ASIC alleges that Bekier, Martin and Hawkins did not adequately address "the money laundering risks that arose from dealing with Asian gambling junket Suncity and its funder, as well as continuing to deal with them despite becoming aware of reports of criminal links", and that the three executives did not escalate money laundering concerns to the company's board of directors. Allegations against Martin and Theodore made by the regulator are that they made misleading statements to the National Australia Bank about the way in which the China UnionPay debit cards were being used at the casino. "Those statements disguised the fact that Star was permitting CUP cards to be used for gambling, which was prohibited by CUP. ASIC is aware over $900 million was obtained by Star customers using CUP cards in NAB ATMs from 2013 to 2019," the regulator says. Court documents also allege that Bekier, Martin and Theodore failed to tell the company board about the debit cards being used for gambling despite China UnionPay having a specific prohibition on the use of cards for this purpose.