December 23, 2021

Virginia Lottery

Casino Gaming

Proposed Regulations

11 VAC 5-90

Greetings,

Giesecke+Devrient Currency Technology America, Inc. (DBA G+D Currency Technology, Inc.) sells and services G+D branded Currency Counting machines and certain associated products. Regarding the proposed the new regulations governing Casino Gaming, we submit the following questions for public comment:

• The “Definition” section does not contain equipment explanations that apply to Currency Counting Machines. In other jurisdictions such as the Nevada Gaming Control Board, casino regulations include definitions for non-gaming equipment as well. It is proposed that the definition section be amended for the scope of defined equipment presented in the Casino Regulations to include non-gaming equipment.

• “Reciprocal Licensing” should be added to the Licensing guidelines for 11 VAC 5-90. In this process, the Virginia Lottery Board can recognize the gaming licenses that a Vendor has already obtained and apply this to the scope of said Vendor’s licensing application for Virginia.

• 11 VAC5-90-70, Section I discusses supplier permit “portability”. Supplier Permits are assigned to one property at a time and are only portable through a transfer request process. It would be preferable for Section I to be amended such that a supplier permit is issued allowing provision of services to all licensed Casino Facilities in the Commonwealth of Virginia.

• 11 VAC5-90-80 details the issuance of service permits. For the employees of Manufacturer Suppliers, will a vendor-major or vendor-minor service permit be required for working onsite, including installations and repairs? If the Employees of Manufacturer Suppliers are not eligible for Vendor-Major or Vendor-Minor service permits, then said employees should be granted access through a temporary permit for installations and emergency servicing.

G+D Currency Technology, Inc. is grateful for the opportunity to participate in the Virginia Regulatory Townhall process. If you have any questions or further discussion is needed, please feel free to contact our Gaming License and Compliance Specialist, Sean Hampton, at the following email (sean.hampton@gi-de.com) or the phone number 703-480-2199.

Thank You,

Giesecke+Devrient

Sean Hampton

Gaming License and Compliance Specialist

Giesecke+Devrient Currency Technology America, Inc.

45925 Horseshoe Drive, Dulles, VA 20166, U.S.A.

www.gi-de.com