The Nevada Gaming Control Board (NGCB) has released an online gambling update guide specifically regulating the activities of Nevada-licensed businesses operating online gambling outside the state. As global internet gambling rapidly develops, the distribution methods of Nevada-related entities are increasing, and this guide is designed to address this trend. The guide applies to existing licensees, applicants, and affiliated companies and subsidiaries operating online gambling products in other jurisdictions. Its core goal is to limit the adverse consequences these companies may face in complying with Nevada's overseas gambling requirements and related state regulations. Previously, the industry lacked clear written guidance, leading to inconsistent judgments on the legal boundaries under different distribution models. The introduction of the new regulations is expected to resolve this chaotic situation. Relevant cross-regional gambling compliance cases and standards can be found on the PASA official website.
Scope of Application: Covers Various Business Models Emphasizing Full Due Diligence
The new regulations have a wide scope of application, covering all mainstream business models of online gambling, while specifying due diligence requirements:
Covered business types: Includes B2C operators directly facing players, B2B suppliers providing platforms or game content for third-party brands, and content aggregators distributing games across platforms, all subject to the same criteria;
Due diligence requirements: Businesses must conduct comprehensive due diligence before entering foreign markets, including internal compliance reviews, consulting legal advisors, referring to existing corporate policies, compliance committee reviews, and consulting the NGCB investigation department;
Special case explanation: The absence of enforcement actions in a jurisdiction does not mean that online gambling is allowed there; businesses must judge legality based on local laws and not take chances.
For B2B or aggregator business models, businesses can rely on the due diligence of partners under specific contractual conditions, but must still conduct their own due diligence for jurisdictions presumed prohibited.
Prohibited Jurisdictions: Clear Presumptive Standards and Key Control List
The new regulations clearly define the criteria for presumptive prohibited jurisdictions and have published the first batch of key control lists:
Criteria: Any jurisdiction that explicitly prohibits online gambling or takes enforcement actions against online gambling players or operating businesses (including legal litigation, DNS blocking, cease and desist orders, payment restrictions, etc.) is listed as a presumptive prohibited jurisdiction;
First batch list: Includes China, Australia, Cuba, India, Indonesia, Iran, Russia, Saudi Arabia, Syria, Thailand, etc., and the list is not fixed, it will be updated based on the latest information;
Exception application: If a business wants to enter a presumptive prohibited jurisdiction to conduct business, it must compile complete supportive due diligence materials and submit them to NGCB for approval before starting or continuing operations.
This regulation helps businesses clearly define compliance boundaries and avoid inadvertently "stepping on mines".
Compliance Requirements: Establish a Registration System and Strengthen Dynamic Monitoring and Reporting
To ensure the implementation of the new regulations, the NGCB has specified multiple compliance obligations for businesses, emphasizing dynamic management:
Establish a jurisdiction legality register: Record detailed results and supporting analysis of legality determinations for each jurisdiction, with NGCB having the right to access at any time;
Reporting obligations: Businesses operating online gambling products overseas must submit a list of all operating jurisdictions within 60 days after the new regulations are published, and then update compliant jurisdictions quarterly;
Dynamic monitoring and reassessment: Businesses must monitor the access jurisdictions of their products in real time, and immediately withdraw products if access from prohibited jurisdictions is detected (unless the prohibition presumption is overturned through sufficient due diligence); also, reassess the legality of all jurisdictions every two years to adapt to changes in legal and enforcement environments.
These requirements form a closed loop from registration, reporting to monitoring, making the compliance management of interstate online gambling operations more operable.
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This article is from "PASA-Global iGaming Leader" gambling news channel:https://t.me/pasa_news
Original in-depth gambling channel:https://t.me/gamblingdeep
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