USA - Nevada: GCB/NGC

USA - Nevada: GCB/NGC

Brief reference

• Nevada Gaming Control Board (GCB) - operational oversight, licensing, investigation, technology, audit and collection.
• Nevada Gaming Commission (NGC) - rulemaking and quasi-judicial decisions (approval/rejection of licenses, sanctions, fines, conditions).

Legal Framework: Nevada Revised Statutes (NRS) Chapter 463 and related chapters plus Nevada Gaming Regulations (including key Reg. 5, 5A, 6, 14, 22, etc.).

Regulatory architecture

• Enforcement Division - investigations, raids, criminal law interaction.
• Investigations & Licensing - due diligence, sources of funds, ownership structure.
• Tax & License - fees/interest payments, reporting, GGR monitoring.
• Technology Division - testing/certification of devices and "associated equipment," network/server solutions, cashless, progressives, linked systems.
• Audit - audits of revenue, procedures and MICS (Minimum Internal Control Standards).

NGC approves the rules and makes decisions on GCB applications: issuance/refusal/terms of licenses, disciplinary measures, interpretation of regulations.

Legal Framework (NRS/Regulations)

NRS 463 and accompanying chapters are Nevada's general "gambling constitution."

Regulation 5 - general duties, internal accounting, control, cashless/accounting of funds, game operations and personnel behavior.
Regulation 5A - interactive games (historically - online poker; interstate liquidity is allowed under separate agreements).
Regulation 6 - financial reporting, revenue accounting, reporting forms, documentation storage procedures.
Regulation 14 - technical standards: gaming devices, RNG, progressives, server-based/linked systems, version control, cybersecurity, etc.
Regulation 22 - race & sports: betting rules, limits, line formats, reporting, deductions/limits on parlays, etc.

Licensing - Types and Logic

• 1) Nonrestricted (full casinos and large properties)

Usually> 15 slot machines and/or the presence of board games, poker rooms, sweepstakes, sportsbook.
A comprehensive check of owners (beneficial owners), sources of funds, experience, reputation is required.

2) Restricted

Up to 15 slots, no board games. Often - bars/restaurants/shops.
Simplified, but still strict verification of owners/operator.

3) Specialized licenses

Manufacturer/Distributor of gaming devices.
Operator of a Slot Route.
Operator of an Inter-Casino Linked System.
Interactive Gaming Operator / Service Provider (по Reg. 5A; focus - online poker).
Race & Sports Book / Sports Pool (по Reg. 22), including mobile applications linked to state requirements.
Service Provider/Technology Provider (providers of key services/technologies affecting game integrity/revenue accounting/access to game data).

Suitability principles: complete transparency of the ownership structure, cleanliness of capital, experience, business reputation, absence of conflicts and hidden beneficiaries.

Taxes, fees and payment discipline

The percentage fee on gambling revenue (GGR) of the state is a graduated scale, the upper margin is traditionally at the level of ~ 6.75% GGR.
Fixed/periodic fees: for tables, slots, licenses, routes, etc. (quarterly/annual).
Municipal fees (county/city) are possible, depending on local jurisdiction.
Sports bets are also subject to federal excise on the handle.
There is no corporate income tax in Nevada, but the Commerce Tax is on gross receipts above a certain threshold (at low industry-specific rates).

Reporting and checkout: strict delivery of reporting forms, timely payment, daily drop/count, reconciliations, jackpot/progressive inventory, daily sportsbook reports.

Compliance and responsible play

Age threshold: 21 +.
Responsible play: mandatory RG policies, staff training, limiting marketing to vulnerable audiences, hotlines at venues, self-restraint tools.
Self-exclusion: Nevada historically has no mandatory single state program with a centralized roster; large operators implement their own (or multi-property) self-exclusion and limit programs.
AML/BSA: KYC risk procedures, CTR (threshold cash reports), SAR (suspicious transactions), chip control/labeling, cage/markers monitoring, "structuring" prohibition, training, and independent tests.

Technical requirements (Reg. 14 and related standards)

Gaming devices and RNG: certification, checksum/version stored and tracked by Technology Division; changes - through the approval process.
Associated Equipment: accounting systems, TITO, progressives, cashless, surveillance systems, servers, hosting - all subject to approval.
Server-based/Linked: download control, air-gap/network perimeter, keys, cryptography; immutable logs, backup, DR.
Cashless & e-wallets: allowed if KYC/AML, limits, transaction auditing, and cage/verification system integrations are met.
Cybersecurity: network segmentation, IDS/IPS, MFA, vulnerability management, security logging, penetration tests (on demand/license terms).
MICS (minimum internal controls): relate to cash registers, slots, tables, jackpots, sportsbook, IT shifts, access to sources/compilations, dev→prod, duty segregation.

