USA v Michigan: MGCB
USA v Michigan: MGCB
Brief reference
Michigan is one of the most "complete" markets in the United States: land casinos (3 commercial in Detroit + tribal in compacts), iGaming (online slots/table games/poker), sports betting (retail and online) and fantasy competitions. The regulator - the Michigan Gaming Control Board (MGCB) - licenses and oversees commercial casinos, internet games, sports betting and fantasy; interacts with tribes on compacts/online issues and coordinates standards for player integrity and protection.
Legal framework
Michigan Gaming Control & Revenue Act (MGCRA) - Detroit commercial casinos, licensing/fees/supervision.
Legal Internet Gaming Act - legal iGaming (online slots, board games, poker) through licensed operators and their platforms.
Legal Sports Betting Act - sports betting in retail and online with mandatory geolocation within the state.
Fantasy Contests Consumer Protection Act - rules and licensing of fantasy operators.
Tribal segment - according to IGRA and standard compacts; the tribes' online partnerships with the platforms come under MGCB licenses.
MGCB Roles and Structure
Licensing & Investigations - suitability of licensees/beneficiaries, suppliers, key employees.
Audit & Enterprise Risk - reporting GGR/AGR, MICS, control of promotions and deductions, revisions.
Gaming Lab/Technology - approval of games/platforms/RNG/wallets, version control, integration of CUS/geolocation/payments.
Enforcement & Compliance - inspections, disciplinary cases, violation cases.
Responsible Gaming & Outreach - self-exclusion, communication, operator training.
License Categories and Tolerances
Land-based casinos
Commercial Casinos (Detroit) - MGM Grand Detroit, MotorCity, Hollywood Casino at Greektown. Full set of tables/slots/poker (according to operator's decisions).
Tribal casinos (Class III) - within the framework of federal law and compacts with the state; Ground Surveillance - Tribal/NIGC, but online activities are conducted under the MGCB framework.
Online verticals
iGaming Operator (right to online slots/tables/poker) + Platform Provider (B2B platform).
Sports Betting Operator (retail + online) + Platform Provider / Management Services Provider.
Fantasy Contest Operator - separate licensing and reporting.
Suppliers and personnel
Supplier/Software Provider/Content Studio - certification of games, RNG, jackpots, integrations.
Vendor/Occupational - registration of counterparties and key personnel by risk/roles.
Suitability principles: transparent ownership and sources of funds, management competence, absence of disqualifying factors, stable financial contour.
Taxes, fees and reporting (benchmarks)
Land casinos (Detroit): combined state and city rates (the benchmark is collectively about ~ 19% GGR, depending on the structure of receipts and local shares).
iGaming (online casino): graduated scale of taxation AGR (the most common range ~ 20-28% depending on the level of AGR and the status of the licensee); for Detroit, an additional city share applies.
Online/retail sports betting: state base rate ≈8 -9% AGR; for Detroit - an additional city share (retail is higher than online).
Fantasy: Fixed rate on carrier revenue + annual fees.
Reporting: monthly/quarterly forms for AGR/GGR and taxes, registers of promotional loans, deductions for freebets/bonuses, mandatory reconciliations with payment gateways and banks.
Responsible play and limitations
Age: 21 + for casino/iGaming/sports betting; 18 + for fantasy.
Self-exclusion: state lists for internet games/sports, as well as the Disassociated Persons List for commercial casinos; prohibition of registration/play/marketing self-excluded.
Marketing: clear transparency requirements for bonuses, prohibition on targeting minors/self-excluded, mandatory RG messages and links to help.
AML/BSA: risk-oriented KYC, CTR/SAR, cash/wallet/payment monitoring, no "split" transactions, staff training.
Technical Standards and MICS
Games/RNG/platforms: lab approval, checksums/versions, update logging, key management.
Geolocation: accurate determination of the player's location within the state; anti-spoofing, device fingerprinting, failure reports.
Payments/wallets: transaction accounting, limits, returns/chargeback control, reconciliation with processing and reporting.
MICS: cash desk/accounting, promo/computers, jackpots/progressives, sportsbook processes, separation of duties, immutable logs, Dev→Prod access control, periodic audits and inventories.
