Build an IT Gaming Compliance Program
Cost-effective compliance is possible.
- Overlapping standards and compliance efforts lead to duplicated efforts to maintain compliance. This redundancy not only wastes resources but also complicates the compliance process for operators.
- The high stakes of noncompliance can result in severe consequences, including fines, the loss of an operator’s license, and significant damage to their reputation.
- There is a lack of a standardized IT gaming compliance framework, making it difficult for operators to implement effective compliance measures, leading to inconsistencies and potential regulatory breaches.
Our Advice
Critical Insight
An IT gaming compliance framework illustrates the relationship between different obligations of an effective and lawful gaming strategy, allowing the organization to test once and attest to many industry IT obligations.
Impact and Result
- Reduce complexity within the IT gaming control environment by using a single framework to align multiple compliance regimes.
- Provide senior management with a structured framework for making business decisions on allocating costs and efforts related to IT gaming compliance obligations.
- Ensure continuous monitoring and improvement to update the compliance management tool accordingly while conducting periodic reviews and audits to ensure the business remains compliant.
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Cost-effective compliance is possible.
Analyst perspective
Eliminate redundancies while remaining compliant
The gaming industry is grappling with overlapping standards and compliance efforts, which leads to duplicated work and wasted resources. This redundancy complicates the compliance process, making it inefficient and costly for operators. The consequences of noncompliance are severe, including hefty fines, potential loss of an operator’s license, and significant damage to their reputation. The absence of a standardized IT gaming compliance framework further exacerbates the issue, making it difficult for operators to implement consistent and effective compliance measures.
As regulatory expectations evolve, operators must remain vigilant and adapt quickly, which can be resource-intensive. Ensuring player protection is a top priority, requiring operators to implement robust measures to prevent fraud and protect personally identifiable information (PII) while maintaining a seamless user experience.
To address these challenges, reduce complexity within the IT gaming control environment by using a single framework to align to multiple compliance regimes. Continuous monitoring, periodic reviews, and audits are crucial to ensure ongoing compliance, ultimately enhancing the efficiency and sustainability of the gaming environment.
Elizabeth Silva
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Executive summary
Your Challenge
Overlapping standards and compliance efforts lead to duplicated efforts to maintain compliance. This redundancy not only wastes resources but also complicates the compliance process for operators.
The high stakes of noncompliance can result in severe consequences, including fines, the loss of an operator’s license, and significant damage to their reputation.
There is a lack of a standardized IT gaming compliance framework, making it difficult for operators to implement effective compliance measures, leading to inconsistencies and potential regulatory breaches.
Common Obstacles
Evolving regulatory expectations require operators to stay vigilant and adapt quickly to new regulations, which can be resource-intensive.
Ensuring player protection is a top priority, and operators must implement robust measures, including fraud prevention, to safeguard players and protect PII while providing a seamless experience.
New trends and market entrants frequently arise, and organizations with low maturity may lack experience navigating the complex regulatory landscape, leading to challenges and inefficiencies.
Info-Tech’s Approach
Reduce complexity within the IT gaming control environment by using a single framework to align multiple compliance regimes.
Provide senior management with a structured framework for making business decisions on allocating costs and efforts related to IT gaming compliance obligations.
Ensure continuous monitoring and improvement to update the compliance management tool accordingly while conducting periodic reviews and audits to ensure the business remains compliant.
Info-Tech Insight
An IT gaming compliance framework illustrates the relationship between different obligations of an effective and lawful gaming strategy, allowing the organization to test once and attest to many industry IT obligations.
Hundreds of global regulatory updates are relevant to the gaming industry annually
Regulatory updates happen across the globe every year, and a good fraction of them are relevant to the gaming industry and require action from operators. Several actionable updates overlap with existing regulatory frameworks such as NIST, PCI, SOC, etc., and alignment to existing frameworks can ease the resources required to remain compliant.
Additionally, gaming compliance and internal audits require significant time and resources. Typically, four to five FTEs from cybersecurity, security, applications, infrastructure, and IT departments conduct four to five annual audits, each taking one week, per month across North America (interview with Mark Rosa, 2025).
The cost of compliance is high, but the cost of noncompliance is even higher
There are many challenges to remaining compliant and cost-effective at the same time.
- A lack of a standardized gaming compliance framework makes it difficult for operators to implement effective compliance measures, leading to inconsistencies and potential regulatory breaches.
- Overlapping standards and compliance efforts lead to duplicated efforts to maintain compliance. This redundancy not only wastes resources but also complicates the compliance process for operators.
- Noncompliance can result in severe consequences, including fines, the loss of an operator’s license, and significant damage to their reputation.
The Rideau Carleton Casino was served with penalties totaling CA$227,250 for 36 alleged breaches of Ontario’s Registrar’s Standards for Gaming, including the following:
- The company did not promptly address issues raised by internal auditors.
- It did not adequately safeguard gaming systems and data from security vulnerabilities, neglecting industry and technology best practices.
- Advertising and marketing materials were sent to individuals who had opted out of gambling activities.