Sports and sweepstakes (Reg. 22)

Sports Book/Race Book license with mandatory accounting procedures and limits.
Mobile rates: allowed subject to state registration/verification/geolocation requirements; limits and control of transactions - on the side of the licensed operator.
Lines/limits/pools: operating rules, line change announcements, cancellation and settlement procedure, counterparty risk and trading book management, logging.

Interactive games (Reg. 5A)

Focus - online poker (peer-to-peer). Non-poker casino games have historically not been allowed to be played remotely in the community, with the exception of mobile on-property within the resort under local schemes.
Interstate player pool agreements for poker are allowed subject to NRS/Reg. 5A and the compact conditions.
Licensing includes the operator and service provider (platform/networks/wallets), with separate technical certification.

Inspections, audits, discipline

GCB conducts scheduled/sudden inspections, thematic audits (drop/count, sportsbook, progressives, IT controls).
NGC reviews GCB complaints: fines, conditions, suspensions, license revocation, stipulated settlement (settlement agreements with conditions).
Typical violations include reporting/payment delays, MICS failures, AML deficiencies, unauthorized software/version changes, Reg violations. 22/5/14, inappropriate marketing to minors.

Practice for operators and B2B

Casino/sportbook operators

Construct the NRS/Reg correspondence matrix. per zone (slots/tables/poker/sports/cashless/IT).
Separate Release-management of game firmware/content, maintaining "golden image" and checksums.
Geo-compliance for mobile sportsbook: SDK geolocation, device verification, anti-spoofing.
RG + AML: training, escalation scenarios, high-risk triggers, logging.

Suppliers (Manufacturers/Service/Tech Providers)

Early gap analysis of Reg. 14 and Technology Division requirements.
Evidence of RNG reliability, cryptography, channel protection, immutability logs.
Field trial and GCB run-in procedures.

Taxes and Economics: Notes for the P&L Model

Put the state interest rate in the model (~ 6.75% GGR upper margin), fixed license/quarterly payments, federal excise for sports.
Consider municipal fees and entertainment/permit fees where applicable.
Nevada without CIT, but Commerce Tax can "bite" with large gross revenue (minimum rate, but for all turnover above the threshold).
CapEx/OpEx: surveillance systems, cage, slot routes, sportsbook platform, Reg cybersecurity. 14, audit/certification, RG/AML programs.

Product Output Timeline (Reference Plan)

1. 0-1 months: pre-filing, structuring of ownership, engagement with local consultants.
2. 1-3 months: submission of a suitability questionnaire, disclosure of sources of funds/officials, RG/AML policy, MICS drafts.
3. 3-6 months: process tests (Reg. 14), equipment/software pilots, field trial as agreed.
4. 6 + mo: Public hearing/NGC decision, launch with phased expansion.

Frequent risks and red flags

Non-transparent beneficiaries/debt instruments "hostile jurisdictions" in the chain of ownership.
Aggressive marketing practices affecting minors/vulnerable.

Unaccounted changes in software versions of gaming devices, bypassing the procedures of "two control persons."

Weak logging/SIEM, lack of regular pentest/patch management.
Insufficient geolocation/anti-spoofing in mobile sports books.
Gaps in CTR/SAR, fragmentation of cash transactions, weak KYC stratification.

Trends 2025

Expanding cashless and "tax-free" ecosystem with more rigorous transaction auditing.
Growing cyber requirements: from DDoS stability to software supply chain monitoring.
Development of interstate poker liquidity within existing compacts (if any).
ESG/Responsible Gaming as a KPI of the board of directors: metrics for early detection of problem games, transparency of retention mechanics.
Data/analytics for sportsbook: strengthening integrity control (match fixing, insider activity, abnormal patterns).

Check sheets

Casino Operator (Nonrestricted)

• Full set of MICS by slot/table/jackpot/cage.
• RG/AML policies/sanctions, training + tests.
• Technical version register, checksums, change process.
• SIEM/SoC processes, IAM/MFA, network segmentation.
• Reporting by Reg. 6, payment schedule, drop/count reconciliation.
• Cameras/supervision by standards, record storage.

Sportsbook

• Line/Limit/Cancellation Policy (Reg. 22).
• Geolocation, registration, in-app KYC, anti-spoofing.
• Price/trading/market change logs.
• Federal excise accounted for in P & L.

Interactive (poker)

• Operator + Service Provider licenses.
• Reg compliance. 5A: servers/wallets/audits.
• Interstate liquidity - only within the framework of approved agreements.

Technology Provider

• Gap analysis Reg. 14 and a cybersecurity checklist.
• RNG/crypto protection/log integrity document.
• Field update and version recall procedures.

What is important to remember

Nevada is a mature, demanding and predictable jurisdiction: rigid procedural discipline and unconditional structure transparency are key.
Technical line (Reg. 14) and MICS are not "paper," but actually verifiable standards.
The online vector is focused on poker, sports betting is regulated separately, the mobile segment is strictly geo-closed and procedurally loaded.
The tax burden on GGR is competitive, but compliance/cyber infrastructure and operational standards require appropriate investment.