Gaming Regulations And Legal Environment Accounting Essay


As the only gaming inspection organization of Macau, DICJ has a very important role. This paper is to discuss the powers, functions and operations of DICJ and to understand the status and importance of DICJ


In the history, gaming industry is always be born with organizational crimes. In the beginning of Las Vegas, the casinos had a lot of problem, such as money launderings and the controlling of Mafia. So Macau SAR government established The Gaming Inspection and Coordination Bureau named DICJ (Direcção de Inspecção e Coordenação de Jogos). "It provides guidance and assistance to the Chief Executive of Macao SAR on the definition and execution of the economic policies for the operations of the casino games of fortune or other ways of gaming, Pari-Mutuels and gaming activities offered to the public." [1] This paper is written to understand the powers, functions and operations of DICJ through the research on internet, newspapers, past paper discussions to collect second hand information.

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According to Article 2 of 34/2003, DICJ has the following powers and responsibilities:

"Assist in establishing, co-ordination and implementation the economic policy of Casino Games of Fortune or other gaming business industry, mutual betting and gaming activities available to the public.

Supervision and monitoring the grantee's activities, particularly with regard to fulfilling its statutory obligations, regulatory obligations and contractual obligations.

Supervision and monitoring grantee company and legal requirements and other appropriately qualified people and financial resources.

In the locations and sites where Operating in the license for casino gambling or other gaming lucky, provide assistance to the Government.

License and proof of the grantee to grant the company to operate the business for all equipment and instruments.

Issue of Casino Games of Fortune or other gaming intermediary business licenses

Supervision and monitoring casino gaming intermediary business, particularly with regard to fulfilling its statutory obligations, regulatory obligations and contractual obligations, and perform other duties applicable law.

Supervision and monitoring natural or legal person as gaming intermediaries, their collaborators and key employees of appropriate qualifications.

Monitoring under the applicable substantive law and procedural law, investigate and deal with administrative violations.

Ensure the relationships between Macau SAR government and concessionaires and sub concessionaires and the relationships between concessionaires and sub concessionaires are legal and fit the highest benefits of Macau.

According to the instructions of the Chief Executive or the law, the implementation of any not listed above are by nature within the purview of the Council's work generally." [2] 

To analyze why DICJ should have the powers and responsibilities above, we can find some reasons to understand the Article 2 of Law 34/2003. First of all, DICJ can make some voice in the process of making the economic policy. This is because that the main reasons for Macau SAR government to legalize gaming industry is to make the Macau's economy develop rapidly, sustaining and steadily. And to maintain a stable gaming environment of Macau, government must prevent gaming industry away from the organizational crimes, such as money laundering. So DICJ has the power and responsibility to monitor and supervise the concessionaires and sub concessionaires. Also, DICJ assist the government to determine the location of permission of casinos. However, there is no regulation about the location where cannot build a casino. To prevent treating in casinos, DICJ has the power and responsibility to license and proof the equipments and instruments which is being or will be operated in the casinos. Thus it will provide a fair game and safety environment to the public gamblers. Also, DICJ has the powers and responsibilities to license the gaming promoters as the gaming intermediary business, monitor and supervise the activities of the gaming promoters about their suitability and obligations and responsibilities in law and contract. Macau's gaming promoter is a very special case. Gaming promoter is an important role of many functions on them. They introduce players to casinos, and provide credit money for players to solve their crying needs. They also arrange the tourist programs for high end players. The gaming promoters get profits by selling chips to players and receive service fees about the whole tourist programs. In the old days, some behaviors of the gaming promoters, or we can call the chip rollers, is not legal. But the gaming promoters are really important and profitable in the gaming industry in Macau. So, for the purpose to control and supervise the gaming promoters, government legalizes the gaming promoters and has the laws to regulate them. Thus, the DICJ takes the job to implement the law and monitor and supervise the activities of gaming promoters. Furthermore, DICJ has the power and responsibility to investigate and treat the administrative violations. The purpose of this is to prevent to briberies between government staff and casino operators or gaming promoters. And DICJ is to ensure the highest benefits of the public.

