Compliance Updates
NGCB: Addendum 3 to April 21, 2020 Policy Memorandum

Procedures for Reopening after Temporary Closure Due to COVID-19
On April 21, 2020, the Nevada Gaming Control Board (“Board”) issued a Policy Memorandum related to Procedures for Reopening after Temporary Closure Due to COVID-19. The Board is providing the following additional information to licensees regarding reopening procedures.
1. Internal Audit Procedures: On May 29, 2020, the Board issued Addendum 1 to the April 21, 2020 Policy Memorandum. This addendum granted a waiver to allow certain internal audit procedures, required pursuant to Regulation 6.090(15), for calendar year 2020 to only be performed if a licensee operates an applicable gaming or entertainment area for three consecutive full months or more during 2020. The Board is extending this waiver to allow licensees with calendar business years to reduce the required procedures for table games and slots from a semi-annual requirement to an annual requirement for calendar year 2020. This reduction would include completion of the MICS Compliance – General Walk-through – All Procedures Checklist for both table games and slots.
2. Branch Office Visits: The Internal Audit Compliance Checklist – Branch Offices Walk-Through Procedures requires that “branch offices and/or independent agents that either took possession of more than $500,000 (cash or non-cash) in deposits or collected, in total, more than $500,000 (cash or non-cash) on credit instruments during the previous fiscal year, or more than $500,000 in the fiscal year to date are visited and compliance reviewed at least every other year. Branch offices not meeting the aforementioned $500,000 criteria are visited and compliance reviewed at least once every five years.” Any branch office and/or independent agents that are scheduled to be visited in 2020, based on the preceding criteria, may either be 1) “visited” through video conferencing and online document inspection, or 2) deferred until 2021.
3. In-House Progressive Payoffs: For progressive payoff schedules that were removed from the floor due to the Governor’s Declaration of Emergency – Directive 002 dated March 18, 2020, the time period to either put a progressive payoff schedule back on the casino floor or to distribute the entire incremental amount, pursuant to Regulation 5.110(5), is being extended to October 1, 2020.
4. Extended Business Closures: Pursuant to NGC Regulation 9.010(2), a licensee that ceases gaming “for a period exceeding 1 month” must either surrender their gaming license or obtain authorization from the Board to remain closed for “longer periods.” However, under current gaming regulations, any such authorization “will not permit closing for an entire calendar quarter.”
Generally, the Board will interpret Regulation 9 to contemplate closures that are within the control of the gaming licensee. Accordingly, the Board will not include periods of mandatory closure when determining the applicability of NGC Regulation 9.010(2). Therefore, the Board will calculate the “period exceeding 1 month” to commence June 4, 2020, the date that gaming licensees were permitted to reopen. Thus, a licensee that has not resumed gaming on or before July 6, 2020 must either surrender their license or request authorization from the Board to remain closed for a Addendum 2 to April 21, 2020 Policy Memorandum
Compliance Updates
New Bill in California Could End Online Sweepstakes Gaming

California State Assemblymember Avelino Valencia (D-Anaheim) has introduced Assembly Bill (AB) 831 to protect Californians from unregulated online gambling by prohibiting online sweepstakes games that use a “dual currency” model to mimic casino-style wagering.
“Sweepstakes” platforms sell virtual coins that are used to play casino-style games and can be redeemed for cash or prizes, essentially operating as unlicensed gambling businesses. By exploiting “No Purchase Necessary” disclaimers, they sidestep California’s regulatory framework and evade the state’s voter-approved proposition related to Tribal-State gaming. Many of these “sweepstakes” operators are based offshore and function without proper oversight, avoiding requirements like consumer protections, responsible gaming safeguards, background checks, and tax compliance.
“We cannot look the other way while these platforms exploit legal grey areas. These operations undermine the voter-approved framework that affirms Tribal governments’ sovereign right to conduct gaming in California. AB 831 strengthens that framework and ensures gaming in California remains fair and accountable,” said Assemblymember Avelino Valencia.
AB 831 fortifies existing sweepstakes laws and clarifies the illegality of internet-based sweepstakes that use the dual currency model. It reinforces the shared responsibility between the State, licensed operators, and Native Nations to keep gaming safe, transparent, and accountable. AB 831 is co-sponsored by the Yuhaaviatam of San Manuel Nation, the California Nations Indian Gaming Association (CNIGA), and the Tribal Alliance of Sovereign Indian Nations (TASIN), reflecting strong support from across Indian Country.
“For over 25 years, Tribal governments like Yuhaaviatam of San Manuel Nation, have upheld the will of California voters by operating gaming with integrity. That commitment has allowed us to reinvest in our communities, boost local economies, and support essential public services on reservations and in partnerships across the state. Illegal online gaming now threatens this foundation—compromising voter-approved law and putting Californians at risk,” said Yuhaaviatam Tribal Council of San Manuel Chairwoman Lynn Valbuena.
“We support this legislation that will close dangerous loopholes and strengthen the integrity of California’s gaming system. We remain committed to defending a proven framework that protects the sovereignty of Tribal Nations and delivers real and lasting benefits to all Californians. Together, Tribal governments and the State of California will continue to address and take decisive action against illegal internet gaming in all its forms,” said Yuhaaviatam Tribal Council of San Manuel Vice Chairman Johnny Hernandez, Jr.
“Tribal government gaming contributes nearly $25 billion to California’s economy, sustains over 112,000 jobs, and funds critical community programs. Unregulated online sweepstakes threaten this voter-approved system by imitating casino gaming without oversight, accountability, or community investment. These illegal platforms erase the benefits of regulated gaming while exposing consumers to serious risks,” said CNIGA Chairman James Siva.
AB 831 is pending a hearing in the Senate.
Compliance Updates
New Initiative from DI Council Aims to Enable Betting on Professional Sports

