USA - Maryland: Lottery & Gaming

USA - Maryland: Lottery & Gaming

Brief reference

Maryland is a "lottery-treasury" jurisdiction with a six-case model and separate oversight architecture:

MLGCA (Maryland Lottery and Gaming Control Agency) - operational regulator (licensing, audit, inspections, technical standards, Responsible Gaming).
MLGCC (Commission) - commission decisions, sanctions, final approvals.
SWARC (Sports Wagering Application Review Commission) - selection/distribution of licenses for sports, including mobile.

State portfolio: VLT (slots), board games, sports betting (retail + mobile), lottery. iGaming (online casino/poker) is not allowed for 2025.

Legal Framework and Regulatory Architecture

State statutes and regulations MLGCA/MLGCC - licensing procedure, suitability, internal controls (MICS), reporting and disciplinary procedures.
Casino model: VLT as "slots" in state terms + board games (table games). VLTs are managed through a central system, income is distributed according to the state formula (accounting for shares of the Education Trust Fund and other trust funds).
Sports Wagering: Retail and mobile betting in place after referendum and legislative package; SWARC distributes licenses, MLGCA/MLGCC supervises operations.
Related modes: lottery and individual forms of charitable gaming (outside of commercial casinos).

Market and sites

6 casinos in the state (iconic examples: MGM National Harbor, Live! Casino & Hotel Maryland, Horseshoe Baltimore, Hollywood Perryville, Ocean Downs, Rocky Gap) operate on the VLT model and have admission to board games; retail sportsbooks and partnerships with mobile brands are possible at casinos.

Tolerance perimeter and licensing

Casinos (VLT + desktop)

Casino Licensee - operation of slots (VLT), board games, progressives, VIP zones; MICS surveillance and reporting.
Manufacturers/Distributors/Suppliers - gaming devices/software, CMS/ACS/OTS, surveillance, cashless/TITO, payment solutions - by tolerance levels.
Key/Occupational - key personnel, IT/finance/supervision/pit boss/jackpots, etc. - personal suitability.

Sport rates

License roles and types are structured by site size and type:

Class A (A-1/A-2) - large operators (casinos, large venues/arenas), including the right to mobile skins.
Class B - local retail outlets (small sites/CTE/bars according to the list).
Mobile (Online) - separate licenses for mobile operators (through market access), the limit of the total number is set by law; SWARC evaluates applications, MLGCA licenses and controls.
Management/Service Provider - trading/lines, risk systems, geo, KYC/AML, wallets/payments, affiliates - by tolerance levels.

Suitability (general principles): transparent ownership structure, sources of funds, management competence, cyber and operational readiness, internal controls and audit trail.

Taxes, distributions and reporting (benchmarks)

💡 Specific rates/formulas are fixed in the law and regulations and periodically adjusted; in financial modeling, reconcile current norms.

VLT (slots) - distribution model (state/operator/trust fund shares), not "net" tax; telemetry goes to the central system.
Board games are a separate bet/formula on table games revenue (different from VLT distributions).
Sports Wagering (AGR) - bet on net revenue after allowable deductions; promotional deductions are regulated and limited by rules (different approaches at market phases).
Fees - significant primary/annual for operators/mobile skins/suppliers and personal for Key/Occupational.
Reporting - monthly (and quarterly) forms: VLT drop/metering, table revenue, sports AGR (with promo registries), reconciliation with banks/processors, timely filing and share/tax transfers.

Responsible play and limitations

Age: 21 + for casinos and sports betting.
Self-exclusion: full-time program (including mobile sports), prohibition of registration/games/marketing for self-excluded; data exchange between operators is mandatory.
Marketing: prohibition of targeting of minors/self-excluded, prohibition of misleading wording ("risk-free," etc.), disclosure of promo terms and visible RG disclaimers.
AML/BSA: identity/age verification, sanction/PEP filters, monitoring of sources of funds, SAR/CTR procedures; personnel training.

Technical Standards and MICS

Gaming devices/software (VLT/tables): laboratory certification, checksums/signatures, version control, progressive accounting, log/video storage, TITO/cashless.
Sports platforms: geolocation within state borders, device fingerprinting, anti-spoofing, KYC/AML/sanctions, wallets/payments, log of failures and incidents; house rules are mandatory and public.
MICS: cash desk/accounting, drop/count, computers/promo, separation of duties, Dev→Prod control, inventory, DR/BCP plans, tamper-evidence logs.
Cybersecurity: network segmentation, MFA/IAM, vulnerability/patch management, SIEM/logging, regular pentest/tabletop exercises, supply-chain security (signed assemblies/SBOM).

