# EMERGENCY TICS PROMULGATION

> Briefs, arguments, decisions, and more.

URL: https://www.frixlaw.com/law-library/documents/tribal%3Apueblo_laguna%3A7d8a1f446f5cb0b4

## Record

- **Collection:** Tribal code
- **Document type:** Tribal code

## Text

NOTICE OF
EMERGENCY TICS PROMULGATION
GLI-33
September 3, 2019
Pursuant to Part 1203(c) of the Laguna Gaming Control Board (“LGCB”) Regulations, the Pueblo of
Laguna Tribal Gaming Regulatory Authority hereby promulgates Gaming Labs International (“GLI”) Event
Wagering Systems standards “GLI-33” as Tribal Internal Controls Standards for the conduct of sports betting
activities.
The TGRA concludes that emergency promulgation of GLI-33 is necessary because implementing TICS
for sports betting activities is required for the gaming enterprise to install gaming equipment and conduct sports
betting activities within the gaming facilities.
The emergency promulgation of GLI-33 is attached and can be found at the TGRA website at the following web
address: https://www.lagunapueblo-nsn.gov/TGRA.aspx.

STANDARD SERIES

GLI-33:
Event Wagering Systems

Version: 1.0

Release
elease Date: August 7, 2018

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ABOUT THIS STANDARD

This technical standard has been produced by Gaming Laboratories International, LLC (GLI)
for the purpose of providing independent technical analysis and/or certifications to wagering
industry stakeholders indicating the state of compliance for wagering operations and systems
with the requirements set forth herein.

This document is intended to be used by regulatory bodies, operators, and industry suppliers as a
compliance guideline for technologies pertaining to Event Wagering Systems. This standard is
not intended to represent a set of prescriptive requirements that every Event Wagering System
must comply with; however it does establish a technical standard regarding the technologies used
to facilitate these operations. It should be stressed that some of the technical standards addressed
within this document may be satisfied through manual operational controls as approved by each
regulatory body.

A supplier is expected to provide internal control documentation, credentials and associated
access to a production equivalent test environment with a request that it be evaluated in
accordance with this technical standard. Upon completion of testing, GLI will provide a
certificate of compliance evidencing the certification to this Standard.

GLI-33 should be viewed as a living document that provides a level of guidance that will be
tailored periodically to align with this developing industry over time as wagering
implementations and operations evolve.

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GLI Standard #33 – Standards for Event Wagering Systems

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TABLE OF CONTENTS
CHAPTER 1: INTRODUCTION TO EVENT WAGERING .............................................................................. 7
1.1 Introduction.......................................................................................................................................7
1.2 Acknowledgment of Other Standards Reviewed................................................................................8
1.3 Purpose of Technical Standards .......................................................................................................8
1.4 Other Documents That May Apply ....................................................................................................9
1.5 Interpretation of this Document ...................................................................................................... 10
1.6 Testing and Auditing ....................................................................................................................... 10
CHAPTER 2: EVENT WAGERING REQUIREMENTS .................................................................................. 12
2.1 Introduction..................................................................................................................................... 12
2.2 General Wagering Requirements .................................................................................................... 12
2.3 Wager Placement ............................................................................................................................ 14
2.4 Results ............................................................................................................................................. 17
2.5 Winnings ......................................................................................................................................... 18
2.6 Fixed Odds Wagers ......................................................................................................................... 18
2.7 Pari-Mutuel Wagers ........................................................................................................................ 19
2.8 Additional Features......................................................................................................................... 19
2.9 Virtual Event Wagering .................................................................................................................. 22
2.10 External Wagering Systems............................................................................................................. 25
CHAPTER 3: WAGERING DEVICE REQUIREMENTS ................................................................................ 27
3.1 Introduction..................................................................................................................................... 27
3.2 Program Requirements ................................................................................................................... 27
3.3 Wagering Device Operations and Security ..................................................................................... 28
CHAPTER 4: SELF-SERVICE WAGERING DEVICES ................................................................................. 31
4.1 Introduction..................................................................................................................................... 31
4.2 Player Safety ................................................................................................................................... 31
4.3 Environmental Effects on Integrity ................................................................................................. 31
4.4 Self-Service Wagering Device Identification .................................................................................. 32
4.5 Basic Hardware Requirements ....................................................................................................... 32
4.6 Electrical Power ............................................................................................................................. 33
4.7 Doors and Security.......................................................................................................................... 34
4.8 Critical Non-Volatile (NV) Memory ................................................................................................ 35
4.9 Peripheral Devices.......................................................................................................................... 36
CHAPTER 5: REMOTE WAGERING DEVICES ............................................................................................ 38
5.1 Introduction..................................................................................................................................... 38
5.2 Client Software ................................................................................................................................ 38
5.3 Remote Wagering Device Integrity ................................................................................................. 40
5.4 Location Detection for Wagering on a Wireless Local Area Network ............................................ 40
5.5 Location Detection for Wagering Over the Internet ....................................................................... 41
CHAPTER 6: PLAYER ACCOUNT REQUIREMENTS .................................................................................. 43
6.1 Introduction..................................................................................................................................... 43
6.2 Player Account Registration and Access ........................................................................................ 43
6.3 Player Account Controls ................................................................................................................. 46
6.4 Player Loyalty Programs ................................................................................................................ 51
CHAPTER 7: SYSTEM AND OPERATOR REQUIREMENTS....................................................................... 52
7.1 Introduction..................................................................................................................................... 52
7.2 System Clock Requirements ............................................................................................................ 52
7.3 Control Program ............................................................................................................................. 52
7.4 Shutdown and Recovery .................................................................................................................. 53
7.5 Wagering Control ........................................................................................................................... 55
7.6 Information to be Maintained ......................................................................................................... 55
7.7 Reporting......................................................................................................................................... 60
Table of Contents
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7.8 Taxation .......................................................................................................................................... 64
7.9 Operational Guidelines ................................................................................................................... 64
CHAPTER 8: SYSTEM SECURITY REQUIREMENTS .................................................................................. 66
8.1 Introduction..................................................................................................................................... 66
8.2 System Operation & Security .......................................................................................................... 66
8.3 Communication Requirements ........................................................................................................ 68
8.4 Backup and Recovery ...................................................................................................................... 71
8.5 Technical Controls .......................................................................................................................... 73
8.6 Remote Access and Firewalls.......................................................................................................... 74
8.7 Change Management ...................................................................................................................... 76
GLOSSARY OF KEY TERMS ............................................................................................................................ 78

Table of Contents
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CHAPTER 1: INTRODUCTION TO EVENT WAGERING
1.1

Introduction

1.1.1. General Statement. Gaming Laboratories International, LLC (GLI) has been testing
gaming devices since 1989. Over the years, GLI has developed numerous technical standards
utilized by jurisdictions all over the world. This document, GLI-33, sets forth the Technical
Standards for Event Wagering Systems.

1.1.2 Document History. This document is a compilation based upon many standards
documents from around the world. Some were written by GLI; others were written by industry
regulators with input from independent test laboratories and Event Wagering System
manufacturers. GLI has taken each of the standards documents and merged the unique rules,
eliminated some rules and updated others, to reflect both the change in technology and the
purpose of maintaining an objective standard that achieves common regulatory objectives
without unnecessarily impeding technological innovation. GLI lists below, and gives credit to,
agencies whose documents were reviewed prior to writing this Standard. It is the policy of GLI
to update this document as often as warranted to reflect changes in technology and/or testing
methods. This document will be distributed without charge and may be obtained by downloading
it from the GLI website at www.gaminglabs.com or by contacting GLI at:

Gaming Laboratories International, LLC.
600 Airport Road
Lakewood, NJ 08701
(732) 942-3999 Tel
(732) 942-0043 Fax

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1.2

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Acknowledgment of Other Standards Reviewed

1.2.1 General Statement. This technical standard has been developed by reviewing and using
portions of the documents from the following organizations. GLI acknowledges and thanks the
regulators and other industry participants who have assembled these documents:

a)

Nevada Gaming Commission and Gaming Control Board.

b)

British Columbia Gaming Policy and Enforcement Branch (GPEB).

c)

Association of Racing Commissioners International (ARCI).

d)

Tasmanian Liquor and Gaming Commission.

e)

Northern Territory Racing Commission.

f)

Victorian Commission for Gambling and Liquor Regulation.

g)

Danish Gambling Authority.

h)

Spanish Directorate General for the Regulation of Gambling (DGOJ).

i)

South African Bureau of Standards (SABS).

1.3

Purpose of Technical Standards

1.3.1 General Statement. The purpose of this technical standard is as follows:

a)

To eliminate subjective criteria in analyzing and certifying Event Wagering Systems.

b)

To test the criteria that impact the credibility and integrity of Event Wagering Systems
from both the revenue collection and player’s perspective.

c)

To create a standard that will ensure wagers on events are fair, secure, and able to be
audited and operated correctly.

d)

To distinguish between local public policy and Independent Test Laboratory criteria. It is
up to each local jurisdiction to set its own public policy with respect to wagering.

e)

To recognize that the evaluation of internal control systems (such as Anti-Money
Laundering, Financial and Business processes) employed by the operators of the Event
Wagering System should not be incorporated into this standard but instead included
within the regulatory operations of the local jurisdictions.

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f)

To construct a standard that can be easily revised to allow for new technology.

g)

To construct a standard that does not specify any particular design, method, or algorithm.
The intent is to allow a wide range of methods to be used to conform to the standards,
while at the same time encourage new methods to be developed.

1.3.2 No Limitation of Technology. One should be cautioned that this document must not be
read in such a way that limits the use of future technology. This document should not be
interpreted to mean that if the technology is not mentioned, then it is not allowed. To the
contrary, GLI will review this standard and make changes to incorporate minimum standards for
any new and related technology.
1.3.3 Adoption and Observance. This GLI technical standard can be adopted in whole or in
part by any regulatory body that wishes to implement a comprehensive set of requirements for
Event Wagering Systems.

1.4

Other Documents That May Apply

1.4.1 Other GLI Standards. This standard covers the requirements for Event Wagering
Systems. Depending on the technology utilized by a system, additional GLI technical standards
may also apply.

NOTE: The entire family of GLI Standards is available free of charge at www.gaminglabs.com.

1.4.2 Operator’s Minimum Internal Control Standards (MICS). The implementation of an
Event Wagering System is a complex task, and as such will require the development of internal
process and procedures to ensure that the system is configured and operated with the level of
security and control necessary. To that end, it is expected that the operator will establish a set of
Minimum Internal Control Specifications (MICS) to define the internal requirements for the
creation, management, and handling of wagering transactions as well as the requirements for
internal control of any system or component software and hardware, and their associated
accounts.

