Wyoming Gaming Commission details permitting rules, bond levels and compliance challenges

Officials from the Wyoming Gaming Commission briefed the Select Committee on Gaming on June 9 about permitting procedures, enforcement, and gaps in monitoring for skill‑based amusement games.

Director Laramendi described the two‑step permitting process: an applicant must first obtain a live event permit (including a $5,000 surety bond/certificate of deposit and background checks) and then apply location‑by‑location for simulcasting (off‑track betting terminals and HHR). Simulcast applicants must post a larger financial assurance — a $100,000 surety bond or equivalent in favor of the state — and supply operational plans, financial statements, security and, where statute requires, a county resolution or letter of support. The commission said the $5,000 bond applies to live event permits and the $100,000 bond applies to simulcasting operations.

Director Laramendi clarified a statutory requirement for live‑race activity: a permittee must run 16 live race days per year to retain simulcasting authority; failure to run the required dates generally results in loss of simulcasting for the remainder of the calendar year and the next year unless the commission grants an exception for reasons such as weather or safety. Commission staff said operators may add makeup days and that the commission evaluates feasibility and public input when considering simulcast applications. The commission also described its licensing vetting: management and key personnel file multi‑jurisdictional history forms, submit to criminal history checks and provide financial statements on request.

On compliance, the commission and its chair (Paul "Cactus" Covello Jr.) said they are actively enforcing licensing, safety and age‑restriction rules and have field compliance staff and a third‑party auditor for tote/handle reporting on HHR. But staff warned of a monitoring gap: for skill‑based amusement games and some skill game vendors, tax and net‑proceeds reporting is largely self‑reported and the commission has found that self‑reported revenues "lack verifiable reliable verification" in a recent audit. The commission has explored a central monitoring system (CMS) to get real‑time terminal reporting but said responses to an RFP put potential CMS costs over $2 million; commission staff said they are reworking the procurement to seek more cost‑effective options.

Commission officials also described program differences: skill‑based amusement games require player interaction and pattern recognition and are regulated under separate rules (placement in liquor‑licensed establishments, truck stops or smoke shops and a 21‑and‑over operational standard in practice), while HHR terminals offer a handicapping screen and pari‑mutuel style wagering with statutory and rule‑based safeguards.

Committee members pressed on enforcement of underage play, how the commission verifies operators' reported revenue, the adequacy of bond amounts and whether counties or municipalities can play a greater role in siting OTPs; staff said they are developing an underage compliance check program and can provide additional materials on background checks, bonds, and audit procedures.