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NEW ANTI-MONEY LAUNDERING RECOMMENDATIONS FOR BRITISH COLUMBIA CASINOS by Michael D. Lipton, Q.C., Kevin J. Weber, and Chantal A. Cipriano On December 5, 2017, following an internal government review of the casino sector after allegations of transnational money laundering and illicit cash transactions in gaming facilities in the Lower Mainland, British Columbia (“B.C.”), the provincial government of B.C. recommended two new anti-money laundering regulations applicable to B.C. casinos. The first recommendation requires any gambler who exchanges $10,000 or more in cash, cash equivalents, or bearer bonds to provide identification and, at a minimum, declare the source of the funds, the account the cash came from, and the financial institution in which the money was held. The casino will be required to record this information in a “Source of Funds Declaration.” In addition, after two consecutive transactions, the British Columbia Lottery Corporation will be required to review the transaction and apply a greater level of scrutiny in analyzing whether the funds are from a suspicious source. Although the exact process of verifying the cash has yet to be determined, casinos will be required to deny a third transaction until this review is completed. The second recommendation requires provincial regulators from the Gaming Policy Enforcement Branch (“GPEB”) to be on site at high-volume and high-gaming limit casinos at all times. Previously, these provincial regulators were only required to be on site...

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4 Dickinson Wright Attorneys Co-Author Chapter for International Comparative Legal Guide to: Gambling 2018

In association with DLA Piper and the International Masters of Gaming Law, Kate Lowenhar-Fisher (Member, Las Vegas), Greg Gemignani (Member, Las Vegas), Jennifer Gaynor (Member, Las Vegas), and Jeff Silver (Of Counsel, Las Vegas) have co-authored the exclusive Nevada chapter for the International Comparative Legal Guide to: Gambling 2018. This Guide may be accessed here.   About the Authors: Kate Lowenhar-Fisher is a leading Nevada gaming attorney who counsels many of the world’s premier gaming companies on regulatory issues in connection with mergers and acquisitions, corporate restructuring, reorganizations and financings. She has extensive experience advising clients on issues related to Internet gaming, social gaming, fantasy sports, parimutuel products, liquor licensing, sweepstakes, contests, and promotions. She regularly represents individuals and businesses before regulatory agencies, including the Nevada State Gaming Control Board, the Nevada Gaming Commission, the Clark County Liquor and Gaming Licensing Board and the Las Vegas City Council. Kate may be contacted at 702-550-4459. Greg Gemignani’s practice focuses primarily on intellectual property law, gaming law, technology law, internet law, online gaming law, and online promotions law. He has represented many clients ranging from the largest casino companies to start-up internet ventures. Greg is a member of the International Association of Gaming Advisors and the International Masters of Gaming Law. In addition, he is an Adjunct Professor at the University of Nevada, Las Vegas, William S. Boyd School of Law, teaching...

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by: Jeff Silver, Jennifer Gaynor, Greg Gemignani, and Kate Lowenhar-Fisher How far do Nevada’s casinos need to go to police marijuana use by their customers? Can a casino resort allow a marijuana industry conference to utilize its convention facilities? What practices do casinos need to follow regarding customers that may be gambling with funds acquired through participation in the state-legal marijuana industry? Nevada’s gaming licensees and regulators have been grappling with these questions, and more, since the state legalized both medical and recreational marijuana sales and use. As discussed in our article “Marijuana and the Gaming Industry in Nevada: Just Say No,” the Nevada Gaming Commission (“Commission”) kicked off the public discussion on these topics this past August. But this discussion really left more questions than answers. Therefore, Nevada Governor Brian Sandoval signed an Executive Order reconvening the state’s Gaming Policy Committee (“Committee”) to gather information, engage in discussion, and provide recommendations on policies related to the potential interactions between Nevada’s gaming industry and the marijuana industry. The Gaming Policy Committee is a special advisory board designated to weigh in on touchy or novel regulatory matters, and the Committee members include elected legislative officials, a tribal gaming representative, an educator, the Chairmen of both the Nevada Gaming Control Board and Nevada Gaming Commission, and “industry representatives” (Jim Murren, CEO and Chairman of MGM, Keith Smith, President of Boyd Corporation,...

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Tribal Courts Have Say On Project Suit: Arizona Panel

An Arizona appeals court on Tuesday upheld the dismissal of a suit alleging that several Hualapai Tribe officials committed fraud in terminating a company’s contract to run a tribal tourist attraction, saying tribal courts rather than state courts must tackle a case that deals entirely with on-reservation activity. WD at the Canyon LLC had asked the Arizona Court of Appeals to overturn a lower court’s ruling that state courts didn’t have jurisdiction over the company’s suit alleging the tribal officials wrongly canceled its contract to manage the Hualapai Ranch. The company contended that the acts of fraud and misrepresentation it alleged weren’t only located on the reservation and were actually subject to state court jurisdiction. The appeals court rejected that argument Tuesday, saying that the company’s claims were directed against tribal officials acting in their officially capacity and that the suit hinged on two activities — the euthanization of a horse and a letter describing the company’s alleged breach of its management contract for the ranch — that “occurred solely on the Hualapai reservation.” “Because extending state jurisdiction here would infringe on the tribe’s sovereignty and ability to self-govern, the superior court did not err by granting the motion to dismiss,” Judge Randall M. Howe wrote on behalf of the court’s panel. WD at the Canyon reached an agreement with a Hualapai Tribe-owned entity called the Grand Canyon Resort...

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by: Jennifer Gaynor, Greg Gemignani, Kate Lowenhar-Fisher, and Jeff Silver The biggest legal showdown in a long time on a question of gaming policy is about to come before the United States Supreme Court. At stake is the ability of the states to tap into a legalized sports betting market that could grow to between $2 billion to $5.8 billion within the next five years, according to a recent Gambling Compliance study. On one side: the State of New Jersey, which seeks to overturn the federal law that bans legalized sports wagering in all but a few grandfathered states, the Professional and Amateur Sports Protection Act or “PASPA” (28 U.S.C. 3701). New Jersey claims that PASPA violates states’ rights by forcing the states to carry out the federal prohibition against sports wagering and therefore “commandeers” (usurps) the regulatory power of the states. On the other side: the National College Athletic Association (“NCAA”), National Football League (“NFL”), National Basketball Association (“NBA”), National Hockey League (“NHL”), and Major League Baseball (the “MLB”) (together, “the Leagues”). Their claim is that PASPA is not unconstitutional commandeering because it does not require the states to do anything proactively. With arguments scheduled for December 4, 2017, this should be a vigorous war of words! Here are the highlights of the major arguments: New Jersey New Jersey’s argument, in short, is that PASPA impermissibly commandeers the...

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The Gaming and Hospitality Practice blog is published by Dickinson Wright PLLC to inform the public of important developments within the firm and practice areas. The content is informational only and does not constitute legal or professional advice. We encourage you to consult a Dickinson Wright attorney if you have specific questions or concerns relating to any of the topics covered in this blog.