — the area where inspectors found the majority of breaches during the blitz
Liquor & Gaming NSW reported that 93 per cent of inspected venues were complying with the measures required since 1 July, which is a reasonably strong result — but it also means a material number of venues were found short, predominantly on the ATM signage front.
The Date That Matters Most: 1 January 2025
The requirement generating the most operational work for venues going forward is physical, not procedural: from 1 January 2025, ATMs must be located outside a five-metre radius of any entrance or exit to a gaming area in a hotel or club. This is a floor-plan and fit-out issue as much as a compliance one. Venues with ATMs currently positioned near gaming room entries will need to physically relocate the unit, or apply to Liquor & Gaming NSW for an exemption where relocation isn’t feasible.
Executive Director Regulatory Operations Jane Lin noted that inspectors are specifically testing whether the policies and procedures described in a venue’s GPOM are actually being followed in practice, not just whether a document exists. That distinction matters for how venues prepare: a GPOM that sits in a folder unread by gaming floor staff won’t survive an inspection that asks staff to demonstrate the procedure in real time.
Operational and Security Implications
For venues Mallen works with, this compliance push intersects with physical security and surveillance planning in a few practical ways. Relocating ATMs away from gaming area entrances often means re-thinking sightlines, cable runs, and camera coverage for cash-handling zones. Any ATM move should be planned alongside a review of CCTV coverage to ensure the relocated unit — and the path patrons take to and from it — remains within clear camera view, since ATM areas are a known target for both patron safety incidents and tampering attempts.
Gambling incident registers also tend to rely on video evidence to substantiate entries, particularly where an RGO or manager needs to review footage after an incident is logged. Venues should confirm their video retention periods align with the monthly review cycle required for incident registers, and that camera coverage of gaming floors, RGO intervention points, and ATM locations is documented and current. This is exactly the kind of gap an independent site audit is designed to catch before a regulator does.
Access control is a secondary consideration here too — some venues use the GPOM to define restricted zones or self-exclusion enforcement points, which in turn depend on staff being able to identify and act on patron access at the door. Where this intersects with card access or visitor management systems, it’s worth reviewing alongside the physical ATM relocation work.
The Mallen Take
This isn’t a security-system vendor notice, but it’s a compliance deadline with real physical infrastructure consequences for clubs, pubs, and RSLs across NSW. The 1 January 2025 ATM relocation requirement is the hard date to plan around now, particularly for venues where moving an ATM also means re-cabling power, network, or security infrastructure in that area. We’d recommend venues treat this as a trigger to review CCTV coverage of gaming and cash-handling areas generally, rather than treating the ATM move as an isolated facilities task. Venues that haven’t yet mapped out their gaming floor camera coverage against these new obligations should get that documented well before the new year.
Original source: nsw.gov.au