Cem Ozturk
Regional Managing Director and Co-Head of APAC
Investigations, Diligence and Compliance
Sydney
Kroll's Independent Monitorship of Crown Casino Sydney
Discover how Kroll's financial crime, risk management, and monitorship expertise helped Crown Sydney regain its casino license while establishing world-leading benchmarks in responsible gaming and governance
The Challenge
The Challenge
Crown Sydney stood ready to open its doors to a stunning new casino on Sydney's iconic harbor. However, following a public inquiry into money laundering, risk management and cultural issues at other Crown Resorts Group properties, the NSW Independent Casino Commission (NICC) determined that Crown Sydney was unsuitable to give effect to its casino license, which effectively suspended the casino's license. To regain it, Crown Sydney needed to develop and implement a comprehensive remediation plan that would satisfy the regulator's concerns.
The path forward was complicated by unprecedented challenges. COVID-19 lockdowns restricted operations across Sydney and Melbourne. As a public company, Crown Resorts faced intense media scrutiny. The organization was dealing with multiple state-based casino inquiries while simultaneously managing the complexity of aligning group-level and local functions. Adding to this complexity, the entire board and senior management team were replaced, followed by additional board and leadership changes when Crown Resorts was acquired by private equity mid-project.
Kroll's Solution
Kroll’s world-class Investigations, Diligence and Compliance practice stepped in as an independent monitor, appointed by NICC, under a tripartite agreement with Crown Sydney and NICC. We assembled an experienced senior monitorship team, supported by specialized independent contractors bringing deep expertise in financial crime, governance, risk and compliance, gaming operations, organizational culture and business ethics.
The monitorship unfolded in two distinct phases. During Phase 1, we focused on assessing the remediation plan developed by Crown. Despite COVID-19 restrictions, we built strong relationships with Crown's senior management and remediation team through regular virtual meetings, collaborating over 12 months, culminating in the creation of a remediation plan that met NICC's requirements. In Phase 2, we shifted to monitoring implementation of the remediation plan, developing standardized reporting documents to track progress, conducting thorough reviews of deliverables and interviews with key Crown personnel, working closely with Crown’s remediation team and maintaining consistent communication with NICC throughout the process. We also assisted NICC in developing elements of the suitability assessment framework they used to assess Crown’s suitability to give effect to its casino license.
The Impact
The monitorship's success ultimately led to Kroll providing a positive assessment of Crown Sydney's progress in demonstrating suitability to give effect to its casino license, together with recommendations for ongoing monitoring by NICC—a crucial factor in NICC's decision to find Crown Sydney suitable to give effect to its casino license, effectively allowing casino operations to commence. Beyond the suitability assessment, our work helped Crown establish new benchmarks in responsible gaming that are now recognized as the world's leading practice. We facilitated significant cultural reform that created a better balance between profitability, risk management and social responsibility. The project also established Kroll as a leading casino advisor, both in Australia and globally.
NICC acknowledged our impact, stating: "The NICC notes the efforts of Kroll as the independent monitor in overseeing the remediation plan. The NICC also notes the quality of Kroll's recommendations throughout the monitorship, which have improved oversight of Crown Sydney's operations."
Ciaran Carruthers, former CEO of Crown Resorts, highlighted the collaborative nature of our work: "The collaborative engagement throughout, with both the Crown and Kroll teams working together to ensure the best outcome possible for all stakeholders, was a key factor in the findings announced today. It wasn't always plain sailing, but worthy accomplishments rarely are ... It's a proud moment in Crown's long history and thank you to you and your team for the role that you have played in this success!”
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