Nevada Changes Restricted Gaming License Requirements for Individuals

Effective February 28, 2022, the Applicant Services section of the Nevada Gaming Control Board’s (“Board” or “GCB”) Investigations Division significantly changed the forms required for individuals who are applying for a restricted gaming license. The change impacts all applications for (1) a Restricted Gaming License, (2) approval/licensure to participate in Restricted Gaming Revenue and (3) Licensure as an Officer, Director, Key Employee, or similar position in connection with a restricted gaming operation.

Different Forms and More Information
In addition to requiring restricted license applicants to complete two different forms, the change also requires more extensive and more detailed information that was previously required only in connection with a nonrestricted gaming license application. In some respects, the new requirements elevate components of the restricted license application to the equivalent of applying for a nonrestricted gaming license. Therefore, it is imperative for restricted gaming license applicants to understand the new forms, complete them accurately, and begin planning for how the additional information provided will also affect their background investigation as well as their ongoing compliance and reporting requirements.

The complexity, comprehensiveness and cost of Nevada’s gaming license application, background investigation and approval process depends on which of four general categories relates to the specific applicant: (1) gaming employees, (2) people associated with the gaming industry (such as service providers and people owning less than 5% of a gaming company), (3) people in a “restricted” gaming location (such as a bar that operates 15 or fewer slot machines) or (4) people in a “nonrestricted” gaming location (including key positions such as owners, operators, executive management, and Board members). The stringent and voluminous nature of the application requirements increases from category one to four, but the Board’s new changes that were publicly announced on January 26, 2022, makes part of the “restricted” category as exhaustive as the “nonrestricted” category.

Forms 7 and 7A Replace Forms 4 and 5
Previously, individuals seeking licensure in connection with a restricted gaming operation were required to complete and file a GCB Form 4 (Personal History Record) and, in most cases, a GCB Form 5 (Personal Financial Questionnaire). As of February 28, 2022, all individuals seeking licensure in connection with a restricted gaming operation will instead be required to complete and file a GCB Form 7 (Multi-Jurisdictional Personal History Disclosure Form) and a GCB Form 7A (Nevada Supplemental Personal History Disclosure Form). Previously, these lengthy and often complicated forms were only required of individuals seeking findings of suitability or licensure in connection with nonrestricted gaming operations.

For example, the Multi-Jurisdictional Personal History Disclosure Form is utilized in many U.S. jurisdictions, is a total of approximately 65 pages, and has two sections.

  • The first section focuses on detailed personal history such as family and marital status, educational background, residence information, civil lawsuit and criminal court records, employment history, licensing history, and references.
  • The second section focuses on a detailed financial statement that includes salary and tax information, personal assets and liabilities disclosures, bankruptcy filings, and any investments in the gaming entity related to the application.

The revised and updated restricted gaming application instructions and forms are available on the Board’s website at Nevada Gaming Control Board: Forms and Applications (nv.gov). The Board has advised that restricted gaming applications filed on or after February 28, 2022, without the GCB Forms 7 and 7A, where required, will be considered incomplete and will not be processed by the Board until all the new requirements are fulfilled.

All other GCB application forms required to be filed by individuals in connection with restricted gaming operations remain the same as before. If you have questions concerning these new restricted gaming application forms requirements and the resulting increase in the scope and depth of the associated background investigation, please contact Greg Giordano, Dennis Gutwald, A.G. Burnett, or Kelci S. Binau for assistance.


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