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Licensing: Who Regulates (Nevada Gaming Commission, New Jersey Division of Gaming)
The United States is federalism in action: each state determines the format and depth of gambling regulation. The most famous and "reference" models for the industry are Nevada and New Jersey. In Nevada, the Nevada Gaming Control Board (NGCB) and the Nevada Gaming Commission (NGC) are considered the "gold standard" for offline regulation and licensing discipline, and in New Jersey, the Division of Gaming Enforcement (DGE) has become the technological benchmark for iGaming and payment compliance. Below is how the competencies, procedures and requirements are arranged in each of the areas.
1) Who exactly regulates
Nevada
Nevada Gaming Control Board (NGCB) - the investigative and supervisory body of the "first line": investigations, verification of applicants, monitoring compliance with the rules, audit, recommendations for issuance/refusal.
The Nevada Gaming Commission (NGC) is a collegial body that makes final administrative decisions (approval, refusal, license conditions) after the recommendations of the NGCB.
The NGCB + NGC bundle creates a two-tier system: thorough checks → a public meeting → a legally significant decision.
New Jersey
New Jersey Division of Gaming Enforcement (DGE) - the main "operational" regulator: investigations, licensing, audit, technical supervision, compliance with iGaming/sports betting, control of advertising and responsible practices.
Casino Control Commission (CCC) is an independent commission that retains a number of adjudication powers (on key licensing issues and appeals). In the 2010s, the powers were optimized in favor of DGE, but the "two-circuit" in the state remains.
New Jersey is known for its strong expertise in the online segment: geolocation, payment flows, reporting, external technical control.
2) Types of licenses and market participants
Baseline categories (generalized to both states)
Casino/interactive games/sports book operators.
Game and technology providers (iGaming platforms, RAM/wallets, slots/RNG, content aggregators, geofencing, KYC/AML, risk monitoring).
Service providers (payment gateways, KYC bureaus, hosting/data centers, marketing outsourcers).
Key employees/personnel: managers, compliance officers, employees affecting the control of means/data/results.
Owners and beneficiaries: disclosure of ownership structure, sources of capital and suitability.
3) Licensing procedure (with a high degree of unification)
1. Pre-license consultation: discussion of the structure, required license classes, offline/online plans.
2. Application: detailed forms by company and beneficiaries; business plan, financial models, sources of funds, IT architecture, responsible play policy.
3. Background check: criminal, financial, tax, corporate audits, interviews, collection of prints (where applicable).
4. Technical package: description of RNG/slots, platforms, reporting, API, logging, cybersecurity; independent laboratories test games and systems (RNG, return, accounting, reports).
5. Consideration and hearings: in Nevada - NGCB recommendation → NGC meeting; in New Jersey - DGE will investigate and issue for resolution/approval as appropriate (with CCC involvement on individual issues).
6. License terms: limits, requirements for reserves, reporting, anti-money laundering procedures, advertising practices.
7. Continuous supervision: regular audits, incident-reporting, updating key employees/vendors, technical regression tests, marketing and bonus reviews.
4) Key requirements and standards
Finance and the origin of capital
Full transparency of sources of funds; absence of "doubtful" counterparties; capital adequacy and liquidity to cover jackpots/reserves.
Compliance and responsible practices
KYC/AML by federal requirements and staff rules, transactional monitoring, deposit/rate limits, self-exclusion.
Responsible play: verifiable self-control mechanisms, hotlines, staff training.
Technical certification
RNG, returns, honesty: independent test labs and regulatory sandboxes; version control, build procedures, hash sums.
Reporting and logs: immutable logs, storage in accordance with the rules, operational unloading for the regulator.
Cybersecurity: vulnerability management, SOC monitoring, penetration tests, key/access management, encryption at rest and during transmission.
Advertising and Marketing
Ban on misleading offers; age/geographical restrictions; disclosure of bonus terms; affiliate partner rules and restriction of aggressive advertising.
5) Online verticals: iGaming and sports betting
Nevada
World leader in offline environment; online focus historically on interactive poker and mobile sports betting.
Tight control of geolocation and face-to-face confirmation, when required; high level of suitability for associated personnel and suppliers.
New Jersey
One of the most developed iGaming markets in the US: online slots/board games, poker, and retail and mobile sports betting.
Deep "map" of permissions for platforms, content and service providers; clear regulation of data flows and money, detailed daily reporting by DGE.
6) Differences in approaches (thesis)
Regulator architecture
Nevada: NGCB duo (investigating/recommending) + NGC (deciding).
New Jersey: DGE (Investigates/Regulates) + CCC (Adjudication on a number of issues).
Historical focus
Nevada: Offline benchmark and owner/top management suitability.
New Jersey: a benchmark for online, integration, reporting and payment compliance.
Supplier model
Both jurisdictions require licensing/registration of vendors, but in New Jersey there is usually more detail on integrations and daily reports for iGaming.
7) Practical steps for applicants
1. Assemble ownership structure before final beneficiary; exclude "gray" links.
2. Financial package: audited reports, sources of capital, adequacy of reserves, tax and fee compliance plan.
3. Policies and Procedures: KYC/AML, Responsible Play, Secure Development (SDLC), Vendor Management, Incident Response.
4. Technical dossier: platform architecture, change control, API diagrams, logging, reporting, independent test results.
5. HR and key employees: license key roles in a timely manner; conduct internal verification interviews.
6. Marketing and affiliates: uniform advertising code, white-/black-lists, provable transparency of bonuses and tracking.
8) Frequent errors of applicants
Underestimating the depth of background check on beneficiaries and boards.
Unwritten or "verbal" agreements with subcontractors involved in critical processes.
Fragmentary technical reporting (no continuous logs/versions), weak cybersecurity.
Aggressive advertising without scrutiny for jurisdictional limitations.
Untimely notification of the regulator about material changes (capital, structure, key personnel, incidents).
9) Taxes and fees (general guidelines)
License fees and annual fees depend on license class and revenue.
In iGaming/sports betting, there are additional GGR tax rates and deductions for responsible game funds.
Correct daily/monthly reporting - the basis for calculating taxes and inspections.
10) Totals
Nevada and New Jersey have built different but complementary systems. Nevada is a rigorous offline regulation school with a focus on personal fitness and NGC public decisions following an in-depth NGCB investigation. New Jersey is the technological leader in iGaming/sports betting, where DGE sets the standards for reporting, integration and payment control, and CCC provides the necessary level of adjudication. For applicants, this means: transparent capital, impeccable compliance, mature technical architecture and discipline of communications with the regulator. Following these principles accelerates the path to a license and reduces the risk of regulatory claims in the future.