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.
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.
Compliance Updates
PHAI Files Lawsuit in Pennsylvania Over Caesars’ Dangerous Online Casino Promotion and “Pay Through Bonuses”

The Public Health Advocacy Institute (PHAI), a nonprofit advocacy organization that continues to lead the movement to develop a comprehensive public health response to the threat posed by the gambling industry, announced a new lawsuit filed in Philadelphia, Pennsylvania, seeking to expose and stop an alleged dangerous, misleading, and illegal “deposit match” promotion by Caesars Online Casino and its brick-and-mortar partner Harrah’s Philadelphia Casino.
In this promotion, Caesars and its partners are luring new customers with a false and misleading promise of a “$2500 deposit match,” according to the lawsuit. Only in the small-print terms and conditions is it disclosed that a new customer playing Blackjack is required to gamble and risk $375,000 in just the first seven days after opening an account. In other words, no money or winnings can be withdrawn unless a total of $375,000 is gambled and risked. All money lost during the first 7-day period is kept by Caesars and Harrah’s Casino.
The lawsuit alleged that Caesars and its partners have effectively rewritten the laws of the Commonwealth of Pennsylvania by mandating that new customers gamble up to $375,000 before being paid any of their winnings. The public is not told that the promotion is designed to snare new customers in a “wild chase of action,” where the bonus is unattainable and therefore impossible to win.
Under the leadership of Executive Director Mark Gottlieb, PHAI continues to spearhead the burgeoning movement to bring comprehensive public health change to the threat posed by the gambling industry and its partners across the US.
Gottlieb said: “We know the gambling industry, with the assistance of the American Gaming Association (AGA) and the National Council of Legislators from Gaming States (NCLGS), is aggressively attempting to push the legalization of online casino gambling across the United States. Thus far, the seven states with online casino gambling seem ill-prepared or unwilling to regulate the wild tactics of the industry. This promotion, engineered by Caesars, is among the most egregious we have seen to date.”
Dr. Harry Levant, Director of Gambling Policy at PHAI, warned that Caesars and others in the gambling industry are acting with impunity, disregarding existing laws, and placing the public directly at risk.
According to Dr. Levant: “It is unconscionable for a gambling company to knowingly require people to gamble excessively and put their mental health at risk as a condition to cash out their winnings. More importantly, nothing in Pennsylvania’s gambling rules or laws permits a casino to refuse payment unless and until customers begin gambling to excess. This is dangerous to Caesar’s customers, immoral, and just plain wrong.”
PHAI Director of Litigation Andrew Rainer, Esq., said: “PHAI continues to utilize the courts to protect clients and the public from unreasonable risks of harm caused by the negligent, careless, and reckless conduct of the gambling industry.”
PHAI Founder and President. Dr. Richard Daynard said: “The mission of the Public Health Advocacy Institute is to protect public health and advance social justice. The days of the gambling industry disregarding public health and safety are coming to an end. When Caesars doesn’t play fair, it puts players’ health at risk.”
The case is Brubaker vs Chester Downs and Marina LLC et al. (Ct of Common Pleas, Philadelphia County, First Judicial District, Case ID 250602325).
In December 2023, PHAI and its Center for Public Health Litigation filed a class action suit against DraftKings in Massachusetts that garnered nationwide headlines. In August 2024, a judge in Massachusetts denied DraftKings’ motion to dismiss, allowing the litigation to move forward.
In October 2024, PHAI filed a lawsuit against the Massachusetts Gaming Commission, asking the court to compel the MGC to adhere to state law and turn over data that casinos compile to track player behavior. Under Section 97 of the Expanded Gaming Act, the Massachusetts Gaming Commission is required to collect behavioral data from casino operators and share anonymized customer data with researchers. This data is essential for analyzing what casino practices are causing harm and who is being harmed. The Gaming Commission has been subject to the legal requirement to collect this data since its formation in 2011. Now, more than a decade later, the Commission has yet to collect a single piece of data from any licensee or make any data available to researchers.
Compliance Updates
The Saskatchewan Indian Gaming Authority (SIGA) Selects New Board Chair

The Saskatchewan Indian Gaming Authority (SIGA) has announced Chief Tammy Cook-Searson, of the Lac La Ronge Indian Band, as its new Board Chair for SIGA’s Board of Directors.
SIGA is a non-profit First Nation gaming operator for seven land-based casinos and the online gaming platform PlayNow.com in Saskatchewan.
Chief Cook-Searson first joined SIGA’s Board of Directors in 2018 and has been a regular SIGA Board member as well as a member of SIGA’s Audit & Finance Committee.
She is serving in her 20th year as Chief of Lac La Ronge Indian Band and has a Master of Business Administration (MBA) degree and a graduate diploma in management from Athabasca University. She also holds honorary degrees from the University of Regina, the Saskatchewan Indian Institute of Technologies (SIIT) and Saskatchewan Polytechnic.
Chief Cook-Searson replaces outgoing Board Chair former Chief of Muskowekwan First Nation Reginald Bellerose, who has held the Board Chair position since February 4, 2015.
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