Compliance Updates
Koi Nation of Northern California Casino Plan Meets Requirements of Indian Gaming Laws

The Koi Nation of Northern California is in full compliance with the Indian Gaming Regulatory Act’s “Restored Lands Provision” in the tribe’s pursuit of the Shiloh Resort & Casino project in unincorporated Sonoma County, California.
“The promise of the Indian Gaming Regulatory Act’s “restored lands provision” was to remedy the tragic history of forced removal and relocation by allowing restored lands to be utilized for tribal gaming. Like it or not, a rigid set of rules exists to qualify for this provision of federal law — and we’ve dutifully met them all,” said Darin Beltran, Chair of the Koi Nation of Northern California’s Tribal Council.
The Koi Nation’s ancestors relocated to Sonoma County after rejecting the Bureau of Indian Affairs’ offer of a Rancheria in neighboring Lake County in 1916 that the agency itself deemed uninhabitable. This tragic series of events rendered the Koi Nation landless and led to the improper termination of its federal recognition status, ending its ability to pursue gaming through the same rights afforded to all other federally recognized tribes.
The Koi Nation’s federal recognition status was finally restored in 2000, and a 2019 ruling in a case overseen by the Chief Judge of the U.S. District Court of the District of Columbia, Beryl A. Howell, recognized the tribe’s ability to pursue gaming through the “restored lands provision”.
“This unique provision of federal law allows tribes restored to federal recognition status, such as the Koi Nation, to pursue gaming according to strict statutory and regulatory requirements,” Beltran said.
These requirements include the demonstration of a “significant historical connection” to the site of proposed gaming projects.
In its filing for a restored lands opinion, the Koi Nation methodically details the tribe’s deep ties to Sonoma County. These include their ancestors’ well-regarded roles as Sonoma County Native American political leaders who advocated for 1928 federal native claims legislation, Native American social rights and community organization with other Pomo tribes, and voters for the tribe’s organization under President FranklinRoosevelt’s Indian Reorganization Act of 1935.
“Since that time, the center of Koi Pomo life – and death – has been in Sonoma County. Our application is in full compliance with Indian Gaming Regulation Act’s restored lands provision,” said Dino Beltran, Vice Chair of the Koi Nation of Northern California’s Tribal Council.
The Koi Nation’s strong historical connection to Sonoma County was recently supported by an opinion piece published by the project site’s local paper of record, the Press Democrat.
Additionally, the largest native American news publication in the US, Indian Country Today, published an opinion piece supporting the Koi Nation’s utilization of the restored land provision in the face of recent opposition.
The publication of these two pieces demonstrates that the opinions contained therein are significant not just in the region surrounding the proposed Shiloh Resort & Casino project, but for all of Indian country throughout the US.
Compliance Updates
Zimpler Becomes Certified Payment Institution in Brazil, Strengthens Local Open Finance Ecosystem

Zimpler, a leading Swedish company in Pay-by-bank solutions, has become a certified Payment Institution (PI) in Brazil, authorized by the Central Bank. Now Zimpler is allowed to facilitate payments and other Open Finance ecosystem resources, streamlining the checkout process and reducing friction by allowing direct transactions without redirecting users to bank apps. This movement solidifies Zimpler’s plans and structure in Brazil.
“We are thrilled to receive this authorization from the Brazilian Central Bank. The recognition of Zimpler as a payment initiator reinforces our commitment to this local market, which offers a great opportunity for growth and value in a very dynamic and competitive environment,” said Johan Strand, CEO of Zimpler.
The authorization, which also allows Zimpler to act as an electronic money institution, strengthens the Open Finance ecosystem in Brazil, one of the most advanced in the world and which now welcomes the leading payments fintech from Sweden. Businesses looking to thrive in the country can now benefit from the Zimpler’s seamless payment experience, giving them a competitive edge in a dynamic and fast-moving market.
“This milestone showcases the strength of Swedish innovation and the mutual benefits that come from closer economic collaboration between Sweden and Brazil. Sweden has long been a leader in financial technology, and we are proud to see companies like Zimpler bring their experience and trusted solutions to contribute to Brazil’s dynamic digital economy,” said Andreas Rentner, Trade Commissioner and Country Manager of Business Sweden in Brazil.
“With our experience powering over 80% of Sweden’s population through Swish, we’re bringing the same proven technology and approach to Brazil through Pix, one of the most successful real-time payment systems in the world. We’re looking forward to helping businesses unlock the full potential of Open Finance in Brazil with seamless, secure payments that drive market growth,” Strand said.
The authorization by the Central Bank is another step in strengthening Zimpler’s foundation in Brazil, following the opening of its São Paulo office in 2022. The company remains focused on expanding its footprint and deepening its partnerships across key verticals such as iGaming, where it sees strong growth potential.
Compliance Updates
MGCB Issues Cease-and-Desist Orders to Six Illegal Online Gambling Operators

