US Gaming Law

US Gambling Law at a Glance

The table below summarizes the key elements of the US gambling regulatory landscape. It is designed as a quick reference for legal advisers, operators, investors, and regulators approaching the US market for the first time.

Topic	Summary
Regulatory model	Primarily state-by-state and tribal, with federal overlays
Main regulators	State gaming boards or commissions, lottery agencies, racing commissions, tribal gaming commissions, NIGC, FinCEN, IRS, and other federal agencies depending on activity
Core federal laws	Wire Act, UIGEA, Illegal Gambling Business Act, Travel Act, IGRA, Bank Secrecy Act, Interstate Horseracing Act, and federal tax laws
Tribal gaming	Governed by IGRA, tribal law, NIGC oversight, and for Class III gaming, tribal-state compacts
Sports betting	Legalization and licensing determined mainly by states following the Supreme Court’s 2018 PASPA decision
Online gambling	Legal only where authorized by state law, tribal compact, or other applicable framework
Key compliance issues	Licensing, suitability, geolocation, age verification, KYC, AML, responsible gambling, advertising, tax, and reporting
Emerging issues	Prediction markets, sweepstakes gaming, iGaming expansion, sports betting integrity, and responsible gambling reform

Why US Gambling Law Is State-by-State

There is a foundational presumption in the US constitutional framework that regulatory power rests with individual states unless they are acting in an area reserved for federal authority. Gambling law is no exception: there is no single nationwide gambling licence that covers all US gambling activity.

Most gambling activity is authorized, prohibited, or limited by individual state law. State regulators license and supervise commercial casinos, sports betting, online gaming, lotteries, racing, charitable gaming, fantasy sports, and gaming machines depending on the jurisdiction.

Tribal gaming operates under a separate federal-tribal-state framework governed by the Indian Gaming Regulatory Act (IGRA). Under IGRA, federally recognized tribes may regulate certain classes of gaming on tribal lands for the economic benefit of their communities.

Federal law becomes relevant when activity involves interstate communications, payment processing, criminal enforcement, tax obligations, AML compliance, or tribal lands crossing state lines.

The breadth of US state gaming agencies – from the Nevada Gaming Control Board to the Michigan Gaming Control Board to specialized lottery and racing commissions in dozens of other states – reflects the depth of this state-by-state framework.

For practitioners: a gambling product that is fully licensed and operational in one state may be prohibited, separately licensed, or subject to entirely different rules in the next state. Multi-state analysis is always required.

Key US Gambling Laws and Regulatory Frameworks

State Gambling Laws

State law is the starting point for almost every US gambling analysis. States determine whether an activity constitutes gambling, typically by assessing whether it involves the combination of prize, chance, and consideration. States set their own licensing and suitability standards, location and age restrictions, promotional rules, tax structures, and responsible gambling requirements. They also establish enforcement authority and personnel to ensure compliance.

Because each state operates independently, compliance obligations vary significantly from one jurisdiction to another. A sportsbook licensed in New Jersey, for example, faces different technical standards, tax rates, and responsible gambling requirements than one operating under a Michigan or Colorado licence.

Federal Gambling Laws

Federal law applies across state lines and targets specific conduct such as interstate communications, payment processing, organized illegal gambling, and AML compliance. The table below summarizes the primary federal statutes.

Federal Law	What It Covers
Wire Act (18 U.S.C. § 1084)	Restricts certain interstate or foreign wire communications by persons in the business of betting or wagering, particularly in connection with sporting events or contests
UIGEA (2006)	Prohibits gambling businesses from knowingly accepting certain payment methods connected with unlawful internet gambling; requires payment systems to maintain procedures to identify and block restricted transactions
Illegal Gambling Business Act (18 U.S.C. § 1955)	Targets illegal gambling businesses that violate state law and meet federal scale thresholds, including five or more persons involved and either more than 30 days of operation or $2,000 in gross revenue in a single day
Travel Act (18 U.S.C. § 1952)	Can apply to interstate or foreign travel or use of facilities to promote or carry on unlawful gambling business enterprises
Bank Secrecy Act	Requires covered casinos and card clubs to maintain AML compliance programs, file currency transaction reports, and file suspicious activity reports
Federal Tax Laws	Apply excise taxes, occupational taxes, and reporting obligations (including Form W-2G and Form 1042-S) to certain wagering activity

Tribal Gaming Law Under IGRA

Tribal gaming is not simply ‘state gaming on tribal land.’ It is a distinct legal framework with its own regulatory hierarchy, compliance requirements, and enforcement mechanisms.

