"We submit that the evidence in the public hearing establishes that The Star is not suitable to hold the casino licence and that its close associate Star Entertainment is not suitable either," counsel assisting Naomi Sharp SC said on Tuesday.
In closing argument, Ms Sharp told the NSW gaming regulator inquiry Star and its Sydney casino were only at the start of their journey "about what has gone wrong within these organisations".
"There has not yet been the period of deep reflection which of course will be necessary in order to develop a concrete plan about what ... can bring these corporations into a position of suitability," she said.
The high-profile inquiry has examined claims that ASX-listed Star enabled suspected money laundering, organised crime, fraud and foreign interference at The Star Sydney as part of assessing whether the venue should retain its casino licence.
The inquiry was told a notorious gang-linked junket operated an illegal cage at the casino, that the venue flouted rules on the use of Chinese debit cards, and that casino staff lied to banks and did not do enough in dealings with regulators.
There has been evidence that Star worked covertly to stop the public hearings taking place.
Also on Tuesday, Ms Sharp SC outlined 26 areas she would address in closing argument, describing the The Star Sydney's casino licence as a privilege that conferred on the venue the ability to earn "very substantial revenue".
"In exchange for that privilege, the casino operator is given a number of very important responsibilities," Ms Sharp said.
Among closing submissions, Ms Sharp said she would address a briefing given by Star's management to the board in the wake of 2019 media allegations.
"It will be our submission that these representations were quite misleading," she said.
She would also argue there was a lack of supervision in the casino's international VIP team and "certain shortcomings" existed on high-value patrons.
Other topics to be covered in closing included the suitability of the casino to keep its licence, the venue's risk management framework, the credit of witnesses, and an examination of whether Star underpaid gaming duties to the state government.
In the wake of the inquiry there has been a clean-out of Star top brass, including chief executive Matt Bekier, chief financial officer Harry Theodore, chief casino officer Greg Hawkins, chief legal and risk officer Paula Martin and board chairman John O'Neill.
The Star inquiry follows a review of its rival Crown Resorts, which ultimately deemed that casino unfit to hold a licence in NSW.
The inquiry continues on Tuesday.
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