GPWA Times Magazine - Issue 29 - July 2014

ship in the company, seniormanagement and on-site sales representatives may be required tofilepersonal application forms andcompletea limitedbackgroundcheck. For gaming suppliers and non-gaming suppliers that conduct significant vol- umesof businesswithgamingproperties, theprocess ismore thoroughand includes the submission of a greater amount of in- formation and documents. The applicant company is typically required to provide muchmoredetailed information. In addi- tion, the companywill likely be required to submit copies of corporate governance documents (Articles of Incorporation, By-Laws, etc.), three to five years of tax returns, public filings and court filings. Parent and affiliated companiesmay also have to complete similar applications de- pending on the nature of the association with the applicant company. These individuals include seniormanage- ment, those who own a significant stake in the company (traditionallygreater than 5 percent of public companies or greater than 1 percent of a private company – thoughexemptions are typicallyavailable for institutional investors), and those in- dividuals who maintain a sales relation- shipwith theparticular gamingproperty. Individual filings include much of the same information anddocument submis- sions as required in the company forms, such as tax returns and criminal history, aswell as apersonal interview conducted by a member of the gaming regulatory body’s staff. Many jurisdictions use the Multijuris- dictional Personal History Disclosure Form (MJPHDF), a standard form for personal licensing investigations devel- oped by the International Association of GamingRegulators, alongwitha jurisdic- tion-specific supplement. Other regulato- rybodiesutilize forms that requiresimilar information for their investigationsof key persons. The MJPHDF is a 66-page form that requests detailed information on the applicant’s background and includes fi- nancial andother schedules toassist gam- ing regulators in their reviewof theappli- cant. As noted above, the purpose of the investigation is to ensure that applicants meet the jurisdiction’s licensing require- ments and do not pose a threat to the in- tegrityof thegaming industry. II.Developing andmaintaining a compliancemodel Given the time and resources that a sup- plier must dedicate to gaining the neces- sary regulatoryapprovals toparticipate in the gaming industry, developing a mul- tijurisdictional compliance model when entering the industrywill create efficien- cies and cost savings related to regulatory expenditures. In addition, given the in- tense and ongoing scrutiny of companies operating in the industry, amissed filing or regulatoryviolation in one jurisdiction could create a cascading effect of regula- tory sanctions in other gaming jurisdic- tionswhere the companydoes business. As technology companies that are best situated to assist in the development of newly authorized online gaming oppor- tunitieswill be entering the gamingmar- ket for the first time, knowing how and where to file the company’s initial sup- plier licenses is important. Some gaming regulators allow for license reciprocity for companies that already hold a supplier license in another gaming jurisdiction, al- lowing such a company to file only limit- ed informationor avoid the licensingpro- cess in that jurisdiction completely. Even if reciprocity is not offered,manygaming regulators give weight to the fact that a company is successfully licensed in other gaming jurisdictions, thus increasing the chances for apositive licensedecision. In addition,maintaining compliance after licensure is crucial to the continued suc- cess of a supplier in the industry.Gaming laws and regulations often require licens- ees to report certain eventswithindays of the occurrence, as well as requiring noti- fication of public filings or other routine submissions made to other regulatory bodies. Knowing what filings need to be submitted to each jurisdiction allows companies to develop internal models to ensure continued compliance with the various gaming laws and regulations un- derwhich it operates. The gaming industry will continue on its path toward Internet and interactive gaming opportunities as legislators and regulators transition existing compli- ance models to new forms of wagering. Understanding these complianceprocess- es and their developmentwill allow com- panies new to the industry to efficiently navigate theoftendaunting taskofobtain- ing supplier-relatedapprovals inmultiple gaming jurisdictions. Inaddition, technol- ogy companies can provide crucial input and commentary toproposed regulations and policy decisions as gaming regula- tors develop compliance practices for the evolving interactivegaming realm. The authorswould like to thankBlaine DeGracia for his contributions to this article. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . DaveWaddell is an attorney andpresident of Regulatory Management Counselors. He has 30 years of experience helping clients resolve business issues inheavily regulated industries. His areas of practice include gaming law, Title 31 compliance andbusiness, tax andmunicipal law. Mr. Waddell takes pride in forming partnershipswithhis clients to become sensitive to their needs, goals and future plans inorder tohelp them succeed. He canbe reached at www.rmclegal.com. DustinFord is anattorney withRegulatoryManagement Counselors. His areas of practice include supplier andprincipal licensing, gaming law, and regulatory compliance. Prior tohis current role, heworked for TheUnited States Playing Card Company in its licensing department. He canbe reached at www.rmclegal.com . 50 Regulations 101: An introduction to supplier licensing for technology companies

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