What Is IGRA?

The Indian Gaming Regulatory Act (IGRA) is the primary federal statute governing gaming on Indian lands. Enacted in 1988, it recognizes tribal rights to conduct gaming under defined conditions, established the National Indian Gaming Commission (NIGC), and created distinct rules for Class I, Class II, and Class III gaming.

IGRA was enacted in 1988 to provide a legal basis for tribal gaming, encourage economic development for tribal communities, and protect gaming operations from organized crime and other corrupting influences. The NIGC is an independent federal regulatory agency whose core mission is to regulate and support gaming activities on tribal lands, ensuring that operations are fair, protected from organized crime, and structured so that tribes remain the primary beneficiaries of their gaming revenue.

IGRA Gaming Classes

IGRA divides tribal gaming into three distinct classes, each subject to different levels of tribal, federal, and state authority.

Class	Primary Game Types	Who Regulates?	State Approval Required?
Class I	Traditional and cultural games; social games for minimal prizes	100% Tribal	No
Class II	Bingo, pull-tabs, non-banked card games (e.g., poker)	Tribal + Federal (NIGC)	No
Class III	Slots, blackjack, roulette, sports betting, and all other casino-style games	Tribal + State + Federal	Yes – requires a Tribal-State Compact

Class III games are the most commercially significant category and include virtually all forms of casino gaming found in major tribal gaming facilities. Because Class III gaming requires a tribal-state compact, tribes must negotiate directly with state governments, which sometimes results in revenue-sharing arrangements and jurisdictional compromises.

A great deal of legal creativity has been applied to Class II gaming products, which have been developed to the edge of their definitions precisely because they can be offered without a tribal-state compact.

Tribal-State Compacts

A tribal-state compact is a negotiated agreement between a federally recognized tribe and a state government that governs the conduct of Class III gaming. Compacts typically address:

• The specific games the tribe is authorized to offer
• Regulatory responsibilities and inspection rights
• Revenue sharing arrangements between the tribe and the state
• Technical standards for gaming devices and systems
• Dispute resolution mechanisms
• Coverage of mobile and online sports betting where relevant

Compacts must be approved by the Secretary of the Interior. Compact negotiations and renegotiations are a significant area of tribal gaming law practice, and disputes over compact terms have generated substantial litigation.

Tribal Gaming Ordinances and Vendor Approvals

Tribes enact Tribal Gaming Ordinances to establish and govern gaming on their lands. Under IGRA, a tribal ordinance must be formally approved by the NIGC Chair before gaming can commence. Vendor relationships with tribal gaming operations involve two distinct legal tracks: standard vendor and supplier licensing handled primarily at the tribal level, and management contracts that require strict federal approval through the NIGC. The consequences of misclassifying a management contract as an ordinary vendor agreement are severe.

Who Regulates Gambling in the United States?

