Can an existing state gaming license be transferred to another state?

Q: My company has sold goods to a casino client for a number of years and currently holds a supplier’s license in good standing in my state. We recently expanded to a new state and want to provide goods to casinos in that jurisdiction, but the casino says that we need a separate supplier license issued by the new jurisdiction. Is it possible to simply transfer my existing license to the new state?

A: No, although many state and tribal gaming authorities offer some form of reciprocity for certain types of casino gaming licenses. While it is not typical to “transfer” a license, it may be possible to limit certain disclosure filings as part of the application for a new license in a new jurisdiction. However, the reciprocity process varies significantly between jurisdictions and often involves the applicant filing at least basic identification and other information with the new jurisdiction. As such, it is important to include a review of gaming licensing requirements as part of your overall business expansion plans in order to reduce licensing burdens.

Even if a jurisdiction does not offer reciprocity, listing the gaming licenses that you currently hold within the license application will assist with the review process. This may accelerate the process for issuing a temporary license that will allow business with the casino property to begin before the conclusion of the full license investigation. It is beneficial to show gaming regulators that you and your company are currently licensed in other jurisdictions as evidence of your ongoing compliance and good standing. Gaming staff often contact their counterparts in other jurisdictions during licensing reviews, thus a good reputation can provide regulators with comfort during the application review process.