11 VAC 5-70-300 Internal Control Standards

GLI Recommendations

1. A permit holder and its sports betting platform supplier shall develop and maintain MICS internal control standards that meet or exceed industry standards, such as Gaming Laboratories International’s Standard GLI-33.
2. A permit holder’s MICS internal control standards shall address at a minimum:
   1. Safeguarding assets and revenues;
   2. Safeguarding player accounts;
   3. Requirements for internal and independent audits of the permit holder and its sports betting platform supplier;
   4. User access controls for all personnel;
   5. Segregation of duties among personnel;
   6. Automated and manual risk management procedures;
   7. Procedures for identifying and reporting fraud, cheating, and suspicious or unusual wagering activity;
   8. Procedures for identifying and preventing sports betting by prohibited individuals;
   9. Description of its AML compliance standards;
   10. Description of all types of wagers available to be offered by the permit holder;
   11. Description of all integrated third-party hardware, software, or systems;
   12. A monitoring system to identify irregularities in volume or odds and swings that could signal unusual or suspicious wagering activity that should require further investigation; and
   13. A wager or attempt to wager above any maximum wager threshold set by the permit holder that qualifies as unusual or suspicious wagering.

The way the term “MICS” is used here describe internal controls which are from the permit holder. Considering this, GLI recommends change to “internal control standards”

GLI also recommend elaborations on how Virginia expects GLI-33 to be utilized, such as indicating whether or not Virginia will require GLI-33 to be evaluated for sports betting platforms in addition to the requirements within these rules and regulations (as GLI recommends be clarified under 11 VAC 5-70-270).