State Gaming Regulators

Each state that has legalized gambling maintains its own regulatory structure. Depending on the state, gaming oversight may be distributed across multiple agencies, including:

• Gaming control boards (e.g., Nevada Gaming Control Board, Pennsylvania Gaming Control Board)
• Casino control commissions
• Lottery commissions and lottery corporations
• Racing commissions and horse racing authorities
• Sports wagering regulators, sometimes embedded within existing gaming agencies
• Attorney general offices with enforcement jurisdiction over gambling
• Alcohol, consumer protection, or revenue agencies with ancillary gambling roles

Tribal Gaming Regulators and the NIGC

Tribal gaming is overseen through a layered regulatory structure:

• Tribal gaming commissions, established by tribal ordinance, serve as the primary regulators of tribal gaming operations
• Tribal governments retain sovereign authority over gaming on their lands within the IGRA framework
• The National Indian Gaming Commission provides federal oversight, approves ordinances, and can impose enforcement actions
• The Department of the Interior is involved where tribal-state compacts or land-into-trust issues arise
• State governments participate in compact negotiation and have inspection rights in some compacts

Federal Agencies with Gambling Oversight Roles

Agency	Role in Gambling Regulation
DOJ / Federal Law Enforcement	Enforcement of federal criminal gambling statutes, including the Wire Act, UIGEA, and IGBA
National Indian Gaming Commission (NIGC)	Federal oversight of Indian gaming under IGRA; approves tribal gaming ordinances and management contracts
FinCEN	AML obligations for covered casinos and card clubs under the Bank Secrecy Act
IRS	Federal wagering excise and occupational taxes; information reporting requirements
FTC	Oversight role under HISA for Thoroughbred horse racing safety and medication-control standards
CFTC	Event contracts and prediction market oversight; active regulatory and litigation disputes with state regulators

US Gambling Regulation by Sector

The following sections address the primary regulated gambling sectors in the United States. Each sector has its own licensing structure, compliance requirements, and regulatory history.

Commercial Casino Gaming

Commercial casinos are licensed and regulated by state gaming agencies. Authorization typically requires state legislation, followed by a licensing process that may include:

• Competitive bidding or legislative authorization for casino locations
• Operator licensing and suitability investigations
• Key employee and occupational licensing
• Gaming equipment testing and approval by certified labs
• Supplier and vendor licensing
• Internal control system approval
• Ongoing compliance monitoring, inspections, and reporting

Commercial gaming is the largest regulated gaming sector in the US. The American Gaming Association reported record US commercial gaming revenue of $72.04 billion in 2024, across 38 commercial gaming jurisdictions.

Sports Betting

Sports betting was effectively prohibited at the state level for decades under the Professional and Amateur Sports Protection Act (PASPA). The Supreme Court’s 2018 decision in Murphy v. NCAA struck down PASPA as unconstitutional, restoring to states the right to authorize sports wagering.

Sports betting law now varies substantially by state. Key legal and compliance issues include:

• State legislative authorization and licensing framework
• Retail (in-person) versus mobile and online sports betting authorization
• Operator, platform, and supplier licensing
• Official league data mandates and integrity requirements in some states
• College sports restrictions (some states limit or prohibit wagering on in-state college teams or events)
• Advertising standards and responsible gambling disclosures
• Federal wagering excise tax obligations

Online Casino Gaming and iGaming

Online casino gaming is authorized only in a small number of US states, including New Jersey, Pennsylvania, Michigan, Delaware, Connecticut, and West Virginia. Online poker authorization overlaps with but is distinct from general iGaming authorization. Key compliance areas include:

• State-specific operator and platform licensing
• Geolocation technology to confirm player location within the authorized state
• Age and identity verification at account registration
• Payment processing compliance and restricted transaction management
• Responsible gambling tools including deposit limits, self-exclusion, and session controls
• Game testing and certification against approved technical standards
• Cybersecurity controls and breach notification obligations
• Interstate compact considerations for shared online poker liquidity

Horse Racing and Pari-Mutuel Wagering

Horse racing has long occupied a unique position in US gambling law. It relies on a pari-mutuel wagering system in which bettors wager against each other rather than against a house. The key federal statutes governing horse racing are:

The Interstate Horseracing Act (IHA) of 1978 governs simulcasting and Advance Deposit Wagering (ADW), enabling bettors in one state to legally place remote wagers on races in another. Under the IHA, a racetrack cannot accept an interstate wager without written consent from the host racetrack, the relevant state racing commission, and the recognized horsemen’s group. ADW platforms require pre-funded accounts rather than credit.

