New York state lawmakers Sen. Joseph Addabbo and Assemblyman Gary Pretlow have submitted a bill, which aims to expedite the process of awarding casino licenses in the New York City area. 

New Bill Proposes Earlier Deadline for NYC Casino Licenses to Boost State Revenue

The proposal stipulates that all casino license bids must be submitted by July 31, 2024. The bill also requires the New York State Gaming Commission to approve three licenses by March 31, 2025. As a comparison, according to the current schedule, licenses have to be awarded by December 31, 2025. 

Addabbo and Pretlow submitted the new bill as they consider the current timetable inefficient, reported The New York Post. They further added that it is delaying economic benefits for the state and believe that speeding up the licensing can generate billions of dollars in additional revenue for the state.

Addabbo noted that the prolonged timeline is holding up about 5,000 jobs and that a streamlined process needs to be implemented. The bill’s goal is not to benefit particular bidders but to eradicate the inefficiencies in the current system.

Some industry sources think that the current system is advantageous for those of the bidders who are facing political and zoning challenges. 

For example, Mets owner Steve Cohen, who proposed a $8 billion casino near Citi Field in Queens, and the Related Companies, proposing a $12 billion casino and office tower complex in Manhattan’s Hudson Yards, are some of the projects that are dealing with such hurdles.

However, the accelerated timeline that Addabbo and Pretlow are proposing could benefit existing slot parlors like Resorts World at Aqueduct and MGM Empire City at Yonkers. To get a license, all these entities need to do is expand their facilities to include live card games.

New Legislation Proposes $500M Upfront Fee for NYC Casino Licenses

As per the new legislation proposal, every bidder that gets a license must pay an upfront license fee of at least $500 million. The bill also allows two years to resolve any legal or land-use issues.

However, there are some significant challenges. For example, Cohen’s project needs state legislative approval to redesignate parkland around Citi Field for commercial use. However, state Sen. Jessica Ramos, who represents the area, has not yet backed this approval.

Assemblyman Pretlow, whose district includes the Yonkers racino, has expressed his frustration over the slow pace of the process. He noted that New York state is potentially forfeiting $2 billion in revenue.

Gov. Kathy Hochul, who oversees the gaming commission, has stated that she will review all legislation, which has been passed by both houses but has not made any statement either in support or against the accelerated casino licensing process. 

In addition to Cohen’s and Related Companies’ bids, other proposed casino projects in New York City include developments by SL Green/Caesars/Roc Nation in Times Square, Bally’s in The Bronx, Silverstein Properties in Hell’s Kitchen, and the Thor Equity consortium along the Coney Island boardwalk.

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During Las Vegas Sands’ first-quarter earnings call, CEO Rob Goldstein addressed both setbacks in New York‘s licensing process and the company’s interest in Thailand‘s gaming potential, shedding light on its strategic outlook amidst evolving market dynamics.

Las Vegas Sands Faces Extended Timelines in New York

In response to delays in New York’s casino licensing, Goldstein expressed frustration, citing ongoing uncertainties surrounding the timeline for approvals. Las Vegas Sands had anticipated progress in 2024 but now faces extended timelines, with decisions pushed back to potentially 2025 or 2026. 

Patrick Dumont, Las Vegas Sands president and COO, also expressed his exasperation: “Now they are saying 2025 or 2026, but I do not think we have any real clarity. And to be honest, it is confusing and disappointing because we have done a lot of work in New York and invested a lot of time into it. So I have no guidance because I do not really know what to say with candor and insight.”

Regulatory hurdles, particularly in New York City, have impeded advancements, with zoning amendments awaiting approval to facilitate casino developments within the city’s five boroughs. 

Moreover, legal disputes, including challenges from Hofstra University regarding a planned resort near the Nassau Coliseum, have further complicated matters. Goldstein emphasized the need for clarity and resolution in New York’s regulatory landscape, reflecting the company’s long-standing commitment to the market.

Las Vegas Sands Eyes Thailand Amidst New York Setbacks

Despite challenges in New York, attention turned to Southeast Asia, with Wall Street analyst Chad Beynon from Macquarie US Equity Research probing about prospects in Thailand. Goldstein responded optimistically, acknowledging Thailand’s potential to expedite developments. 

