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Compliance Updates

Michigan Gaming Control Board Rejects Recent Claims Regarding Skill Games

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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.

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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.

Canada

AGCO Fines Great Canadian Casino Resort Toronto $350,000 for Serious Regulatory Violations Linked to Impromptu After-Party on Gaming Floor

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The Alcohol and Gaming Commission of Ontario (AGCO) has issued monetary penalties totaling $350,000 against Great Canadian Casino Resort Toronto for multiple violations of provincial gaming standards. The penalties follow an impromptu after-party that was permitted to take place in the pre-dawn hours directly on the casino’s gaming floor.

On September 27, 2024, an electronic dance music event attended by thousands of people was hosted in the theatre adjacent to the casino at Great Canadian Casino Resort Toronto. The event was marked by widespread intoxication, disorderly behavior, and numerous criminal and medical incidents – both inside and outside the venue – including alleged assaults, drug overdoses, and acts of public indecency. Although paid duty officers were present, additional police and emergency services were required to manage the situation.

In the midst of this high-risk environment, casino management approved an unscheduled request by the performing artist to host an after-party on the active gaming floor. The artist and more than 400 guests were permitted onto the gaming floor where the artist was allowed to perform amidst operational table games and gaming machines – without any prior risk assessment or planning.

As a result, security personnel were unable to effectively control the casino floor, including witness reports that an attendee was seen climbing onto slot machines. Failure to maintain appropriate control compromises the security, safety, and integrity of the casino floor. Following the conclusion of the event, the operator failed to promptly report these incidents to the AGCO as required.

Based on the findings of its review, the AGCO’s Registrar has issued an Order of Monetary Penalty (OMP) totaling $350,000 against Great Canadian Casino Resort Toronto. These penalties address critical failures in their operations, incident reporting, employee training, and the management of disturbances.

A gaming operator served with an OMP has 15 days to appeal the Registrar’s decision to the Licence Appeal Tribunal (LAT), an adjudicative tribunal that is part of Tribunals Ontario and independent of the AGCO.

“Casino operators have a fundamental duty to control their gaming environment. Great Canadian Casino Resort Toronto’s lapses in this incident compromised the safety of patrons and the security and integrity of the gaming floor,” Dr. Karin Schnarr, Chief Executive Officer and Registrar of AGCO, said.

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Compliance Updates

Esportes da Sorte holds forum on “Integrity in Sports” with Ceará and Náutico

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Esportes da Sorte holds forum on “Integrity in Sports” with Ceará and Náutico

 

Esportes da Sorte hosted its Match-Fixing Prevention Forum last week at Ceará and Náutico as main sponsor of both clubs. Held in partnership with Sportradar, the initiative is part of a series of in-person workshops, with upcoming sessions planned for Corinthians and Ferroviária.

The project aims to combat illegal practices and reinforce a strong commitment to integrity in sport. Activities were tailored for athletes and members of the technical staff from the men’s and women’s professional teams, as well as the under-20 squads. During the sessions, topics such as the definition of match-fixing, types of fraud, fraudsters’ modus operandi, legal risks, and reputational impacts were covered. Participants were offered practical guidance on how to respond to suspicious approaches.

“This training programme reinforces our commitment to sports integrity and responsible gaming, pillars that guide our actions. We believe education is the best form of prevention, and we want to stand alongside clubs in this joint effort for transparency and the protection of sport,” said Ana Carolina Luna Maçães, Compliance Manager at Esportes Gaming Brasil, the group behind the Esportes da Sorte brand.

“Ceará takes this topic very seriously. The club is an important player in the fight against match-fixing. We act preventively with regular meetings and have a handbook that addresses the topic with our squad. It is our duty to provide these moments of learning for athletes and technical staff. We live in a time when the integrity of sport is being questioned. In this scenario, actions like this are extremely important,” commented Lucas Drubscky, Football Executive at Ceará.

The sessions were led by Felippe Marchetti, Integrity Partnerships Manager at Sportradar, a global sports technology company and recognized authority in sports integrity. In Brazil, Sportradar partners with the Brazilian Football Confederation (CBF) and 17 state federations, monitoring more than 10,000 matches per season. The company recently signed a Technical Cooperation Agreement (TCA) with the Ministry of Finance and the Ministry of Sports.

“Raising awareness among athletes and teams is one of the most effective ways to protect competitions from manipulation. These workshops are designed to equip participants with the knowledge and tools to recognize threats and act responsibly. We are proud to support initiatives like this that strengthen the integrity of Brazilian sports,” said Felippe Marchetti.

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Compliance Updates

New Bill in California Could End Online Sweepstakes Gaming

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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.

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