Epstein Files

EFTA01123540.pdf

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U.S. VIRGIN ISLANDS INTERNET GAMING AND GAMBLING PROPOSED REGULATIONS — November 19, 2002 §603-1.1 Definitions The following words and terms, when used in these rules, shall have the following meanings, unless the context clearly indicates otherwise. (a) "Act" means all current and previous Virgin Islands legislation enacted to enable land-based casino and Internet gaming or Internet gambling operations. (b) "Approved Game" means an Internet game that the Commission has approved for use in online wagering by an Internet gaming or Internet gambling licensee. (c) "Approved Internet Gambling" means conducting Internet gambling with the approval of the Commission. (d) "Bank" means any financial institution organized under federal, state or territorial law including, but not limited to: a bank; a thrift institution; a credit union; a credit card services institution and any other financial services institution recognized under the laws of the United States and United States Virgin Islands as a financial intermediary. (e) "Commission" means the Casino Control Commission established pursuant to the provisions of Title 32, Virgin Islands Code. (f) "Control" means: ownership of, or the power to vote, directly or indirectly, at least fifteen percent (15%) of a class of voting securities or voting interests of an Internet gaming or Internet gambling licensee or person in control of an Internet gaming or Internet gambling licensee; or the power to elect a majority of executive officers, managers, directors, trustees, or other persons exercising managerial authority of an Internet gaming or Internet gambling licensee or person in control of an Internet gaming or Internet gambling licensee; or the power to exercise directly or indirectly, a controlling influence over the management of policies of an Internet gaming or Internet gambling licensee or person in control of an Internet gaming or Internet gambling licensee, if the Commission, after notice and opportunity for hearing, so determines. (g) "Control System" means any system of internal controls, gaming and legal compliance procedures, and administrative and accounting procedures for the operation of an approved game by an Internet gaming or Internet gambling licensee. (h) "Court" means the Territorial Court of the Virgin Islands. (i) "Division" means the Division of Gaming Enforcement as established pursuant to the provisions of Title 32, Virgin Islands Code. EFTA01123540 Internet Gaming and Gambling Regulations November 19, 2002 "Executive Office?' means a president, chairperson of the executive committee, chief financial officer, principal employee, responsible for individual, or other individual who performs similar functions. "Gaming Record" means information that is inscribed on a tangible medium or that is stored in an electronic or other medium and is retrievable in perceivable form, including documents, about the operation of an approved game conducted by an Internet gaming or Internet gambling licensee pursuant to a license issued by the Commission. "Gross Franchise Revenue" means the total of all sums received by the Master Service Providers from Internet gaming or Internet gambling licensees. "Gross Internet Gambling Revenue" means the total of all sums, including checks received by the Internet gaming or Internet gambling licensee under the Internet Gaming Act actually received by an Internet gaming or Internet gambling licensee from gaming operations, less the total of all sums paid out as winnings to players, but including an allowance for uncollectible gaming receivables. The deduction for uncollectible gaming receivables shall not exceed the lesser of: a reasonable provision for uncollectible player checks received from gaming operations; or four percent (4%) of the total of all sums including checks, whether collected or not, less than the amount paid out as winnings to players. (n) "Gross Service Provider Revenue" means the total of all sums received by the Master Service Providers from Internet gaming or Internet gambling licensees. (0) "Hardware" means any computer, computer server, or other device whether electronic, electrical or mechanical, required for or used in approved Internet gaming or Internet gambling. (P) "Identity" in relation to a person means name, physical, mailing and e- mail address, date of birth or a prescribed aspect of the person's identity. (q) "Internet Funds" are funds that are transferred through a third party or peer-to-peer and which the payee can access and retrieve for debiting or crediting an account. (r) "Internet Game" means a scheme, arrangement, or plan comprised of prize, chance, and consideration or prize, mixed chance and skill, and consideration that is approved and authorized by the Commission. (s) "Internet Gaming or Internet Gambling" means the dealing, operating, carrying on, conducting, maintaining, or exposing for pay, of any Internet Game. (t) "Internet Gaming