In a continued effort to safeguard Michigan residents and uphold the integrity of its regulated gaming environment, the Michigan Gaming Control Board (MGCB) has issued cease-and-desist orders to six online gambling operators unlawfully offering services in the state.
The named entities—Bonus Blitz Casino, DomGame, Royal Ace Casino, Slots Capital, Supernova Casino, and Wins Mania—have been found providing internet-based gambling without obtaining the necessary state authorization, violating Michigan’s Lawful Internet Gaming Act, the Michigan Gaming Control and Revenue Act, and sections of the Michigan Penal Code.
“These illegal operators often masquerade as legitimate gaming platforms, but they exist entirely outside the legal safeguards that protect consumers. When Michiganders play on unlicensed sites, they’re placing their personal and financial security at risk—with little to no recourse if things go wrong,” said Henry Williams, Executive Director of the MGCB.
Unlike Michigan-licensed gaming platforms—which undergo rigorous vetting, continuous monitoring, and must comply with strict state regulations—these unlicensed operators are not authorized to offer gaming services in the state. Some are based outside the US, operating beyond the reach of U.S. regulatory oversight, while others may claim domestic ties but still fail to meet Michigan’s legal and licensing requirements.
Because they operate without state approval, these entities do not follow Michigan’s consumer protection standards, responsible gaming mandates, or transparent dispute resolution procedures designed to ensure fair play and data security.
“This action sends a clear message to illegal operators: Michigan is not a place for rogue gambling. We are committed to preserving a safe, legal, and accountable gaming landscape—and that includes rooting out bad actors who threaten the trust we’ve built with consumers,” Williams said.
Compliance Updates
Responsible Online Gaming Association Releases Guidelines for Operator VIP Programs

The Responsible Online Gaming Association (ROGA), an independent association representing 90% of the legal U.S. sports betting industry by handle, published its guidelines for operator VIP programs. These evidence-based recommended practices are intended to support members’ VIP policies to further incorporate robust responsible online gaming. These can help players maintain a balanced, enjoyable gaming experience within their own personal limits.
“Like in many sectors of entertainment, leisure and hospitality, sportsbook’s VIP programs aim to reward and retain loyal players, and it is essential that these programs are operated with a strong commitment to responsible gaming. These programs should support a shared understanding between hosts and players on the value of responsible gaming that fosters long-term loyalty and player well-being. There is a robust conversation ongoing regarding VIP programs, which is why we have prioritized this issue, as it is essential to provide research-driven guidance to adequately support these programs to help keep VIP players’ experience fun and recreational,” said ROGA Executive Director, Dr. Jennifer Shatley.
Guided by existing evidence, ROGA found that the most effective VIP programs combine proactive education, personalized engagement, and periodic program evaluation. Pursuing these objectives, ROGA identified the following recommended practices for operating VIP programs, many of which have already been implemented by some operators:
• Role-specific Training for VIP Hosts: Provide ongoing education specifically tailored to the unique needs of VIP Hosts.
• Automated Review: Operators will take advantage of technology to attempt to detect potentially risky behavioral patterns among VIP players, such as increased deposit frequency, extended play sessions, or repeated failed withdrawal attempts.
• Escalation Process: Operators will implement measures to escalate to a responsible gaming specialist when the operator identifies that a player might be exhibiting potential signs of problematic play. The specialist should conduct a review of the player’s behavior and take appropriate action on a case-by-case basis, such as connecting with trained behavioral health personnel.
• Integrate RG Messaging into VIP Communications: Communicate responsible gaming messages to VIP players using a range of tailored engagement channels.
• VIP Engagement Protocols: Establish protocols to guide interactions between VIP hosts and VIP players, with a focus on transparency, support, and responsible gaming.
• Promotions, Bonuses, and Incentives: VIP Hosts should not offer any VIP promotions, bonuses, or incentives to VIP players who are on a cool-off period, have self-excluded, or have a suspended or banned account, and must also provide all VIP players with the ability to opt out of receiving such incentives.
• Making Data Available: Provide VIP players with access to player data that show player activity, including deposits, wagers, and withdrawals.
• Confirm Awareness of Tools: Require VIP players to confirm their familiarity with responsible gaming tools and resources upon onboarding.
• RG Education for VIP Players: Regularly provide VIP players with responsible gaming educational materials to support responsible gaming behavior.
• Regular Program Evaluation: Conduct annual reviews of the VIP program. This can include feedback from both VIP players and VIP hosts, as well as tracking the success of engagement strategies.
• Development and Updates: Operators should keep apprised of new tools and methods for responsible gaming as they are developed.
This non-exhaustive list of recommended practices is a critical step toward further supporting these programs. ROGA’s members have independently made the decision to commit to implementing these guidelines within a commercially reasonable timeframe.
With its members’ support, ROGA continues to identify and publish research-based recommended practices for responsible gaming across a variety of priority topics.
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