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1.5

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Interpretation of this Document

1.5.1 General Statement. This technical standard applies to systems that support wagering on
sports, competitions, matches, and other event types approved by the regulatory body. The
requirements in this technical standard apply to wagering on events in a way that is general in
nature and does not limit or authorize the specific events, markets or types of wagers. The intent
is to provide a framework to cover those currently known and permitted by law. This document
is not intended to define which parties are responsible for meeting the requirements of this
technical standard. It is the responsibility of the stakeholders of each operator to determine how
best to meet the requirements laid out in this document.

1.5.2 Software Suppliers and Operators. The components of an Event Wagering System,
although they may be constructed in a modular fashion, are designed to work seamlessly
together. In addition, Event Wagering System components may be developed to have
configurable features, the final configuration of which will depend on the options chosen by the
operator. From a testing perspective, it may not be possible to test all of the configurable features
of an Event Wagering System component submitted by a software supplier in the absence of the
final configuration chosen by the operator; however, the configuration that will be utilized in
production must be communicated to the independent test laboratory in support of a creating an
functionally equivalent testing environment. Because of the integrated nature of an Event
Wagering System, there are a number of requirements in this document which may apply to both
operators and suppliers. In these cases, where testing is requested for a “white-label” version of
the component, a specific configuration will be tested and reported.

1.6

Testing and Auditing

1.6.1 Phases of Testing. The approval of an Event Wagering System will be certified in two
phases:

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a)

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Initial laboratory testing, where the independent test laboratory will test the integrity of
the Event Wagering System in conjunction with Wagering Devices, in the laboratory
setting with the equipment assembled; and

b)

At a frequency specified by the regulatory body, an on-site operational audit of the
production system as required. This may include, but is not limited to, an information
security system (ISS) assessment, review of the operational processes that are critical to
compliance, penetration testing focused on the external and internal infrastructure as well
as the applications transferring, storing and/or processing player credentials and/or
sensitive information, and any other objectives established by the regulatory body.

NOTE: Requirements within this standard can be met with a technical solution evaluated in the
laboratory testing phase or alternatively, operational controls to be audited during the on-site
phase. It is the recommendation of this standard that any requirement identified as met through
operational procedure is documented within the evaluation report and supplements the scope of
the periodic operational audit.

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CHAPTER 2: EVENT WAGERING REQUIREMENTS
2.1

Introduction

2.1.1 Introduction. This chapter sets forth technical requirements for wagering operations,
including, but not limited to rules for creating markets, settling wagers, closing markets,
cancellations of events, cancelling wagers.

NOTE: The display requirements within this chapter apply to information displays for a
Wagering Device as supported, websites managed by the venue and/or operator, and/or
information that are otherwise provided to players via external signage, forms, or brochures
available at a venue.

2.2

General Wagering Requirements

2.2.1 General Statement. The following sections describe the information which must be made
available to the player through the Wagering Device or upon request at a venue regarding the
events, markets, and associated types of wagers available on the Event Wagering System, and
the methods for placing a wager on the Event Wagering System. An event may support multiple
wagering opportunities, known as markets (e.g., money line, point spread, over/under, etc.).

2.2.2 Wagering Rules and Information. The following requirements apply to the wagering
rules and information including any written, graphical, and auditory information provided to the
player:

a)

Wagering Device usage instructions, if applicable, payout information, and rules of
participation shall be complete and unambiguous and shall not be misleading or unfair to
the player.

b)

Wagering rules and information, including all wagering eligibility and scoring criteria,
available events and markets, line postings, and advertised awards, shall be accessible by

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a player without the need for placing a wager.
c)

Payout information shall include all possible winning positions, rankings, and
achievements, along with their corresponding payouts, for any available wager option.

d)

Any prizes that are offered in the form of merchandise, annuities, lump sum payments, or
payment plans instead of cash payouts shall be clearly explained to the player in each
market that is offering such a prize.

e)

Wagering rules and information that is presented aurally (via sound or voice) shall also
be displayed in written form.

f)

Wagering rules and information shall be rendered in a color that contrasts with the
background color to ensure that all information is clearly visible/readable.

g)

Statistical data that is made available to the player pertaining to the event must use a
source approved by the regulatory body and shall be reasonably accurate and updated.

h)

The wagering rules and information shall clearly explain whether the odds/payouts are
locked-in at the time of the wager (e.g., fixed odds), or if the odds/payouts may change
dynamically prior to the commencement of the event (e.g., pari-mutuel).

i)

The wagering rules and information must clearly state the means by which a winning
wager is determined and the handling of an award in any case where a tie is possible.

j)

If prizes are to be paid for combinations involving participants other than solely the first
place finisher (e.g., in an Olympic competition), the order of the participants that can be
involved with these prizes shall be clearly indicated (e.g., result 8-4-7).

k)

The rules for any exotic wagering options (e.g., perfecta, trifecta, quinella, etc.) and the
expected payouts shall be clearly explained to the player.

l)

The wagering rules and information shall disclose any restrictive features of wagering,
such as minimum wager amounts or maximum win values.

m)

The operator commission amount for each wager, if any, must be indicated to the player.

2.2.3 Disclosure of Promotions and/or Bonuses. Players must be able to access information
pertaining to any available promotions and/or bonuses. This information must be clear and
unambiguous, especially where promotions or bonuses are limited to certain events, markets, or
when other specific conditions apply.

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2.2.4 Access to Current Odds/Payouts and Prices. Players must be able to access current
odds/payouts and prices for available markets prior to the placement of a wager.

NOTE: It is accepted that, depending on the medium, communication delays are variable and
beyond the knowledge or control of the operator, and the displayed information may be different
from the information recognized in the system.

2.2.5 Player Fairness. In order to ensure player fairness, the Event Wagering System must
identify situations where the player has placed a wager for which the associated odds/payouts or
prices have changed, but not yet refreshed on the Wagering Device or external display, and,
unless the player has opted in to auto-accept changes as permitted by the regulatory body, notify
the player accordingly to confirm the wager given the new values.

2.2.6 Advertising. All advertising or marketing material that is displayed or otherwise
conveyed to the player must not:

a)

Contain graphics and/or audio deemed indecent or offensive by the regulatory body;

b)

Contain content that contradicts the wagering rules and information or terms and
conditions; and

c)

Specifically target players that have been excluded from play.

2.3

Wager Placement

2.3.1 General Statement. Depending on the type of Wagering Device, wagers may be placed
directly by the player or on behalf of a player by an attendant. Refer to the chapter entitled
“Wagering Device Requirements” for additional information.

2.3.2 Selection of a Wager. The following rules apply to the selection of a specific wager:

a)

Players shall have the ability to select the wagering option they want to place a wager on.

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b)

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No paid wagers shall be automatically placed on behalf of the player without the player’s
selection, or authorization, which may be given in advance.

c)

Players shall have an opportunity to review and confirm their selections for a particular
offering before the wager is submitted. This does not preclude the use of “single-click”
wagering as permitted by the regulatory body and opted in by the player.

2.3.3 Placing Wagers. Wagers may be placed either in conjunction with a player account, by
funds provided to a Wagering Device, or through interaction with an attendant.

a)

The method of placing a wager shall be straightforward, with all selections (including
their order, if relevant) made clearly obvious to the player.

b)

When the wager involves multiple events (e.g., parlays), such groupings must be clearly
obvious to the player.

c)

Clear indication shall be provided to the player that a wager has been accepted by the
Event Wagering System. Each individual wager shall be acknowledged and clearly
indicated to the player separately so that the player is not in doubt as to which wagers
have been accepted.

d)

If the wager attempt is rejected (in full or in part) by the Event Wagering System, the
player is to be informed of the rejection. The wagering rules and information must
disclose any reasons for which a wager may get rejected.

e)

For paid wagers conducted using a player account:
i.

A Wagering Device shall make the player’s balance readily accessible.

ii.

No wager amount may be greater than the player’s balance.

iii.

The player’s balance is to be debited when the wager is accepted by the system.

2.3.4 Wager Record. Upon completion of a wagering transaction, the player shall receive a
virtual or printed wager record which contains the following information:

a)

The date and time the wager was placed;

b)

The date and time the event is expected to occur (if known);

c)

Any player choices involved in the wager:

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i.

Wager selection (e.g., athlete or team name and number);

ii.

Type of wager and line postings (e.g., money line bet, point spreads, over/under
amounts, win/place/show, etc.);

iii.

Any special condition(s) applying to the wager;

d)

Total amount wagered, including any promotional/bonus credits (if applicable);

e)

Event and market identifiers;

f)

Unique identification number of the wager record;

g)

For printed wager records, the following must be also included:
i.

Venue Name/Site Identifier;

ii.

Unique Wagering Device ID which issued the wager record; and

iii.

Expiration period (if applicable).

2.3.5 Cancellations. Wagering transactions cannot be modified except to be cancelled as
provided for in the operator’s published cancellation policy. The following requirements apply
toward wager cancellations:

a)

The player must be able to access any policies relative to cancellations, including the
prohibition of cancellations (e.g., after a fixed time period);

b)

The cancellation policy must cater for wagers with multiple events (e.g., parlays);

c)

Player initiated cancellations may be authorized in accordance with the cancellation
policy. A cancellation grace period may be offered to allow players to request a
cancellation of wagers placed; and

d)

Operator initiated cancellations must provide a reason for cancellation to a player (e.g.,
past-post wager).

2.3.6 Wagering Period Close. The wagering rules and information shall clearly explain that
wagering periods can be closed at the discretion of the operator. It shall not be possible to place
wagers once the wagering period has closed.

2.3.7 In-Play Wagering. The player must be informed that due to varying communication
speeds or broadcast transmission latencies:

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a)

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There may be delays in updates of the displayed information and the player may be at a
disadvantage to others who may have more up-to-date information.

b)

The Event Wagering System may incorporate delays in the registered time of an in-play
wager to prevent past-post wagers and cancellations.

2.4

Results

2.4.1 Entering Results. Results entry must include the entry of all information which may
affect the outcome of all types of wagers offered for that event.
2.4.2 Displaying Results. The player must be able to view the results of their wagers on any
decided market, once they have been confirmed.

a)

Players must be able to view any change of results (e.g., due to statistics corrections).

b)

Where individual wager amounts are gathered into pools, the player must be able to view
the dividends of any decided market.

