Casino Compliance Programs

On 15 May 2024, Adjunct Professor Jennifer Roberts of the William S. Boyd School of Law, University of Nevada, Las Vegas presented a seminar entitled ‘Casino Compliance Programs’. Dean Leah Chan Grinvald and students of the William S. Boyd School of Law, University of Nevada, Las Vegas were also in attendance. This seminar was moderated by Senior Lecturer Justin Jerzy Tan.

Professor Roberts began her seminar by stating that in Nevada, gambling was a privilege and not a right, as the gambling licence was something which was earned that could be revoked. She explained that the Nevada regulatory regime for entering the gambling industry was front-loaded; i.e., through  filing the relevant paperwork to apply for the licence, and subsequently updating the information as and when changes occurred. The required information is extensive and included building requirements, location requirements, gambling types, and suitability standards namely the criminal history, associations, habits, business probity, and financial affairs of the applicants and defined gaming employees. Post-licensing compliance requirements were necessary as it was impractical for regulators to maintain compliance through enforcement. While regulators had the expertise to define compliance goals, they did not necessarily have the resources or knowledge on the internal workings of gambling to ensure compliance with all regulations. As such, compliance programs were aimed at bridging this gap.

The broad purposes of compliance programs are to prevent possible regulatory violations, monitor activities impacting the casino’s ongoing qualifications as a licensee, report such activities to senior management and gambling regulators, and assist with the review of new gaming markets or gambling types. Professor Roberts then delved into various aspects of the compliance plan, including its introduction, definitions, the role of the compliance officer, the plan proper, the compliance committee, compliance meetings, reporting and due diligence, compliance records and regulatory reports. She also elaborated on the steps needed in preparing for audit by the regulator.

The seminar ended with an animated question and answer session.

Adjunct Professor Jennifer Roberts giving the presentation

Attendees listening attentively to the presentation