Regulatory and Compliance Services

Gaming regulation around the world is built on the foundations of ensuring good character, honesty and integrity in every aspect of this important industry.  Spectrum professionals have played pioneering roles in the establishment, maintenance and evolution of core gaming principles that have ensure public confidence in the governance of gaming.  In areas ranging from anti-money laundering compliance to the complete development of effective regulatory agencies, our team is justifiably proud of our work.

Our Services Include:

  • Licensing investigations
  • Drafting of legislation and regulations
  • Anti-money laundering controls
  • Drafting and implementing minimum internal control standards
  • Compliance auditing
  • Investigations relating to cheating, swindling, fraud and abuse
  • Establishment of investigative procedures
  • Evaluation of public policy

Our regulatory experience includes the following engagements:

  • Spectrum played a critical role in helping the Massachusetts Gaming Commission to meet its obligations in licensing a new casino industry, with a slot parlor and destination resorts planned for different regions, subject to an intense competitive bidding process. Spectrum’s role included investigating the backgrounds of many applicants, and developing a strategic plan to help create the new agency.

     “Spectrum provided Massachusetts a strategic and operational plan. (Chairman Steven) Crosby called it ‘a big, fat plan that takes us from soup to nuts.’ ”

         Tampa Tribune, May 20, 2013

  • Spectrum was retained by the Singapore Ministry of Home Affairs to conduct due diligence investigations of all applicants for the proposed Marina Bay and Sentosa integrated resorts. The Government of Singapore determined to establish a gaming industry that offered the highest global standards of integrity and effective regulation. Spectrum has played an instrumental role in helping Singapore meet that goal, having since 2005 been retained by the Government of Singapore to assist in gaming, regulatory and law enforcement issues related to legalization of casino gaming and the opening of the two integrated gaming resorts. The Singapore engagements have been especially complex, as Spectrum was initiating major polices that had not been proven in that part of the world. The trust placed in Spectrum by the Singapore government has been extraordinary.
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  • The State of Ohio hired Spectrum to provide myriad services, including a statewide and regional market analyses; analysis of gaming public policy; analysis of gaming-tax rates, capital investment and licensing fees; drafting of gaming regulations; due diligence investigations of license applicants and qualifiers; developing table of organization for Casino Control Commission.

    “It was obvious to the evaluation team that … Spectrum possessed unrivaled expertise in the nuts-and-bolts operations of regulating the casino industry.”

         Dan Kaman, legislative liaison and spokesman for the Ohio Department

           of Administrative Services (quoted in Columbus Dispatch)

  • Spectrum assisted the Government of Bermuda by working with the Attorney General’s office and the Ministry of Tourism and Transportation in assisting in drafting Bermuda’s gaming law.

    “Without doubt, the contribution of Spectrum played a major role in us meeting the very tight times to introduce this Bill, therefore accept my sincere thanks to you and your team for all of your assistance.”

     Francis C. Richardson, Permanent Secretary, Government of Bermuda, Ministry of Tourism Development and Transport

  • Spectrum further assisted the Government of Bermuda by drafting regulations pertaining to the imposition and collection of the gaming tax.
  • The Maryland Lottery Commission retained Spectrum to conduct suitability background investigations for the entities and employees that apply for licenses for the state’s VLT casinos. We investigated companies that applied for operator licenses, vendors and employees.
  • The Puerto Rico Tourism Company Gaming Division, responding to gaming-expansion legislation, retained Spectrum to (a) draft regulations regarding the operation of slot machines at the commonwealth’s international airports and cruise ports and (b) draft regulations for the operation of Internet gaming.
  • The State of Delaware retained Spectrum to lead the implementation of table games in what had been a slots-only market. Spectrum’s expertise helps ensure that table games are implemented comprehensively and efficiently, while ensuring the maintenance of the public’s trust. In 2010, Spectrum was honored with a “Governor’s Team Excellence Award” certificate issued by Delaware Gov. Jack Markell for our work in helping to implement table games.
  • The Jamaica Ministry of Finance retained Spectrum to conduct the licensing due diligence investigations for the applicants for the country’s planned integrated resorts.
  • The West Virginia Lottery retained Spectrum to manage and implement the highly sensitive and complex task of implementing live table games on an expedited basis in a market that had previously authorized only slot machines. Spectrum oversaw all critical aspects of this task to ensure that table games were implemented in a manner that was comprehensive, timely and fair, and that the regulations were drafted to ensure that the rules protect the public interest, as well as the interests of the casino operators.
  • Massachusetts House Speaker Robert A. DeLeo retained Spectrum in 2010 to update its 2008 economic-impact report and to advise the Commonwealth in drafting legislation for the proposed expansion of gaming.

Anti-Money-Laundering Services

  • Spectrum Gaming Group has conducted audits and investigation regarding AML issues since the inception of the company in 1993. Spectrum Managing Director Fredric Gushin, while serving as Assistant Director for New Jersey’s Division of Gaming Enforcement, worked on a task force to implement amendments to the Bank Secrecy Act when it determined that casinos were considered financial institutions in 1986 to 1988.
  • After being fined a record $75 million by FinCEN for egregious money-laundering violations, Tinian Dynasty Hotel & Casino in the Commonwealth of Northern Marian Islands retained Spectrum to bring its operational into compliance with US AML regulations.

    “‘This case represents the intersection of Macau gaming practices and U.S. regulation,’ said Fred Gushin, managing director of Spectrum Gaming Group, which has been hired by Tinian Dynasty to bring it into compliance with U.S. anti-money-laundering regulations. The nonprosecution agreement requires the casino operator to cooperate with the U.S. in continuing criminal investigations and to overhaul its compliance procedures. Mr. Gushin said Tinian Dynasty has been cooperating with his team.”

    — Wall Street Journal, July 23, 2015

    “‘The practice of Asian junkets has basically been to conceal the identity of their patrons, and the junkets act on behalf of the high-roller patrons, and that’s unacceptable when it comes to U.S. AML/BSA procedures,’ said Gushin. ‘It’s know-your-customer, not know your junket rep.’”

    — ACAMS, August 5, 2015

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  • The Oklahoma Indian Gaming Association engaged Spectrum to provide training services for its member gaming operators.
  • A casino in Central Asia retained Spectrum to perform a risk assessment and reasonableness review of its AML program and to provide best practices policies and procedures for AML controls.
  • A European bank retained Spectrum to evaluate its efforts to implement an effective AML program and conduct due diligence suitable to its gaming clients.

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