Senior management at Star Entertainment were seemingly in the dark about its Sydney casino's ongoing operations with a controversial junket operator.
Bank enquiries regarding overseas transactions were met with delay while Star scrambled to investigate.
Testimony by high-ranking Star figures to the NSW gaming authority inquiry could also be inconsistent with documented evidence about a loan provider.
Lawyers assisting the inquiry by Adam Bell SC are closing their case after examining claims Star enabled suspected money laundering, organised crime, fraud and foreign interference.
The inquiry heard on Thursday a relationship with junket operator Kuan Koi continued despite the board being warned it could violate the law.
Counsel assisting Naomi Sharp SC went over an August 2019 memorandum from Star's corporate general counsel Oliver White piecing together the company's relationship with Mr Koi.
He described how money could be transferred into Star accounts for gambling by international patrons.
Mr White warned: "We have not been able to verify the lawfulness of the process used."
Ms Sharp said there was also a workaround for people wanting to pay in cash.
"They're reluctant to have it appear that their funds are going into an international casino because of the crackdown in (Chinese special administrative region) Macau," Ms Sharp said.
"That problem is pointed out in the papers that go up to the board at this time."
She said it was concerning there had been no risk assessment of the methods used.
Senior Star employees were told they could violate anti-money laundering and counter-terrorism financing laws because it was difficult to identify the source of the cash payments.
"It's just completely unacceptable for a casino in view of the intrinsic money laundering risks here," Ms Sharp said.
"None of them are advised to authorities at the time."
Mr Bell said "no one at a senior level seems to have had any idea of how this arrangement was continuing or the terms on which it was continuing".
"That's so," Ms Sharp said.
Star could also help customers hide gambling transactions through its loan-giving Hong Kong subsidiary EEIS.
The National Australia Bank asked Star to explain why most funds transferred to EEIS accounts originated from overseas.
NAB's corporate banking head Tanya Arthur continued to press Star for a response and Star continued to delay in September 2019, Ms Sharp said.
"There was something of a mad scramble within Star Entertainment while they tried to understand what had been going on," she said.
The accounts had not been properly monitored, were active while they were supposed to be dormant, and the subsidiary's purpose changed over time, Ms Sharp said.
In its initial application to become a close associate of Star, EEIS stated it was not an agent of the casino.
"Merely stating that does not make it so," Ms Sharp said.
"This company was entirely controlled by Star ... to funnel money into the casino."
There was no commercial purpose to the loans given by EEIS, they were really designed to comfort patrons that the money would not be connected to casinos, Ms Sharp said.
Mr Bell said a number of witnesses, including former Star CEO Matt Bekier, had given evidence to the inquiry EEIS loans were to extend the time patrons had to repay their debts.
"But it may be that these loans served more than one purpose," Mr Bell said.
EEIS' standard operating procedures indicated the loans were to fund gambling, and patrons had 30 days to repay.
"That's the same amount of time," said Ms Sharp, who will conclude her submissions to the inquiry on Friday.
