GPWA Times Magazine - Issue 29 - July 2014

code or algorithms that affect the “shuf- fling” of online poker card decks, for ex- ample, will face much greater scrutiny than those merely providing artwork for online casinowebsites. Byunderstanding the specific factors that trigger licensure in various jurisdictions, technology firms can seek theappropriate level of licensure at theoutset of their business relationship withoperators, includingwaivers and ex- emptions thatmay be available to reduce or avoid the often cumbersome license investigation process. In addition, under- standing the process will allow compa- nies thatmay face specific licensing issues — for example, a company thatmayhave past links to illegal Internet gaming— to address these issues at theoutset of the li- censingprocess. b. The application and investigation process Depending on the types of goods and services being provided, the application and investigationprocessmay range from a simple registration form filed directly with a casino property to the comple- tion of numerous application forms and a lengthy investigation process. Notably, some gaming jurisdictions require that the company seeking licensure have a signed contract with a gaming property in their jurisdiction prior to submitting an application, so it is important to stay in communicationwith the gamingprop- erty throughout theapplicationprocess to ensure that all requirements aremet. For non-gaming suppliers, companies that generally supply goods or services that do not affect the outcome of a gam- bling game, simply registering basic identification information (e.g., name, address, type of business, etc.) with the gamingproperty or regulatory bodymay beall that isnecessary to receiveapproval to sell to a gaming establishment. More typical, however, are application require- ments that include the identification of the company’s owners and senior man- agement, a limited financial and criminal history, and identification of other gam- ing jurisdictions where the company is operatingorholds approvals. Inaddition, those individualswith significant owner- “ Keypersons of a gamingor significant non-gaming supplier are often required to seek individual approval or qualification in addition to the applicant company.” Regulations 101: An introduction to supplier licensing for technology companies

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