Crown is yet to examine why 19 of its staff were arrested in China for gambling promotion offences, a royal commission has been told.
Ann Siegers, the chief risk officer for the James Packer-backed group, said on Thursday while the 2016 arrests were "absolutely traumatic" for Crown, they had not been analysed.
Ms Siegers, who joined Crown in December 2017, said any review of the incident would have had to have been undertaken immediately to be effective.
"There are always lessons to be learned from the past," she told the inquiry into whether Crown can retain a licence for its Melbourne operations.
"A review could be undertaken now, but we're four or five years after the fact.
"By the time I joined Crown many of the people and individuals were no longer in place and therefore it was too late."
Ms Siegers also revealed she had only "scanned" a report on the arrests made by the Victorian Commission for Gambling and Liquor Regulation.
Peter Rozen QC, acting for the VCGLR, asked Ms Siegers if the 2016 arrests represented a "significant failure" in Crown's risk management processes.
"It was a complex event ... there were large communication failings," she responded.
Mr Rozen also put to her that Crown had been warned about the risks of this operation and could have avoided the arrests.
"I don't know that we could have averted it," Ms Siegers said.
"A large part of it was outside our control. It was about the Chinese actions and objectives ... which I don't know that we could control.
"(But) there were failings in escalating some of the warnings to the risk management committee."
Mr Rozen said Crown's risk management structure failed to prevent the arrests back in 2016 as it was "bypassed".
He then asked how the royal commission, overseen by former Federal Court judge Ray Finkelstein, could be satisfied any of Crown's updated structures could be relied upon now.
"At the time there were pieces of paper ... dealing with risk," Mr Rozen said.
"There are now more pieces of paper, more processes, more committees.
"But if they're not engaged in a future crisis, then that crisis won't be averted, or at least the consequences won't be ameliorated."
"Yes," Ms Siegers responded.
"If process is not embedded, then it's not going to assist."
She said that Crown had, in her time at the company, improved its risk management and compliance.
The inquiry was told on Wednesday that Ms Siegers asked a consultancy firm to rephrase a report it was paid to complete in 2019, following scrutiny from the VCGLR.
Ms Siegers emailed partners at Deloitte, expressing concerns their report did not reflect well on recent "enhancements" Crown had made to its risk management.
Deloitte ignored Ms Sieger's request.
The royal commission was set up by Daniel Andrews' Labor government after a NSW inquiry found Crown unsuitable to operate its newly built casino in Sydney's Barangaroo.
It continues next week.