2.4.3 Withdrawn Selections. The player must be able to view withdrawn selections for wagers
with multiple events (e.g., parlays) through the Wagering Device or upon request at a venue. The
wagering rules and information available to the player must clearly state what is to occur when
these selections are withdrawn.
2.4.4 Cancelled Events and Markets. The wagering rules and information available to the
player through the Wagering Device or upon request at a venue must clearly state what is to
occur when an event or market is cancelled, including the handling of wagers with multiple
events (e.g., parlays) where one or more of these legs are cancelled. If an event or market is
cancelled for any reason, all associated wagers are to be refunded in full as soon as reasonably
possible.

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2.5

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Winnings

2.5.1 Payment of Winnings. Once the results of the event are entered and confirmed, the
player may receive payment for their winning wagers. This does not preclude the ability for the
player to perform a redemption for an adjusted payout before event conclusion where offered by
the Event Wagering System.
NOTE: Amounts won that exceed any jurisdictional specified limit shall require the appropriate
documentation to be completed before the winning player is paid.

2.5.2 Rounding. Where the calculation of payouts may involve rounding, information on how
the system handles these circumstances must be provided to the player through the Wagering
Device or upon request at a venue, which must clearly specify what is to occur:

a)

Rounding to what level (e.g., 5 cents) must be clearly explained;

b)

Rounding up, down (truncation), true rounding, must be clearly explained; and

c)

Metering of rounding amounts must be clearly explained.

2.6

Fixed Odds Wagers

2.6.1 Fixed Odds Wagers. The following requirements are applicable for types of wagers
where the odds/payout is fixed at the time the wager is placed:

a)

The Event Wagering System must store a table of all line postings that were available
throughout the duration of a market and keep an accurate record of all wagers placed for
each posting.

b)

The wagering rules and information available to the player through the Wagering Device
or upon request at a venue must clearly state that the operator reserves the right to reject
or limit a wager for the purposes of limiting liability.

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2.6.2 Adjustments to Fixed Prize Payouts. The wagering rules and information available to the
player through the Wagering Device or upon request at a venue must disclose that the
odds/payouts may be adjusted under situations such as:

a)

Atypical winning outcomes (e.g., dead heats);

b)

Cancelled legs of wagers with multiple events (e.g., parlays); and

c)

Prorating.

2.7

Pari-Mutuel Wagers

2.7.1 Pari-Mutuel Wagers. The following requirements are applicable for types of wagers
where individual wagers are gathered into pools:

a)

The player must be able to view up-to-date odds/payouts information for simple wagering
pools. For complex wagering pools, it is accepted that there may be reasonable
limitations to the up-to-date accuracy of the pool estimates displayed to the player.

b)

The player must be able to view up-to-date values of total investments for all wagering
pools.

2.7.2 Dividends. The rules for dividend calculation including the prevailing formula for pool
allocations and the stipulations of the contest being wagered upon must be approved by the
regulatory body and disclosed to the player.

2.8

Additional Features

2.8.1 General Statement. The requirements within this section pertain to additional features
which may be offered by the Event Wagering System where allowed by the regulatory body.

NOTE: It is recommended that the Event Wagering System supports a secure option to enable or
disable each of these features to accommodate regulatory bodies that may either allow or
prohibit such features.

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2.8.2 Player Resources. An Event Wagering System may contain a resource, such as a data
stream that may be used to externally facilitate wager selection for peer-to-peer wagering,
provided that the rules are made available to the player:

a)

Clearly describe to all players that the resource is available and the advantage it offers;

b)

Disclose the method for obtaining the resource; and

c)

Provide players with sufficient information to make an informed decision, prior to
participation, as to whether or not to participate with player(s) who may possess such a
resource.

2.8.3 Player Advice Features. An Event Wagering System may support a feature that offers
advice, hints, or suggestions to a player provided that it conforms to the following requirements:

a)

The player advice feature shall clearly describe to the player that it is available and the
options that exist for selection;

b)

Any player advice that is offered to the player for purchase shall clearly disclose the cost
and benefit;

c)

The player advice feature shall allow the player the option of accepting the advice, and
must not force the player to accept the assistance; and

d)

The availability and content of player advice shall remain consistent for all players.

2.8.4 Automatic Acceptance of Changes in Wagers. An Event Wagering System may support
a feature that allows a player while placing a wager to auto-accept changes in odds/payouts or
price of the wager provided that it conforms to the following requirements:

a)

Any auto-accept options available (e.g., auto-accepting all wagers with higher price,
auto-accepting all wagers with lower price, etc) must be explained to the player;

b)

The player must opt in to use this functionality (i.e., it should not be set by default); and

c)

The player must be able to opt out at any time.

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2.8.5 Contests/Tournaments. A contest/tournament, in which permits a player to either
purchase or be awarded the opportunity to engage in competitive wagering against other players,
may be permitted providing the following rules are met:

a)

Rules shall be made available to a player for review prior to registering for the
contest/tournament. The rules must include at a minimum:
i.

All conditions registered players must meet to qualify for entry into, and
advancement through, the contest/tournament;

ii.

Specific information pertaining to any single contest/tournament, including the
available prizes or awards;

iii.

For a contest/tournament with multiple awards, the distribution of funds based on
specific outcomes; and

iv.

The name of the organization (or persons) that conducted the contest/tournament
on behalf of, or in conjunction with, the operator if applicable.

b)

The results of each contest/tournament shall be made available for the registered players
to review. Subsequent to being posted publically, the results of each contest/tournament
shall be made available upon request. The results include the following:
i.

Name of the contest/tournament;

ii.

Date(s)/times(s) of the contest/tournament;

iii.

Total number of entries;

iv.

Amount of entry fees;

v.

Total prize pool; and

vi.

Amount paid for each winning category.

NOTE: For free contests/tournaments (i.e., registered player does not pay an entry fee), the
information required by the above must be recorded except for the number of entries, amount of
entry fees and total prize pool.

2.8.6 Free Play Mode. An Event Wagering System may support free play mode, which allows
a player to participate in wagering without paying. Free play mode shall not mislead the player
about the odds/payouts available in the paid version.

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Virtual Event Wagering

2.9.1 General Statement. Virtual event wagering allows for the placement of wagers on
simulations of sporting events, contests, and races whose results are based solely on the output of
an approved Random Number Generator (RNG) as allowed by the regulatory body. The
following requirements are only applicable to cases where virtual event wagering is conducted in
total by the Event Wagering System where a wager is placed at a Wagering Device or through
interaction with an attendant and then the virtual event is displayed via a public or common
display. For virtual events conducted by a gaming device (e.g., player makes a wager and the
event plays out before them on their machine or a shared display on a multi-player machine),
please refer to GLI-11 Gaming Devices as applicable.

2.9.2 Randomization and Virtual Events. A cryptographic RNG must be utilized to determine
virtual event outcomes and shall comply with applicable requirements set out for RNGs. In the
absence of specific jurisdictional standards, the “Random Number Generator (RNG)
Requirements” chapter of GLI-11 Gaming Devices should be used as applicable. Additionally,
the evaluation of virtual event outcomes using an RNG shall comply with the following rules:

a)

Where more than one RNG is used to determine different virtual event outcomes, each
RNG shall be separately evaluated; and

b)

Where each instance of an RNG is identical, but involves a different implementation
within the virtual event, each implementation shall be separately evaluated.

2.9.3 Virtual Event Selection Process. Determination of events of chance that result in a
monetary award shall not be influenced, affected, or controlled by anything other than the values
selected by an approved RNG within the Event Wagering System, in accordance with the
following requirements:

a)

It shall not be possible to ascertain the outcome of the virtual event prior to its
commencement;

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When making calls to the RNG, the virtual event shall not limit the outcomes available
for selection, except as provided for by design;

c)

The virtual event shall not modify or discard outcomes selected by the RNG due to
adaptive behavior. Additionally, outcomes shall be used as directed by the rules of the
virtual event;

d)

Subsequent to the commencement of a virtual event, no subsequent actions or decisions
shall be made that change the behavior of any of the elements of chance within the virtual
event, other than player decisions;

e)

Except as provided for by the rules of the virtual event, events of chance shall be
independent and shall not correlate with any other events within the same virtual event,
or events within previous virtual events;

f)

Any associated equipment used in conjunction with an Event Wagering System shall not
influence or modify the behaviors of the Event Wagering System’s RNG and/or random
selection process, except as authorized, or intended by design;

g)

Virtual event outcomes shall not be affected by the effective bandwidth, link utilization,
bit error rate or other characteristic of the communications channel between the Event
Wagering System and the Wagering Device; and

h)

Wagering Devices shall not contain any logic utilized to generate the result of any virtual
event. All critical functions including the generation of any virtual event shall be
generated by the Event Wagering System and be independent of the Wagering Device.

2.9.4 Virtual Event Display. Displays for a virtual event shall conform to applicable display
requirements of this standard. In addition, the following display requirements apply:

a)

Statistical data that is made available to the player pertaining to the virtual event shall not
misrepresent the capabilities of any virtual participant. This does not prevent the use of
an element of chance or randomness from impacting performance of the virtual
participant during the virtual event;

b)

For scheduled virtual events, a countdown of the time remaining to place a wager in that
event shall be displayed to the player. It shall not be possible to place wagers on the event

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once this time has passed, however, this requirement does not prohibit the
implementation of in-play wagers; and
c)

The final outcome of each virtual event shall be displayed for a sufficient length of time
that permits a player a reasonable opportunity to verify the virtual event’s outcome.

2.9.5 Simulation of Physical Objects. Where a virtual event incorporates a graphical
representation or simulation of a physical object that is used to determine virtual event outcome,
the behaviors portrayed by the simulation must be consistent, unless otherwise denoted by the
virtual event rules. This requirement shall not apply to graphical representations or simulations
that are utilized for entertainment purposes only. The following shall apply to the simulation:

a)

The probability of any event occurring in the simulation that affects the outcome of the
virtual event shall be analogous to the properties of the physical object;

b)

Where the virtual event simulates multiple physical objects that would normally be
expected to be independent of one another based on the rules of the virtual event, each
simulation must be independent of any other simulations; and

c)

Where the virtual event simulates physical objects that have no memory of previous
events, the behavior of the simulated objects must be independent of their previous
behavior, so as to be non-adaptive and non-predictable, unless otherwise disclosed to the
player.

