Star Entertainment Group is "not suitable" to hold a licence for its Sydney casino, a public inquiry has been told.
An inquiry by the NSW gaming regulator is investigating the company's suitability to run its casino in Pyrmont.
Several top executives have resigned over the course of the inquiry, which has heard allegations of money laundering, fraud and criminal infiltration at the casino.
Counsel assisting the inquiry Naomi Sharp SC delivered a scathing assessment of the casino's procedures on Tuesday.
That included "unethical behaviour" within the legal team, a VIP team that was "not properly supervised" and "very serious failures" in risk management frameworks.
She said responsibility for the failures went "all the way up to the board".
In late March, CEO and managing director Matt Bekier resigned from the Star board, claiming he wanted to take "responsibility" for the misconduct uncovered at the inquiry.
But Ms Sharp cast doubt over whether the departure of executives would allow The Star to continue operations.
"There is more to the question of suitability than particular individuals within the corporation."
While Ms Sharp accepted that some employees, including outgoing CEO Matt Bekier, were "frank and candid" during their evidence, she was more scathing of others.
She said chief financial officer Harry Theodore was "very reluctant to make concessions".
Others she described as "highly unsatisfactory" and "evasive".
She was also critical of the board for being "passive" about the dangers posed by overseas high rollers.
"There was a failure to bring a questioning mindset to what it was that management did report," she said.
Ms Sharp urged Adam Bell SC, who is leading the inquiry, to take a more "nuanced" view of corporate responsibility.
"One needs to have regard to the leaders of the organisation but also situate them within the broader context of the corporation's governance, risk management and culture overall."
Ms Sharp said although there was no suitability test for holding a casino licence, guidelines set out during the Bergin and Finkelstein inquiries into Crown Casino offered useful guidance.
She said casino operators must obey the law, act honestly, deter illegal and immoral behaviour, not exploit gamblers, take active measures to minimise the harm caused by gambling and cooperate fully with regulators.
There had been a "falling short" in relation to a number of code of conduct requirements at The Star, Ms Sharp said.
Chairman John O'Neill, chief financial officer Harry Theodore, chief casino officer Greg Hawkins and chief legal & risk officer and company secretary Paula Martin have all resigned in recent weeks.
Ms Sharp said given the large number of executives that have resigned, it is "not necessary to make findings about their suitability".
