IMGL Magazine April 2023

PAYMENT TECHNOLOGY

Regulating a Cashless Casino WITH EARLY MODELS OF CASHLESS CASINOS PROVING POPULAR, JENNIFER CARLETON OUTLINES A REGULATORY MODEL FOR ROLLOUT

Anonymity In a cash-based system, a patron can remain relatively anonymous (unless he or she hits a jackpot, is issued a marker or uses a player’s card). In a cashless environment, that anonymity is limited. When developing a set of cashless wagering regulations, the first necessary consideration for any gaming agency is whether the wagering requires the patron to be registered with the casino. If a cashless system is account based, the patron will not be anonymous. Most cashless wagering regulations require some form of account to be established in order for a player to gamble without cash at a casino. The minimum requirements for establishing a cashless wagering account are typically the patron’s name, date of birth, physical address and social security number (if a U.S. citizen). 1 Once an account has been established, the operator will assign a customer or patron ID “reasonably designed to prevent the unauthorized access to, or

Since 2020, casinos have started moving away from a reliance on cash. In the U.S., roughly 50 casinos have implemented some form of cashless technology, including commercial operators in Mississippi and Tribal casinos in Connecticut, Florida, Oklahoma and California. As the interest in cashless gaming has risen, so has the need to update gaming regulations. Studies by the American Gaming Association have shown that 87 percent of high-visitation, high-value customers would like to use some type of cashless gaming system. As cashless gaming continues to gain acceptance by casinos and popularity among patrons, gaming regulations will have to be refined and updated to provide an optimal customer experience. A “cashless system” is generally characterized as a system where a player maintains an electronic account on a casino database. Beyond that, the criteria for establishing a cashless casino system varies in each jurisdiction. Some of the key regulatory concerns are outlined below:

1 Nevada Gaming Commission Regulation 5.225(5)(a).

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IMGL MAGAZINE | APRIL 2023

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