Compliance Updates
Michigan Gaming Control Board Rejects Recent Claims Regarding Skill Games

The Michigan Gaming Control Board (MGCB) has refuted recent assertions questioning the legitimacy of its efforts to protect citizens by combating illegal gambling within the state, particularly in relation to the rise of casino-style electronic gaming machines that self-identify as “skill games.”
In recent years, there has been a notable increase in the presence of electronic gaming machines in bars and restaurants across Michigan. The suppliers of these machines misleadingly contend that the games include an element of skill and are therefore exempt from Michigan’s gambling prohibitions. Specifically, they claim that the games qualify as “redemption games” under MCL 750.310b, which allows a limited and very narrow exception to Michigan’s gambling prohibitions.
“As the regulatory authority overseeing the three Detroit commercial casinos and online gaming in Michigan, the MGCB is committed to upholding the integrity of the state’s gambling regulations and ensuring a fair and responsible gaming environment for all citizens. It is essential to clarify that these casino-style electronic gaming machines are not exempt from Michigan’s penal code, and individuals operating or utilizing them are subject to enforcement actions by the state,” MGCB Executive Director Henry Williams said.
Ongoing investigations by the MGCB have consistently established that the operation of these games does not comply with the strict requirements of MCL 750.310b because these games operate in a manner that is identical to a slot machine, whereby winning depends primarily upon fortuitous or accidental circumstances beyond the control of the player. Patterns observed with the illegal use of casino-style electronic gaming machines have included the use of cash as prizes, issuance of Visa gift cards, and false claims of legality and/or state authorization. Operations of these unregulated gaming machines put citizens at risk — because they have no recourse should they be misled, cheated, or otherwise taken advantage of — and results in a loss of state revenue, depriving Michigan citizens of taxes and revenue used to support schools through the School Aid Fund and communities and local governments with essential state funding dollars.
Comprehensive joint investigations conducted by the MGCB and the Michigan Attorney General’s Office in the past five years have resulted in 29 individuals being convicted of 27 felonies and 16 misdemeanors. These investigations have also resulted in 436 illegal machines seized, along with $176,001.69 in cash and $15,415 in Visa, MasterCard, and/or Simon gift cards.
“The public is being misled when told that skill and gift cards equate to the legality of a machine. What is being ignored is that the machines in question have been played and/or examined by investigators and determined to be casino-style slot machines for which winning depends on chance. And by law they do not qualify as a redemption game exception to the penal code. The mere use of a gift card as a prize does not render the machine legal,” ,” Williams said.
Unregulated machines used illegally lack the necessary consumer safeguards that licensed and regulated establishments provide, leaving the individuals who use them susceptible to unfair practices. More importantly, they offer no player protections and do not allow patrons to influence game outcomes through skill or strategy. This lack of oversight poses significant risks, particularly when minors can access these machines, potentially increasing the likelihood of future gambling problems among youth.
“The presence of unregulated casino-style electronic gaming machines in restaurants and small businesses risks grooming minors for gambling at an early age. This can have damaging consequences on their future well-being, potentially desensitizing them to the negative impacts of gambling, leading to addiction and financial problems later in life. Kids don’t need access or exposure to slot machines when they go out to enjoy a burger and fries or a pizza. If it’s not on the menu, it should not be available,” Williams added.
The MGCB has provided businesses with educational materials to ensure that any machine they are considering having in their business complies with Michigan law. Additionally, these materials have been uploaded to the MGCB website for public consumption. But the MGCB’s efforts continue to be undermined by the repeated spreading of misinformation, causing the illegal use of these machines to expand across Michigan.
The MGCB has also made it clear that it is not hindering local business owners’ ability to increase profits. Businesses engaged in the use of these machines are committing criminal acts with false assurances that their conduct is legal. In cases where investigations into casino-style slot machines have taken place at bars and restaurants, each of the affected business owner(s) were served adequate, advance warning that they were not in compliance with the law by way of cease-and-desist letters that provided them an opportunity to comply before enforcement action, including criminal charges, was taken.
“The MGCB encourages business owners to contact the agency should they have any questions on whether a gaming machine they have in their establishment complies with the law. Our goal is education and compliance. Any suggestion otherwise is simply not true,” Williams said.
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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