2.9.6 Physics Engine. Virtual events may utilize a “physics engine” which is specialized
software that approximates or simulates a physical environment, including behaviors such as
motion, gravity, speed, acceleration, inertia, trajectory, etc. A physics engine shall be designed to
maintain consistent play behaviors and virtual event environment, unless an indication is
otherwise provided to the player by the virtual event rules. A physics engine may utilize the
random properties of an RNG to impact virtual event outcome.

NOTE: Implementations of a physics engine in a virtual event will be evaluated on a case-bycase basis by the independent test laboratory.

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2.10 External Wagering Systems
2.10.1 General Statement. This section contains requirements for wagers placed through the
Event Wagering System that are forwarded to an external wagering system which controls the
wagering, processes results and determines winning wagers. An example might be the Event
Wagering System interfacing to a totalisator system. The requirements of this section apply
towards the interoperability of the Event Wagering System with the external wagering system
and not a complete evaluation of the external wagering system itself.

NOTE: The external wagering system may independently be subject to evaluation by the
independent test laboratory per regulatory body discretion.

2.10.2 Information. The following requirements apply to information being conveyed to the
Event Wagering System by an external wagering system:

a)

If the external wagering system provides pari-mutuel wagering facilities for the Event
Wagering System, the Event Wagering System must be able to periodically receive the
current dividends estimates for active pools from the external wagering system.

b)

If the external wagering system provides fixed price wagering facilities for the Event
Wagering System where the odds/payouts can be dynamically changed, the Event
Wagering System must be able to receive the current odds from the external wagering
system whenever any odds are changed.

c)

The Event Wagering System must be able to receive change of event status information
from the external wagering system whenever any change occurs, including:
i.

Withdrawn/reinstated selections;

ii.

Altered event starting time;

iii.

Individual markets opened/closed;

iv.

Results entered/modified;

v.

Results confirmed; and

vi.

Event cancelled.

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2.10.3 Wagers. If wager placement or pricing information is interfaced through an external
wagering system, the following requirements apply:

a)

Wagers placed on the Event Wagering System must receive clear acknowledgment of
acceptance, partial acceptance (including details), or rejection by the external wagering
system.

b)

If the cost of the wager is determined by the external wagering system, there must be a
positive confirmation sequence in place to enable the player to accept the wager cost and
the Event Wagering System to determine that there are enough funds in the player’s
balance to meet the wager cost prior to making an offer to an external wagering system.

c)

Where wagers may be placed in bulk, the following requirements apply:
i.

If the stream of wagers is interrupted for any reason, there must be a means
available to determine where in the stream that the interruption occurred.

ii.

No wager in the stream may be greater than the current remaining balance of the
account. If such a bet is attempted, the entire stream is to be halted.

d)

The player’s balance shall be debited an amount equaling the offer and cost to the
external wagering system. The funds shall remain as a pending transaction with details of
the offer to the external wagering system logged. On receipt of acknowledgment from the
external wagering system, the appropriate adjustments shall be made to the "pending"
account and the player’s balance.

e)

Cancellation requests from the Event Wagering System must receive clear
acknowledgment of acceptance or rejection by the external wagering system. The player
is not to be credited by the Event Wagering System until final confirmation is received
from the external wagering system including the amount of the cancelled wager.

2.10.4 Results. When results are entered and confirmed on the external wagering system, each
winning wager must be transferred to the Event Wagering System with the amount of the win.
Confirmation of receipt of the winning wagers must be acknowledged by the Event Wagering
System.

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CHAPTER 3: WAGERING DEVICE REQUIREMENTS
3.1

Introduction

3.1.1 Introduction. A wager may be placed using one of the following types of Wagering
Devices as allowed by the regulatory body. Any other types of Wagering Devices will be
reviewed on a case-by-case basis, as allowed by the regulatory body.

a)

Point-of-Sale Wagering Device: A player may place a wager from a venue-controlled
Point-of-Sale Wagering Device by using funds from their player account or by providing
payment for the wager(s) directly to the attendant.

b)

Self-Service Wagering Device: A player may place a wager on the venue-controlled SelfService Wagering Device by using funds from their player account or through the use of
peripheral devices as authorized by the regulatory body. In addition to the requirements
of this chapter, the “Self-Service Wagering Devices” chapter of this document shall also
be met for all proprietary components.

c)

Remote Wagering Device: A player may only place a wager on their Remote Wagering
Device by using funds from their player account. In addition to the requirements of this
chapter, the “Remote Wagering Devices” chapter of this document shall also be met.

NOTE: Unless otherwise specified the requirements within this chapter refer to all types of
Wagering Devices. The term “venue-controlled Wagering Devices” refers to Self-Service
Wagering Devices and Point-of-Sale Wagering Devices.

3.2

Program Requirements

3.2.1 Program Identification. All Wagering Device programs shall contain sufficient
information to identify the software and revision level of the information stored on the Wagering
Device.

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NOTE: The process used in the identification of the software and revision level will be evaluated
on a case-by-case basis.

3.2.2 Program Validation. The Event Wagering System shall have the ability to authenticate
that all critical components being utilized on the Wagering Device are valid upon installation of
the software, each time the software is loaded for use, and on demand as required by the
regulatory body. Critical components may include, but are not limited to, wagering rules and
information, elements that control the communications with the Event Wagering System, or
other components that are needed to ensure proper operation of the Wagering Device. In the
event of a failed authentication (i.e., program mismatch or authentication failure), the Wagering
Device shall cease all wagering operations and display an appropriate error message.

NOTE: Program verification mechanisms will be evaluated on a case-by-case basis and
approved by the regulatory body and the independent test laboratory based on industry-standard
security practices.

3.2.3 Independent Software Verification. The Wagering Device shall have the ability to allow
for an independent integrity check of the device’s software from an outside source. This
verification is required for all programs that affect integrity. The verification shall be
accomplished by being authenticated by a third-party application run from the device, by
allowing a third-party device to authenticate the media, or by allowing for removal of the media
such that it can be verified external to the Wagering Device. The independent test laboratory,
prior to device approval, shall evaluate the integrity check method.

3.3

Wagering Device Operations and Security

3.3.1 Touch Screen Displays. Touch screen displays, if in use, shall be accurate, and if
required by their design, shall support a calibration method to maintain that accuracy;
alternatively, the display hardware may support automatic self-calibration.

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3.3.2 User Interface Requirements. The user interface is defined as an application or program
through which the user views and/or interacts with the Wagering Device software to
communicate their actions to the Event Wagering System. The user interface shall meet the
following:

a)

The functions of all buttons, touch or click points shall be clearly indicated within the
area of the button, or touch/click point and/or within the help menu. There shall be no
functionality available through any buttons or touch/click points on the user interface that
are undocumented.

b)

Any resizing or overlay of the user interface must be mapped accurately to reflect the
revised display and touch/click points.

c)

The display of the instructions and information shall be adapted to the user interface. For
example, where a Wagering Device uses technologies with a smaller display screen, it is
permissible to present an abridged version of the wagering rules and information
accessible directly from within the wagering screen and make available the full/complete
version of the wagering rules and information via another method, such as a secondary
screen, help menu, or other interface that is easily identified on the visual wagering
screen.

3.3.3 Simultaneous Inputs. The Wagering Device shall not be adversely affected by the
simultaneous or sequential activation of the various inputs and outputs which might, whether
intentionally or not, cause malfunctions or invalid results.

3.3.4 Communications. A Wagering Device must be designed or programmed such that it may
only communicate with authorized Event Wagering Systems components.

a)

The Event Wagering System must have the capability to uniquely identify and authorize
each Wagering Device used to place wagers or handle financial transactions.

b)

If communication between the Event Wagering System and the Wagering Device is lost,
the Wagering Device shall cease wagering operations and display an appropriate error
message.

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3.3.5 Access Controls. Access to the venue-controlled Wagering Device software by an
attendant shall be controlled by a secure logon procedure or other secure process approved by the
regulatory body. It must not be possible to modify the configuration settings of the Wagering
Device without an authorized secure process.

a)

An attendant session is initiated by the attendant logging in to their controlled account
using their secure username and password or an alternative means for the attendant to
provide identification information as allowed by the regulatory body.

b)

All available options presented shall be tied to the account of the attendant logged in.
Only access available to the logged in account shall be available through the Wagering
Device.

c)

If the Wagering Device does not receive input from the attendant within 5 minutes, or a
period of time specified by the regulatory body, the attendant session shall time out.
i.

The attendant may establish a new session by re-establishing their login with the
Wagering Device. This process shall include, at a minimum, the manual entry of
the attendant’s secure password or other accepted methods.

ii.

No further attendant functionality is permitted until a new session is established.

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CHAPTER 4: SELF-SERVICE WAGERING DEVICES
4.1

Introduction

4.1.1 Introduction. This chapter applies to wagers and financial transactions conducted using
Self-Service Wagering Devices. All proprietary devices developed for Self-Service Wagering
Devices must meet the applicable requirements within this chapter. This chapter does not apply
to devices that solely utilize unaltered off-the-shelf products, such as PCs or tablets.

4.2

Player Safety

4.2.1 Physical Hazards and Environmental and Electrical Safety Testing. Electrical and
mechanical parts and design principles of the Self-Service Wagering Device shall not subject a
player to any physical hazards. The independent test laboratory does not make any findings with
regard to Electro-Magnetic Compatibility (EMC) or Radio Frequency Interference (RFI), as that
is the responsibility of the manufacturer of the device, or those that purchase the device. Such
EMC and RFI testing may be required under separate statute, regulation, law, or act and should
be researched accordingly by those parties who manufacture or purchase said device. The
independent test laboratory does not test for, is not liable for, nor makes any findings related to
these matters. However, during the course of testing, the independent test laboratory may inspect
for marks or symbols indicating that a Self-Service Wagering Device has undergone product
safety or other compliance testing by some other party but that is outside the scope of the
requirements defined by this technical standard.

4.3

Environmental Effects on Integrity

4.3.1 Self-Service Wagering Device Integrity. The independent test laboratory shall perform
certain tests to determine whether or not an Electro-Static Discharge (ESD) impacts the integrity
of a Self-Service Wagering Device. ESD testing is intended to simulate techniques observed in

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the field that may be used in an attempt to disrupt the integrity of a Self-Service Wagering
Device.

4.3.2 ESD Effects. Protection against ESD requires that the Self-Service Wagering Device’s
conductive cabinet be earthed in such a way that static discharge energy shall not permanently
damage or permanently impact the normal operation of the electronics or other components
within the Self-Service Wagering Device. A Self-Service Wagering Device may exhibit
temporary disruption when subjected to a significant external ESD with a severity level of 27kV
air discharge. The Self-Service Wagering Device shall exhibit a capacity to recover and complete
any interrupted operation without loss or corruption of any control information or critical data
following any temporary disruption.