Equipment" or "Internet Gambling Equipment" means a computer or other device (whether electronic, electrical or mechanical), computer software, or another thing used, or suitable for use, in the conduct of an approved game. (u) "Internet Gaming or Internet Gambling Licensee" means a person or entity approved by the Commission to conduct Internet gaming or Internet Page 2 of 2 EFTA01123541 Internet Gaming and Gambling Regulations November 19, 2002 gambling; or, a person or entity approved by the Commission to provide goods and services to any other person or entity approved by the Commission to conduct Internet gaming or Internet gambling. (v) "Internet Gaming or Internet Gambling System" shall mean the integrated system of hardware, software, data, communications, and security components used by the Internet gaming or Internet gambling licensee to conduct Internet gaming or Internet gambling. (w) "Key Employee" means a person who occupies or acts in a managerial position or carries out managerial functions in relation to an operation carried out under an Internet gaming or Internet gambling operation, or is a person in a position to control or exercise significant influence over Internet gaming or Internet gambling operations. (x) "License" means a license for Internet gaming or Internet gambling issued pursuant to the Internet Gaming and Gambling Act. (y) "Master Service Provider means the person or entity authorized by the Internet Gaming and Gambling Act to host the physical operations, including hardware, software, and personnel of approved Internet gambling in the Virgin Islands, all shareholders, partners, members, or other owners thereof, subject to the rules and regulations promulgated by the Commission in accordance with the provisions of section 4, subsection (b) of the Master Franchise Agreement. (z) "Outstanding," with respect to a payment instrument, means issued, awarded, or sold by or for the Internet gaming or Internet gambling licensee and which has been reported as issued, awarded or sold but not yet paid by or for the Internet gaming or Internet gambling licensee and which has been reported as issued, awarded or sold but not yet paid by or for the Internet gaming or Internet gambling licensee. (aa) "Play" means participate in an approved game conducted by an Internet gaming or Internet gambling licensee. (bb) "Player" means a person who has attained the age 21 and who participates in an approved game conducted by an Internet gaming or Internet gambling licensee. (cc) "Random Number Generator" or "RNG" means a computer or computer server or software program used to produce a selection of numbers in no particular order and with no favor being given to any numbers that behave similarly to realizations of independent, identically distributed random variables; a procedure which produces different values each time it is called simulating a random selection process that ensures the fairness of an approved game or approved Internet gaming or Internet gambling. (dd) "Record" means information that is inscribed on a tangible medium or that is stored in an electronic or other medium and is retrievable in perceivable form. Page 3 of 3 EFTA01123542 Internet Gaming and Gambling Regulations November 19, 2002 (ee) "Regulations" means all current and previous Virgin Islands rules or orders proscribed or adopted by the Commission with regard to land-based casino and Internet gaming or Internet gambling operations. (f0 "Responsible individual" means an individual who programs or customizes the specific hardware platform for the Internet gaming or Internet gambling licensee, operating system of the Internet gaming or Internet gambling licensee, and application software of and for the Internet gaming or Internet gambling licensee that can affect game play or has access to sensitive areas, or who is employed by an Internet gaming or Internet gambling licensee, and has principal, active, managerial authority, empowered to make discretionary decisions over the provision of approved gaming and approved Internet gaming or Internet gambling by the Internet gaming or Internet gambling licensee in the Virgin Islands. "Software" means the assembled, compiled or engineered intellectual information and instructions in a program and includes procedures and associated documentation concerned with the operation of a computer, computer program, or computer network. "System Tester" means an accredited systems testing entity licensed by the Commission to perform systems and game testing for Internet gaming or Internet gambling licensees. "Unsafe or unsound practice" means a practice or conduct by a person licensed to engage in approved Internet gaming or Internet gambling which creates the likelihood of insolvency or material loss or dissipation of the Internet gaming or Internet gambling licensee's assets beyond that prescribed by law, or otherwise materially prejudices the interests of its players. "Virgin Islands or Territory" means the United States Virgin