The Horseracing Integrity and Safety Act (HISA), enacted in the early 2020s, replaced the patchwork of individual state racing regulations with a national framework for equine safety and anti-doping, overseen by the Federal Trade Commission. HISA’s two pillars cover racetrack safety (launched July 2022) and Anti-Doping and Medication Control (launched May 2023).

Lotteries and iLottery

State lotteries operate under government monopoly or quasi-public models. Retail lottery is available in 45 states plus Washington DC, Puerto Rico, and the US Virgin Islands. A growing number of states also permit online lottery ticket sales, online instant games, or lottery courier services. Multi-state jackpot games such as Powerball and Mega Millions are operated through interstate agreements. Lottery advertising, responsible gambling disclosures, and prize claim procedures are regulated at the state level.

Daily Fantasy Sports

Daily fantasy sports (DFS) contests are legal and licensed in most states, though some states prohibit or restrict them. DFS is generally distinguished from sports betting by its skill-based nature, though the legal boundary is contested. State DFS laws typically address operator registration, segregation of player funds, prohibited contest types, player fund protections, and advertising and disclosure requirements.

Charitable Gaming, Bingo, and Raffles

Charitable gaming is authorized in most states subject to strict rules limiting operators to qualifying nonprofit organizations. Permitted games typically include bingo, raffles, pull-tabs, and in some states casino nights. Prize caps, reporting obligations, net proceeds requirements, and local permitting requirements vary widely by state.

Gaming Machines, Route Operations, and Skill Games

Slot machines and video lottery terminals are regulated by state gaming agencies. Some states also permit distributed gaming, in which gaming machines are placed in bars, taverns, or other non-casino locations under a route operator licensing framework. Skill games occupy a contested legal space: operators claim their machines are exempt from gaming regulation due to a skill element, while state regulators in numerous jurisdictions have pursued enforcement actions and litigation. State-by-state machine definitions and exemptions vary significantly.

Social Casino, Sweepstakes, and Promotional Games

Social casino and sweepstakes gaming models operate on the premise that they do not constitute gambling under state law, typically by eliminating one of the three elements of gambling – prize, chance, or consideration. Sweepstakes models provide an alternative, free method of entry (eliminating consideration). These models are subject to state sweepstakes law and consumer protection rules, and have attracted increasing regulatory scrutiny. Key compliance issues include the prize-chance-consideration analysis, no-purchase-necessary alternative entry mechanisms, virtual currency treatment, and advertising and bonus term disclosures.

Prediction Markets

Prediction markets represent one of the most actively contested regulatory questions in US gambling law. CFTC-regulated platforms allow consumers to place wagers on the outcomes of elections, sporting events, and other real-world occurrences. Proponents argue these are financial derivatives under federal commodities law subject exclusively to CFTC regulation. State gaming regulators and tribal gaming interests argue that the products function as gambling and are subject to state law, and that states stand to lose both regulatory authority and tax revenue if federal preemption is established.

Active litigation and cease-and-desist activity is occurring across multiple states and federal circuits. Most commentators anticipate the issue will ultimately reach the US Supreme Court, though that process could extend into 2028 or beyond. Operators considering this space should conduct thorough analysis of both federal commodities law and state gambling law before proceeding.

Online Gambling Laws in the United States

Is online gambling legal in the US? Online gambling is legal in the United States only where it is authorized under applicable state, tribal, and federal law. Some states permit online sports betting; a smaller number permit online casino gaming or online poker; and many states prohibit or restrict online gambling entirely.

