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What is the legal definition of gambling?
Although D.C. law does not provide a single, generally applicable definition of “gambling” or “game of chance,” courts have recognized the three traditional elements of a lottery: (1) consideration, (2) chance, and (3) prize.
D.C. law separately defines a “wager” as “the betting, staking, or risking by an individual, group of individuals, or entity of something of value” under an agreement that the participant or another person will receive something of value upon a specified outcome. The definition applies to the District’s general criminal gambling provisions as well as its lottery and gaming laws. It also excludes certain activities, including contests in which participants risk only personal effort or qualifying free play credits.
The District generally prohibits gaming tables and devices designed for games of chance played for money or property, but expressly permits certain authorized gambling activities, including government operated lotteries, licensed sports wagering, charitable gaming, and licensed game of skill machines. In distinguishing games of chance from games of skill, D.C. law provides that a gaming device does not qualify as a “game of skill machine” if a player’s success may be determined by a chance event that cannot be altered by the player’s actions.
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What legislation applies to gambling? Please provide a summary of the legal/regulatory framework.
The general prohibitions on unauthorized lotteries, gaming devices, and bookmaking are found in D.C. Code §§ 22-1701 through 22-1708. Over time, the District has enacted several laws establishing exceptions to these prohibitions and creating regulatory frameworks for permitted gambling activities.
The Sports Wagering Lottery Amendment Act of 2018 (D.C. Law 22-312) legalized sports wagering and established a framework for licensing and regulating retail and mobile sports betting. The law designated the D.C. Office of Lottery and Gaming (“OLG”) as the regulator of sports wagering operators and related service providers. The framework was subsequently expanded by the Sports Wagering Amendment Act of 2024 (D.C. Law 25-217), which authorized additional private operators to offer mobile sports wagering throughout the District, subject to geographic restrictions, and modified the applicable licensing provisions. These requirements are codified principally at D.C. Code §§ 36-621.01 et seq.
The District also permits certain game of skill machines at licensed establishments, with the OLG responsible for licensing manufacturers and distributors and the Alcoholic Beverage and Cannabis Administration (ABCA) responsible for licensing retail establishments.
Most recently, the Commercial Bingo Amendment Act of 2025 (D.C. Law 26-55) authorized commercial bingo at qualifying on-premises alcohol establishments, subject to obtaining an OLG license and an ABCA endorsement.
The implementing regulations for the District’s authorized gaming activities are primarily contained in Title 30 of the District of Columbia Municipal Regulations (Lottery and Charitable Games), with additional requirements under Title 25 governing licensed establishments. The regulatory framework does not generally authorize traditional casino gambling or online casino gaming.
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Which body/ies regulate gambling?
The OLG is the principal gaming regulator. It operates the lottery and licenses private sportsbooks, charitable gaming, commercial bingo, and game of skill machine manufacturers and distributors.
Since October 1, 2025, the D.C. Alcoholic Beverage and Cannabis Administration (“ABCA”) regulates Game of Skill retail licensing. Commercial bingo requires both an OLG license and an ABCA endorsement. The D.C. Attorney General has civil enforcement authority, alongside applicable criminal enforcement.
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Are licences available? If so: a) What is the duration of a licence? b) What types of licences are available? c) Are there different types of licences for B2C and B2B operators? d) Do software suppliers need to be licensed?
a. What is the duration of a licence?
Sports wagering operator licenses (Classes A, B, and C) are issued for five years and may be renewed for additional five-year terms. Sports wagering management services provider (MSP), supplier, and occupational licenses are renewed annually. Game of skill machine manufacturer, distributor, and retailer licenses also require annual renewal. Lottery retailer licenses generally renew every two years, while charitable gaming licenses are issued for specific events or approved operating periods.
b. What types of licences are available?
Sports wagering has three operator classes (Classes A, B, and C), which differ based on the location and type of operation and the extent to which the operator may offer in-person and online or mobile wagering. Depending on the license class, operators may conduct sports wagering at designated sports venues, other approved establishments, or through mobile platforms accessible throughout permitted areas of D.C. Separate licenses are available for sports wagering management service providers, suppliers, and certain employees.
Other gaming related licenses include lottery retailer licenses; licenses to conduct charitable bingo, raffles, and Monte Carlo night parties; and licenses for commercial bingo operations. The District also licenses manufacturers and distributors of game of skill machines through the OLG, while the ABCA handles retail licensing and endorsements for establishments offering those machines.
c. Are there different types of licences for B2C and B2B operators?