Islands. (ck) "Wager means an amount a player puts at risk in playing an approved game conducted by an Internet gaming or Internet gambling licensee. §604-1.1 Authority of the Commission (a) These regulations are issued under and pursuant to the authority of the U.S. Virgin Islands Technology Initiative, Chapter 21 of Title 32 of the Virgin Islands Code, as amended. (b) The Commission may request a legal opinion from the Virgin Islands Department of Justice regarding whether Internet gaming or Internet gambling can be operated in compliance with all federal and territorial law. (c) To fulfill its legislative mandate and given the innovative nature of Internet gaming or Internet gambling, the Commission shall have the power to amend these regulations from time to time through both formal and informal rulemaking. Page 4 of 4 EFTA01123543 Internet Gaming and Gambling Regulations November 19, 2002 (d) These regulations shall be liberally construed in favor of unfettered regulatory oversight to permit the Commission and the Division to effectively carry out their respective statutory functions and to secure a just and expeditious determination of issues properly presented to the Commission. §604-1.2 Severability If any Court shall declare any parts or portions, subsection, section, or provision of these Regulations invalid, the remaining parts and portions, subsection, section and provision shall remain in full force and effect. §605-1.1 License Required (a) All persons or entities must receive an Internet gaming or Internet gambling license from the Commission prior to conducting an Internet gaming or Internet gambling business at or from a place in the Virgin Islands. (b) All persons or entities must receive an Internet gaming or Internet gambling license from the Commission prior to engaging in owning, controlling, or operating a computer server in the Virgin Islands that enables an Internet game to be played. (c) All persons or entities must receive an Internet gaming or Internet gambling license from the Commission prior to engaging in offering, advertising, or soliciting in the Virgin Islands the playing of Internet games; provided, however, that such a requirement is not applicable to electronic and print media providers with no ownership interest in, or common ownership with, any Internet gaming or Internet gambling business. (d) All persons or entities must receive an Internet gaming or Internet gambling license from the Commission prior to engaging in any behavior that a reasonable person would believe indicates that the person or entity is holding themselves out as an approved Internet gambling licensee. §605-1.2 Person & Entity Approval Required (a) All persons or entities must receive approval from the Commission prior to working for, contracting services to, or consulting to, an Internet gaming or Internet gambling business at or from a place in the Virgin Islands, provided, however, that regulated professional service providers such as certified accountants and licensed attorneys shall not be required to obtain approval from the Commission when they do not have an interest in the Internet gaming or Internet gambling business. Page 5 of 5 EFTA01123544 Internet Gaming and Gambling Regulations November 19, 2002 Approval as required under Section 605-1.2(a) may be granted on an interim basis by the Commission; provided, however, that such interim approval shall be effective for no longer than 12 months. Each employee, consultant, and service contractor, shall at a minimum submit the following information to the Commission: 1. Any casino or Internet gaming or Internet gambling license or registration number; 2. Last name, first name and middle initial as indicated on his or her license, birth certificate, or registration; 3. If an entity, the legal name of the entity and the jurisdiction of incorporation, and tax identification number; 4. date of birth; 5. Job title; 6. Job description; 7. The initial date of hire in the position indicated in the notice; 8. The effective date of any change in the employee's position or job title; 9. Social security number; and 10. If the person has no social security number, then the federal tax identification number. §605-1.3 Computer Systems Approval (a) An Internet gaming or Internet gambling licensee shall apply to the Commission for approval of the computer system, hardware, systems software, application software and any other gaming equipment the Internet gaming or Internet gambling licensee proposes to use to conduct Internet games. (b) All computer systems, hardware, systems software, application software and any other gaming equipment the Internet gaming or Internet gambling licensee proposes to use to conduct Internet games shall be specifically tested by the Division of Gaming Enforcement or a system tester selected by the Division of Gaming Enforcement. (c) An Internet gaming or Internet gambling licensee shall apply to Commission for approval to change the Internet gaming or Internet gambling licensee's