Overview
Our Gaming Law practice encompasses the full range of gaming activity except for criminal prosecutions for violation of State and federal gambling laws. Our attorneys have been involved with the regulated gaming industry in Missouri from its inception back in the early 1990s. They have developed an understanding of the statutes and regulations applicable to gaming in the State and have formed working relationships with the regulators in this area. They are also active in the two major gaming attorney associations in the industry – International Masters of Gaming Law (IMGL) and International Association of Gaming Advisors. They have served as principal officers to IMGL, presented programs and authored papers on the law of gaming, and continually attend programs and trade shows to keep current on the evolving substance of gaming law.
Who We Represent
- Casino Licensees
- Supplier Licensees
- Occupational Licensees
- Bingo Licensees
- Gaming-Related Entrepreneurs
- Charitable Organizations
- General Businesses
- Special Events Promoters
Service We Provide
- Missouri Gaming Licenses: This includes casino operators and their holding companies; suppliers of games and equipment to Missouri casinos, including slot machines, other electronic gaming devices, playing cards, dice and other non-electronic games equipment; and persons or entities with ownership interests in a licensee that require them to be licensed as a key person. This representation has included application preparation, review and filing; response to application investigation requests for information; license renewals; regulatory compliance; regulatory investigations; regulatory aspects of financing transactions; disciplinary complaints; waivers of specific requirements; institutional investor waivers; and license denial actions; legislative and regulatory initiatives; and litigation.
- Casino property ownership: An emerging trend in the structuring of casino ownership is the Gaming REIT, which owns the real estate on which the casino is located and leases it to the casino. The Gaming REIT is licensed as a key person business entity in Missouri. We represent Gaming REITs in Missouri providing for other key person business entity licensees.
- Change in control transactions: When ownership of a gaming license is to change hands, it must have prior approval of the Missouri Gaming Commission. In furtherance of obtaining that approval, we prepare and file the petition for change of control and supporting documentation. In addition, we assist in coordinating the ancillary applications and notices involved, including but not limited to, casino license applications, supplier license applications, key person license applications and financial transaction notices. As part of the process we can also provide post-closing notices to the regulators.
- Financial transactions: In Missouri, certain financing and other financial transactions have their own regulatory compliance requirements: notice of the transaction; completion and filing of forms; and Missouri-specific provision to be included in the financing documents. With respect to such financing transactions, we typically review the financing documents and provide advice on the Missouri-specific language that must be included; prepare the transaction notice and lender affidavit; file the documents; request institutional investor waivers; request waivers for untimely filings; and notify the Missouri Gaming Commission of the closing of the financing transaction. In addition, we often provide Gaming Compliance opinions and Corporate Authority opinions to the lenders related to the financing transaction.
- Fantasy Sports: In 2016, Missouri legalized daily fantasy sports websites and the licensing of operators of those sites. We have provided review and legal counsel on proposed fantasy sports websites to multiple start-up companies, including advice and assistance on license applications.
- Bingo Law Compliance: We have represented bingo operator licensees and bingo suppliers to the same extent and in the same type of matters as with casino licensees and supplier licensees.
- Sports Betting: Sports book and online betting have not been authorized in Missouri to date, but we are monitoring legislative action with respect to these activities. We have also reviewed contingent sports book contracts for sports book activities to be operated in Missouri should the activity be authorized.
- Sweepstakes Legal Reviews and Opinions: Our gaming practice has also included providing reviews, legal opinions and rules drafting for sweepstakes, that is, promotional giveaways, raffles and fund-raisers conducted by businesses and charitable organizations.
Where We Represent Our Clients
- Missouri Gaming Commission
- Missouri Administrative Hearing Commission
- State and Federal Trial and Appellate Courts
- Missouri Legislature (excluding lobbying)