Yes. The District distinguishes between operators offering wagering directly to the public and business-to-business providers supporting those operations. Sports wagering operators must obtain a Class A, B, or C license. Management services providers that manage wagering operations or provide wagering platforms require an MSP license, while suppliers of equipment, software, systems, data, and related services generally require a supplier license. Entities sharing in sports wagering revenue, including marketing affiliates, also require an MSP license.
Separate licensing requirements apply to other gaming activities. The OLG licenses manufacturers and distributors of game of skill machines, while ABCA licenses retail establishments offering those machines. Suppliers of bingo equipment are also subject to separate licensing requirements.
d. Do software suppliers need to be licensed?
Yes. Providers of software, systems, or other technology necessary to conduct sports wagering generally require a supplier license from the OLG. Providers that also manage wagering operations may instead require an MSP license, depending on their role. Licensed suppliers must disclose the equipment and services provided to operators, and wagering equipment must undergo independent laboratory testing and approval. Separate licensing and technical requirements apply to game of skill machine manufacturers and distributors.
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Are any types of gambling products prohibited?
Yes. The District generally prohibits traditional casino gambling, including slot machines, roulette, and commercial poker, and does not authorize online casino gaming. Limited exceptions exist for licensed charitable gaming and certain games of skill machines.
Sports wagering is limited to approved events and betting markets. Prohibited categories include high school sports, events involving D.C.-based college teams, and most amateur sporting events.
Social casinos and sweepstakes are not expressly authorized as gaming categories and must be evaluated under D.C.’s general gambling laws.
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What is the headline application procedure? Please include any eligibility and other application requirements, including approximate application costs and any need to establish a local presence.
Sports wagering operator applicants apply through the OLG’s licensing process and undergo a review of their ownership, financial suitability, criminal history, and proposed operations. Applicants must submit supporting documentation and satisfy applicable background investigation, financial, technical, and bonding requirements. Incorporation in the District is not required, although certain licenses require an eligible physical location or other local presence. For example, Class C operators must maintain transactional servers within the District. Sports wagering operator and MSP applicants must also satisfy D.C.’s CBE participation requirements, generally through a plan committing at least 35% of their operating budget to qualifying CBEs, an eligible joint venture, or an approved waiver.
Initial sports wagering operator licensing fees are $1 million for Class A, $100,000 for Class B, and $2 million for Class C. MSP and supplier application fees are $10,000 each. Applicants may also incur additional investigation and processing costs.
Other gaming activities have separate application requirements.
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Do individuals within the business need to be personally licensed or authorised? If so, please provide headline requirements.
Yes. Individuals employed in on-premises retail sports wagering positions require occupational licenses. The initial and annual renewal fees are $100 each. Employees may work only in their licensed capacity. Controlling owners and influential executives, employees or agents also undergo suitability review in connection with the business license. Required disclosures include criminal history checks and fingerprinting.
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Is advertising of gambling permitted and, if permitted, how is it regulated?
Advertising lawful gambling is permitted subject to product-specific restrictions.
Sports wagering advertising is subject to detailed requirements under 30 DCMR § 2131. Advertisements must clearly disclose material conditions, identify the operator as licensed by the OLG, and include responsible gambling information. Advertising may not be false or misleading, target minors, excluded players, or individuals at heightened risk of gambling addiction, encourage chasing losses, or portray gambling as a solution to financial problems. Direct marketing requires player consent and an opportunity to unsubscribe.
Additional restrictions apply to game of skill machines, including prohibitions on exterior advertising signs and certain window and door advertisements.
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Are marketing affiliates permitted? If so, are they licensed or regulated?
Yes. Marketing affiliates are permitted, but licensing requirements depend on their compensation arrangements and the services they provide. Under D.C. law, affiliates that share in sports wagering revenue must obtain an MSP license from the OLG.
Affiliates compensated through fixed fees or customer acquisition payments are not automatically subject to MSP licensing, although their activities may require a supplier license depending on the services provided. The OLG evaluates supplier licensing requirements based on the nature of those services. Affiliate marketing must also comply with applicable sports wagering advertising restrictions, including prohibitions on misleading advertising and targeting minors or vulnerable individuals.
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What are the penalties for offering, facilitating or marketing unlawful gambling, and can the gambler be penalised for participating in unlawful gambling?
Violations of the District’s gambling laws may result in criminal penalties, including fines and imprisonment, depending on the offense. Unauthorized lottery promotion or advertising can carry up to three years’ imprisonment; maintaining prohibited gaming devices or inducing play can carry up to five years. The ordinary maximum individual fine for these offenses is $12,500, with higher penalties possible for organizations or offenses involving substantial financial gains or losses.
