Expanded Surveillance Requirements May Be Coming To California Cardrooms

New regulations meant to aid in criminal investigations are on the mind of California Gambling Control Commission (CGCC) members. While surveillance equipment in California’s largest cardrooms is common and required by state law, not all cardrooms have video cameras recording gambling activity.

If the CGGC gets its way, that may change before the end of the year.

Currently, only the largest California cardrooms, those with over 61 tables, must have monitored surveillance. This includes five facilities in the Los Angeles area: Hustler Casino, Casino, Hollywood Park Casino, Parkwest Bicycle Casino, Commerce Casino, and Hawaiian Gardens Casino.

Classified as Tier V operators, these establishments must have up-to-date, closed-circuit televisions monitored from a secure area. The proposed regulations would extend those mandates to Tier IV businesses.

Mid-size CA cardrooms must adhere to extensive new guidelines

California’s tier classifications for cardrooms are as follows:

• Tier I – 1 to 5 tables
• Tier II – 6 to 10 tables
• Tier III – 11 to 30 tables
• Tier IV – 31 to 60 tables
• Tier V – 61 or more tables

As of January 2023, there were 84 active cardroom licenses, but only 59 were active. Ten licenses belong to Tier IV operators. More cardrooms could also open in the coming years since the state’s 28-year moratorium on adding new cardrooms expired in January.

While the CGCC requires that cardrooms “maintain security controls over the gambling premises and all operations…related to gambling,” the Tier V operators have more stringent guidelines than the smaller operators. The CGCC wants to extend these guidelines to Tier IV operators and update its overall procedures for all cardrooms. Specifically, Tier IV businesses will need to install monitored CCTV equipment to function during all hours of operation.

The state hopes that this will assist cardrooms in discovering dubious activity the moment it happens, as “unattended surveillance systems can only provide evidence after a crime or suspicious event takes place.” Updated requirements would also help the commission and law enforcement during investigations of illegal activity.

California cardrooms keeping up with other states

The commission also indicated that the current guidelines are out-of-step with regulations in other states where smaller cardrooms are already required to have monitored surveillance cameras. Previously, the commission excluded smaller cardrooms because investing in CCTV-based security would “put an undue financial burden on the cardrooms.”

Cardrooms are unique entities in California, as many smaller ones are mom-and-pop operators. The state prohibits publicly-owned corporations from investing in cardrooms.

Due to the prevalence of low-cost surveillance technology, the CGCC argues that the financial burden of purchasing surveillance equipment is lessened. According to state figures, California’s Tier IV licensees generate “approximately $10 million in gross gaming revenues per year on the low end, and upwards of $70 million per year on the high end.”

Additional requirements of the proposed regulations

Among the other rules and regulations put into place are the following:

• Tier IV and V cardrooms will be required to use cameras that provide high-resolution video in real-time at a minimum of 15 frames per second.
• Surveillance equipment must monitor the interior and exterior of all entrances.
• Cameras must record patrons, dealers, card values, wagers, game outcomes and the count room.
• All equipment must be checked daily, and any malfunctioning equipment must be repaired within 72 hours.
• No cardroom activity under the proposed regulations can occur until the faulty equipment is replaced.
• Cardrooms must have portable digital storage devices to archive footage. The state’s Bureau of Gambling Control can demand and take footage anytime. The bureau also has the right to access the surveillance room and any area where monitoring equipment is stored.
• Cardrooms must maintain a surveillance log that records security personnel shifts and a summary of surveillance activity witnessed by those employees.

The CGCC published the details of the proposed regulation on April 7, 2023, when a 45-day public comment period began. Written comments are due May 22, 2023. The full text of the proposed regulation is on the commission’s website. The commission may also decide to schedule a public hearing so citizens can have a chance to provide oral comments and ask questions.