Sports betting: retail and mobile

Market access: mobile brands are released through a partnership with a local market holder (casino/arena/other), with MLGCA exercising the final license/control and SWARC distributing the licenses.
House Rules: limits, cancellations, calculations, order of publication of changes; trading/risk activity log.
Integrity: providers of sports data/alerts, anomaly monitoring (pre-match/in-play), prohibition of insider participation; notification and escalation procedures.
Promo and AGR: accounting free bets/boosts/insurance by limits and windows; the correct AGR base is critical for taxes/distributions.
Registration/geo: device-hygiene, anti-VPN/emulators, geo-incident and failure reports.

iGaming

Online casinos/poker for 2025 are not allowed; the online vertical is limited to mobile sports betting.

Licensing Process: Reference Roadmap

1. 0-1 months - pre-filing: ownership/financing map, role selection (casino/sports/mobile/vendor), gap analysis of MLGCA/MLGCC/SWARC requirements, integration roadmap.
2. 1-3 months - suitability packages (company/beneficiaries/officers/key employees), MICS/RG/AML/InfoSec projects, drafts of house rules (sports), technical packages (geo/CUS/wallets/payments).
3. 3-6 months - laboratory tests/certification, integrations (VLT telemetry, payment rails, sports providers), pilots/field trials, reporting setup (VLT/tables/AGR).
4. 6 + mo - hearings/conditional approvals, commercial agreements (market access/skins), staged go-live (retail→mobile), post-audit and fine-tuning.

💡 Actual dates depend on the role and maturity of the technical stack.

Operational checklists

Casino (VLT + board games)

Full MICS circuit: cage, VLT/tables, progressives, computers/promo.
Video surveillance and storage; key/access control.
Daily drop/count, timely filing on VLT/tables and transfers of shares/taxes.
Software/content version control, immutable logs, Dev→Prod procedures.
RG training and 21 + control; honest marketing.

Sportsbook (retail/mobile)

House rules, publicity and change log.
Geolocation/anti-spoofing; fault/interlock log and incident reports.
Accounting promo (free bets/boosts), correct AGR base and taxes.
Integration alerts, contracts with data providers/leagues.
KYC/AML: risk scoring, SAR/CTR, wallet→bank monitoring.

Vendor/Platform

Certification of integrations (geo/CUS/wallets/payments), key/secret management.
Signed releases, tamper-evident logs, rollback/version recall.
SLA/observability (uptime/bugs/latency), vulnerabilities/patches, DR/BCP.

Frequent risks and red flags

Non-transparent beneficiaries/debt constructs and side-agreements affecting control.
Unauthorized changes to software versions/settings, incomplete logs, Dev→Prod violations.
Errors in VLT telemetry and progressive accounting; bad table games reports.
Incorrect accounting of AGR (sports), overheating of promo, delays in transfers.
Weak geo-hygiene (VPN/emulators), marketing to self-excluded/under 21.

Economics and P&L: accents

VLT - Distribution Model: Forecast cashflow based on state/operator/trust fund shares and telemetry/surveillance/cyber spending.
Tabletop - separate bet/formula: optimize mix of games and progressives, comp policy and pit schedule.
Sports (AGR base) - sensitive to limits/trading/promotional policies; hard read ROI free bets/boosts.
CapEx/OpEx - geo/KUS-SDK, SIEM/logging, certification, cameras/storage, integrated providers - mandatory budget items.

Trends 2025

Strengthening requirements for cashless/wallets and transaction traceability (AML triggers, chargebacks).
The growth of supply-chain security standards (signed assemblies, SBOM, reproducible builds).
Accurate formalization of promotional accounting in sports and RG-KPI (early behavioral signals, transparency of involvement).
Further optimization of the mobile channel and convergence roznitsa↔onlayn within a single monitoring and reporting stack.

What is important to remember

Maryland is a mature VLT + table model with mobile sports betting, with MLGCA/MLGCC overseeing operations and SWARC distributing sports licenses.
iGaming is not allowed; online vertical is a mobile sport.
Success requires: a transparent ownership structure, impeccable MICS/accounting, strong geo/KYC/AML/IS contours, discipline in promo/AGR and the correct cache model for VLT distributions and tables.