Participants may also face criminal liability. Placing unlawful sports wagers or acquiring interests in prohibited lotteries is punishable by up to 180 days’ imprisonment and a fine of up to $1,000.
Separate civil and administrative penalties apply to regulated gaming activities. The OLG may impose fines of up to $50,000 and suspend or revoke licenses for violations of sports wagering or game of skill machine requirements. The D.C. Attorney General may also seek injunctions and civil penalties of up to $50,000 for violations of those regulatory frameworks.
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Briefly detail key requirements for licensees, including ongoing payment and reporting requirements.
Sports wagering operators must maintain approved internal controls, secure wagering systems, adequate financial safeguards, and procedures to monitor suspicious betting activity. Operators must promptly report suspected violations and suspicious wagering to the OLG, and changes to licensing information generally must be reported within 10 days.
Operators must also submit annual financial audits conducted by a certified public accountant, and provide monthly reports detailing wagers received, prizes paid, gaming revenue, and player self-exclusions. Operators and MSPs must also maintain financial reserves sufficient to cover player account balances, outstanding wagers, and unpaid winnings, subject to a minimum of $25,000. Wagering transaction records must generally be retained for five years.
Ongoing financial obligations include applicable gaming taxes, licensing renewal fees, and reporting requirements.
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Briefly detail key anti-money laundering requirements.
Sports wagering operators and MSPs must maintain anti-money laundering controls designed to detect and prevent suspicious financial activity, including fraud and money laundering. These controls must be included in their internal control procedures submitted to the OLG for approval. Operators must also promptly report suspected unlawful activity and suspicious wagering transactions to the OLG.
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Briefly detail key responsible gambling (or safer gambling) requirements.
The minimum legal age for participating in permitted gaming activity is 18, although operators may impose higher age requirements. Sports wagering operators must verify players’ ages and identities and implement safeguards to prevent underage and impaired gambling.
Sports wagering operators and MSPs must maintain an OLG approved responsible gaming plan addressing player protections, employee training, and access to problem gambling resources. Operators must allow players to establish limits on deposits, wagering amounts, and time spent gambling, and take reasonable steps to prevent those limits from being overridden.
The OLG also administers a voluntary self-exclusion program. Operators must prevent excluded individuals from placing wagers and refrain from directing marketing or promotional offers to them. Additional protections include prohibitions on operators and their personnel extending credit to bettors and requirements allowing players to close their accounts at any time.
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Briefly detail shareholder reporting and approval threshold(s).
Sports wagering license applicants must disclose their ownership and control structures, including individuals and entities exercising control over the business. The OLG must approve controlling persons before issuing a license. For corporate applicants, control generally includes the authority to direct business operations or elect a majority of the board. For non-corporate applicants, individuals or entities holding a 5% or greater beneficial or ownership interest are generally considered controlling persons.
Changes in ownership may also trigger regulatory review. The OLG may suspend or revoke a license if more than 5% of a corporate licensee’s voting stock, or that of its controlling corporation, is sold to an unapproved person. Similar restrictions apply where an unapproved person acquires more than a 10% interest in a non-corporate licensee. Licensees must notify the OLG of changes to application information within 10 days and submit a new license application within three days following an acquisition, merger, or other change of control.
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Briefly detail the regulator’s enforcement powers, including sanctions and common themes.
The OLG has broad authority to investigate potential violations, inspect licensed premises, audit financial records, and enforce compliance with D.C.’s gaming laws. For sports wagering violations, the OLG may impose fines of up to $50,000, suspend licenses for up to 365 days, or revoke them. Licensees generally have the right to an administrative hearing and judicial review. The D.C. Attorney General may separately pursue injunctions and civil penalties of up to $50,000.
Key areas of regulatory oversight include licensing compliance, consumer protection, responsible gambling, and advertising practices. Enforcement also extends to game of skill machines, with oversight shared between the OLG and the ABCA. For example, in June 2026, the Alcoholic Beverage and Cannabis Board approved cease and desist orders against more than a dozen establishments for failing to apply for the newly required retail game of skill machine license.
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What is the tax rate?
The District imposes a tax on sports wagering operators based on their license classification: 20% for Class A, 10% for Class B, and 30% for Class C. The tax applies to gross sports wagering revenue, generally calculated as total wagers received less winnings paid to players and certain other qualifying prize-related costs. Other gaming activities are subject to different tax rates.
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Is cryptocurrency permitted for online gambling and, if permitted, how is it regulated?
