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CASINO & GAMING VENDOR LICENSING GUIDE
applications for certain “Key Persons” as well
as fingerprint cards and a criminal history
summary.
Frequently, gaming jurisdictions have
strict provisions prohibiting people who
have been convicted of felonies, gaming-
related crimes, and, in some jurisdictions,
misdemeanors involving dishonesty, from
becoming licensed as suppliers. If any of
your owners or employees has had problems
in the past, you may wish to consult legal
counsel for assistance with the process.
Suppliers, owners, and key employees of
suppliers of goods and services may also
be asked for extensive financial information
and personal balance sheets. Gaming
jurisdictions examine this information to
determine whether the potential licensee
has financial issues that may provide a
vulnerability or inclination to criminal
elements to attempt to exert influence
within the industry. Gaming regulators
are concerned that individuals who are
in desperate financial straits may be
susceptible to attempts by criminals to get
assistance in illegal endeavors.
Frequently gaming control authorities
are empowered with broad discretion to
deny licensure based on a lack of “business
probity”or a lack of“financial stability.”
Importantly, each gaming jurisdiction tends
to have unique requirements or restrictions
that apply to licensed gaming industry
suppliers. Additionally, initial licensing is
not the end of the process. Most gaming
jurisdictions impose ongoing reporting
and disclosure requirements on gaming
suppliers and require licenses to be renewed
on a periodic (e.g., annual or biannual) basis.
Very typically, gaming industry suppliers will
be subject to a wide variety of additional
criminal law provisions as a result of their
participation in the casino industry.
In the state of Michigan, for example,
gaming suppliers are prohibited from
making political contributions to state or
local candidates. Violation of this law can
result in 10 years’ imprisonment and up
to a $100,000 fine. It is imperative that any
company beginning to supply casinos with
goods or services finds out what unusual or
peculiar laws there may be in a particular
jurisdiction as this is the only way to ensure
that an inadvertent criminal violation does
not occur.
Please see the “Licensing by Jurisdiction”
section on the following pages for a broad
look at the various licensing requirements
and ongoing reporting obligations for
suppliers/vendors working with casinos
located in a variety of international and
North American commercial and tribal
gaming jurisdictions. Detailed jurisdictional
analysis summarizing the licensing and
reporting
obligations
for
individual
jurisdictions is available on
Casino City’s
CasinoVendors.com website.
This article is provided by Regulatory
Management Counselors, P.C. For information
about the services they provide please see their
company listing on page 25.
