Senator Moran Page 3 of 3
Paraphernalia Act , 18 U.S.C. § 1953 and the Federal Wagering Tax Act , 26 U.S.C. §§ 4401- 4413. In sum, sports event contracts are prohibited because they violate state and federal laws. Additionally, sports and other such nebulous “event contracts” authorized by the CFTC must be prohibited because they are contrary to the public interest. Unlike tribal and state-regulated sports betting, which protect the public through age verification, geolocation restrictions, key employee background checks and financial integrity reviews, lists of prohibited participants, including a prohibition against athletes from gambling, “Know Your Customer” programs and AML controls; CFTC sports event contracts lack comparable safeguards. Sports event contract operators allow persons under 21 to gamble in violation of tribal and state laws, while portraying sports bets as “investments”—confusing the public about the risks of gambling . (emphasis added). By allowing these event contracts that are wholly unrelated to commodities, the CFTC risks making public policy decisions that ignore the detrimental impacts from sports betting that every State and Tribal government has a sovereign duty to evaluate. Additionally, every sports event contract that is traded on tribal land or in violation of a Tribal-State compact deprives tribes and states of revenue that our communities rely upon. Therefore, the IGA urges you and the Senate Agriculture Committee to discuss this issue with Mr. Selig at his nomination hearing and urge the CFTC to stay committed to their responsibilities under the CEA and stay out of this Nation’s gambling policy for which they have no mechanisms to enforce or regulate. I look forward to discussing this issue with you and your staff further. Sincerely, /s/ DAVID BEAN Chairman David Z. Bean 224 2 nd Street SE Washington, DC 20003
CC: Senate Committee on Agriculture, Nutrition, and Forestry
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