In a pitch to regulators, Star Entertainment Group says it accepts the findings of an inquiry which found it unsuitable to hold a casino licence in NSW and will do whatever is necessary to reform.
The gaming company on Tuesday announced "a comprehensive remediation plan" and pleaded to be allowed to continue to operate its Sydney casino under strict supervision.
The report by Adam Bell released on September 13 found "extremely serious governance, risk management and cultural failures" had occurred at the Pyrmont complex.
The NSW gaming regulator found Star had repeatedly breached the law, misled banks and allowed criminals to operate with impunity and gamble almost without restraint.
After delivering the scathing report NSW Independent Casino Commission (NICC) chief Phillip Crawford said Star could be booted from NSW and faced fines of up to $100 million.
Senior management's willingness to take risks for financial outcomes over numerous years had been "appalling", he said.
The company was given 14 days to explain why it shouldn't face disciplinary action.
A statement issued by executive chairman Ben Heap on behalf of the board said The Star Sydney accepted the findings of the Bell report, "including the finding of unsuitability" and acknowledged "the gravity of the conduct".
The company says it has taken "significant and urgent remedial steps, including increased risk, compliance, and security staff, approval of upgrades to surveillance technology as well as permanently exiting junkets and closing the Marquee nightclub".
The company pledged to take "additional necessary and appropriate action" so the NICC "can be satisfied The Star Sydney has taken sufficient steps, and has bound itself to take further steps, so that it may continue to hold its licence".
The Star Entertainment Group (TSEG) says it has a plan for "a multi-year transformation of the governance, accountability and capabilities, culture and risk, and compliance management practices of the organisation".
"We intend to do whatever is necessary, in consultation with NICC, to restore The Star Sydney to suitability.
"We submit that the appropriate action NICC should take is to allow TSEG to continue to operate the licence, under strict supervision and being held accountable to the milestones on the remediation plan."
Achieving the stipulated milestones "should give NICC confidence that TSEG has restored suitability".
The response comes a day after Star's acting chief executive Geoff Hogg resigned.
The statement noted there had already been significant changes in Star's leadership, with a number of key executives' resignations.
"The team to lead us on the path to suitability will be very different to those who led TSEG in the past."
New appointments included a Sydney controls officer and a chief risk officer, subject to regulatory approval.
Interim appointments were in place, with changed reporting lines to create better accountability and independence for risk management, "to ensure we move swiftly to strengthen The Star Sydney's operations and risk and controls management".
By October 31 the company will have an independent compliance committee, as recommended in the Bell Report.
