ATM

GUIDELINE 5 - AUTOMATED TELLER MACHINES (ATM’s) IN CASINOS

1. Nothing in the Gaming Act 1968 obliges a licence holder to offer an automated cash dispensing facility to    members. Whether to provide such a service is a matter of policy for the licence holder.

2. This Guideline applies to Automated Teller Machines (“ATMs”), that is automated cash dispensing machines that accept debit, credit or charge card transactions, sited on casino premises.  Terminals that issue third party cheques, to be exchanged for cash or chips at the casino Cash Desk, are covered by a separate Code of Practice agreed by the Gaming Board.

3. ATMs must be so positioned within a casino that a customer has to physically leave the gaming table or machine in order to use them.

4. Cash dispensed in an ATM transaction must not exceed the cardholder's daily limit of cash withdrawals authorised by the card issuing institution.  No more than £1,000 may be withdrawn in any single ATM transaction.  

5. The amount of cash withdrawn by a casino customer in an ATM transaction on the casino premises may be disregarded for the purpose of calculating the limit of cash or chips with which he may be provided under the provisions of Guideline Number One concerning the Acceptance of Cheques/Debit Cards from Members and Guests.

6. Should it become apparent that a customer has been refused an ATM transaction, it will not be permissible for the licence holder to accept in exchange for cash or chips for gaming a cheque backed by the same card during the same gaming day.

7. A sticker must be displayed in a prominent position on the face of an ATM, giving the phone number of the national helpline and stating that self help leaflets are on display in the casino.

ATM’s that can be used in casinos to process debit cards only

8. An ATM in the operation of which the licence holder has some involvement is caught by section 16 of the Gaming Act 1968 and can only be programmed to accept debit cards.  In exchange for each card transaction, the ATM must dispense cash to the full value requested by the cardholder. Also, this means that it is not permissible for the licence holder or any person acting on his behalf, as an agent or under any arrangement with him, to charge the customer a fee for providing the ATM facility.  However it is permissible for the customer’s bank to make a charge to its customer for the withdrawal from its customer’s account provided the bank is not doing so as an agent for, or under any arrangement with the casino.

9. A standard transaction slip should be available from the ATM at the time of use.  The transaction data should be stored by the relevant service provider at the time the transaction takes place.  Confirmation of the amount of the day’s transactions should be given automatically the following day by each service provider for the purpose of reconciliation.  The actual transfer of funds must occur no later than two banking days after the transaction date.

10. The transaction is recorded as follows:

· a transaction statement (see 9) is available to the customer at the time of the transaction;
· a journal of all transactions is printed off by the casino not less than once each week for use by the casino Treasury.

11. The Gaming Board requires that records of transactions (including refused transactions) are kept as follows:-

· Casino Treasury (i.e. Journal) copy to be retained on site for three years
· The casino copy of the transmission of transactions is to be retained on site for three years.  (This is the requirement of the Act).

ATM’s that can be used in casinos to process debit, credit and charge cards

12. ATM’s which accept credit or charge cards in a casino (whether or not they also accept debit cards),  must be operated by a third party ATM service provider unconnected with the licence holder (such as Hanco, TRM, etc.). There must be no “arrangement” within the meaning of Section 16 of the Gaming Act between the casino and the provider of any credit to the credit or charge cardholder.  

13. Where an ATM is programmed to accept credit or charge card transactions, the full amount of any cash float used to operate an ATM must be drawn from funds belonging to the ATM service provider.  Thus, whilst a licence holder may physically empty and refill an ATM cash float on behalf of the service provider, a clear audit trail must be maintained sufficient to establish to the Gaming Board's satisfaction that all funds used in the cash float originated from, or from an account held for, the ATM service provider.  It is important that these arrangements are followed exactly as failure to do so is likely to result in breaches of Section 16.  Cases of doubt should be referred to the Board before implementation. All records relating to the float must be retained for a period of twelve months and made available to the Gaming Board on request.

14. In exchange for each transaction in an ATM programmed to accept credit or charge cards in addition to debit cards, the ATM must dispense cash to the full value requested by the cardholder.  However, there may be debited to the cardholder's account, in addition to the amount of cash dispensed, a handling fee charged to the cardholder by the ATM service provider.   The ATM terminal must clearly notify the cardholder of the amount of such fee before processing the card payment and enable the cardholder to choose not to proceed with the transaction.   The terms on which the ATM is supplied to the licence holder may permit the licence holder to receive a share of any such charge levied by the ATM service provider.

15. In case any query should arise in respect of a card transaction, journal records relating to such transactions normally maintained by the ATM service provider must be retained, and made available to the casino licence holder and the Gaming Board, for a period of twelve months from the date of each transaction.   A reasonable period of notice will be given in the event that such information is required. There should be a notice on or adjacent to the ATM giving details of the service provider and contact details in the case of difficulty.
 
Information source: Gaming Board of Great Britain

last updated: May 2003