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The chief of staff of the Michigan Gaming Control Board (MGCB) believes requiring licensed suppliers to attest that they do not provide games to illegal operators internationally will enhance the agency’s overall efforts to crack down on illegal gambling activity.
“It goes hand-in-hand with the actions we are taking to try and deter anyone that’s participating in the illegal, unregulated market,” Kurt Steinkamp, MGCB’s chief of staff, told Vixio GamblingCompliance in an interview.
“We don’t want the suppliers that are doing business in Michigan supporting the illegal market,” Steinkamp said. “So, it provides transparency to that.”
The new attestation form approved in April requires suppliers of internet gaming content in Michigan to disclose, when applying for or renewing their license, whether they currently or have previously supplied game content to unlicensed operators active in either the United States or in international markets.
The control board’s “attestation” form requires answers to six specific questions, including whether an applicant or licensed supplier accepts or has previously accepted any “money or any other valuable thing for supplying internet gaming content, directly or indirectly, to jurisdictions in which internet gambling is prohibited or illegal”.
The six-page form also requires a licensee to disclose if they have ever accepted money from a jurisdiction sanctioned by the Office of Foreign Assets Control, a division of the U.S. Department of Treasury.
Suppliers also must disclose if they have ever received a cease-and-desist letter, fine or other penalty in any jurisdiction related to illegal gambling operations.
Steinkamp acknowledged that supplying game content to various international jurisdictions is a “more complex issue because it is not always black and white”.
“There are countries where it is black and white, and we want to know about that,” Steinkamp told Vixio. “If there are issues there, we will certainly look into them and address it.”
Right now, he said, the form was more about “information gathering”.
“We will need to work through these disclosures and come to our own decision on what we see as a suitability issue,” Steinkamp said.
The form is required to be submitted by suppliers annually when license fees are paid to the state.
Steinkamp noted that requiring information about where licensees and applicants do business is “not a new concept”.
“We’ve had something like that for a couple of years now,” he said. “But what we did is update it, renamed it, and then we sent it out to all content providers and mandated that it is completed.”
“We had rolled it out after the initial launch [of online gaming],” he added. “We were catching new content providers, but we wanted to retro it back as well. So, we made some enhancements to that and sent it out.”
Recent enforcement actions taken by the agency include cease-and-desist action letters issued to offshore sportsbook Bovada and unregulated sweepstakes casinos.
Steinkamp stressed that the agency had multiple segments to go after illegal operators and business activity, which was intended at trying to make progress preventing those gaming companies targeting Michigan residents or supplying content to licensed operators.
“Expect to see more,” Steinkamp said. “If you take action against one, people get the idea.”
