distribution of so-called "Bingo'' cards -- also known as pull-tab or krack-its cards -- which operate on a similar basis to scratch-and-win cards.

While the Finance Ministry sought the legal advice of the Attorney General in recent weeks, the Bermuda Monetary Authority (BMA) also took an interest.

Finance Minister Grant Gibbons revealed his thinking on the matter by stating: "The first issue for us was whether or not these cards were legal. I'm still not sure. If they are legal, then a second issue becomes one of regulatory oversight and that has not yet been discussed with Cabinet, because we haven't officially received an answer from the Attorney General's Chambers on the issue of their legality.

"Another issue, if they are legal, is that we may look at it from a revenue raising perspective. But, no decisions have been taken, because there still is some question in my mind as to whether or not these things are legal.

"I have had no official confirmation yet, although there seemed to be some indication from The Royal Gazette story last week that Police had some legal advice from the AG's Chambers.'' Police officials said last week the AG had advised that the operation may not be legal. Police have been visiting licensed establishments with the "Bingo'' machines and warning them of the potential for prosecution.

The revenue raising aspect may come into play if the game is deemed to be gambling, which is generally only legal here under licence. One critic has already complained privately that unlike licensed gambling offices in Bermuda for activities such as betting on horse racing, the Government is not obtaining the statutory 20 percent betting tax.

Dr. Gibbons conceded that the sale of these cards in private clubs to their membership may also raise a legal distinction.

He said: "I would much prefer to get the legal opinion before commenting on any possible distinction between public sale and private club sales to their members, or commenting on a distinction that Government may wish to make between the two.'' The distinction may arise because of the difference in the way that private clubs are regulated when compared to licensed establishments open to the public.

But there are also concerns about the operation from other quarters, because the game machines in various establishments can only be operated using US Dollars.

BMA general manager Malcolm Williams confirmed the Authority had been studying the cards, as they related to matters which come under the Authority's purview.

He conceded: "We don't feel that it is in Bermuda's interest to have machines that only accept foreign coinage or currency. And it is questionable whether such actions by residents in putting that money into the machine is legal.

"The currency of Bermuda is the Bermudian dollar and while we do accept the usage of US currency, we do so really in the expectation that usage will be in the main by tourists. That assists tourism.

"But if all machines were only to accept foreign currency, the Bermudian dollar would disappear, which I don't think is in Bermuda's interests.'' The cards have been distributed in many licensed establishments, including at least one that is operated by a concessionaire in a Government building.

The Minister of Finance was unaware of this when asked about the issue.

Distribution of the cards began shortly after a June, 1995 Magistrates' Court ruling that Bingo was legal in licensed establishments.

The cards do not resemble the traditional Bingo concept. In fact, customers simply buy the cards by placing US dollars into a machine and then examine them to see if they have won a monetary prize.

In some private clubs, the use of US dollars is not required because there is no machine and patrons can buy the tickets individually. People buy the cards under the possibility that they can win up to $300 from one dollar cards, or up to $1,000 from $2 cards. They discover the size of their luck by simply opening the back of the card.

Private clubs, in some cases, have brought different versions of the game into the Island. Although the largest supplier is the group that began operating island-wide traditional bingo games that led to the court ruling. They circulate cards which have "Bermuda Islands Bingo'' printed on them.

All of the cards distributed here appear to be manufactured by a US firm, Bingo King Co. which prints a standard warning: "For sale or use only in a bingo game authorised under California law and pursuant to local ordinance'' (Applies to California Only.) A spokesman for the local distributor, Neil Inchcup, declined to discuss the matter for the record, although he is known to be upset by the latest decision by the AG and subsequent action by Police.