30JAPAN LAWYERS GUIDE 2018/19within the IR will be excluded from the general pro-hibition of gambling, the people/entities which take part in the IR/casino operation will be subject to strict regulation.Below is the chart showing the relation among those followed by a brief explanation of the roles they play (note that the alphabets “A, B, C…” and “a, b, c…” correspond to the headings of each explanatory state-ments which follows).3.Key OperatorsWhile the regulation mostly concerns the IR/casino operators and their shareholders, it is possible that the operator of the IR/casino and the ownership of the un-derlying land, facility and equipment are dierent. e Act provides for such cases, each of which having dier-ent licensing/authorization/permission requirements.A) Establishment and Operaon Business OperatorAn entity that conducts business to establish and oper-ate an IR (and other businesses incidental to the oper-ation of an IR) is categorized as an Establishment and Operation Business Operator (Article 2 (4) of the Act). An Establishment and Operation Business Operator is prohibited from engaging in any business other than the establishment and operation of such IR, so this en-tity needs to be a SPC (Article 18 (1) of the Act).B) Casino Business OperatorAn Establishment and Operation Business Operator who conducts Casino Business by obtaining a license from the Casino Administration Committee is categorized as a Ca-sino Business Operator (Article 2 (9) of the Act). Here, the term “Casino Business” means a business that performs the following services:(i)Services for conducting Casino Gambling with cus-tomers or having it conducted between customers in Casino Facilities. e methods and types of gam-bling to be admitted will be specied in the Casino Administration Committee’s rules as ones that are reasonably found to be acceptable in Japan in terms of conventional wisdom from the perspective of en-suring public condence in sound Casino Business

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