How does a Supplier Register to Participate in CT iGaming and Sports Betting?

By: Sara Dalsheim

Connecticut legalized sports betting this year and is hoping to launch in time for the 2021 NFL season.  However, the registration process for operators and suppliers has yet to be set forth.  The focus in Connecticut is largely on licensing fantasy operators in time for the 2021 NFL season.  As a result of protests from players in the fantasy sports industry, Connecticut lawmakers added a provision into the budget implementer bill, creating a process through which fantasy operators can receive provisional licenses, provided they contract with either Connecticut’s two tribal nations or with the state Lottery.  According to the implementer bill, provisional licenses for fantasy sports companies will last until September 30, 2021, or until all final licenses have been issued, whichever comes first. Although, there is little to no information about licenses for suppliers specifically.

Connecticut will require an Online Gaming Service Provider License for any entity offering goods or services to a licensed operator that are in any way “related to” online sports betting, casino gaming or DFS. The state statute provides limited examples of the types of services that may be considered “related to” online gaming, including payment processors and geolocation service providers.  Absent further regulations, the process and details regarding licenses is limited.  The state has yet to set a specific date or timeframe that further regulations would be released. The statute does, however, provide that:

An online gaming service provider shall apply for a license on a form and in a manner prescribed by the commissioner. Such license shall be renewed annually. The initial application fee for an online gaming service provider license shall be two thousand dollars ($2,000) and the annual renewal fee shall be two thousand dollars ($2,000).

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The commissioner shall establish through regulations, the criteria for determining when licensure as an online gaming service provider is required, based, in part, on whether the online gaming service provider (1) provides goods or services related to accepting wagers for Internet games or retail sports wagering, including, but not limited to, services to determine the location and identity of customers such as geolocation and “know your customer” services, payment processing and data provision, or (2) provides other goods or services that the department determines are used, in, or are incidental to, Internet games or retail sports wagering, in a manner requiring licensing in order to contribute to the public confidence and trust in the credibility and integrity of the gaming industry in this state.

The Connecticut regulations for casino suppliers may provide a hint as to what the state will expect for suppliers in iGaming and sports betting.  Casino supplier businesses that require licenses include but are not limited to: Association; Totalizer; Concessionaire; Affiliate; Gaming service provider; Nongaming vendor.  Also, the regulations declare that the department may consider the following factors when determining whether to grant or renew a business organization license:  (A) Character and reputation of any control persons, or managers or supervisors with operational oversight at the applicant’s facility; (B)  Criminal record of any control persons; (C) Financial suitability of the applicant and any control persons; (D) Past or present personal or business affiliations of the applicant or the persons identified with the applicant; (E) Local zoning and building code compliance approval; (F) Prior administrative or civil actions against the business organization, its parent company or subsidiaries, including negotiated settlements; (G) Applicant or any control persons prior or current involvement in the gaming industry; and (H) the personal or business affiliations of applicant or the persons identified with applicant.