It’s time to reimagine the future for Thai casinos
11 July, 2025
Casinos in the Crossfire of Thai Border Conflict
30 July, 2025
Winna Media Insights
10 July, 2025
Building a sustainable regulatory framework
Fairness, openness and integrity are just some of the non-negotiables when it comes to regulating gaming
With 16 years of experience as the Director of Licensing for Pennsylvania’s Gaming Control Board, as well as being a co-founder and partner of the gaming industry-focused law and advisory firm Hensel Grad PC, Susan Hensel is clearly a voice that would-be regulators should take notice of.
Susan states: “The goal for new gaming regulators is to establish a framework that will create a sustainable industry. That means building a regulatory system that is based on integrity and a clear understanding and execution of the regulator’s industry oversight responsibilities.
While she has been observing the progress of the Thailand Entertainment Complex (EC) Bill, Susan feels strongly that, regardless of location, there are fundamentals critical to the creation of successful gaming regulatory bodies.
Integrity, integrity and more integrity
“First, you have to ensure that only suitable individuals are involved in the industry. The people who own, control, and benefit from gaming must possess the requisite character, honesty and integrity. This is the reason regulatory agencies must create a robust licensing process that requires thorough background investigations, ” she says and adds, “The best indicator of integrity in the future is a life that has demonstrated integrity in the past.”
“Second, the regulatory body must safeguard operational integrity. Key to accomplishing this goal is requiring a strong system of internal controls that detail procedures for how the business will run. Internal controls address all aspects of the operation, including financial reporting, the effectiveness and efficiency of the operations, and compliance with laws and regulations. Among the critical components of the internal controls are anti-money laundering protections. In addition, internal controls should be established to ensure checks and balances, such as dual document verification requirements and rank-based credit approvals. Another important component is the establishment of the casino’s chain of command.
“When a problem occurs, the internal controls should pinpoint what procedure failed and who the responsible parties are so that corrections can be made to avoid future issues,” Susan adds.
Fairness is not negotiable
Fairness is another non-negotiable for Susan. “You have to ensure that the games are fair. That means members of the public can have confidence that the games play and pay as advertised. If a player hits a jackpot, there should be no issue with the player getting the winnings.”
“This means that the regulator will have to make sure the games are sufficiently tested and certified. If players do not have trust in the games, they will not continue to play, which puts the success of the industry at risk.”
Susan is also clear that the regulatory framework spans well beyond the physical boundaries of the casino. “Taxes and fees as required in the authorizing legislation need to be paid and accounted for, says Susan. “In exchange for granting a company a privileged license to offer gaming, the public needs to get something in return, and part of what the public gets is payment of fees and taxes. The industry needs to fulfil its share of the bargain.”
Protecting the vulnerable
Susan’s final component of the regulatory fundamentals is the protection of the vulnerable. This includes protection for those who have trouble gambling responsibly and can include a variety of measures such as self-exclusion protections and restrictions on advertising. There should also be protections for minors to make certain they are not able to access the gambling product.
An overarching requirement for the gaming oversight agency is to recognise the importance of open communication. “Being transparent and keeping the public informed on progress with implementation, the achievement of milestones and the reasons for delays is key to building trust with the public and is in the best interest of the agency,” says Susan.
‘Fun’ and ‘entertainment’ aren’t often used in the same breath as ‘policy’, but when it comes to resort casinos where gaming is one of many features on offer to visitors, they are an important part of the mix. “The idea of the resort casino is to have something for everyone in the audience the operator is trying to attract. That can mean offering a menu of amenities to please parents, kids and grandparents in addition to those who want to game.”
Regulations with teeth
Throughout 2025, certain community groups in Thailand have protested against legalising gaming. Without referring specifically to this opposition, Susan says that as a rule, gaming legislation needs to be able to have bite so that the pro and anti populations are clear about what the regulators expect of the operators.
“The regulators must be empowered to enforce the law and the regulations so that if someone violates the rules, there are consequences, and those consequences should be communicated to the public.”
Finally, Susan says that the people of Thailand will shape the regulatory framework in their own image.
“All jurisdictions, whether they are individual states in the U.S. or nation-states like Thailand, will have their own policy goals and priorities and cultural considerations that they’re trying to protect or advance.
“While there will be commonalities across jurisdictions, each jurisdiction will also put its own stamp on its regulatory framework as it seeks to fulfil the goals that motivated authorizing gambling in the first place.”
Susan Hensel is co-founder and partner of Hensel Grad P.C., a gaming industry law and advisory firm. Prior to that, she was Director of Licensing for the Pennsylvania Gaming Control Board, overseeing the licensing, suitability and compliance of the individuals and entities involved in the state’s casinos, online gaming sites, retail and sports wagering providers, as well as other gaming verticals.
Susan has spoken and published articles around the world on gaming regulation in addition to collaborating with industry regulators from across the globe, earning her a reputation as one of the most respected former U.S. regulators on the international stage. She is also a two-time former President of the International Association of Gaming Regulators.
Susan Hensel – LinkedIn