The District does not expressly authorize cryptocurrency as a payment method for online sports wagering. Sports wagering regulations specify permissible methods for funding player accounts and placing wagers, including cash, credit and debit cards, bank transfers, and other methods approved by the. Although cryptocurrency is not expressly listed, operators may seek OLG approval to accept it.
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Are there any proposals for changing gambling laws and regulations in the next 12-24 months? If so, please provide an overview of the proposed changes and likely timing.
The Internet Gaming and Consumer Protection Act of 2026 (“IGCPA”) would legalize and regulate online casino gaming, including slots, blackjack, roulette, poker, and live dealer games, for adults aged 21 and older. The legislation would establish a licensing and regulatory framework administered by the OLG, including consumer protection, responsible gambling, and technical requirements. As introduced, the bill proposes a $2 million initial operator licensing fee, a 25% tax on adjusted gross gaming revenue, and separate 2% assessments for regulatory oversight and community programs. It would also expressly prohibit certain unlicensed sweepstakes casinos and dual currency gaming products.
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What key regulatory developments are proposed or on the horizon in the next 12-24 months?
Following the legalization of commercial bingo in 2025, the OLG is developing implementing regulations addressing licensing, permitted equipment, game operations, and consumer protections. The District is also implementing its revised oversight framework for game of skill machines.
If the proposed IGCPA is enacted, the District would need to develop a comprehensive regulatory framework for online casino gaming, administered by the OLG. This would include licensing, technical testing and certification, identity and location verification, payment processing, advertising, and responsible gambling requirements.
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Do you foresee any imminent risks to the growth of the gambling market in your jurisdiction?
We are not aware of any significant imminent risks that would materially impede the growth of D.C.’s gambling market. However, the market remains subject to evolving regulatory requirements, potential legislative changes, and broader economic and commercial factors. Licensing costs, operating restrictions, and the relatively limited scope of authorized gaming activities may also influence opportunities for market expansion. At the same time, proposed legislation to authorize additional forms of gaming could create new opportunities for operators and service providers.
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If a gambling start-up was looking for a jurisdiction in which to commence its activities, why would it choose yours?
The District offers an established regulatory framework for sports wagering, with opportunities for start-ups to partner with professional sports teams, entertainment venues, and hospitality businesses. Its licensing structure accommodates different business models, including retail and mobile sports wagering operations, as well as technology suppliers and service providers supporting licensed operators. The District’s relatively concentrated market and strong presence of professional sports teams and entertainment venues may be particularly attractive to businesses seeking to develop local partnerships or offer specialized gaming services. The availability of different licensing classes also allows businesses to pursue opportunities tailored to their operational capabilities and commercial objectives. However, the District’s gaming market remains relatively limited in scope, with traditional casino gambling and online casino gaming generally prohibited. Nevertheless, proposed legislation to authorize additional gaming activities could create further opportunities for businesses seeking to enter or expand within the market.
United States - Washington D.C.: Gambling Law
This country-specific Q&A provides an overview of Gambling laws and regulations applicable in USA – Washington D.C..
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What is the legal definition of gambling?
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What legislation applies to gambling? Please provide a summary of the legal/regulatory framework.
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Which body/ies regulate gambling?
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Are licences available? If so: a) What is the duration of a licence? b) What types of licences are available? c) Are there different types of licences for B2C and B2B operators? d) Do software suppliers need to be licensed?
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Are any types of gambling products prohibited?
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What is the headline application procedure? Please include any eligibility and other application requirements, including approximate application costs and any need to establish a local presence.
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Do individuals within the business need to be personally licensed or authorised? If so, please provide headline requirements.
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Is advertising of gambling permitted and, if permitted, how is it regulated?
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Are marketing affiliates permitted? If so, are they licensed or regulated?
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What are the penalties for offering, facilitating or marketing unlawful gambling, and can the gambler be penalised for participating in unlawful gambling?
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Briefly detail key requirements for licensees, including ongoing payment and reporting requirements.
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Briefly detail key anti-money laundering requirements.
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Briefly detail key responsible gambling (or safer gambling) requirements.
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Briefly detail shareholder reporting and approval threshold(s).
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Briefly detail the regulator’s enforcement powers, including sanctions and common themes.
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What is the tax rate?
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Is cryptocurrency permitted for online gambling and, if permitted, how is it regulated?
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Are there any proposals for changing gambling laws and regulations in the next 12-24 months? If so, please provide an overview of the proposed changes and likely timing.
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What key regulatory developments are proposed or on the horizon in the next 12-24 months?
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Do you foresee any imminent risks to the growth of the gambling market in your jurisdiction?
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If a gambling start-up was looking for a jurisdiction in which to commence its activities, why would it choose yours?