Cybersecurity: Network segmentation, MFA/IAM, vulnerabilities/patches, penetration tests, DR/BCP plans.
Sports betting (retail and online)
Retail sportsbook based on casino (commercial or tribal) and online skin under operator license.
Requirements: house rules (lines, limits, calculations/cancellations), logging of quotation changes, integration control (collaboration with data providers/anomaly alerts), correct accounting of promotional deductions, reporting on AGR and taxes.
iGaming (online casino and poker)
Separate tolerances for slots, board games and poker; each product - its own reports/taxes/version control.
Market access/skins model: The B2C brand operates through a Detroit commercial casino or tribal partner.
RG tools: deposit/time/loss limits, timeouts, self-exclusion, clear visibility of risks; advanced problem game analytics.
AML/financial contour: sources of funds, KYC stratification, monitoring wallet→bankovskiye rails, risk behavior indicators.
Tribal segment
Tribes operate land casinos according to compacts; online products are launched in partnership with platforms under MGCB licenses.
Taxes/payments for the breeding segment are determined by the terms of the compacts and differ from Detroit's commercial model.
Licensing Processes - Reference Plan
1. 0-1 months - gap analysis by verticals (land-based/iGaming/sports/fantasy), ownership structure, preliminary consultations with MGCB.
2. 1-3 months - applications for suitability (beneficiaries/officers/key counterparties), RG/AML/MICS policies, technical packages to the laboratory.
3. 3-6 months - testing of platforms/games, integration of CUS/geo/payments, adjustment of MICS, personnel training.
4. 6 + mo - hearings/conditional approvals, launch (retail→online), post-audit and fine-tuning reporting.
Operational checklists
Commercial Casino (Detroit):- Full MICS coverage (cage, slots/tables, promo, jackpots).
- Cameras/storage of records according to standards; key/key ring/access control.
- Daily drop/count and timely reporting of GGR/taxes.
- RG training of personnel, verification of age, prohibition of marketing to prohibited audiences.
- Cyber and physical security plan, incident management.
- Split Slot/Board/Poker approvals; version registry and immutable logs.
- Geolocation/anti-spoofing, device fingerprinting, fault/lock log.
- KYC/AML: SAR/CTR triggers, risk scoring, bonus abuse/chargeback monitoring.
- Tax/deduction regime by verticals; reconciliation with payment reports.
- Self-limiting tools and their mandatory visibility in UX.
- Actual house rules, limits, cancellation order.
- Integrity alerts and collaboration with league data providers.
- Accounting promo (free bets/odds boosts) and correct tax base AGR.
- Geo-control, registration and device-control in mobile.
- RNG/game/wallet certification, cryptography/keys, secure builds.
- Release Management and Version Recall Procedures; field updates according to the regulations.
- Provable log traceability (tamper-evident), SLA monitoring.
Frequent risks and red flags
Non-transparent beneficiaries/debt instruments; hidden side-agreements.
Weak geo-contour and anti-spoofing online; "treating" VPN/emulators.
MICS mismatch: unauthorized version changes, incomplete logs.
Errors in calculating AGR and promo deductions, delays in reporting/payments.
Insufficient RG tools and marketing to self-excluded/younger than 21.
The economy and P&L: What to watch
iGaming with a progressive AGR tax scale requires fine-tuning promo plans and a content portfolio (especially the share of slots vs board/poker).
Sports with a relatively low state base rate are beneficial with strict limit/anticore discipline and transparent accounting for promotional deductions.
For Detroit, add city share to the model; for the breeding segment - the conditions of a specific compact.
Trends 2025
Strengthening cashless/wallet requirements and transaction traceability; mandatory anomaly reporting.
The growth of standardization of cyber resistance: supply-chain security, Dev→Prod control, regular pentest and tabletop drills.
Additional focus on RG analytics (early signals of problem play, transparency of the mechanic of involvement).
Further evolution of tribal online partnerships and optimization of revenue sharing.
What is important to remember
Michigan is a mature "omnichannel" market: casino + iGaming + sports + fantasy with a clear MGCB frame.
Success is ensured by: a transparent ownership structure, impeccable MICS/technical processes, strict geolocation/CUS and a neat tax/promo model along the verticals.
For Detroit, consider the city share; for tribes - the specifics of the compact.