4.4

Self-Service Wagering Device Identification

4.4.1 Identification Badge. A Self-Service Wagering Device shall have an identification badge
affixed to the exterior of the device by the manufacturer. The identification badge shall not be
removable without leaving evidence of tampering. This badge shall include the following
minimum information:

a)

The complete name of the manufacturer or some appropriate abbreviation for same;

b)

A unique serial number;

c)

The Self-Service Wagering Device model number; and

d)

The date of manufacture.

4.5

Basic Hardware Requirements

4.5.1 Printed Circuit Board (PCB) Identification Requirements. Identification for any PCB
that impacts the integrity of the Self-Service Wagering Device shall include the following:

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Each PCB shall be clearly identifiable by an alphanumeric identification and, when
applicable, a revision number. It is recommended that this identification be readily
viewable without removal of the PCB from the Self-Service Wagering Device; and

b)

If track cuts, patch wires, or other circuit alterations are introduced to the PCB, then a
new revision number shall be assigned.

4.5.2 Switches and Jumpers. If the Self-Service Wagering Device contains switches and/or
jumpers, they shall be fully documented for evaluation by the independent test laboratory.

4.5.3 Device Wiring. The Self-Service Wagering Device shall be designed so that power and
data cables into and out of the Self-Service Wagering Device can be routed so that they are not
accessible to the general public.

NOTE: The independent test laboratory will make no determination as to whether the SelfService Wagering Device installation conforms to local electrical codes, or to any other
electrical testing standards, and practices.

4.5.4 Wired Communication Ports. Wired communication ports shall be clearly labeled and
must be securely housed within the Self-Service Wagering Device to prevent unauthorized
access to the ports or their associated cable connectors.

4.6

Electrical Power

4.6.1 Power Surges. The Self-Service Wagering Device shall not be adversely affected, other
than resets, by surges or dips of ± 20% of the supply voltage. It is acceptable for the Self-Service
Wagering Device to reset provided no damage to the equipment or loss or corruption of data is
experienced.

4.6.2 Circuit Protection. The power supply used in a Self-Service Wagering Device must be
appropriately fused or protected by circuit breakers. The amperage rating of all fuses and circuit
breakers must be clearly stated on or near the fuse or the breaker.

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4.6.3 On/Off Switch. An on/off switch that controls the electrical current supplied to the SelfService Wagering Device shall be located in a place which is readily accessible within the
interior of the Self-Service Wagering Device. The on/off positions of the switch shall be clearly
labeled.

4.7

Doors and Security

4.7.1 Physical Security. A Self-Service Wagering Device shall be robust enough to resist
forced entry into any secured doors, areas, or compartments. In the event that extreme force is
applied to the cabinet materials causing a potential breach in Self-Service Wagering Device
security, evidence of tampering must be conspicuous. “Secured areas” or “secured
compartments” shall include the external doors such as the main door, cash compartment doors
such as a drop box door, peripheral device access area(s), and/or other sensitive access areas of
the Self-Service Wagering Device.

4.7.2 External Doors. The following requirements apply to the Self-Service Wagering
Device’s external doors:

a)

External doors shall be manufactured of materials that are suitable for allowing only
legitimate access to the inside of the Self-Service Wagering Device cabinet. Doors and
their associated hinges shall be capable of withstanding determined and unauthorized
efforts to gain access to the interior of the Self-Service Wagering Device and shall leave
conspicuous evidence of tampering if such an attempt is made;

b)

The seal between the Self-Service Wagering Device cabinet and the door of a locked area
shall be designed to resist the entry of objects. It shall not be possible to insert an object
into the Self-Service Wagering Device that disables a door open sensor when the SelfService Wagering Device’s door is fully closed, without leaving conspicuous evidence of
tampering; and

c)

All external doors shall be secure and support the installation of locks.

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4.7.3 Door Monitoring. All doors that provide access to secure areas of the Self-Service
Wagering Device shall be monitored by a door access detection system.

a)

The detection system shall register a door as being open when the door is moved from its
fully closed and locked position, provided power is supplied to the Self-Service
Wagering Device.

b)

When any door that provides access to a secured area or secured compartment registers as
open, the Self-Service Wagering Device shall cease all wagering operations, and display
an appropriate error message

4.8

Critical Non-Volatile (NV) Memory

4.8.1 Contents of Critical NV Memory. Critical Non-Volatile (NV) memory shall be used to
store all data elements that are considered vital to the continued operation of the Self-Service
Wagering Device, including, but are not limited to Self-Service Wagering Device configuration
data and state of operations. Critical NV memory shall not store sensitive information outside of
Self-Service Wagering Device operations.

NOTE: Critical NV memory may be maintained by any component(s) of the Event Wagering
System.

4.8.2 Critical NV Memory Backup. The Self-Service Wagering Device must have a backup or
archive capability, which allows the recovery of critical NV memory should a failure occur.

4.8.3 Critical NV Memory Errors. Critical NV memory storage shall be maintained by a
methodology that enables errors to be identified. This methodology may involve signatures,
checksums, redundant copies, database error checks, and/or other method(s) approved by the
regulatory body.

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4.8.4 Critical NV Memory Checks. Comprehensive checks of critical NV memory data
elements shall be made on startup. NV memory that is not critical to Self-Service Wagering
Device integrity is not required to be checked.

4.8.5 Unrecoverable Corruption of Critical NV Memory. An unrecoverable corruption of
critical NV memory shall result in an error. Upon detection, the Self-Service Wagering Device
software shall cease to function. Additionally, the critical NV memory error shall cause any
communication external to the Self-Service Wagering Device to cease.

NOTE: This section is not intended to preclude the use of alternate storage media types, such as
hard disk drives, for the retention of critical data. Such alternate storage media is still expected
to maintain critical data integrity in a manner consistent with the requirements in this section, as
applicable to the specific storage technology implemented.

4.9

Peripheral Devices

4.9.1 General Statement. A peripheral is defined as an internal or external device connected to
a Self-Service Wagering Device that supports credit acceptance, credit issuance, player
identification, wager record issuance/redemption, or other specialized function(s). The following
requirements apply for Self-Service Wagering Device peripherals as supported:

a)

Bill validators must meet the applicable jurisdictional requirements for bill validators. In
the absence of specific jurisdictional standards the requirements established within the
“Bill Validators and Stackers” section of GLI-11 Gaming Devices should be used as
applicable.

b)

Coin acceptors must meet the applicable jurisdictional requirements for coin acceptors. In
the absence of specific jurisdictional standards the requirements established within the
“Coin Acceptors, Diverters, and Drop Boxes” section of GLI-11 Gaming Devices should
be used as applicable.

c)

Player identification components, including card readers, must meet the applicable
jurisdictional requirements for these components. In the absence of specific jurisdictional

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standards the requirements established within the “Integrated Player Identification
Components” section of GLI-11 Gaming Devices and “Card Reader Requirements” of
GLI-16 Cashless Systems should be used as applicable.
d)

Hoppers and/or printers must meet the applicable jurisdictional requirements for these
devices. In the absence of specific jurisdictional standards the requirements established
within the “Machine Payment and Payment Devices” section of GLI-11 Gaming Devices
and the “Voucher Validation System Requirements” of GLI-13 On-Line Monitoring and
Control Systems (MCS) and Validation Systems should be used as applicable.

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CHAPTER 5: REMOTE WAGERING DEVICES
5.1

Introduction

5.1.1 Introduction. This chapter applies to wagers and financial transactions conducted using
Remote Wagering Devices. The player may obtain/download an application or software package
containing the Client Software, or access the Client Software via a browser interface. Depending
on the implementation(s) authorized by the regulatory body, Remote Wagering Devices may be
used on an in-venue wireless network or an over the internet environment.

5.2

Client Software

5.2.1 Client Software Functionality. The Client Software is any software downloaded to or
installed on a Remote Wagering Device which is used to take part in wagers and financial
transactions with the Event Wagering System and shall meet the following requirements:

a)

Players shall not be able to use the Client Software to transfer data to one another, other
than chat functions (e.g., text, voice, video, etc.) and approved files (e.g., user profile
pictures, photos, etc.);

b)

The Client Software must not automatically alter any device-specified firewall rules to
open ports that are blocked by either a hardware or software firewall;

c)

The Client Software must not access any ports (either automatically or by prompting the
user to manually access) which are not necessary for the communication between the
Remote Wagering Device and the server;

d)

If the Client Software includes additional non-wagering related functionality, this
additional functionality shall not alter the software’s integrity in any way;

e)

The Client Software shall not possess the ability to override the volume settings of the
Remote Wagering Device; and

f)

It is recommended that auto complete, password caching, or other methods that will fill in
the password field are disabled by default for Client Software.

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5.2.3 Compatibility Verification. During any installation or initialization and prior to
commencing wagering operations, the Client Software used in conjunction with the Event
Wagering System must detect any incompatibilities or resource limitations with the Remote
Wagering Device that would prevent proper operation of the software. If any incompatibilities or
resource limitations are detected the Event Wagering System shall:

a)

Provide notification of any incompatibility and/or resource limitation preventing
operation (e.g., software version, minimum specifications not met, browser type, browser
version, plug-in version, etc.); and

b)

Prevent wagering operations while the incompatibility or resource limitation exists.

5.2.4 Content. Client Software shall not contain any functionality deemed to be malicious in
nature by the regulatory body. This includes, but is not limited to, unauthorized file
extraction/transfers, unauthorized device modifications, unauthorized access to any locally stored
personal information (e.g., contacts, calendar, etc.) and malware.

5.2.5 Cookies. Where cookies are used, the operator shall take reasonable measures to ensure
that such cookies do not contain malicious code, and players must be informed of the cookie use
upon installation or during registration. When cookies are required for wagering, wagering
cannot occur if the Remote Wagering Device does not accept them.

5.2.6 Player Inactivity. After 30 minutes of inactivity or a period of time determined by the
regulatory body, the Event Wagering System shall require a player to re-authenticate in order to
access their player account.
a)

No further wagering or financial transactions are permitted on the Remote Wagering
Device until the player has been re-authenticated.

b)

The Client Software may allow a simpler means for a player to re-authenticate, such as
operating system level authentication (e.g., biometrics) or a Personal Identification
Number (PIN). Each means for re-authentication will be evaluated on a case-by-case

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basis by the independent test laboratory.
i.