approved computer system. (d) The Commission shall evaluate the system or proposed change in a timely manner, if the Commission determines that it is necessary to engage in an evaluation. (e) The Commission, after considering the application, and performing an evaluation if deemed necessary, shall provide a written approval or denial for the proposed computer system. Page 6 of 6 EFTA01123545 Internet Gaming and Gambling Regulations November 19, 2002 (0 The Internet gaming or Internet gambling licensee shall be responsible for all costs of the Commission and Division that are incurred in testing and evaluating any computer system; and the Commission may require an advance payment of such costs as the Commission deems reasonable. (g) Any denial of approval by the Commission shall be accompanied with a detailed reason for the denial. (h) Internet gaming or Internet gambling licensees may only conduct Internet games using the Internet gaming or Internet gambling licensee's computer system that has been approved by the Commission and licensed on St. Croix, U.S. Virgin Islands. (i) An Internet gaming or Internet gambling licensee must not change, or authorize a change to, the Internet gaming or Internet gambling licensee's approved computer system, unless the change has been approved in writing by the Commission. §605-1.4 Computer Systems Evaluation Criteria (a) The Commission shall establish the criteria to be applied in evaluating the functionality of computer systems used to provide Internet gaming or Internet gambling, the approved games and wagering types to be offered, the communications interface which connects these systems to the Internet, and the communications interface which connect these systems to other computer equipment. The Commission shall revise the criteria from time to time and may publish a technical standards reference to supplement the evaluation criteria. (b) The hardware platform, operating system and application software must be proven to be reliable. 1. The hardware platform(s) used must have a mean time between failure (MTBF) in excess of 22,000 hours. 2. Where redundant sub-systems are used (e.g. Master/Slave configurations, clusters, RAID), each redundant system must have an MTBF in excess of 10,000 hours. 3. Published MTBF figures should be included with any application for approval by the Commission. (c) Operating System reliability will be measured in terms of re-boots not due to non-redundant system faults and the time taken for restoration. 1. System re-boots that occur due to the failure of a redundant component will be counted as Operating System Failures. 2. A reliable Operating System is one that re-boots less than once per week and requires less than 10 minutes to return to service. 3. Operating System reliability will be tested during evaluation. Page 7 of 7 EFTA01123546 Internet Gaming and Gambling Regulations November 19, 2002 (d) Application software reliability will be measured in terms of application re-starts not due to non-redundant system faults and the time taken for restoration . 1. Application re-starts that occur due to the failure of a redundant component will be counted as application software failures. 2. Reliable application software is software that re-starts less than once per week and requires less than 10 minutes to return to service. 3. Application software reliability will be tested during evaluation. (e) Logical security will be tested, reviewed and evaluated. 1. The computer system must meet the security requirements for Trusted Computer System Evaluation Criteria (TCSEC) C2 level class computer systems or similar rating/certification. 2. The operating system of the computer(s) must provide comprehensive password security. 3. All computer systems (including operator PCs) in the same broadcast domain as the Internet gaming or Internet gambling system must have the same logical and physical security as the Internet gaming system host. 4. The Internet gaming or Internet gambling system and all computer systems that connect to the Internet gaming or Internet gambling system at the IP level must run resident virus detection software. 5. All programs and important data files must only be accessed by entry of a password that will be known only to authorized personnel. 6. All Personal Identification Numbers (PINs) and passwords in the system must be stored in an encrypted, nonreversible form. 7. Use of the system for development or testing must be completely logically separated from the live production system and its database. 8. A program must be available that will list all registered users on the system including their privilege level. 