As reported last week, online operators and platform providers who will accept wagers on an operator’s behalf should submit their internal control standards (ICS) for internet gaming and/or internet sports betting to the MGCB by August 31, 2020. Operators and platform providers should provide ICS based on their roles and responsibilities. The MGCB has indicated that it anticipates that online platform providers to “be responsible primarily for the processes identified in the ICS requirements.” The MGCB has issued guidance on its requirements for such ICS. 

The MGCB staff has asked applicants to do the following to facilitate an efficient review process:

  • Submit separate internet gaming and internet sports betting ICS if offering both services
  • Submit ICS in Microsoft Word format
  • Use specific reference numbers provided in the MGCB requirements to identify the location of each ICS requirement.
  • Provide written explanations of any requirements not addressed in your submission
  • Follow the same order format as outlined in the MGCB’s requirements.

The ICS requirements are applicable to the initial launch. Additional requirements may be necessary following the initial launch. According to the MGCB, operators and platform providers who submit a complete set of ICS by August 31, 2020, will increase their likelihood of “going live” during the initial launch of internet gaming and internet sports betting.

JJ Burchman, an attorney with RMC Legal noted, “The MGCB has outlined a clear path to help online operators and platform providers to assure compliance with its ICS requirements. It is very important to get the ICS submitted in a timely manner in order to ensure that the online operation will be able to “go live” during the initial launch of such wagering in Michigan.” Anyone needing more information can contact RMC Legal for further details.  


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