This functionality may be disabled based on preference of the player and/or
regulatory body.

ii.

Once every 30 days, or a period specified by the regulatory body, the player will
be required to provide full authentication.

5.3
5.3.1

Remote Wagering Device Integrity

Remote Wagering Device Integrity. To ensure the integrity of the Remote Wagering

Device, the Event Wagering System shall use software to detect the use of remote desktop
software, rootkits, virtualization, and/or any other programs identified as having the ability to
circumvent location detection. This software shall follow best practice security measures to:

a)

Detect and block location data fraud (e.g., fake location apps, virtual machines, remote
desktop programs, etc.);

b)

Examine the IP address to ensure a known Virtual Private Network (VPN) or proxy
service is not in use;

c)

Detect and block devices which indicate system-level tampering (e.g., rooting,
jailbreaking, etc.);

d)

Utilize detection and blocking mechanisms verifiable to an application level;

e)

Stop "man in the middle" attacks or similar hacking techniques and prevent code
manipulation; and

f)

Monitor and prevent wagers placed by a player account from geographically inconsistent
locations (e.g., wager placement locations were identified that would be impossible to
travel between in the time reported).

5.4

Location Detection for Wagering on a Wireless Local Area
Network

5.4.1 Location Tracking Component. The Event Wagering System shall incorporate a location
tracking component that can track the locations of all Remote Wagering Devices connected to

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the Wireless Local Area Network (WLAN) in real-time. The system shall detect when any
devices have been transported out of the permitted area and prevent further wagers from being
placed. This can be accomplished with the use of specific IT hardware such as directional
antennas, Bluetooth sensors or other methods to be evaluated on a case-by-case basis by the
independent test laboratory.

5.5

Location Detection for Wagering Over the Internet

5.5.1 Location Detection. The Event Wagering System must utilize a location service or
application to reasonably detect and dynamically monitor the location of a player attempting to
place a wager; and to monitor and enable the blocking of unauthorized attempts to place a wager.

a)

Each player must pass a location check prior to completing the first wager.

b)

Subsequent location checks must occur prior to completing wagers after a period of 30
minutes, or as otherwise specified by the regulatory body, since the previous location
check.

c)

If the location check indicates the player is outside the permitted boundary, the wager
shall be rejected and the player shall be notified of this.

5.5.2 Location Data Accuracy. To ensure location data is accurate and reliable, a geolocation
method shall be used to provide a player’s physical location and an associated confidence radius.
The confidence radius shall be entirely located within the permitted boundary. In addition, the
geolocation method shall:

a)

Utilize accurate location data sources (Wi-Fi, GSM, GPS, etc.) to confirm the player’s
location. If a Remote Wagering Device’s only available location data source is an IP
Address, the location data of a mobile device registered to the player account may be
used as a supporting location data source under the following conditions:
i.

The Remote Wagering Device (where the wager is being placed) and the mobile
device must be determined to be in close proximity to one another.

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ii.

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If allowed by the regulatory body, carrier based location data of a mobile device
may be used if no other location data sources other than IP Addresses are
available.

b)

Possess the ability to control whether the accuracy radius of the location data source is
permitted to overlap or exceed defined buffer zones or the permitted boundary; and

c)

Utilize boundary polygons based on audited maps approved by the regulatory body as
well as overlay location data onto these boundary polygons in order to mitigate and
account for discrepancies between mapping sources and variances in geospatial data.

5.5.3 Reporting and Analytics. Given that location fraud must be assessed on a single location
check, as well as cumulative player histories over time, the location service or application shall:

a)

Display a real-time data feed of all location checks;

b)

Display an up-to-date list of potential fraud risks;

c)

Offer an alert system to identify unauthorized or improper access; and

d)

Record in a time stamped log any time a location violation is detected, including all
associated location(s) and unique player ID(s).

5.5.4 Maintenance. To maintain the overall integrity of the location service or application, it
shall:

a)

Be reviewed regularly to assess and measure its continued ability to detect and mitigate
existing and emerging location fraud risks;

b)

Undergo frequent updates to maintain cutting-edge data collection, device compatibility,
and fraud prevention capabilities; and

c)

Utilize databases (IP, proxy, fraud, etc.) that are updated daily at minimum and are not
open-source.

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CHAPTER 6: PLAYER ACCOUNT REQUIREMENTS
6.1

Introduction

6.1.1 Introduction. The following chapter applies to player account management, including
player registration and player account controls.

6.2

Player Account Registration and Access

6.2.1 Player Account Registration. The operator must employ a method to collect (either
online or via a manual procedure approved by the regulatory body) player information prior to
the registration of a player account. The operator must conform to limits for financial
transactions as specified in the terms and conditions or as set by the regulatory body until
registration information is verified.

6.2.2 Age and Identity Verification. A full identity check must be undertaken before a player
is allowed to place a wager:

a)

Only players of the legal participation age for the jurisdiction may deposit funds or
participate in wagering. The operator must deny the ability to deposit funds or participate
in wagering to any person that submits a birth date that indicates they are under the legal
participation age.

b)

Player verification must authenticate the legal name, physical address, age and nationality
of the individual at a minimum as required by the regulatory body.

c)

Player verification must also confirm that the player is not on any exclusion lists held by
the operator or the regulatory body.

d)

Details of player verification must be kept in a secure manner.

e)

Third party service providers may be used to verify the age and/or identity of players as
allowed by the regulatory body.

f)

The operator must have a documented public policy for the handling of players

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discovered to be using an account in a fraudulent manner, including but not limited to:
i.

The maintenance of information about any player’s activity, such that if
fraudulent activity is detected, the regulatory body has all of the necessary
information to take appropriate action;

ii.

The suspension of any player account discovered to be providing access to
fraudulent players; and

iii.

The treatment of deposits, wagers, and wins associated with a fraudulent player’s
account.

6.2.3 Terms and Conditions. A set of terms and conditions must be readily accessible to the
player. During the registration process and when any terms and conditions are updated, the
player must agree to the terms and conditions.

a)

The terms and conditions must clearly define the rules by which any unrecoverable
malfunctions of hardware/software are addressed including if this process results in the
voiding of any wagers.

b)

The terms and conditions must describe procedures to deal with interruptions caused by
the discontinuity of data flow from the network server during an event.

c)

The terms and conditions must advise the player to keep their account credentials (e.g.,
password and username) secure; requirements regarding forced password changes,
password strength and other related items shall also be specified, as applicable.

d)

The terms and conditions must state that no underage individual is permitted to
participate in wagering.

e)

The terms and conditions must state that only players legally permitted by their
respective jurisdiction can participate in wagering.

f)

The terms and conditions must specify the conditions under which an account is declared
inactive and explain what actions will be undertaken on the account once this declaration
is made.

g)

The terms and conditions must clearly define what happens to the wagers placed if a
player has placed wagers prior to any self-imposed or operator-imposed exclusion,
including the return of all wagers to the players, or settling all wagers, as appropriate.

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6.2.4 Privacy. A privacy policy must be readily accessible to the player. During the registration
process and when the privacy policy is updated, the player must agree to the privacy policy.

a)

The privacy policy must state the information that is required to be collected, the purpose
for information collection, the period in which the information is stored, the conditions
under which information may be disclosed and an affirmation that controls are in place to
prevent the unauthorized or unnecessary disclosure of the information.

b)

Any information obtained in respect to player registration or account establishment must
be done in compliance with the privacy policy and local privacy regulations and
standards observed by the regulatory body.

c)

Any information about player accounts which is not subject to disclosure pursuant to the
privacy policy must be kept confidential, except where the release of that information is
required by law.

d)

All player information must be securely erased (i.e., not just deleted) from hard disks,
magnetic tapes, solid state memory and other storage devices before the device is
decommissioned. If erasure is not possible, the storage device must be destroyed.

6.2.5 Establishment of Player Account. Once age and identity verification are successfully
completed, the player is determined to not be on any exclusion lists, and the player has
acknowledged all of the necessary privacy policies and terms and conditions, then the player
account registration is complete and the player account can become active.

a)

A player must only be permitted to have one active player account at a time unless
specifically authorized by the regulatory body.

b)

A player accesses their player account through the use of a username (or similar) and a
password or a secure alternative means for the player to perform authentication to log in.
Authentication methods are subject to the discretion of the regulatory body as necessary.
The requirement does not prohibit the option for more than one method of authentication
being available for a player to access their account.

c)

Where a player has forgotten their username and/or password, a multi-factor

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authentication process must be employed for the retrieval of the username/resetting of the
password. Any and all processes for dealing with lost usernames or passwords must be
clearly disclosed to the player and sufficiently secure.
d)

The Event Wagering System must allow players to change their passwords, and remind
them on a regular basis.

e)

A multi-factor authentication process must be employed for changes to a player’s
registration information and/or account used for financial transactions.

f)

The Event Wagering System must support a mechanism that allows for an account to be
locked in the event that suspicious activity is detected (e.g., too many failed attempts for
login). A multi-factor authentication process must be employed for the account to be
unlocked.

6.3

Player Account Controls

6.3.1 Player Protection. Player protection information must be readily accessible to the player.
The player protection information must contain at a minimum:

a)

Information about potential risks associated with excessive participation, and where to
get help related to wagering responsibly;

b)

A list of the available player protection measures that can be invoked by the player, such
as self-imposed limits, and information on how to invoke those measures; and

c)

Mechanisms in place which detect unauthorized use of their account, such as reviewing
credit card statements against known deposits;

6.3.2 Self-Imposed Limits. Players must be provided with an easy and obvious method to
impose limitations for wagering parameters including, but not limited to, deposits, wagers and
losses, as required by the regulatory body. The self-imposed limitation method must provide the
following functionality:

a)

Upon receiving any self-imposed limitation order, the operator must ensure that all
specified limits are correctly implemented immediately or at the point in time (e.g., next

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login, next day) that was clearly indicated to the player;
b)

The self-imposed limitations set by a player must not override more restrictive operatorimposed limitations. The more restrictive limitations must take priority;

c)

Once established by a player and implemented by the Event Wagering System, it must
only be possible to reduce the severity of self-imposed limitations upon 24 hours notice,
or as required by the regulatory body; and

d)

Self-imposed limitations must not be compromised by internal status events, such as selfimposed exclusion orders and revocations.