Why Location Determines Legality

In online gambling, determining legal exposure requires analysis of multiple geographic factors:

• The location of the customer at the time of play (not just their state of residence)
• The state or tribal jurisdiction under which the operator is licensed
• The physical location of servers and gaming equipment
• Whether the transmission crosses state lines and implicates the Wire Act
• Whether tribal lands are involved and whether a compact covers online activity
• The accuracy and reliability of geolocation technology used to confirm player location

Federal Online Gambling Overlays

Several federal statutes apply specifically to online gambling, regardless of state authorization:

• The Wire Act restricts certain interstate wire communications for betting and wagering purposes, particularly in connection with sporting events
• UIGEA prohibits gambling businesses from knowingly accepting restricted payment methods in connection with unlawful internet gambling and imposes obligations on payment processors
• State criminal laws may also reach online operators depending on facts and jurisdictional nexus
• AML obligations under the Bank Secrecy Act apply to covered gambling businesses operating online

Online Gambling Compliance Checklist

Operators conducting or planning online gambling in the US should address each of the following:

• State authorization confirmed for each jurisdiction where players are located
• Operator and platform licences obtained in each required state
• Geolocation technology implemented and validated to confirm player location in real time
• Age and identity verification completed at account registration (KYC)
• Restricted transaction controls and payment processor agreements in place
• Responsible gambling tools active: deposit limits, session limits, self-exclusion, and cooling-off periods
• Game testing and certification against applicable technical standards
• Cybersecurity controls and breach notification protocols implemented
• Data privacy compliance with applicable state privacy laws
• AML and sanctions screening program in place where required
• State and federal tax reporting obligations confirmed
• Advertising materials reviewed against state and platform-specific restrictions
• Terms and conditions, bonus terms, and withdrawal policies clearly disclosed

US Gambling Licensing and Market Access

Common Licence Types

Licence or Approval Type	Who May Need It
Casino operator licence	Commercial casino operators authorized by state law
Sports wagering operator licence	Sportsbook operators and mobile betting brands
iGaming operator licence	Online casino or poker operators in authorized states
Platform / supplier licence	Technology platforms, odds providers, game suppliers, and other B2B vendors
Key person / occupational licence	Executives, owners, directors, investors, and employees in sensitive positions
Affiliate / marketing registration	Lead generators, affiliates, and marketing partners (required in some states)
Tribal vendor approval	Vendors, contractors, and suppliers working with tribal gaming operations
Racing / ADW licence	Pari-mutuel wagering operators and advance deposit wagering platforms

Suitability Investigations

Most US gambling licences involve a suitability investigation of the applicant and its key principals. Regulators typically examine:

• Ownership structure and ultimate beneficial ownership
• Financial suitability, including source of funds and absence of undisclosed financial interests
• Criminal history and civil litigation background
• Regulatory history in other jurisdictions
• Business integrity and character of key individuals
• Change-of-control requirements and advance approval obligations for ownership transfers

State-by-State Licensing Strategy

Entities entering or expanding in the US gambling market should build a multi-state licensing strategy that addresses:

• Every state where customers, servers, partners, equipment, or marketing activity may be located
• Confirmation that the activity is legally authorized before any operational planning
• A matrix of applicable licence types, filing fees, tax rates, vendor obligations, and ongoing reporting deadlines
• Timeline planning for regulatory review, which can range from a few months to more than two years depending on the jurisdiction and licence type

Advertising and Responsible Gambling Rules

Gambling Advertising

US gambling advertising is regulated at the state level, with additional constraints imposed by platform policies, industry codes, and the terms of individual operating licences. Key requirements typically include:

• Mandatory responsible gambling disclosures and helpline references in advertising
• Clear and conspicuous bonus and promotion terms
• Age restrictions and age-gating requirements for digital advertising
• Restrictions on advertising during events with significant youth audiences
• Prohibitions on misleading or deceptive claims about odds, winnings, or promotional terms
• Rules governing affiliate and influencer marketing, which varies significantly by state
• College and amateur sports advertising restrictions in some states

Responsible Gambling Requirements

Responsible gambling (RG) requirements are embedded in most US gambling licences and are an area of increasing regulatory focus. Standard requirements include:

• Self-exclusion programs with multi-state interoperability in some jurisdictions
• Mandatory deposit limits, session time limits, and cooling-off periods
• Problem gambling helpline display requirements on all platforms
• Staff training on responsible gambling and identifying problem gambling signs
• Player monitoring systems with intervention protocols for at-risk behavior
• State responsible gambling plans reviewed and updated on regulatory schedules