Functions and operations

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To understand and analyze the operations of DICJ, it is a good way to look at its organizational structure. Article 3 of Law 34/2003 regulates the organizational structure of DICJ:

"1. Gaming Inspection and Coordination Bureau lead by a Director, and Director assisted by a Deputy Director.

2. In order to fulfill their responsibilities, Gaming Inspection and Coordination Bureau has the following sub units:

(1) Inspection of games of fortune department

(2) Inspection of interactive games department

(3) Audit Office

(4) Research and investigation department

(5) Administrative and Financial Office" [3] 

From the article above, the operations of DICJ is clearly understood. It has several departments. And each department has it functions and operations. And every department performs its own functions and cooperates with each others. Then we will look at the unique functions and operations of each department. The structure of DICJ is in the appendix.


For the director, Article 4 of Law 34/2003 clarifies his functions and operational powers. To summarize, the director is leading and planning the whole jobs of DICJ and supervise and monitor the job of his or her subordinates. Also, director can give, suspend and terminate the concessions and sub concessions. And director is handling the punishment of DICJ's employees who are against the disciplines.

So, in the DICJ, the director is the leader and he organizes the whole work of DICJ and monitor and supervise the subsidiary units. The methods of his job is to announce and approval the regulation. The purpose of these functions of the director is to manage and control the DICJ and make sure that each department of DICJ is performing its functions legally and efficiently. And the director is representing the DICJ in the public. So director must have a clear background and he has the responsibility to create a good reputation of DICJ in the public, such as fair, honest, and so on. Also, the director is in charge of recruiting, promoting and firing the employees of DICJ. So, the director has the functions of optimize the human resources and he is the man who distributes the rights to each department or officers in DICJ. Furthermore, the director can deliver, suspend and abolish the intermediary license of games of fortune in casinos. This means the director has the function of control the intermediary license and make sure that the licenses are legally operated and supervised. Also, the director has the functions to give administrative punishment the illegal behaviors in DICJ.

Deputy director

For deputy director, article 5 of Law 34/2003 clarifies his functions and powers: "In particular, the following terms of reference is the power and functions of Deputy Director. So, the functions of deputy director are to assist the director and exercise the functions and powers given by the director. If the director cannot perform his functions reasonable, the deputy director takes the functions and powers of director. The purpose of setting the position of deputy director is to assist the director and share responsibility for director. And in case of emergency, the deputy of director can be the leader instead of no one lead and control DICJ, which will make chaos in each department of DICJ.

Inspection of games of fortune department

For Inspection of games of fortune department, Article 6 of Law 23/2003 clarifies its functions and powers. The mainly functions of Inspection of games of fortune department are monitoring and supervising the operation of the gaming areas, such as casinos, and make sure the games of fortune which operated in gaming areas are complied with the laws and regulations. Furthermore, Inspection of games of fortune department monitors and supervises the equipments and instruments which is been or will be used to serve the gaming operations. That means Inspection of games of fortune department has the functions to keep the fairness of the games of fortune that offering to the players in casinos. Also, Inspection of games of fortune department has the functions to prevent the illegal activities in gaming industry. And it monitors and supervise the activities of adjust accounting of gross incomes to make sure that the revenue which reported to the public are correctly accounted. Inspection of games of fortune department has the rights to record the illegal activities of administrative and suggest the relative department to punish it. That means its one function is to ensure a legal environment of Macau gaming industry.

Inspection of interactive games department

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For Inspection of interactive games department, its functions and powers are clarified by Article 7 of Law 34/2003. Inspection of interactive games department has the similar functions and powers with Inspection of games of fortune department. The mainly difference is that Inspection of interactive games department is focusing on the interactive games. It monitors and supervises the operation, areas, equipments and instruments of interactive games to ensure a fair environment and conditions for players of interactive games.