The Division I Council introduced a proposal that, if adopted in October, would change sports betting rules to permit student-athletes and staff members to bet on professional sports and refocus the Association’s enforcement efforts on college sports betting and behaviors that directly impact game integrity. If adopted, the change will be implemented only if Divisions II and III also vote to allow betting on pro sports.
The council’s introduction of the proposal, which comes after a directive from the Division I Board of Directors in April that the council adopt changes to sports betting rules, is not an endorsement of sports betting behaviors, especially for college athletes. The NCAA’s prohibition against betting on college sports would remain in place, as would the prohibitions against sharing information about college events with bettors. The NCAA also would continue to maintain its prohibition for NCAA championships against advertising and sponsorships associated with betting.
“NCAA rules prohibiting sports betting at all levels were written and adopted at a time when sports gambling was largely illegal nationwide,” said Josh Whitman, athletics director at Illinois and chair of the council. “As betting on sports has become more widely accepted across the country, Division I members have determined that further discussion of these sports betting rules is warranted, particularly as it relates to the potential distinctions between betting on professional versus collegiate sports. Throughout our discussions, the council has remained focused on student-athlete wellness and educating student-athletes about the risks and potentially harmful impacts of betting.”
Current NCAA rules do not allow student-athletes or institutional staff to engage in sports betting at any level (professional, college or amateur) for any sports that have NCAA championships, and NCAA members have continually maintained that any betting by a student-athlete on his or her own team or own sport in college should continue to result in a permanent loss of any remaining collegiate eligibility. However, in 2023, Division I changed the reinstatement guidelines for student-athletes who participate in sports betting on professional sports to focus on harm reduction for problematic betting behaviors.
“Deregulating professional sports betting may provide schools an additional opportunity to implement harm-reduction strategies, which can be more effective and have long-term benefits not seen with abstinence-only approaches. Harm-reduction strategies include education, stigma reduction and acknowledging actual behaviors,” said Dr. Deena Casiero, NCAA chief medical officer. “By meeting student-athletes where they are, schools may be more effective at preventing, identifying and supporting student-athletes with problematic gambling behaviors. Regardless of the change, schools are encouraged to use the many sports betting resources already available.”
The recently released Harm Reduction Considerations for Gambling & Sports Betting in Collegiate Sports references available sports betting resources, including the NCAA Mental Health Best Practices. Additionally, more than 100,000 student-athletes, coaches and administrators have been reached through the NCAA’s education efforts with EPIC Global Solutions, and the NCAA has launched an e-learning module to educate student-athletes on problem gambling harms and the integrity risks associated with sports betting.
Several sports betting-related violations by staff members at NCAA schools have been resolved through the infractions process in recent years, and the enforcement staff is working on issuing Notices of Allegations in several ongoing cases that involve allegations of betting on professional and college sports by student-athletes and/or athletics department staff members at a handful of NCAA schools.
The proposed rule change would not be retroactive. If it is adopted, it would apply only to sports betting activities that occur after the effective date of the proposal.
“The enforcement staff’s sports betting-related caseload has significantly increased in recent years, and our staff — including our new sports betting integrity unit — has been effective in detecting and pursuing violations,” said Jon Duncan, NCAA vice president of enforcement.
The Association prioritizes competition integrity, which is vital to college sports. The NCAA uses a layered strategy to respond responsibly to the rise in sports betting across the United States by monitoring over 22,000 contests per year, advocating for limits on prop bets that pose heightened risks, reducing the potential for student-athlete abuse by aggrieved bettors, and creating greater transparency to assist with the timely investigation and resolution of integrity-related issues.
This layered approach includes the most recent agreement extension with Genius Sports to establish unprecedented betting restrictions on high-risk proposition bets. Sportsbooks licensing NCAA championship data must cooperate fully with NCAA investigations, including providing access to account data, financial history and geolocation records. This will allow the NCAA to work with the sportsbooks to gather detailed account information when harassers are identified to prevent repeat offenders from continuing to place bets across platforms, increasing safeguards to protect student-athlete mental health and well-being.
Compliance Updates
Honolulu Mayor Signs New Laws Targeting Illegal Game Rooms

Last Thursday, Honolulu Mayor Rick Blangiardi signed into law three bills — Bills 11, 12 and 13 — each of which are related to illegal gambling in the county.
The first, Bill 11, sets requirements on “electronic amusement devices” in public establishments. Operators of the establishment are now required to obtain a permit from the Honolulu Police Chief to use such a device on the premises, or else forfeit the device.
The Police Chief could deny a permit application if the proposed location of the device “would be reasonably likely to result in an increase in criminal activity, vandalism, litter, noise or traffic congestion,” according to the bill. The bill also requires anyone with a permit to allow a police officer to enter the premises and inspect the device and other records.
Meanwhile, Bill 12 allows the Honolulu Department of Planning and Permitting to deny permit applications for properties that have been cited for a gambling-related public nuisance within the previous two years.
And Bill 13 allows landlords to request a police escort while inspecting a private property for nuisance claims, with the accompanying officers authorized to document law violations or unsafe conditions, and to warn people not authorized to be there to leave.
In tandem, the three bills are meant to clamp down on illicit gambling rooms, which often become hotspots for associated complaints of criminal behavior.
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