6.3.3 Operator-Imposed Limits. The operator must be capable of applying limitations for
wagering parameters including, but not limited to, deposits, wagers and losses, as required by the
regulatory body. The operator-imposed limitation method must provide the following
functionality:

a)

Players must be notified in advance of any operator-imposed limits and their effective
dates. Once updated, operator-imposed limits must be consistent with what is disclosed to
the player;

b)

Upon receiving any operator-imposed limitation order, the operator must ensure that all
specified limits are correctly implemented immediately or at the point in time (e.g., next
login, next day) that was clearly indicated to the player; and

c)

Operator-imposed limitations must not be compromised by internal status events, such as
self-imposed exclusion orders and revocations.

6.3.4 Self-Imposed Exclusion. Players must be provided with an easy and obvious method to
self-exclude from wagering for a specified period of time as defined in the terms and conditions,
or indefinitely, as required by the regulatory body. The self-imposed exclusion method must
provide the following functionality:

a)

In the case of temporary self-imposed exclusion, the operator must ensure that the player
is not prevented from withdrawing any or all of their account balance, provided that the
operator acknowledges that the funds have cleared;

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In the case of indefinite self-imposed exclusion, the operator must ensure that the player
is paid in full for their account balance, provided that the operator acknowledges that the
funds have cleared;

c)

Immediately upon receiving the self-imposed exclusion order, no new wagers or deposits
are accepted from that player, until such time as the self-imposed exclusion has been
removed; and

d)

It is recommended that players be provided with a mechanism to request cancellation of
the self-imposed exclusion order.

6.3.5 Operator-Imposed Exclusion. The operator must be capable of excluding a player from
wagering according to the terms and conditions agreed to by the player upon registration, as
required by the regulatory body. The operator-imposed exclusion method must provide the
following functionality:

a)

Players must be provided a notification containing operator-imposed exclusion status and
general instructions for resolution;

b)

Immediately upon receiving the operator-imposed exclusion order, no new wagers or
deposits are accepted from that player, until such time as the operator-imposed exclusion
has been revoked; and

c)

During the operator-imposed exclusion period, the player must not be prevented from
withdrawing any or all of their account balance, provided that the operator acknowledges
that the funds have cleared, and that the reason(s) for exclusion would not prohibit a
withdraw.

6.3.6 Disputes. The operator must provide an easy and obvious method for a player to make a
complaint, and to enable the player to notify the regulatory body if such complaint has not been
or cannot be addressed by the operator, or under other circumstances as specified by the law of
the regulatory body.

a)

Contact information for complaints and dispute resolution must be readily accessible to
the player.

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b)

Players must be able to log complaints and disputes on a 24/7 basis.

c)

Records of all correspondence relating to a complaint and dispute shall be maintained for
a period of five years or as otherwise specified by the regulatory body.

d)

It is recommended that a privately documented process exist between the operator and
the regulatory body on the dispute reporting and resolution process.

6.3.7 Inactive Accounts. A player account is considered to be inactive under the conditions as
specified in the terms and conditions for the Event Wagering System.

a)

Operators must employ a method to protect inactive player accounts that contain funds
from unauthorized access, changes or removal.

b)

It is recommended that a privately documented process be put in place to deal with
unclaimed funds from inactive accounts.

6.3.8 Player Funds Maintenance. The following requirements apply to the maintenance of
funds associated with a player account:

a)

All financial transactions must be conducted in accordance with local commerce
regulations and standards observed by the regulatory body.

b)

A deposit into a player’s account made via a credit card transaction or other methods
which can produce a sufficient audit trail must not be available for wagering until such
time as the funds are received from the issuer or the issuer provides an authorization
number indicating that the funds are authorized. The authorization number is to be
maintained in an audit log.

c)

Positive player identification, including any PIN entry or other approved secure methods,
must be completed before the withdrawal of any funds held by the operator can be made.

d)

A player’s request for withdrawal of funds (i.e., deposited and cleared funds and wagers
won) must be completed by the operator within a reasonable amount of time, unless there
is a pending unresolved player dispute or investigation. Such investigation must be
documented by the operator and available for review by the regulatory body.

e)

Payments from an account are to be paid (including funds transfer) directly to an account

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with a financial institution in the name of the player or made payable to the player and
forwarded to the player’s address or through another method that is not prohibited by the
regulatory body. The name and address are to be the name as held in player registration
details.
f)

An operator must have in place security or authorization procedures to ensure that only
authorized adjustments can be made to player accounts, and these changes are auditable.

g)

It shall not be possible to transfer funds between two player accounts.

6.3.9 Transaction Log or Account Statement. The operator must be able to provide a
transaction log or account statement history to players upon request. The information provided
must include sufficient information to allow the player to reconcile the statement or log against
their own financial records. Information to be provided must include at a minimum, details on
the following types of transactions:

a)

Financial Transactions (time stamped):
i.

Deposits to the player account;

ii.

Withdrawals from the player account;

iii.

Promotional or bonus credits added to/removed from the player account (outside
of credits won in wagering);

iv.
b)

Manual adjustments or modifications to the player account (e.g., due to refunds)

Wagering Transactions:
i.

The date and time the wager was placed;

ii.

The date and time the event started and ended or is expected to occur for future
events (if known);

iii.

The date and time the results were confirmed (blank until confirmed);

iv.

Any player choices involved in the wager, including wager selection, type of
wager and attributes, and any special condition(s) applying to the wager;

v.

The results of the wager (blank until confirmed);

vi.

Total amount wagered, including any promotional/bonus credits (if applicable);

vii.

Total amount won, including any promotional/bonus credits (if applicable);

viii.

Commission or fees collected (if applicable); and

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ix.

The date and time the winning wager was paid to the player.

6.4

Player Loyalty Programs

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6.4.1 General Statement. Player loyalty programs are any programs that provide incentives for
players based on the volume of play or revenue received from a player.

6.4.2 Player Loyalty Programs. If player loyalty programs are supported by the Event
Wagering System, the following principles must apply:

a)

Use of player loyalty data must not breach the privacy policy;

b)

All awards must be equally available to all players who achieve the defined level of
qualification for player loyalty points;

c)

Redemption of player loyalty points earned must be a secure transaction that
automatically debits the points balance for the value of the prize redeemed;

d)

All player loyalty database transactions are to be recorded by the Event Wagering
System; and

e)

If the player loyalty program is provided by an third party service provider the Event
Wagering System must be capable of securely communicating with that service.

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CHAPTER 7: SYSTEM AND OPERATOR REQUIREMENTS
7.1

Introduction

7.1.1 Introduction. The Event Wagering System’s server(s) may be located locally, within a
single venue or may be remotely located outside of the venue as allowed by the regulatory body.
If the Event Wagering System is comprised of multiple computer systems at various sites, the
Event Wagering System as a whole and all communication between its components must
conform to the applicable technical requirements within this document.

7.2

System Clock Requirements

7.2.1 System Clock. The Event Wagering System must maintain an internal clock that reflects
the current date and time that shall be used to provide for the following:

a)

Time stamping of all transactions and events;

b)

Time stamping of significant events; and

c)

Reference clock for reporting.

7.2.2 Time Synchronization. The Event Wagering System must be equipped with a mechanism
to ensure the time and dates between all components that comprise the Event Wagering System
are synchronized.

7.3

Control Program

7.3.1 Control Program Self-Verification. Operators must be capable of verifying that all
control program components contained on the Event Wagering System are authentic copies of
approved components of the Event Wagering System, upon installation, at least once every 24
hours, and on demand using a method approved by the regulatory body:

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The authentication mechanism must employ a hash algorithm which produces a message
digest of at least 128 bits.

b)

A system log or report must be retained and be accessible for a period of 90 days or as
otherwise specified by the regulatory body, which details the verification results for each
control component authentication.

c)

The control program authentication must include all control program components which
may affect regulated wagering operations. Control program components include, but are
not limited to, executables, libraries, wagering or system configurations, operating system
files, components that control required system reporting, and database elements that
affect system operations.

d)

Event Wagering Systems shall also provide a mechanism such that if any control
program component is determined to be invalid, a notification of the authentication
failure will be immediately communicated to the operator and regulatory body as
required.

e)

This mechanism must also require that an administrator of the Event Wagering System
confirm any failed authentication with the system within 72 hours or as otherwise
specified by the regulatory body. Failure to confirm a failed authentication must require
the Event Wagering System to automatically stop any wagering functions related to that
control program component.

7.3.2 Control Program Independent Verification. Each control program component of the
Event Wagering System must have a method to be verified via an independent third-party
verification procedure. The third-party verification process shall operate independently of any
process or security software within the Event Wagering System. The independent test laboratory,
prior to system approval, shall approve the integrity check method.

7.4

Shutdown and Recovery

7.4.1 Shutdown and Recovery. The following shutdown and recovery capabilities must be
available:

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The Event Wagering System must be able to perform a graceful shut down, and only
allow automatic restart on power up after the following procedures have been performed
as a minimum requirement:
i.

Program resumption routine(s), including self tests, complete successfully;

ii.

All critical control program components of the Event Wagering System have been
authenticated using an approved method (e.g., CRC, MD5, SHA-1); and

iii.

Communication with all components necessary for Event Wagering System
operation have been established and similarly authenticated.

b)

The operator must be able to identify and properly handle the situation where a master
reset has occurred on any component which affects regulated wagering operations.

c)

In the event of a catastrophic failure when the Event Wagering System cannot be
restarted in any other way, it shall be possible to restore the system from the last backup
point and fully recover. The contents of that backup must contain the following critical
information including, but not limited to:
i.

The recorded information specified under the section entitled “Information to be
Retained”;

ii.

Specific venue information such as configuration, security accounts, etc.;

iii.

Current system encryption keys; and

iv.

Any other system parameters, modifications, reconfiguration (including
participating venues), additions, merges, deletions, adjustments and parameter
changes.

d)

When two or more components are linked, the process of all wagering activities between
the two components must not be adversely affected by restart/recovery of either
component (e.g., wagering transactions are not to be lost or duplicated because of
recovery of one component or the other). Upon restart or recovery, the components must
immediately synchronize the current status of all transactions, data, and configurations
with one another.

e)

The operator must include a method to void wagers and pays in the event of a
malfunction of the Event Wagering System itself if a full recovery is not possible.

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7.5

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Wagering Control

7.5.1 Wagering Control. The Event Wagering System must be able to suspend the following
on demand:

a)

All event wagering;

b)

Individual events;

c)

Individual markets;

d)

Individual Wagering Devices (if applicable); and

e)

Individual player logins (if applicable).