US Gambling Enforcement and Penalties

State Enforcement

State gaming agencies have broad enforcement authority. Sanctions for non-compliance can include:

• Licence denial, suspension, or revocation
• Civil fines and financial penalties
• Cease-and-desist orders
• Mandatory compliance programs or independent monitors
• Suitability findings that result in exclusion from licensed activity
• Referral to law enforcement for criminal investigation

Federal Enforcement

Federal enforcement actions against US gambling operations may be brought under:

• The Wire Act – targeting interstate wagering communications
• UIGEA – targeting payment processors and gambling businesses accepting restricted transactions
• The Illegal Gambling Business Act – targeting operations that violate state law and meet federal scale thresholds (five or more persons and either more than 30 days of operation or $2,000 gross revenue in a single day)
• The Travel Act – targeting interstate or foreign facilitation of unlawful gambling enterprises
• Money laundering statutes – which may be layered onto gambling offenses
• Asset forfeiture – which can attach to proceeds of unlawful gambling
• Tax enforcement – where wagering taxes or reporting obligations are not met

Common Risk Areas

Based on regulatory enforcement patterns, the following represent the highest-risk compliance areas for US gambling operators and suppliers:

• Offering gambling services in a state where they are not authorized
• Misclassifying a game as skill-based or sweepstakes-based to avoid licensing requirements
• Supplying gaming technology without required licences or vendor approvals
• Geolocation failures that result in unauthorized players accessing licensed platforms
• Inadequate age and identity verification at account opening
• AML program deficiencies, including inadequate transaction monitoring and reporting
• Misleading advertising or inadequate bonus term disclosures
• Affiliate compliance failures, including marketing in prohibited states
• Failure to report material ownership or control changes to regulators
• Tribal compact non-compliance, particularly for Class III activities
• Unapproved technology or game changes introduced without prior regulatory approval

AML and Financial Compliance for US Gambling Businesses

Covered casinos and card clubs are subject to the Bank Secrecy Act and FinCEN regulations requiring risk-based AML compliance programs. Key obligations include:

• A written AML compliance program tailored to the business’s risk profile
• Filing of Currency Transaction Reports (CTRs) for cash transactions exceeding $10,000 in a gaming day
• Filing of Suspicious Activity Reports (SARs) for transactions that may involve criminal activity
• Customer identification and recordkeeping requirements
• Independent AML compliance testing
• Ongoing AML training for relevant staff

In addition to BSA obligations, gambling businesses must consider sanctions screening requirements, particularly for international transactions and beneficial ownership due diligence in corporate structures. FinCEN’s enforcement history against casinos demonstrates that AML compliance failures can result in significant civil money penalties and reputational harm.

US Gambling Compliance Checklist

The following checklist is designed for operators, investors, suppliers, and legal advisers conducting a US gambling compliance review. It does not substitute for jurisdiction-specific legal advice.

• Determine whether the product involves prize, chance, and consideration
• Identify every state, tribal jurisdiction, and territory implicated by the product or activity
• Confirm whether the activity is authorized, prohibited, or exempt in each relevant jurisdiction
• Determine whether the business requires an operator, supplier, vendor, affiliate, or occupational licence
• Review suitability requirements for owners, officers, directors, investors, and key employees
• Assess Wire Act, UIGEA, IGBA, Travel Act, and other applicable federal risks
• For tribal gaming, assess IGRA, compact, and tribal regulatory requirements
• For online activity, confirm geolocation, age verification, KYC, and account controls are in place
• Review payment processing and restricted transaction controls
• Build AML and sanctions screening controls where required
• Confirm state and federal tax obligations and establish reporting procedures
• Review advertising, affiliate, bonus, and responsible gambling compliance
• Confirm game testing, certification, and technical standards compliance
• Establish regulatory reporting, audit, and incident-response processes
• Implement a monitoring program to track state law changes, regulator guidance, and enforcement actions

US Gambling Law: Frequently Asked Questions

What is the main gambling law in the United States?

