USA - West Virginia: Lottery
USA - West Virginia: Lottery
Brief reference
West Virginia is a "lottery" jurisdiction with an expanded portfolio: land casinos (racetracks and resort facility), online casinos and poker (iGaming), sports betting (retail and online), and an extensive Limited Video Lottery (LVL) network in bars/local locations. Supervision and licensing is carried out by West Virginia Lottery (Lottery Commission).
Legal framework
Lottery Act.
Sports Wagering Act - legal sports betting in retail and online through licensed casino partners (market access/skins).
Interactive Wagering Act (iGaming) - online slots, board games and poker through platforms under the auspices of ground licensees.
Limited Video Lottery (LVL) - video lottery outside the casino (terminals in approved locations: bars, clubs, etc.) with separate licensing of the operator, location and devices.
Regulator roles and structure
Licensing & Investigations - suitability of owners/officers/key employees, suppliers/service providers.
Gaming Compliance/Audit - MICS, GGR/AGR reporting, promo/jackpot revisions, field checks.
Gaming Labs/Technology - approval of games, RNG, progressives, iGaming platforms/sports books, geolocation and payment integrations; version control.
Responsible Gaming & Enforcement - self-exclusion, RG policies and disciplinary cases.
Licensing and tolerances
Ground segment
Licensed facilities include racetrack casinos and a resort complex. The portfolio includes slots, board games, poker rooms (by decision of the operator), retail sportsbook.
Online and adjacent verticals
Interactive Gaming (iGaming): operator (via ground license) + platform/provider (B2B).
Sports Wagering: Retail operator and online skins under market access land casinos.
Suppliers/platforms/content studios: individual registrations (software, RNG, wallets, geo/CUS, payment services).
LVL: licenses for the network operator, each location and terminals (quantity limits, location/supervision requirements).
Suitability: full transparency of beneficiaries, sources of funds and debts; review of officers/directors, key personnel and significant counterparties.
Taxes and Levies (Vertical Benchmarks)
Sports betting (retail/online): About 10% AGR at the state level.
iGaming (online casino/poker): a benchmark of about ~ 15% AGR (single rate for interactive games).
Land casinos: combined withholdings with GGR (slots/table games) in favor of the state; the structure differs from the "classic" tax model and is implemented through a lottery distribution mechanism.
LVL: high fiscal burden with distribution of revenue between state/operator/location; fixed and fractional components are in effect.
Reporting: monthly/quarterly forms for AGR/GGR, registers of promo/computers, accounting reconciliations with payment processes and bank registers, timely payment of fees.
Responsible play and limitations
Age: 21 + for casino/iGaming/sports; 18 + may apply for individual lottery products.
Self-exclusion: staff lists (including online and sports) with a ban on registration/play/marketing; visible RG messages and a link to help.
Marketing: banning targeting of minors/self-excluded, transparent promo rules, limiting "aggressive" mechanics.
AML/BSA: risk-based KYC, CTR/SAR, cash/wallet control, anti-structuring, staff training and procedure testing.
Technical requirements and MICS
Games/RNG/platforms: laboratory approval, version control, hashes/checksums, tamper-evident logs.
Geolocation (online): accurate verification of location within the state; anti-spoofing, device fingerprinting, failure reports.
Payments/wallets: transaction accounting, limits and sanction filters, reconciliation with bank/processing reports.
MICS: cash desk/accounting, jackpots/progressives, sportsbook processes, separation of duties, Dev→Prod access control, incident management, DR/BCP plan.
Cybersecurity: network segmentation, MFA/IAM, vulnerability/patch management, periodic pentest and tabletop exercises.
Sport rates
Retail at casino sites + online skins under the umbrella of a ground license.
House Rules: lines/limits/cancellations, settlement procedure; logging of quotation changes.
Integrity: collaboration with data providers and anomaly monitoring; ban on participation of insiders/staff.
Taxes/AGR: correct accounting of bonuses/odds boosts/free bets and impact on the tax base.
iGaming (online casino and poker)
Separate tolerances for slots, board games, poker; version registry and immutable logs.
Market access/skins model through terrestrial rights holders.
RG tools: deposit/time/loss limits, timeouts, self-exclusion, "honest" gamification.
AML: sources of funds, risk scoring, monitoring wallet→bankovskiye rails, bonus bonus/chargeback indicators.
Limited Video Lottery (LVL)
Operators, locations and terminals are licensed; limits on the number of devices/location and geographic distribution.
Strict requirements for telemetry, revenue monitoring, maintenance and replacement of components, requirements for safe storage/access.
RG elements: verification of age, mandatory warnings, time/payment restrictions (according to state rules).
Licensing Process (Reference Plan)
1. 0-1 months - pre-filing, map of ownership structures, gap analysis by verticals (casino/iGaming/sports/LVL), consultations with Lottery.
2. 1-3 months - applications for suitability (beneficiaries/officers/key personnel), RG/AML/MICS policies, technical packages to the laboratory.
3. 3-6 months - testing of platforms/games, integration of CUS/geo/payments, setting up MICS; personnel training.
4. 6 + mo - hearings/conditional approvals, phase-in (retail→online), post-audit and adjustments.
Operational checklists
Land Casino:- Full MICS coverage (cage, slots/tables, progressives, promo).
- Video surveillance and storage of records according to standards; key/access control.
- Daily drop/count, timely reporting and payments.
- RG training and verification of age (21 +), prohibition of marketing to prohibited audiences.
- Slot/board/poker approvals; version control and immutable logs.
- Geolocation/anti-spoofing; fault/interlock log; device fingerprinting.
- KYC/AML: SAR/CTR triggers, bonus abuse/chargeback monitoring.
- Taxes/AGR: accounting for promotional deductions, reconciliation with payment reports.
- Self-limiting tools - visible and easily accessible in UX.
- Actual house rules, limits and cancellation order.
- Integrity alerts and collaboration with league data providers.
- Accounting promo (free bets/boosts) and correct tax base.
- Geo-control and registration, device-control in mobile.
- Operator/Location/Terminal Licenses; GGR telemetry.
- Age verification, visual RG notifications, limits.
- Service and replacement procedures.
Frequent risks and red flags
Non-transparent beneficiaries/debt instruments; side-agreements with influence on control.
Weak geolocation/anti-spoofing (online), bypass attempts via VPN/emulators.
MICS mismatch: unauthorized version changes, incomplete logs.
Errors in the calculation of AGR and promo distributions, delays in reporting/payments.
Insufficient RG tools and marketing to self-excluded/younger than 21.
Economics and P&L: accents
iGaming (~ 15% AGR) allows you to build sustainable margins with competent promotional policies and content management.
Sport (~ 10% AGR) requires discipline in limits and bonus management; a significant role is played by the trading book and integrity.
LVL brings stable turnover with high reg load and network/service/control costs; it is important to model staff/operator/location shares.
Land casinos operate according to a lottery distribution scheme - take into account the specifics of deductions and local fees.
Trends 2025
Deepen cashless/wallet requirements and transaction traceability.
Rise of cyber resilience standards and supply-chain security for platforms/content.
Development of interstate poker liquidity under existing agreements (if/when applicable).
More pronounced RG-KPIs (early signals of a problem game, transparent gamification and promo).
What is important to remember
West Virginia is a compact but full-spectrum model under the Lottery umbrella: land casinos, iGaming, sports and LVL.
Success relies on: a crystal-clear ownership structure, impeccable MICS/reporting discipline, strict geolocation/CCS contours and a neat unit economy for differentiated rates and distributions.