7.5.2 Suspension Logging. When wagering is suspended for an active event an entry must be
made in an audit log that includes the reason.

7.6

Information to be Maintained

7.6.1 Data Retention and Time Stamping. The operator must be capable of retaining and
backing up all recorded information, within this section, for a period of five years or as otherwise
specified by the regulatory body.

a)

The Event Wagering System clock must be used for all time stamping.

b)

Event Wagering Systems must provide a mechanism to export the data for the purposes
of data analysis and auditing/verification (e.g., CSV, XLS).

7.6.2 Wager Record Information. For each individual wager placed by the player, the
information to be maintained and backed up by the Event Wagering System must include:

a)

The date and time the wager was placed;

b)

Any player choices involved in the wager:
i.

Wager selection (e.g., athlete or team name and number);

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ii.

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Type of wager and line postings (e.g., money line bet, point spreads, over/under
amounts, win/place/show);

iii.

Any special condition(s) applying to the wager;

c)

The results of the wager (blank until confirmed);

d)

Total amount wagered, including any promotional/bonus credits (if applicable);

e)

Total amount won, including any promotional/bonus credits (if applicable);

f)

Commission or fees collected (if applicable);

g)

The date and time the winning wager was paid to the player;

h)

Unique identification number of the wager record;

i)

Attendant identification handling the wager, if assisting the player;

j)

Relevant geolocation information (if applicable);

k)

Event and market identifiers;

l)

Current wager status (active, cancelled, etc.);

m)

Unique player ID, for wagers conducted using a player account;

n)

For wagers conducted using a venue-controlled Wagering Device:
i.

Unique Wagering Device ID;

ii.

Status of wager record (valid, unredeemed, pending, void, invalid, redemption in
progress, redeemed, etc.);

iii.

Expiration period (if applicable); and

iv.

Open text field for attendant input of player description or picture file;

7.6.3 Market Information. For each individual market available for wagering, the information
to be maintained and backed up by the Event Wagering System must include:

a)

The date and time the wagering period started and ended;

b)

The date and time the event started and ended or is expected to occur for future events (if
known);

c)

The date and time the results were confirmed (blank until confirmed);

d)

Total amount of wagers collected, including any promotional/bonus credits (if
applicable);

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e)

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The line postings that were available throughout the duration of a market (time stamped)
and the confirmed result (win/loss/push);

f)

Total amount of winnings paid to players, including any promotional/bonus credits (if
applicable);

g)

Total amount for cancelled wagers, including any promotional/bonus credits (if
applicable);

h)

Commission or fees collected (if applicable);

i)

Event status (in progress, complete, confirmed, etc.); and

j)

Event and market identifiers.

7.6.4 Wagering Device Information. For each individual venue-controlled Wagering Device,
the information to be maintained and backed up by the Event Wagering System must include:

a)

Unique Wagering Device ID;

b)

Winning wager record redemptions, if supported;

c)

Wager record voids and adjustments;

d)

Attendant identification and session information (if applicable);

e)

Significant events, if supported:
i.

Any time a control program component is added, removed, or altered;

ii.

Changes made to settings/configurations (including a description of the changes);

iii.

Power resets;

iv.

Communication failures;

v.

Program verification errors or critical NV memory errors;

vi.

Door open errors and door close events; and

vii.

Peripheral device errors.

7.6.5 Player Account Information. For Event Wagering Systems which support player account
management, the information to be maintained and backed up by the Event Wagering System
must include for each player account:

a)

Unique player ID and player name;

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Version 1.0
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b)

Player credentials (including verification method);

c)

Date of player agreement to the operator’s Terms and Conditions and Privacy Policy;

d)

Account details and current balance;

e)

Open text field for attendant input of player description by attendant or picture file;

f)

Previous accounts, if any, and reason for de-activation;

g)

Date and method from which the account was registered (remote vs. on-site);

h)

Exclusions/limitations information as required by the regulatory body:
i.

The date and time of the request (if applicable);

ii.

Description and reason of exclusion/limitation

iii.

Type of exclusion/restriction (e.g., operator-imposed exclusion, self-imposed
limitation);

i)

iv.

Date exclusion/limitation commenced;

v.

Date exclusion/limitation ended, if applicable;

Financial Transaction information:
i.

Type of transaction (e.g., deposit, withdrawal, adjustment);

ii.

The date and time of the transaction;

iii.

Unique transaction ID;

iv.

Amount of transaction;

v.

Total account balance before/after transaction;

vi.

Total amount of fees paid for transaction (if applicable);

vii.

Transaction status (pending, complete, etc.);

viii.

Method of deposit/withdrawal (e.g., cash, debit or credit card, personal check,
cashier’s check, wire transfer, money order);

ix.

Deposit authorization number;

x.

Unique Wagering Device ID that identifies where the transaction took place (if
applicable);

xi.

Attendant identification handling the transaction, if assisting the player; and

xii.

Relevant geolocation information (if applicable).

7.6.6 Significant Event Information. Significant event information to be maintained and
backed up by the Event Wagering System must include:

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a)

Failed login attempts;

b)

Program error or authentication mismatch;

c)

Firewall audit log full;

d)

Remote access, where supported;

e)

Significant periods of unavailability of any critical component of the Event Wagering
System;

f)

Large wins (single and aggregate over defined time period) in excess of a value specified
by the regulatory body, including wager record information;

g)

Large wagers (single and aggregate over defined time period) in excess of a value
specified by the regulatory body, including wager record information;

h)

System voids, overrides, and corrections;

i)

Changes to live data files occurring outside of normal program and operating system
execution;

j)

Changes that are made to the download data library, including the addition, changing or
deletion of software, where supported;

k)

Changes to operating system, database, network, and application policies and parameters;

l)

Changes to date/time on master time server;

m)

Changes to previously established criteria for an event or market (not including line
posting changes for active markets);

n)

Player Account Management:
i.

Changes made to information recorded in a player account;

ii.

Irrecoverable loss of player-related data;

iii.

Deactivation of a player;

iv.

Large financial transactions (single and aggregate over defined time period) in
excess of a value specified by the regulatory body, including transaction
information;

o)

Any other activity requiring employee intervention and occurring outside of the normal
scope of system operation; and

p)

Other significant or unusual events as deemed applicable by the regulatory body.

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7.7

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Reporting

7.7.1 General Reporting Requirements. The operator must be capable of generating reports as
required by the regulatory body. In addition to meeting the requirements in the section above for
“Data Retention and Time Stamping”, the following requirements shall apply for required
reports:

a)

Required reports shall be available on demand and for intervals required by the
regulatory body including, but not limited to, daily, month to date (MTD), year to date
(YTD), and life to date (LTD).

b)

Each required report must indicate the operator, the selected interval and the date/time the
report was generated.

c)

Required reports must be generated by the system, even if the period specified contains
no data to be presented. The report generated shall indicate all required information and
contain an indication of “No Activity” or similar message if no data appears for the
period specified.

NOTE: In addition to the reports outlined in this section, the regulatory body may also require
other reports utilizing the information stored under the “Information to be Maintained” section
of this document.

7.7.2 Operator Revenue Report. The Event Wagering System must be able to provide an
Operator Revenue Report (or similarly named report) which may be used for operator taxation
information. The report must contain the following information at a minimum for each event as a
whole and for each individual market within that event:

a)

The date and time each event started and ended;

b)

Total amount of wagers collected;

c)

Total amount of winnings paid to players;

d)

Total amount of wagers cancelled

e)

Commission and fees collected;

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f)

Event and market identifiers; and

g)

Event status (in progress, complete, confirmed, etc.).

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7.7.3 Operator Liability Report. The Event Wagering System must be able to provide an
Operator Liability Report (or similarly named report). The report must contain the following
information at a minimum:

a)

Total amount held by the operator for the player accounts (if applicable);

b)

Total amount of wagers placed on future events; and

c)

Total amount of winnings owed but unpaid by the operator on winning wagers.

7.7.4 Promotion/Bonus Summary Report. The Event Wagering System must be able to
provide a Promotion/Bonus Summary Report (or similarly named report) for any promotions
and/or bonuses that are redeemable for cash, wagering credits, or merchandise. The report must
contain the following information at a minimum for each promotion/bonus:

a)

Beginning balance for promotion/bonus;

b)

Total amount of promotions/bonuses issued;

c)

Total amount of promotions/bonuses redeemed;

d)

Total amount of promotions/bonuses expired;

e)

Total amount of promotion/bonus adjustments; and

f)

Ending balance for promotion/bonus.

7.7.5 Future Events Report. The Event Wagering System must be able to provide a Future
Events Report (or similarly named report). The report must contain the following information at
a minimum for the gaming day:

a)

Wagers placed prior to the gaming day for future events (total and by wager);

b)

Wagers placed on the gaming day for future events (total and by wager);

c)

Wagers placed prior to the gaming day for events occurring on that same day (total and
by wager);

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d)

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Wagers placed on the gaming day for events occurring on that same day (total and by
wager);

e)

Wagers cancelled on the gaming day (total and by wager); and

f)

Event and market identifiers.

7.7.6 Contest/Tournament

Report.

Event

Wagering

Systems

which

support

contests/tournaments must be able to provide a Contest/Tournament Report (or similarly named
report) for each contest/tournament. The report must contain the following information at a
minimum:

a)

Name of the contest/tournament;

b)

The date and time the contest/tournament occurred or will occur (if known);

c)

Unique player ID and name of each registered player, amount of entry fee paid, and the
date paid;

d)

Unique player ID and name of each winning player, amount paid, and the date paid;

e)

Total amount of entry fees collected, including any promotional/bonus credits (if
applicable);

f)

Total amount of winnings paid to players, including any promotional/bonus credits (if
applicable);

g)

Commission or fees collected (if applicable); and

h)

Contest/tournament status (in progress, complete, etc.).

7.7.7 Significant Events and Alterations Report. The Event Wagering System must be able to
provide a Significant Events and Alterations Report (or similarly named report). The report must
contain the following information at a minimum for each significant event:

a)

Date and time of each significant event or alteration;

b)

Event/Component identifier (if applicable);

c)

Identification of user(s) who performed and/or authorized the alteration;

d)

Reason/description of the significant event or alteration, including data or parameter
altered;

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GLI Standard #33 – Standards for Event Wagering Systems

e)

Data or parameter value prior to alteration

[Text truncated at 120,000 characters. The full text is on the page linked above.]

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Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/tribal%3Apueblo_laguna%3A7d8a1f446f5cb0b4. Public record. Not legal advice.
