Crown insists it has turned a new leaf and should not be punished for past mistakes as a royal commission considers the fate of Perth casino.
The West Australian inquiry, which follows similar probes in NSW and Victoria, is investigating whether lax government oversight contributed to issues including money laundering and problem gambling at Crown Perth.
Former Federal Court judge Ray Finkelstein QC last year condemned Crown's "illegal, dishonest, unethical and exploitative" behaviour but allowed the company to keep its Melbourne casino licence.
Instead, it was recommended Crown continue operating under the oversight of a special manager for two years while it undertakes comprehensive reforms.
The WA royal commission on Tuesday heard closing submissions as it prepares to deliver its final report next month into whether Crown should retain its Perth casino licence.
Crown's lawyer Kanaga Dharmananda SC said the company had made significant changes including overhauling its board and executive team after being subject to three "scorching public inquiries" over the past two years.
He said an independent monitor was not needed in WA because equivalent bodies already existed in NSW and Victoria which would "inevitably" cover Perth.
"Crown has, at great financial cost, embarked on a significant program led by people of goodwill and skill," Mr Dharmananda said.
"Commissioner Finkelstein accepted that important steps towards reform had been taken and that the program is likely to succeed. He concluded in relation to Crown Melbourne that it has the will and capacity to reform itself.
"Those assessments, with respect, are also relevant to Crown Perth."
Mr Dharmananda said gambling related harm was low in WA compared to other jurisdictions and improvements were being made including better staff training.
The Perth casino is regulated by the Gaming and Wagering Commission - a part-time, seven member board which meets monthly - with assistance from the Department of Local Government, Sport and Cultural Industries (DLGSCI).
WA's inquiry has heard the GWC opted not to investigate allegations of money laundering against Crown after the company's "persuasive" former legal boss told them it was a media beat-up.
Evidence has also been aired about the state's former chief casino officer sharing regular fishing trips with two Crown employees.
The inquiry heard the GWC and the department had overhauled their processes and staff were now required to disclose personal relationships with Crown staff and to register gifts, benefits and hospitality.
"The department has accepted, and accepts today, that its historical management of conflicts of interest was not of the standard expected of a modern public sector organisation involved in regulation," DLGSCI lawyer Fiona Seaward said.
The royal commission is examining whether WA's regulators effectively allowed Crown to self-regulate aspects of its Perth operations.
An interim report highlighted changes including the deregulation of junket operations and the reduced use of inspectors, who had not been permanently present on the casino floor since mid-2015.
The NSW Bergin report released last year found Crown had "enabled or facilitated" money laundering at its Perth casino through an account linked to a shell company, Riverbank Investments.
The inquiry will also hear closing submissions from lawyers representing Crown and the company's major shareholder James Packer in coming days.
The billionaire last year told the royal commission there were "many oversights" during his time overseeing Crown's Perth casino operations between 2004 and 2016.