Audit Office

For Audit Office, Article 8 of Law 34/2003 clarifies the powers and functions of Audit Office. It functions and powers are supervising on the grantee company and its management company statutory returns Economic and financial capacity. It Monitor and audit the company or its management company the grantee's accounting or bookkeeping and perform the audit of data confirmed by other sources of data required from the grantee of a systematic review of accounting data. If in the situation of necessary or appropriate, it has the functions to conduct a special audit. It performs on the grantee's procedures for routine operation of the computer audit. And it provide the audit results to the public according to law. So, the purpose of Audit Office is to control the account of each concessionaire and sub concessionaire. Audit Office can check the account and analyze whether there is some illegal behavior on the accounting process. And it can public the accounting situation of each concessionaire and sub concessionaire. Thus, if a casino want to cheating on the accounting process to reduce their taxation or other responsibilities, the Audit Office has the functions and powers to check the accounting profile of them and supervise that the accounts is true and correct.

Research and investigation department

For Research and investigation department, Article 9 of Law 34/2003 clarifies its functions and powers. Research and investigation department is in charge of preparing the economic report about the process of games of fortune and other kinds of gaming activities. It prepares reports on the terms and conditions of the existing interactive gaming activities under the economic forecasts. And it establishes and keeps continuous updating of the important activities of the grantee company database. It collects and analyzes the international information and gaming activities. It researches about application of developed countries or regions and follow-up study of advanced surveillance system to continuously improve the monitoring system used. Also, it has the job of Development, maintenance and improvement of the Council the necessary computer programs work. Furthermore, it supervises and monitors grantee gaming company and the shareholders, directors, key employees of the eligible. So, Research and investigation department has three functions. First is the reporting function about the economy. That means the DICJ take care about the economic environment about gaming industry in Macau and it want a healthy economy by keep on reporting the economic situation. If there was something wrong about the economy, DICJ can find it out and report it. Thus government can take action to fix it. Second function of Research and investigation department is focusing on the technology of supervision, such as surveillance center. Since technology is very useful and highly improving, there is a need to keep an eye on it and follow up. Third function is to monitor and supervise the suitability of the entities in gaming industry. So, Research and investigation department do the research about the important persons in each casino to find out whether they are suitable or not.

Administrative and Financial Office

For Administrative and Financial Office, Article 10 of Law 34/2003 clarifies its function and powers. Administrative and Financial Office is Responsible for personnel management, recruitment and selection process organization and update the data files and documents. It has the functions to provide the necessary assistance with education and training activities in DICJ. It also performs treatment and recovery of private proposals, complaints and objections statements. And Administrative and Financial Office take the inside accounting responsibility, such as budget. So the purpose of Administrative and Financial Office is to handle the daily operations inside the DICJ and the inside accounting system.

From the discussion above, it is clear that the operations and function of DICJ is decentralized to each department. And each department has its mainly functions and powers to operate. Through the operation of each department, DICJ can perform its jobs and duties as the Macau gaming inspection organization.


There is not enough data and information is provided by DICJ. For example, the suspicious transactions are reported to DICJ, but there is no annual report of DICJ has mentioned that. So, it is better for DICJ to provide an annual report each year. The report should tell the public about what have happened last year in the gaming industry. Because the gaming operations are supervised and monitored by DICJ, DICJ can have a summarization of the situation of Macau's gaming industry.


As an organization manages the gaming industry of Macau, DICJ has a great advantage in management and supervision. Especially, it differ the games of fortune into several kinds and implement one department manage one area. This method has pertinence on management and supervision. In terms of the management object, DICJ has it independence in the Macau administrative framework. Its responsibility is to monitor and supervise the activities, qualifications and financial and material capabilities of concessionaire, sub concessionaire, and gaming promoters. And DICJ is in charge of examine and approving of the equipments and infrastructure which will be operated in casinos. Also it must investigate and treat illegal activities according to the suitable substance law and procedure law.