Q: If I am shipping products to a casino, are there any special requirements I should be aware of?

A: Yes. In addition to state-level requirements, federal law requires registration and record keeping requirements related to the shipping of equipment that is considered a “gambling device” under the Johnson Act (as amended by the Gambling Devices Act of 1962, 15 USC 1171, et. seq.). A “gambling device” is generally defined as a slot machine, a device designed primarily for gaming (such as a roulette wheel), or any essential part or subassembly of a gambling device. If your company provides any of these products across state lines, then it will be necessary to seek federal approval in addition to any state-level gaming licenses required to do business with a casino or gaming company.

In addition to the registration requirements, a supplier must retain specific records related to each shipment, such as the device serial number, dates of shipment/receipt, name of common carrier, as well as clearly labeling each shipment in accordance with the Act.

Many gaming jurisdictions require additional reporting, such as prior notice to the gaming commission of a shipment of gambling devices, which must be completed at the state and local level in addition to the Johnson Act's requirements. Although registration is fairly easy, it is prudent to seek outside advice before making gambling device shipments to ensure that all federal, state, local and/or tribal requirements are properly taken into account.