There is no single main US gambling law covering all gambling activity. US gambling law is a combination of state law, tribal gaming law under IGRA, and federal statutes including the Wire Act, UIGEA, the Bank Secrecy Act, and tax laws. The applicable rules depend on the type of gambling, the location of the operator and customer, and whether tribal lands are involved.

Is gambling legal in the United States?

Gambling is legal in the United States only where authorized by the applicable state, tribal, or federal framework. A product may be fully licensed in one state and prohibited or separately licensed in another. There is no universal federal authorization for gambling.

Who regulates gambling in the US?

Gambling is regulated by state gaming agencies, lottery agencies, racing commissions, tribal gaming commissions, the National Indian Gaming Commission, and federal agencies including FinCEN, IRS, DOJ, FTC, and CFTC depending on the type of activity and the jurisdiction.

Is sports betting legal in the US?

Sports betting is legal in many states but is not universally legal nationwide. Following the Supreme Court’s 2018 PASPA decision in Murphy v. NCAA, each state gained the authority to decide whether and how to authorize sports wagering. Dozens of states have since passed sports betting legislation.

Is online gambling legal in the US?

Online gambling is legal only in states or tribal frameworks that specifically authorize it. Online sports betting is available in more states than online casino gaming or online poker, which remain authorized in only a small number of jurisdictions.

What is the Wire Act?

The Wire Act (18 U.S.C. § 1084) is a federal statute that restricts certain interstate or foreign wire communications by persons in the business of betting or wagering, particularly in connection with sporting events or contests. Its scope – particularly as applied to non-sports online gambling – has been the subject of significant litigation and shifting DOJ guidance.

What is UIGEA?

UIGEA (the Unlawful Internet Gambling Enforcement Act of 2006) restricts gambling businesses from knowingly accepting certain payment methods connected with unlawful internet gambling. It also requires financial institutions and designated payment systems to maintain procedures to identify and block restricted transactions. UIGEA does not independently define what constitutes unlawful internet gambling – it relies on underlying state and federal law.

What is IGRA?

IGRA (the Indian Gaming Regulatory Act) is the 1988 federal law governing gaming on Indian lands. It established the National Indian Gaming Commission, recognized tribal rights to conduct gaming under defined conditions, and divided tribal gaming into Class I, Class II, and Class III categories with different regulatory requirements for each.

What is the difference between commercial gaming and tribal gaming?

Commercial gaming is licensed and regulated by state agencies under state law. Tribal gaming is conducted by federally recognized tribes under IGRA, tribal law, NIGC oversight, and – for Class III gaming – tribal-state compacts negotiated with the state in which the tribal land is located. The two systems operate under different legal frameworks with different regulators, different compliance obligations, and different approaches to vendor relationships.

Are prediction markets gambling?

The regulatory status of prediction markets is unsettled and product-specific. Some prediction market platforms operate as CFTC-regulated event contract markets under federal commodities law. State gaming regulators in multiple jurisdictions argue that the products function as gambling subject to state law and are pursuing litigation and enforcement actions. The outcome may ultimately be determined by the US Supreme Court.

Do casinos have AML obligations?

Yes. Covered casinos and card clubs are subject to Bank Secrecy Act obligations including maintaining risk-based AML compliance programs, filing Currency Transaction Reports (CTRs) and Suspicious Activity Reports (SARs), and conducting employee AML training. FinCEN has brought significant enforcement actions against casino operators for BSA failures.

This page provides general information about US gambling law and regulation. It does not constitute legal advice and should not be relied on as such. Laws and regulations change frequently, and the information on this page may not reflect the most recent developments. Readers should consult qualified legal counsel for advice specific to their products, businesses, or jurisdictions. IMGL members with US gambling law expertise can be found in the IMGL Member Directory at imgl.org.

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