As the Chinese game industry's overseas strategy matures, the United States has become a key battleground for Slots games. According to Sensor Tower data, in Q1 2021, Slots games occupied a significant position in the US App Store's revenue rankings for gambling mobile games; among the top 50 best-selling gambling games on iOS, 38 were Slots games. Chinese manufacturers have also achieved impressive results. However, when releasing Slots games in the US, it is crucial to fully grasp compliance issues and avoid regulatory pitfalls.
1. ESRB Rating Requirements
The US game rating is led by the self-regulatory organization ESRB, with both Google and Apple referencing its standards for content review. Slots games are generally rated T (13+) or M/AO for adults:
No real money exchange: Involves only virtual currency operations;
No gambling attributes: No chips, casino interfaces, and the interface style must avoid a gambling atmosphere;
Age restrictions: Google Play requires a T rating, App Store requires 17+; some game user agreements further require 21+.
The first step to ensure content approval is to meet these rating standards.
2. Simulated Gambling vs. Online Gambling
Most states in the US prohibit online gambling, with only a few states allowing it. If a game has the following attributes, it may be defined as "gambling":
Allows real money betting;
Virtual currency and real money can be exchanged;
Offers withdrawal options or can be gifted to friends.
If defined as "online gambling," a license must be obtained, otherwise, it will face severe consequences such as being taken down or penalized.
3. Financial Compliance & Anti-Money Laundering (AML)
The online gambling industry in the US is considered a high-risk area and must adapt to the Title 31/BSA mechanism:
Institutions with annual transactions exceeding ten million dollars must submit Currency Transaction Reports (CTR) and Suspicious Activity Reports (SAR);
Must conduct customer identity verification (KYC), transaction monitoring, and internal audits;
Game internal transaction records exceeding the threshold must be reported promptly.
If Slots games involve actual currency transactions, they must also comply with this system.
4. Responsible Gambling & User Protection
US gambling regulation emphasizes "Responsible Gaming":
Most states require self-exclusion, age verification, and restriction mechanisms;
Operators must set up player protection reminders, counseling resources, and restrict youth access.
Meeting these mechanisms is not only a compliance necessity but also an important way to shape brand reputation.
5. Cultural and Content Compliance
Game content must consider legal and cultural differences between China and the US:
US culture: High tolerance for violence, political speech, and social freedom;
Chinese law: Strict censorship of politically sensitive content, explicit images, violent and bloody scenes, and pornographic content;
Dual-end review: Overseas versions should avoid using Chinese politically sensitive figures, symbols of violence and terror, or real crime themes.
Additionally, if a user chat feature is enabled, keyword filtering and violation penalty mechanisms should be set up.
6. Publishing Entity and Data Compliance
It is recommended to use a legal entity in the United States or a third-party country for publishing to avoid using a Chinese entity;
Must comply with local privacy laws, properly handle user data (such as GDPR, CCPA, etc.);
Prepare regulatory review documents and data, such as user distribution, transaction records, advertising records, etc.
Conclusion
To "conquer America" with Slots games, special attention must be paid to:
ESRB rating and content review;
Avoiding gambling attribute restrictions and licensing issues;
Strictly implementing Title 31/BSA anti-money laundering procedures;
Implementing Responsible Gaming policies;
Dual-end cultural and legal content review;
Choosing the right publishing entity and strengthening data compliance.
If these red lines are ignored, the game may not only be taken down but also face lawsuits, fines, and even criminal liability. In the future, we will continue to delve deeper into "user privacy compliance" and "buying volume advertising standards" to provide comprehensive guidance for overseas manufacturers.
