The commission also considered fining the club up to $300,000 for its "systemic failure" to record incidents of problem gambling, but believed an overall penalty of $120,000 was "just and appropriate" given the gravity of the breaches.

These details were included in the Raiders Group's application to overturn their historic fine for failing to intervene in the case of Professor Laurie Brown, who fed more than $200,000 through gaming machines at Raiders clubs in Canberra.

The documents can now be reported on because a suppression order was lifted during Monday's ACAT hearing.

The club and the commission attempted mediation last month but failed because the club opposed a condition the commission wanted to place on its licence to force it to engage an independent auditor for two years to oversee its record keeping.

The commission also wanted each frontline staff member and manager to undergo face-to-face responsible service of gambling training, even if they've done the course in the last three years.

It called for the club to change its procedures so staff knocking off had to pass on any concerns about problem gamblers to staff coming on shift.

Those conditions, to be placed on the club on top of the $120,000 fine for a period of two years, were considered necessary because of statements made by the club's chief executive and general manager, the commission said.

Raiders Group chief executive Simon Hawkins wrote to Professor Brown's husband, saying repeated cash withdrawals weren't a trigger for a problem gambling report because "staff don't know how wealthy a patron may be".

"If a patron was making repeated withdrawals and a staff member became aware funds weren't available then this combination may trigger a gambling incident report," Mr Hawkins wrote.

Raiders Belconnen general manager Craig Potts told Access Canberra investigators repeated cash withdrawals were only noted as a sign of problem gambling in combination with other factors.

"If there was irrational behaviour occurring, if there was an intoxication or larg amount so alcohol being consumed, if there was bad language, if there was violence in association with this particular patron's use of the ATM then there is definitely an association that we could – we could look at and further – and further investigate," Mr Potts said.

Mr Potts added that multiple withdrawals were not included in a brochure on gambling, handed out to patrons on the floor.

In a letter to the club's lawyers dated November 3, ACT Gambling and Racing Commission chief executive David Snowden said the brochure was clearly targeted at problem gamblers, not licensees, and there was no excuse for not knowing the rules.

"The code and checklist make clear that multiple ATM or EFTPOS cash withdrawals are a 'sign' and that observing a sign a licensee must respond by recording it in the Gambling Incident Register," Mr Snowden said.

"The statements by Mr Hawkins and Mr Potts reveal either a concerning lack of familiarity with the signs of a gambling problem identified in S1.6A of the code and the checklist or an equally concerning attitude that signs identified in the code or checklist need only be recorded when they accord with an individual's personal views about what constitutes a sign.

"The commission is troubled by the fact these statements were made by people occupying senior management positions who must necessarily set an example for staff and help shape the licensee's approach to compliance with the code."

The Raiders Group denies that their staff should have recorded signs of problem gambling for Professor Brown on eight separate days between June 1 2015 and January 30 2017, when she repeatedly drew cash from an EFTPOS terminal at the club's reception.

While Professor Brown pulled out a total of $22,000 over those days, and staff had to physically activate the machine and swipe her card, the club maintains staff were not aware of how much she was withdrawing, as users plug the amount in themselves.

However the commission says the club should have recorded Professor Brown's actions in their incident register regardless.

A staff member told the commission she'd verbally reported Professor Brown's multiple withdrawals to duty managers but the club has produced no proof they recorded the observation anywhere.

Raiders Gungahlin also logged instances of repeated EFTPOS cash withdrawals in their problem gambling incident register, the commission said.

The matter is set down for hearing from June 12 to 20.