Small gaming clubs and slot halls (Guyana)

Small gaming clubs and slot halls in Guyana

In Guyana, the gambling market has historically been built on a restrictive model: the basic law prohibits "common gambling houses," and permits are issued pointwise - primarily for casinos at hotels and state/concession lotteries. Against this background, interest in small slot halls and clubs is high, but their launch requires particularly careful compliance with the rules: from room status and licenses to KYC/AML and responsible play standards.

💡 Important: all below - framework analytics. Before any actions, local legal expertise and reconciliation with current norms, regulatory letters and the practice of departments are required.

1) Legal context: where "the lines pass"

Prohibitive framework: maintaining a "common gambling house" outside of special exceptions is an offense.

Exceptions:

Casino at hotels - under special licenses (separately for the premises and for the operator).
Lotteries - under separate law/concessions.
Pool betting - allowed subject to conditions and payment of special fees/taxes.
Lack of a single "online license": online casinos/bets do not have a comprehensive positive framework; local "digital" projects should rely on existing exceptions and not conflict with the basic prohibition.

Conclusion for "small formats": an independent slot hall outside the hotel model and special exceptions are extremely difficult to license. Realistic ways - integration into a hotel facility (boutique hotel), work in an "entertainment complex" subject to targeted permission, or related products within the permitted verticals (for example, lottery terminals/interactive lotteries - if provided for by the contract and regulation).

2) Acceptable formats for the "small hall" (which can work in practice)

1. Boutique casino with a small hotel. Minimum number of rooms, separate entrance/access control, ticket office and video surveillance area, limited EGM and/or electronic table fleet.

2. Entertainment zone as part of a hotel/mall. "Slot-long" with a limited number of devices adjacent to the F&B zone; strict filtering by age, hours and perimeter.

3. Lottery showcase with interactive draws. If provided for by the concession agreement: sales terminals/video draws, but without turning the space into a "gambling house."

4. Bet point (pool betting) + limited "entertainment" content. Emphasis on rates; any gaming devices - only if the legal status is unambiguous and allowed.

💡 The key to legality is the correct qualification of the activity and a strict distinction between the permitted formats and what falls under the ban "gaming house."

3) Room and safety requirements

Perimeter and access: separate entrance/entrance counter, age control area, clear rules (hours, dress code, ban on minors).

Video and data storage: box office/play area coverage, record retention (retention policy, access at regulator/police request).

Cash discipline: safe, inventory of fish/bills, "four eyes" on large operations, daily reconciliation.

IT circuit: WAF/DDoS (if there are online components), network segmentation, event accounting (unchanging logs), regular updates.

Security and incidents: contract with licensed security, evacuation plan, procedures in case of disputed payments/chargebacks/suspicious actions.

4) KYC/AML and compliance

Even the "small" hall should think like a "large" operator:

Guest identification (age, extended KYC if necessary).
PEP/sanctions screening policy (for VIP and large operations).
Transaction monitoring: triggers by amounts/frequency, reporting on suspicious transactions (SAR/STR to the appropriate department).
Personnel training: annual validation of AML/RG knowledge, training log.
Suppliers/EGM: contracts with certified providers, RNG/RTP certification (if applicable), firmware/update log.

5) Responsible play (RG)

Age control 18 +. Scan/visual check of ID at input.

Limits and timeouts: information and assistance to the guest in setting limits; soft interventions at signs of "chasing losses."

Communications: stands with rules, chances and help contacts; transparent vager on the stock.

Denial of service procedures: in case of disturbance or signs of a problem game - a documented protocol of actions.

6) "small hall" business model

Revenues: slots/EGM, electronic roulettes/tables, F & B- アップseyl, partner events.

Costs: rent/repair, licenses/fees, purchase/leasing of EGM, personnel (operators, cash desk, security), payment services, IT/security, marketing.

Key metrics:

GGR/NGR (on EGM and on the table), Win per machine per day (WPMD), Average session duration, F&B check, TAT cashout, SLA support, Share of guests with RG activity (read the rules, set a limit), AML/RG incidents (closing frequency/rate).

7) Marketing and Community

Hyperlocal funnel: neighboring offices/hotels/shopping center; "evening" packages (drink + game credits) - strictly within the advertising rules.

Small format events: mini-tournaments, thematic evenings, draws (if allowed and correctly qualified).

Partnerships: restaurants, taxi services, hotels; bonus for a proven transfer and safe return of guests.

Digital touches: business card site with rules and contacts, messenger support - without "gray" online games and misleading creatives.

8) Risks and how to manage them

Legal risk of qualification. The small hall will easily "move" into the category of a prohibited "gambling house," if we go beyond the exceptions. → Legal audit of the concept, layout, contracts, advertising materials before launch.

Operational risk (cache, multi-accounts, bonus abuse). → Cashout limits, device/card control, incident log, stop-list.

Cybersecurity. → Patch management, segmentation, redundancy, SOC monitoring (outsourcing), accounting for software changes on EGM.

Reputation. → Fast and transparent payments, clear rules, respectful service, "zero tolerance" to aggressive advertising.

9) Roadmap for launching a "small" project

Stage	Actions	Result
Idea → Due Diligence	Legal evaluation of the format (hotel/entertainment/rate), check of requirements for premises and licenses	Understanding if the project is possible and in what form
Design	Hall plan, access control, video, cash zone, IT/logging, RG zone	Control-compatible layout
Procedures and partners	Contracts with EGM/acquiring suppliers, AML/KYC policies, RG regulations and incidents	Compliance package
Pilot launch (soft-open)	Limited hours/EGM fleets, cashout/payments stress test, staff training	Configuring Processes and SLAs
Full launch	Communications, safe transfer of guests, neat promo	Stable operational performance
Continuous monitoring	Box office/video/magazine audits, RG/AML reporting, penetration tests	Sustainability and trust

10) Compliance checklist (short)

Correct business qualification (not "gambling house" without exceptions)

Licenses/permits and format compliance (hotel/betting/lottery)
KYC/AML: policy, training, triggers, reporting
RG: age control, limits/timeouts, relief materials
EGM/SW: certification, update log, incident accounting
Security: video, ticket office, security, IT circuit, BCP/DR plan
Marketing: no misleading creatives, with rules exposed
SLAs: cashouts, support, complaint handling

Conclusion

In Guyana, the "small slot hall" is possible only as a form neatly mounted in the permitted modes - most often at a hotel or in the form of a strictly limited entertainment area with clear access rules, ticket office and logging. The success of the project is not determined by the number of devices, but by the legal purity of the design, the maturity of KYC/AML/RG, safety and respect for the guest. This discipline reduces regulatory risks, builds trust and creates the basis for a sustainable project economy.