If I hit the lottery for, say, $2 billion (of course, minus taxes) and I want to open a small hotel-casino, is there any prerequisite to obtaining a gaming license? Can I walk in and have no history or issues and the Board OKs a gaming license? I’m sure it's not cheap to get a look over by the Board either!
We submitted this question to the Nevada Gaming Control Board, but received no response. So we turned to retired and respected gaming attorney Anthony Cabot and the floodgates opened. Here is his answer.
“There are no prerequisites to getting a Nevada gaming license. Anyone can apply, but only those who are suitable, have sufficient experience, and sufficient funds from a suitable source should even apply. A person must prove their good character, honesty, and integrity and absence of a significant criminal record and no material association with organized crime.
“Many point to the gaming license investigative process as the most trying episodes in their lives. They were unprepared for investigations so thorough that agents went to the extent of reviewing their emails and text messages. These investigations can last between six months and year and cost hundreds of thousands of dollars.
"The Investigation Division of the State Gaming Control Board conducts licensing investigations. An investigative team has a senior agent and varying numbers of agents, depending upon the complexity of the investigation. There are two types of agents, financial and background. Financial agents have an accounting background. Background agents have law-enforcement training and often are former law enforcement agents.
“The prospective license holder must complete an application. These forms elicit basic information about his character, criminal record, business activities, financial affairs and business associates. The forms are long, and require up to 50 hours to compile and verify the requested information. This includes complete financial statements, residences and employment for the past 20 years, police and litigation records, and names, addresses, and birth dates of the applicant's extended family.
“The real work begins after the application is filed. The scope and intensity of a Nevada gaming license investigation surprised even those who have undergone the highest security clearances by the federal government.
“Applicants must often explain and sometimes justify transactions or decisions made many years ago. If a prospective applicant has any transgressions in their pasts, Nevada's agents probably will uncover them.
“During the investigation, the applicant will receive ongoing requests for various documents. These may include unusual items like diaries, day calendars, emails, text messages and personal correspondence. Agents also routinely examine contents of safety deposit boxes and safes. Basically, anything in writing or digital form is fair game. So, applicants should be prepared for these document requests throughout the process.
“During the investigation, the applicant may not interact much with the background agents. They perform thorough interviews to assess the applicant’s character, going beyond a simple police record check. The agents also show interest in the applicant's business and personal connections, as well as their methods of conducting business. For instance, they review civil-court records to gather information about any civil litigation involving the applicant and its nature.
“The applicant is likely to have more frequent contact with the financial agents, as the production of financial documentation is a significant aspect of the investigation. The applicant will be required to provide various financial records, such as income tax returns, savings passbooks, bank statements, canceled checks, deposit slips, check registers, escrow documents related to real estate transactions, loan documents, telephone records and stock certificates or account statements.
“These documents are requested for several reasons. Firstly, they help determine the adequacy of the applicant's financial resources and the suitability of their funding sources, especially if they are involved in financing the gaming establishment. Secondly, the financial records often unveil the identities of the applicant's associates and reveal their financial arrangements. The agents also closely examine the applicant's sources of income and scrutinize records of payments. In some cases, the applicant may need to clarify the origin of bank deposits or the purpose of payments shown on canceled checks.
“The agents possess extensive powers, enabling them to conduct thorough investigations. They have the authority to inspect premises, access, inspect, and audit books or records, and interview witnesses, all without any liability to the applicant. To proceed with the investigation, the applicant is required to sign various releases that indemnify the agents and allow government agencies, banks, private corporations and others to disclose information directly to the agents.
“On occasion, the agents' inquiries to government agencies, such as the Internal Revenue Service, have led to separate investigations being initiated against the applicant. Moreover, the agents interview a wide range of individuals, including references, business associates, parties involved in litigation, friends, and others, to evaluate the applicant's character, activities, and associations.
“After their investigation, the agents prepare a written summary for the Board. The summary is not available to the applicant. It contains the results of the investigation, and delineates the areas of concern. The summary contains a synopsis of interviews, summaries of court and police records, and financial analysis. In some investigations, a summary can be over 200 pages. While these marks the end of the formal investigative process, the applicant must prove his suitability in open meetings before the Board and the Commission.”
We can also recommend our recent book, Joe's Dash. After stints in the Navy and Coast Guard, Joe Dorsey worked his way up the ranks of the San Diego Police Department to become a detective with the elite Robbery Unit. From there, he was recruited by the Nevada Gaming Control Board to become an agent in Las Vegas. Joe investigated the backgrounds of everyone from unscrupulous junket reps to notorious mobsters and this section of the book gives you a bird's-eye view of the kind of investigations gambling-license applicants could expect back in Joe's day -- and they're even more stringent today.
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Bob
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O2bnVegas
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Henry
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VegasVic
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Wild Bill
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lennylasvegas
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David Miller
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Jon Anderson
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Tim Soldan
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CLIFFORD
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[email protected]
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Kevin Lewis
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Doc H
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Doc H
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AZmaddog
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[email protected]
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VegasVic
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VegasVic
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