Rising to the problem gambling challenge

Japan has the opportunity to pioneer new methods to tackle problem gambling and set a standard for the rest of Asia, as it draws up legislation to govern integrated resorts.

The issue of problem gambling has been a major focus for politicians and is listed as one of the key reasons many Japanese are opposed to IRs in their communities.

Although it is clear the vast majority of Japanese who gamble do so for entertainment and do not suffer any significant harm, recent studies have found problem rates in around 3 to 4 percent of the adult population, which is at the higher range of rates from around the world.

It’s a problem that’s not just felt by individuals, but one that also affects families, colleagues and others in society. Unfortunately, in Asia, gambling addiction has not been viewed as a public policy issue, but rather as a personal or individual problem. These stereotypes of individuals with gambling problems are outdated and a barrier to understanding and addressing the problem, which touches every corner of society and no age, income or ethnic group is exempt.  

Gambling addiction in Japan is a serious public health issue demanding a comprehensive solution, involving not only the national government but also efforts on the part of prefectures, cities, communities, families, civic groups, the gambling industry, the NGO sector, professions such as medicine, law, and finance, and other organizations. This article focuses on some of the policy, program and cultural issues in responsible gaming.

Pachinko policy

Gambling has long been a highly regulated industry. It is unsurprising that historically gambling policies have been quite strict and heavily proscriptive. However regulators from a number of leading jurisdictions have begun to move towards more descriptive or outcome-based measures, particularly on responsible gaming. This allows operators to develop responsible gaming programs that fit within a company culture, maximize resources and meet or exceed the desired outcomes.

However, greater flexibility requires increased reporting. It is highly recommended that regulators require and review annual reports on outcomes with evidence of performance and that these reports are publicly reviewable. NGOs have a great opportunity to serve as advisors and assessors, providing assurance, ratings and rankings. These third-party reviews provide much more credibility and communications opportunities, which may translate into public support.

One of the greatest challenges is the current lack of unified gambling policy in Japan, which includes diffuse regulatory agencies, diverse forms of gambling, and most importantly, longstanding legal and administrative decisions that do not classify pachinko as a gambling activity.  

When gamblers are faced with different minimum ages to gamble, or identification requirements, restrictions on credit or operating hours, it may create an impression among gamblers that certain forms are more or less dangerous than others and may lead to higher concentrations of at-risk or problem gamblers in lesser-regulated sectors.

Therefore the Cabinet’s release in August of a draft of a wide-ranging problem gambling strategy that encompasses most of the current gambling -- including pachinko -- is a very important step towards a more coherent policy. It includes recommendations for pachinko, pachislot, horse, cycle, motorboat and motorcycle racing authorities to develop self-exclusion, advertising criteria, responsible gaming messaging and training policies.

Unfortunately, the measures described above do not appear to apply to the lottery, which still leaves a significant gap. It is assumed measures for the IRs in the long delayed responsible gaming bill will be similar, but perhaps more restrictive. This raises concerns that recreational gamblers may still face hurdles in getting consistent information and assistance, and that problem gamblers will continue to seek illegal or less regulated options.

Proven programs

Once legislators and regulators outline policy, administrators and operators swing into action to develop programs to meet the defined goals. While the exact IR responsible gaming objectives and requirements are not yet known, several of the program areas below have been extensively discussed and can safely be assumed will be included in upcoming legislation. These include self and third-party exclusion, employee training, onsite responsible gaming information centers, payment limitations and entry fees.

Self-exclusion is already being proposed for existing gambling and pachinko/pachislot operators in Japan. The effectiveness of a self-exclusion program at meeting goals to reduce harm or the prevalence of gambling problems relies greatly on two other things—the ability of the operator to identify customers and the availability of treatment services.  

While the individual gambler bears the primary responsibility for compliance with their exclusion agreement, both government and gaming operators have important roles as exclusion programs are a fairly limited tool and unlikely to be effective unless buttressed by comprehensive state treatment programs and adequate enforcement by the gaming industry. Controlling access is important as studies around the world report that an average of 30 percent of individuals who self-exclude will violate their ban at least once, and few of them are detected when entering or when gambling and losing.

Many are only spotted because they finally win and are required to fill out tax forms. And then their jackpot is often forfeited!  This can breed a cynical perception that casinos choose to enforce an exclusion only when someone hits the jackpot. In casinos with high visitor volumes or retail locations like lottery vendors it is understandably difficult to spot individual excluded gamblers, some of whom resort to disguises. High tech surveillance systems are often prioritized for cheating and theft, and many player tracking and loyalty systems are not necessarily automatically tied into a self-exclusion list.   

The second critical factor is the referral of excluded individuals to treatment services. Most people who are excluded from gambling have serious gambling problems, but without treatment their problems are not likely to get better. Treatment services must be highly accessible, widely available and easily affordable. Unfortunately, while many operators do their part, governments often fail to provide for problem gambling services despite huge tax and revenue from gaming in their jurisdictions.  It may be a lack of an effective healthcare infrastructure or system, or there may not be public or political support if the dominant view is that excessive gambling is a moral weakness, solely a personal financial issue, or a shameful secret that dishonors the family.  Facing these challenges will help improve the effectiveness and efficiency of self-exclusion programs in Japan.

Third-party or involuntary exclusion is a fairly recent development--although casinos have long had the ability to exclude cheaters, identified organized crime members and other “undesirables” at will. This is one area where the Singapore model may have just about the right balance. They take an adjudicated approach, where the person who is subject to the ban has the right to contest it in a special administrative proceeding. This provides protection for the gambler who is able to bring counsel and present evidence at the hearing. It appears many bans are not contested, which may indicate they are more of an accepted “intervention” for someone with a serious gambling problem.  

Cultural norms

The social behavior and norms of a society—their “culture”—has a great impact on responsible gaming. Acknowledgement and respect for Japanese customs and social norms must infuse any advice and suggestions for responsible gaming policy and programs.

While Singapore has justifiably earned its reputation as one of the most thorough and progressive regulators in one of the most successful Asian casino jurisdictions, it is important to remember that their responsible gaming regulations are tailored to the unique Singaporean culture and customs. Government representatives spent years visiting and studying casino regulations and operations around the world and adapting them to the city-state. Their resulting best practices may not be as effective when simply transplanted to a new jurisdiction.

Standard setting

Just as Singapore did a global scan of best practices and then adapted them, so should new jurisdictions like Japan. Regulations and the resulting policies and programs should be as efficiently drawn as possible to address a specific population or goal. Their effectiveness should be measured by the desired outcome or change in behavior for the targeted group. An entry fee catches all gamblers, the vast majority of whom are not problem gamblers or even at-risk for problem gambling, so it is likely not very efficient at targeting that group.

Japan has a great opportunity to advance the state of responsible gaming. For example, jurisdictions across Asia and throughout the world would welcome new models of dealing with shame and stigma that prevents many people from addressing gambling problems. Japan could pioneer innovative ways to use technology to help players more easily set limits, monitor their own performance, obtain information on norms and expected cost of play, and receive personalized feedback.

Regulators are encouraged to develop responsible gaming policies that are outcome based and allow operators flexibility in how they develop programs to that goal. Performance should be monitored by regulators and assessed by a 3rd party with public reports to maximize transparency.  

*By Keith Whyte, executive director National Council on Problem Gambling, Washington D.C., U.S.