- The company repeatedly neglected to follow necessary anti-money laundering policies and procedures.
- The compliance oversight function was not independent of the company's operations, as required.
- Staff did not complete essential training in areas such as anti-money laundering policies and procedures.
(Source: Hallo Compliance Network, 2022.)
Ensure player protection while adapting to market trends
Balancing compliance, cost, and player protection in a rapidly evolving market is a major challenge.
- Evolving regulatory expectations require operators to stay vigilant and adapt quickly to new regulations, which can be resource-intensive.
- Ensuring player protection is a top priority, and operators must implement robust measures, including fraud prevention, to safeguard players and protect PII while providing a seamless experience.
- New trends and market entrants frequently arise, and organizations with low maturity may lack experience navigating the complex regulatory landscape, leading to challenges and inefficiencies.
Three gamblers are under investigation for their involvement in an AUS$24-million sports-betting ring, resulting in Crown Resorts being fined the equivalent of US$300 million for violating the AML/CFT Act. (Source: Experian, 2024; Linkurious, 2024)
William Hill was fined £19.2 million for weak player protection and AML controls. This is the biggest fine the UK Gambling Commission has ever handed out. The operator's mistakes included not conducting checks on a new customer who bet over £20,000 in just 20 minutes and repeatedly failing to verify funds’ legitimacy across many five-figure deposits. (Source: Experian, 2024; BBC, 2023)
Blueprint benefits
IT benefits
- Reduces complexity within the control environment by using a single framework to align multiple compliance regimes.
- Reduces costs and efforts related to managing IT audits through planning and preparation.
- Improves information security practices through self-assessments.
Business benefits
- Provides senior management with a structured framework for making business decisions on allocating costs and efforts related to cybersecurity and data protection compliance obligations.
- Reduces compliance risk.
- Enables better visibility into compliance status.
IT Gaming Compliance Conceptual Model
A control framework is the first key to cost-effective compliance, allowing you to satisfy multiple compliance requirements by testing a single control.
Gain a deep understanding of the domains that make up an IT gaming internal control framework
Casino-specific Minimum Internal Control Standards (MICs) and Tribal Internal Control Standards (TICS) revolve around gaming operations, wagering, and regulatory compliance unique to the casino environment. These include controls for wagering instruments, gaming revenue systems, and strict oversight of board-regulated/Tribal-regulated systems. The following domains are explained below.
Domains Within the Gaming Internal Control Framework |
Description |
Access Control & Monitoring |
Implementing strong authentication, role-based access, and physical security measures to protect systems. |
Audit & Reporting |
Conducting regular system and process reviews, retaining logs, and submitting required reports to regulatory bodies. |
Training & Awareness |
Providing employee education on compliance, cybersecurity, and regulatory responsibilities to reduce risk. |
System Integrity & Monitoring |
Maintaining the reliability of systems through monitoring, change management, and incident response processes. |
Gaming Software & Hardware Control |
Ensuring the fairness and integrity of gaming systems through testing, updates, and secure hardware management. |
Vendor & Service Provider Management |
Managing vendor compliance with regulatory requirements and safeguards through contracts and periodic assessments. |
Network Security & Data Protection |
Safeguarding sensitive player data and systems through encryption, cybersecurity measures, and compliance with retention laws. |
Disaster Recovery & Business Continuity |
Developing and testing plans for data backup, system recovery, and operational continuity during disruptions. |
Learn from one of the leading jurisdictions in North America
This research will leverage Nevada, US, as an exemplar of how internal gaming controls can be mapped and aligned to other compliance obligations, reducing redundancies. Nevada is one of many leaders that have been leading the way within the gaming industry for several years. Other jurisdictions tend to follow suit, making it easier for other gaming organizations in different jurisdictions to adopt and adjust this framework.
- Gaming & Entertainment Information Technology Minimum Internal Control Standards
- Technical Standard 1 – Integrity of Gaming Devices
- Technical Standard 2 – Proper Accounting for Gaming Devices
- Technical Standard 3 – Integrity of and Proper Accounting for Online Slot Systems and Cashless Wagering Systems
- Technical Standard 4 – Mobile Gaming Systems
- Technical Standard 5 – Cashless Wagering Kiosk
- Technical Standard 6 – Interactive Gaming Systems and Associated Equipment
Is this research right for you?
Should you use a governance, risk, and compliance system vs. an Excel tool?
- This research offers Excel-based tools to help organizations manage their security compliance obligations.
- Excel spreadsheets are an excellent way of managing compliance data, up to a point.
- Organizations that have more complex structures and greater numbers of compliance requirements should consider the use of a special governance, risk, and compliance (GRC) tool.
- In these cases, this research product may still help you establish your security compliance program even if you opt to use a GRC tool rather than the Excel tools provided.
Operational Environments
Organizations with more than five separate operational environments should consider a GRC tool.
Compliance Obligations
Organizations with more than ten security and privacy/data protection compliance obligations should consider a GRC tool.