9. There must be adequate tools and procedures to regularly assess the vulnerability of the Internet gaming or Internet gambling system from an internal or external attack. (0 The system must ensure that there is no illicit access possible to player accounts or unclaimed prize money residing in the system (e.g. funds in dormant accounts). Page 8 of 8 EFTA01123547 Internet Gaming and Gambling Regulations November 19, 2002 (g) There must be adequate methods to ensure that changes to systems or data are identifiable. (h) An audit trail of changes to gaming parameters must be maintained by the system and accessible on demand by authorized personnel. (i) Areas in which a system must be able to fulfill its tasks in providing reports to the Commission include: 1. Verification of the financial activity of all Internet gaming or Internet gambling (including jackpots) conducted by the Internet gaming or Internet gambling system; 2. Verification of the fair play of games (and jackpots) that the system offers to player; 3. Verification of the correct operation of the gaming system; and 4. Any other events deemed relevant by the Commission. (j) An Internet gaming or Internet gambling system must be capable of producing a daily, weekly and monthly based financial summary report that totals all funds in, funds out, turnover, total wins for the system. This report shall summarize Gross Internet Gambling revenue. (k) An Internet gaming or Internet gambling system must be capable of providing a report that details summary game play information in order to verify the return to play (RTP) for each game configured on the Internet gaming or Internet gambling system. This shall be derived from the network total of turnover & total wins for each game offered. The number of games played and games won for each game shall also be provided. (I) If relevant, the Internet gaming system must: I. Provide financial summary information on each jackpot configured on the system; 2. Provide detailed information regarding jackpot parameter settings, configuration, and changes; and 3. Provide information on player loyalty data details. (m) Internet gaming or Internet gambling licensees must have a system in place to provide the Commission with electronically formatted game play data from a secure part of the service provider's computer system. The data must be of sufficient detail and completeness to allow automated verification of player payouts, gross Internet gambling revenue, trend analysis, and anomaly identification. (n) The Internet gaming or Internet gambling licensee must have a technological method to backup all critical data on a daily basis that comprises financial, security, and event information. (o) There must be an uninterruptible power supply for each CPU and each independently powered data unit that, in the event of a main power outage, Page 9 of 9 EFTA01123548 Internet Gaming and Gambling Regulations November 19, 2002 allows sufficient time for the system to be shut down in a manner that preserves all data and the integrity of the computer system. (p) The computer system, including communications components, must include automated monitoring of critical components. 1. If a critical component fails an automated monitoring test, then it must be taken out of service immediately 2. The component must not be returned to service until there is reasonable evidence that any fault has been rectified. (q) In the event of a failure, the Internet gaming or Internet gambling system must be able to recover all critical information from the time of the last backup to the point in time at which the system failure occurred (no time limit is specified). (r) All software for all application components of the Internet gaming or Internet gaming or Internet gambling system must be maintained under an appropriate software version control system or mechanism. (s) Software and hardware version control should be maintained by the Internet gaming or Internet gambling licensee to coordinate interoperablility of hardware, software and applications. (t) Determination of events of chance must not be influenced, affected or controlled by anything other than numerical values derived in an approved manner from an approved random number generator in conjunction with the prevailing payout table and rules of the game. (u) The output of the events of chance from the RNG must not be predictable. (v) Any outcomes derived from the RNG must be uniformly distributed. (w) Any mappings to convert random numbers into events of chance must be uniformly distributed and unpredictable. (x) Events of chance must demonstrate that they are statistically random when subject to the same statistical tests for randomness specified for the base random number generator. (y) All numbers generated from the RNG shall be created on the Internet gaming or Internet gambling licensee's computer system not on, at, or through the player's computer or playing device. (z) The use of a random number generator must result in the selection of numeric outcomes which are to be proven to be statistically independent; be uniformly distributed over their range; pass various recognized statistical tests; and be unpredictable. (aa) The Internet gaming or Internet gambling system must employ firewall technology to prevent unauthorized access to the Internet gaming or Internet gambling system and to identify