11VAC5-70-200(A). System Integrity and Security Assessment.

Before beginning operations and annually thereafter, the permit holder shall engage an independent professional approved by the Director to perform a system integrity and security assessment of its sports betting operations.

William Hill recommends a security assessment to be performed within 90 days of a platform launching. Any assessment prior to then will not provide accurate data, such as internal documentation, reporting, encryption, pen testing, etc.  As such, we recommend adding the reference to a timeline.  

11VAC5-70-280(B). Geolocation Systems. 

At least every 90 days, a permit holder shall provide the Director evidence that the geolocation system is updated to the latest solution.

11VAC5-70-280(C). Geolocation Systems.

At least every 90 days, the integrity of the geolocation system shall be reviewed by the permit holder to ensure that the system detects and mitigates existing and emerging location fraud risks.

We suggest removing these regulations. If there is evidence of geolocation systems failure, an operator should provide regulators with information about how it ensures it is using a system that adequately detects location fraud and prepares for emerging risks.

11 VAC 5-80-90(2-3) Sports betting platform features

2. Ample opportunities for a player to take note of the passage of time

3. Game designs that promote breaks in play and avoidance of excessive play

These would be best addressed through internal controls. William Hill’s platform provides a push notification to customers every 30 minutes of play and provides an option for a customer to choose to temporarily prevent play.

If this regulation remains, William hill requests further guidance on how to determine “excessive play.”

11VAC5-70-10. Definitions.

“Principal” includes an individual who is employed in a managerial capacity for a sports betting platform on behalf of a permit holder.

William Hill requests clarification regarding “managerial capacity” so it can determine which employees should be licensed. It would also be helpful if this definition is narrowly tailored to capture only high-ranking officers or those with authority over the sports betting business in the state. The current definition could spur a large number of applications from employees without broad authority in the state, creating an administrative burden on the Director and a significant financial strain on applicants, without achieving any greater oversight of the industry.

Finally, in comments previously made to these draft regulations, some entities have proposed that sports governing bodies be provided the same authority and access to information as the Director and law enforcement agencies. These requests were made in comments No. 84419, 84373, 84403, and 84404.

William Hill opposes such a request to grant the same standing to a private entity as is rightfully given to regulators and law enforcement. Any sharing of this information should be between the private entities and not included in the regulations. William Hill has negotiated agreements with some sports governing bodies and is working with others to provide appropriate, timely information to these private organizations.

Should you have any questions, please feel free to contact me at (702) 308-9993 or thayes@williamhill.us.

            Sincerely,

/s/ Trevor Hayes        

Trevor Hayes

Head of Government Relations

cc:       Sylvia Tiscareño - General Counsel

            Dan Shapiro - Vice President of Strategy and Business Development

            Tina Robinson- Vice President of Compliance

William Hill US

6325 South Rainbow Blvd., Suite 100

Las Vegas, NV 89118
702-790-0400