As more and more states switch to regulated sports betting, it is clear that operators, suppliers and merchants are interacting with US regulators, and their interaction with them is also increasing. And while every regulator is unique, there are a few keys to getting your business moving forward with your future government partners.
Forget about the "us versus them" mentality
The definition of "enemy" is a person who actively opposes or is hostile to someone. . This is the exact opposite of what the regulators are trying to do, so stop treating them like the enemy. Regulators and their approvals are key to your market entry, so working with regulators to make sure you understand their needs and they understand your product, processes and procedures is very important.
Ignoring requirements because they are complex, different, or take time to develop will not get you what you want. Not only will this be a hurdle in the jurisdiction you face at that time, but it is likely that you will face this complex requirement in one or more future jurisdictions as well. Thus, the time spent addressing the problem upfront—either by developing a fix or by working with the regulator to find a reasonable solution—will be worth the investment in the long run.
Your first impression doesn't have to be on paper.
Everyone cringes at the Multi-Jurisdictional Personal History Disclosure (MJPHD) site or business disclosure form. These forms are critical and the hard work of completing them should begin as soon as possible (more on that below), but it's important not to get lost in the documentation. Your business is much more than just financial disclosures, licensing history, contractual partners, and other details required on forms. Your business is about interesting products and experiences you create, the people who help create them, and interesting plans for the future.
And the best way to introduce regulators to all your hard work and passion is to take them face to face. “Post-Covid” opportunities come in all shapes and sizes and could potentially be more cost-effective, as government agencies are now as comfortable with videoconferencing as they were in-person pre-Covid meetings.
Organization is a sign of respect
Back to applications... the information on the pages is important, but just as important is how it's presented. Providing organized and consistent responses will help regulators complete their review more quickly. Disorganized, incomplete applications requiring amendments or corrections only lead to delays and frustration both on your part and on the part of agency analysts reviewing your applications.
All license applicants should consider a few simple organizational advantages:
1. Read the instructions: Be sure to answer all questions and mark documents as directed in the instructions.
2. Be consistent: use the same verbiage in questions, in all documents, for different candidates.
3. Keep Records: Keep organized and complete copies of final submissions, if regulators have follow-up requests, you want to make sure you are accurately responding to information submitted by them.
4. Think Software: Using licensing and compliance software solutions that can simplify responses and ensure consistency across jurisdictions, businesses, and individuals can ensure a clean, consistent look for your applications.
Speak with one voice
Providing regulators with uniformity on who should be their point of contact will help streamline issues early and avoid unnecessary delays or missed and/or mixed messages. Each organization will manage this differently, either through a single point of contact for all regulatory matters, or through points of contact for specific business units. The main thing is to give regulators a clear idea of who to call for questions, concerns or feedback.
The information provided in this article does not constitute legal advice and is not intended to do so; instead, all information is for general informational purposes only.
Eric Frank is the founder of EDF Compliance, LLC, a consulting company for the gaming industry and beyond. Frank worked as a Compliance Officer for The Stars Group, one of the world's largest online gaming operators. He has unique experience in dealing with complex compliance and regulatory issues around the world. He has led global compliance teams with responsibilities in over 20 licensed markets worldwide and has served as Principal Legal Counsel for regulatory, licensing and compliance issues in the US, Latin America and Asia. Frank also has over a decade of experience in private practice at one of the largest law firms in the world, advising gaming clients on a full range of regulatory and licensing matters, and in government at all levels—federal, state, and international—on drafting statutes and regulations. and policy advice.