and track suspicious communications activity. (bb) The Internet gaming or Internet gambling system must communicate with the systems of players using a secure or encrypted communications protocol. Page 10 of 10 EFTA01123549 Internet Gaming and Gambling Regulations November 19, 2002 §605-1.5 Control Systems Approval (a) Without a limitation to other sections of these regulations, a control system must include: I. the accounting systems, financial procedures and chart of accounts, the administrative systems and procedures, the compliance plans, the computer software and hardware and the standard forms and terms used to conduct Internet games; 2. the procedures including, if appropriate, formulas for, or with respect to, the hold percentages and their calculation and verification to be followed in conducting Internet games; 3. the procedures and standards for maintaining the integrity of all data and equipment used in conducting Internet games; 4. the procedures for recording and paying prizes won in Internet games and maintaining and using players' accounts, including the procedures for paying in and out of any account, foreign currency dealings and the recording of all transactions relating to gaming operations; 5. the structure of the organization to which it relates, including: i. the management structure and description of positions within the management structure and the responsibilities and functions of those positions; ii. the employee structure and description of positions within the employee structure and the responsibilities and functions of those positions; iii. the chain of authority that shows the diversity of responsibility among employees engaged in all operations of the Internet gaming or Internet gambling business including primary Page 11 of 11 EFTA01123550 Internet Gaming and Gambling Regulations November 19, 2002 and secondary supervisory positions; and iv. if the organization uses an agent, the terms and conditions of the agency agreement including to whom the agent is to report or to whom the agent is accountable within the organization; and v. all measures for securing all data. (b) All approved games shall only be conducted using the control system approved by the Commission. (c) An Internet gaming or Internet gambling licensee shall make an application to the Commission for approval of the Internet gaming or Internet gambling licensee's proposed control system, or changes to a control system approved by the Commission. Such a submission shall, with specificity, identify all material elements and document the proposed control system or proposed control system changes. (d) Emergency Changes. If an approved Internet gaming or Internet gambling licensee's control system has either been breached, compromised, or the integrity of the Internet gaming or Internet gambling licensee's control system has been jeopardized, as in an emergency, then the Internet gaming or Internet gambling licensee may immediately implement changes to the control system that are necessary to address the emergency. In such cases, the Internet gaming or Internet gambling licensee shall immediately inform the Commission of the measures implemented and shall submit such changes to the Commission for approval within 24 hours. (e) Other than emergency changes, as set forth in Section 605-1.5(d), the Internet gaming or Internet gambling licensee shall not change the control systems without prior written approval from the Commission. (f) The Commission shall consider the application of the Internet gaming or Internet gambling licensee for implementing or changing a control system; (g) The Commission shall evaluate the new control system or proposed change in a timely manner if the Commission determines that it is necessary to engage in an additional evaluation. (h) The Commission shall, after considering the application and evaluation if necessary, provide a written approval or denial for the control system or change. (i) In evaluating the control system, the Commission shall, without limitation, ensure that the system promotes security, reliability and provides reasonable assurances that players will be of lawful age and are communicating only from jurisdictions that have not been identified by the Page 12 of 12 EFTA01123551 Internet Gaming and Gambling Regulations November 19, 2002 U.S. Virgin Islands Department of Justice as jurisdictions where engaging in online gambling is illegal. (j) The Internet gaming or Internet gambling licensee shall be responsible for all costs of the Commission and Division that are incurred in testing or evaluating any control system, and the Commission may require an advance payment of such costs as the Commission deems reasonable. (k) The Internet gaming or Internet gambling licensee shall promptly respond to any Commission or Division requests for additional information regarding a control system. (1) Any denial of approval by the Commission shall be accompanied with a detailed reason for the denial. (m) The Commission may, at