The Massachusetts Gaming Commission’s Investigations and Enforcement Bureau (IEB) has begun the labor-intensive process of reviewing the applications submitted by 11 gaming applicants interested in pursuing an expanded gaming license here in the Commonwealth. The Commission imposed a deadline of January 15, 2013 to submit the first phase of a two phase application for entities interested in pursuing a resort-casino license in Region A (Eastern MA) , Region B (Western MA) or the single slots-parlor license. In addition to the $400,000 non-refundable application fee, the Commission received applications from 11 entities which consist of nearly 300 qualifiers (entities or individuals with influence over an applicant) and totals approximately 21,000 pages of information. This first phase or ‘Phase 1’ of the application process is to determine the overall suitability of a gaming applicant in matters related to integrity and finance. The second phase of the application process or ‘Phase 2’ requires that applicants submit a ‘site-specific’ plan for the proposed gaming facility.

Each of the 11 applicants, as well as their qualifiers, is currently undergoing extensive background investigations to ensure they meet the highest standards of good character, honesty, integrity and financial suitability.

These substantial background investigations are being conducted by the Massachusetts State Police in conjunction with investigative teams of gaming experts from the consulting firms of Spectrum Gaming and Michael & Carroll.  These teams collectively include former FBI agents, state investigators, prosecutors, and forensic accountants, all of whom have vast experience in all types of investigations, including, but not limited to, background, corruption, organized criminal enterprise and racketeering as well as corporate due diligence and gaming industry backgrounds for the largest gaming entities in the industry.

The Phase 1 background investigations will include review of regulatory history in other jurisdictions, financial stability, compliance plan and history and recent litigation, among other areas.

The investigations for qualifiers – those entities or individuals who are officers, board members or key investors of the applicant – will cover their employment history, criminal records, education, stockholdings and financial suitability, among other areas.  Much of the information is highly personal and of the type that the law does not permit the Commission to disclose. Although the Commission has instructed each qualifier to provide a copy of the application from which that highly personal information has been redacted, the Commission nevertheless must review each of the approximately 21,000 pages to ensure that the qualifier has in fact redacted the exempt information but has not redacted more information than the law permits. MGC will complete this painstaking and laborious work as quickly as possible and will then make the public versions of the applications available to all who request them.

Investigations are expected to take six months to complete based upon the volume of information that needs to be reviewed and the number of qualifiers for each applicant.  The time-frame is also dependent on the complexity of the investigations, as applicants for licenses in Massachusetts include complicated multi-national organizations operating facilities as far away as Singapore and Macau.