HomePublicationsNewsletter ArchiveNewslettersVolume 18Issue 18Summer Compliance Series: Introduction to Casino Compliance

In addition to its traditional coverage of developments in the state’s gaming industry, The Michigan Gaming Newsletter is proud to announce its first annual Summer Compliance Series. From now until the end of August, The Michigan Gaming Newsletter will be publishing a regular column in order to provide readers with a basic understanding of Michigan gaming regulatory structures and considerations. The following is a general discussion of the state’s compliance requirements and should not be considered legal advice.

In addition to various business license requirements, those entities and individuals operating in the Michigan casino gaming industry must carefully monitor and comply with the provisions of the Michigan Gaming Control and Revenue Act (“Act”), the Michigan Gaming Control Board (“MGCB”) Administrative Rules (“Rules”), as well as gaming control board staff Resolutions, policies, and procedures. In addition, those parties that have business relationships with the state’s tribal casinos must go through similar licensing and suitability review processes with the Native American tribe that operates the gaming facility. These requirements are designed to ensure that unsuitable parties are excluded from operating and that the public is protected from unscrupulous business practices.

Commercial Casino Compliance

In Michigan, those businesses that participate in gaming activities must first receive approval to do so by the MGCB. As a general matter, this includes, but is not limited to, individuals or entities that:

1. Operate casinos or gaming facilities,

2. Manufacture, distribute, or sell goods or services to a gaming facility,

3. Are employed by a casino or gaming facility,

4. Are employed by a manufacturer, distributor, or provider of goods or services to a gaming facility,

5. Invest in a casino,

6. Invest in a manufacturer, distributor, or provider of goods or services to a gaming facility,

7. Are required to access the casino gaming floor of a gaming facility to perform work duties (such as routine maintenance),

8. Are otherwise identified by the MGCB as requiring a license, certification, or suitability determination.

Those individuals or entities that require licensure, certification, or a suitability determination must first notify the MGCB of any intent to do business with one of the three Detroit casinos and file the appropriate application forms with the agency. The application processes for various industry members will be discussed in future Michigan Gaming Newsletterarticles, however, the MGCB website provides a general guide to assist those who are entering the industry in identifying the appropriate licensing path, located at the following link: MGCB Licensure Determination Flowchart.

Initial licensure or suitability determination, however, is only the beginning of an individual or entity’s relationship with the MGCB. Depending on the level of participation in the industry, financial and operational reporting, audits, renewal filings, and periodic updates may be required to be filed on a regular basis in order to remain compliant with the license terms and conditions established in the Act, Rules, and MGCB policy. In addition, those individuals or entities that are under the jurisdiction of the MGCB must provide the agency with information on any material event that would change the information submitted in an initial application (such as the filing of a criminal lawsuit against the licensee). As such, a comprehensive compliance plan should be established once an individual or entity makes the decision to enter into the Michigan gaming market.

Native American Casinos

In addition to those operating in the state’s commercial gaming industry, those individuals or entities operating in the Native American gaming market in Michigan must comply with similar licensing, certification and suitability requirements. Here, however, each Native American tribe regulates its gaming properties independently with the majority having an independent gaming commission that operates similar to the MGCB.

Though each tribe operates independently, the licensing, certification, and suitability requirements are similar to those of the MGCB, including requirements for licensure of operators, suppliers, employees, and others with a relationship with the casino facility. However, each tribe has established its own set of rules and regulations regarding gaming activities, so it is important to research the specific Native American tribe that operates a gaming facility prior to entering into a business relationship with a Native American gaming facility. As with those seeking to do business with a commercial casino, a detailed compliance plan should also be established for those doing business with the state’s Native American casino properties.

The above information is designed to provide a general overview of the Michigan gaming industry from a compliance perspective. Throughout the remainder of this summer, The Michigan Gaming Newsletterwill be publishing additional compliance-themed articles that provide further information on compliance related issues and unique regulatory considerations. You can continue to monitor these articles by subscribing to The Michigan Gaming Newsletter, or by visiting the online publication at www.michigangaming.com.


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