Blueprint deliverable
This blueprint is accompanied by a supporting deliverable to help you accomplish your goals.
IT Gaming Compliance Management Tool
The IT Gaming Compliance Management Tool is a compact GRC system in a convenient spreadsheet.
Measure the value of this blueprint
Consider tracking the following metrics to measure the value of your IT gaming compliance management program.
Metric |
Expected Improvement |
| Number of gaming controls required for compliance obligations | Use of control framework may reduce # of controls by 25% to 50% |
| Control implementation costs | Use of conformance levels may reduce implementation costs by 25% per control on average |
| Control maintenance costs | Use of environments to scope control requirements may reduce maintenance costs by 25% to 50% |
| Audit costs | Test scripts and evidence preparation may reduce audit costs by up to 50% |
| Compliance management efforts | Effort required for overall compliance management may be reduced by 25% or more |
Cost-effective compliance is possible.
Insight summary
Test Once, Attest to Many
A control framework is the first key to cost-effective compliance. Having a control framework allows you to satisfy multiple compliance requirements by testing a single control.
Scope, Scope, Scope
Environments are the second key to cost-effective compliance.
Environments allow you to apply a scope to your IT gaming compliance obligations and reduce your compliance costs.
Enable Business Decisions
Conformance levels are the third key to cost-effective compliance.
Conformance levels allow your organization to make informed business decisions on how compliance resources will be allocated.
Always Be Prepared
Audit readiness is the final key to cost-effective compliance.
Take charge of your audit costs by preparing test scripts and evidence repositories in advance.
Compliance Risk ≠ Security Risk
Compliance risk is not the same thing as security risk. Compliance risk is primarily concerned with the potential legal consequences of noncompliance, such as regulatory fines or contractual penalties.
Of course, most cybersecurity and data protection laws and regulations are designed to address security risks, so noncompliance may leave your organization open to security risks as well as compliance risks.
Info-Tech offers various levels of support to best suit your needs
DIY Toolkit |
Guided Implementation |
Workshop |
Executive & Technical Counseling |
Consulting |
| “Our team has already made this critical project a priority, and we have the time and capability, but some guidance along the way would be helpful.” | “Our team knows that we need to fix a process, but we need assistance to determine where to focus. Some check-ins along the way would help keep us on track.” | “We need to hit the ground running and get this project kicked off immediately. Our team has the ability to take this over once we get a framework and strategy in place.” | “Our team and processes are maturing; however, to expedite the journey we'll need a seasoned practitioner to coach and validate approaches, deliverables, and opportunities.” | “Our team does not have the time or the knowledge to take this project on. We need assistance through the entirety of this project.” |
Diagnostics and consistent frameworks are used throughout all five options. |
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Guided Implementation
A Guided Implementation (GI) is series of calls with an Info-Tech analyst to help implement our best practices in your organization.
A typical GI is between six to ten calls over the course of two to four months.
What does a typical GI on this topic look like?
Phase 1 |
Phase 2 |
Phase 3 |
|
| Call #1: Scope requirements, objectives, and your specific challenges. | Call #2: Establish framework and roles.
Call #3: Identify operational environments. |
Call #4: Identify compliance obligations and conformance levels.
Call #5: Map obligations into control framework. |
Call #6: Cerate a communications plan. |
On Demand
Webinar
Build a Compliance Program in Gaming and Hospitality
Play WebinarLarry
Fretz
Vice President, Industry Research & Sr. Managing Partner
Elizabeth
Silva
Research Analyst
About Info-Tech
Info-Tech Research Group is the world’s fastest-growing information technology research and advisory company, proudly serving over 30,000 IT professionals.
We produce unbiased and highly relevant research to help CIOs and IT leaders make strategic, timely, and well-informed decisions. We partner closely with IT teams to provide everything they need, from actionable tools to analyst guidance, ensuring they deliver measurable results for their organizations.
What Is a Blueprint?
A blueprint is designed to be a roadmap, containing a methodology and the tools and templates you need to solve your IT problems.
Each blueprint can be accompanied by a Guided Implementation that provides you access to our world-class analysts to help you get through the project.
Need Extra Help?
Speak With An Analyst
Get the help you need in this 3-phase advisory process. You'll receive 6 touchpoints with our researchers, all included in your membership.
Guided Implementation 1: Establish
- Call 1: Scope requirements, objectives, and your specific challenges.
Guided Implementation 2: Identify
- Call 1: Establish framework and roles.
- Call 2: Identify operational environments.
Guided Implementation 3: Implement
- Call 1: Identify compliance obligations and conformance levels.
- Call 2: Map obligations into control framework.
- Call 3: Review policies and strategy.
Contributors
- Kevin Scales, Executive Director of IT Compliance, Station Casinos
- John Forelli, SVP CIO, Ocean Casino Resort
- Mark Rosa, CIO, Mohegan Gaming
- Joe Roybal, CIO, Osage Casino & Resort
- Anonymous Contributor, Gaming Compliance Director, Casino Resort Organization