its sole discretion, by written notice to an Internet gaming or Internet gambling licensee, direct the Internet gaming or Internet gambling licensee to change the Internet gaming or Internet gambling licensee's approved control system within the time, and in the way specified in the notice. (n) If the Internet gaming or Internet gambling licensee does not comply with the direction to change a control system, the Commission may, in its discretion, suspend the license of the Internet gaming or Internet gambling licensee to offer Internet gambling, until the Internet gaming or Internet gambling licensee complies with the direction to the satisfaction of the Commission. §606-1.5 Game Approval (a) An Internet gaming or Internet gambling licensee shall apply to the Commission for approval of an online gambling game; or approval of changes to an approved game. (b) In applying for approval of a game, in addition to any other relevant information, the Internet gaming or Internet gambling licensee shall provide to the Commission, without limitation, the following information: 1. The theoretical payout percentage, along with any documentation substantiating such a theoretical payout percentage; 2. The likely payout percentage to average players, along with any documentation substantiating such a likely average payout percentage; 3. The detailed rules of the game; 4. The pay tables for the game; 5. The minimum and maximum bets for each wagering event in a game; Page 13 of I3 EFTA01123552 Internet Gaming and Gambling Regulations November 19, 2002 6. The results of all testing of the game performed by, or on behalf of, the Internet gaming or Internet gambling licensee; 7. The vendor that supplied the game; 8. Information regarding uses of the same or a similar game by other Internet gaming or Internet gambling licensees; and 9. Any other information that may be required by the Commission. (c) The Commission shall consider the game application of the Internet gaming or Internet gambling licensee; (d) The Commission shall evaluate and test the game or the proposed change, for honesty and fairness, if the Commission determines that it is necessary to engage in an evaluation and test; (e) The Commission shall, after considering the application, and the evaluation if necessary, provide a written approval or denial of approval for the computer system or change. (0 The Internet gaming or Internet gambling licensee shall be responsible for all costs of the Commission and Division that are incurred in testing and evaluating any computer system, and the Commission may require an advance payment of such costs as the Commission deems reasonable. (g) The Commission may issue amendments to these regulations as games are approved by the Commission. The amendments shall describe approved games, the payout odds, any vigorish, game rules, payment procedures and other relevant information similar to the information set forth in the Internet Gaming and Gambling Act. §606-1.6 Merger of Approved Licensees and Casino Operations (a) Any Internet gaming or Internet gambling licensee that wishes to merge with a casino operator licensed in the U.S. Virgin Islands or other jurisdiction deemed suitable by the Commission shall submit an application to the Commission for approval of such a merger. Such an application shall contain all relevant information regarding the proposed combined information including, without limitation: I. the proposed integration of the Internet gaming or Internet gambling licensee operations with the licensed casino operations; 2. the proposed business plan of the Internet gaming or Internet gambling licensee after merger; 3. the projected impact on revenue to the Internet gaming or Internet gambling licensee and licensed casino operator; Page 14 of 14 EFTA01123553 Internet Gaming and Gambling Regulations November 19, 2002 4. the projected impact on employees of the Internet gaming or Internet gambling licensee and licensed casino operator; and 5. a statement regarding the commercial reason for the proposed merger. (b) The Commission shall investigate the proposed merger. (c) The Commission shall review the status and history of the Internet gamign or Internet gambling licensee and the licensed casino operator. (d) The Commission shall independently assess whether the merger is consistent with the public policy of the Virgin Islands and its residents. (e) The Commission shall issue a written approval or refusal to grant approval. (f) The Commission shall, if the merger is not approved, provide a reason for not approving the merger. §607-1.1 Contents of the Application for Internet Gambling License (a) Each Internet gaming or Internet gambling license applicant shall provide all information requested by the Commission including, without limitation: 1. the legal name, residential and business addresses of the applicant and any fictitious or trade name used by the applicant in the conduct of its business;

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Feb 3, 2026