He highlighted the market’s allure, citing its sizable population, accessibility, and status as one of Asia’s premier resort destinations. Goldstein affirmed the company’s interest in Thailand, underscoring ongoing efforts to assess opportunities and determine feasibility in the region.

The discussion on Thailand aligns with broader industry sentiments, reflecting growing interest in the Southeast Asian nation’s gaming landscape. Thailand’s recent strides in passing legislation for legal casino gaming suggest that it may launch its first casino before Japan, potentially opening doors for rapid tourism and economic growth. 

With overwhelming support from the House of Representatives and favorable tax rates, experts anticipate Thailand to become a prime destination for international casino companies, possibly outpacing Japan in the race to establish integrated resorts. 

As Las Vegas Sands navigates through regulatory challenges in New York, the company remains committed to exploring new opportunities and expanding its global footprint. Despite uncertainties in mature markets, the company’s strategic vision extends towards emerging destinations like Thailand, where it seeks to leverage its expertise and capitalize on evolving market dynamics.

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The process for awarding three new downstate New York casino licenses may take significantly longer than initially expected. Previously, industry insiders and experts speculated that the bidding process for the licenses may open at some point this month. With the month passing and a range of processes left outstanding, it now looks less likely for the bidding to be launched during the first quarter of this year.

In fact, according to a new report, this lengthy process may be extended even by a year. A recently released report by Newsday, citing the opinions of industry insiders, suggests that the awarding of the downstate licenses may even happen at some point during the first quarter of 2025. This otherwise means that the process may take significantly longer than initially expected.

What’s expected now is for the Gaming Facility Location Board to release the answers to questions submitted by interested casino bidders. The first round of such questions was released back in August, while submissions for the second round, to which responses are yet to be released, started back in October. Once the Board releases the responses, a 30-day window applicable for bidders would open for casino operators.

Besides this process, casino license applicants must also clear outstanding issues related to zoning. Late last year, New York Mayor Eric Adams introduced a new proposal that sought to ease this process. This ambitious plan that sought to expedite the casino approvals faced opposition from Community Boards last month.

New Casino License Fees Missing from FY 2025 Budget

The potential delay, suggested by industry insiders, doesn’t come as a surprise, especially considering that the license fees from the three casinos did not make it into the fiscal 2024-2025 budget. The FY 2025 Budget sets a plan for the revenue through March 31, 2025.

In other words, New York may miss out on significant proceeds unless the three casino licenses are awarded. Early estimates predicted a license fee of $500 million per license or some $1.5 billion in extra proceeds for the state if the licensing is expedited.

The FY 2025 Budget, released by Gov. Kathy Hochul earlier this month, brought bad news for online casinos as well. Despite efforts toward the legalization of iGaming activities, the $233 billion budget did not include texts regarding the activity. According to lawmakers, this action may doom the legalization of the activity, at least for this year.

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Finland might be on the way to introducing a licensing model for online gaming. The country, which is the only EU member to still maintain a monopoly over iGaming, just broke ground by introducing a legislative plan to transition to a licensing system.

Finland’s online gaming monopoly, Veikkaus, commented on the matter, expressing its support for the move. According to CEO Velipekka Nummikoski, the company believes that regulation can benefit the whole Finish gaming market.

Nummikoski praised the Ministry of the Interior for what he called the most significant reforms in Finnish gaming yet. He hailed the government’s clear plan of action and said that he hopes that it would be able to channel players toward the legal market.

Under the new legislative plan, Finland will abolish Veikkaus’ exclusivity when it comes to online gambling. Still, the company will retain its monopoly over retail slots and the lottery.

Despite its apparent support of the measure, Veikkaus warned that the transition to a licensing model will likely lead to redundancies, forcing the company to restructure its business, close properties and lay off workers. According to the company’s estimates, as many as 240 employees may lose their jobs.

A New Age for Finnish iGaming

If Finland introduces a regulated gambling model, Veikkaus will split into two companies within the same group. One of the newly-formed entities will be Veikkaus’ arm which will retain its monopoly over retail slot machines and the lottery, while the other joins the competitive online market.

The Finnish government’s plans to introduce a licensing model come amid strong support for the introduction of regulated gambling. However, the transition process is set to take a few years at the very least. Under the current plans, the Ministry of the Interior will take two years to draft a legislative proposal for regulated iGaming.

The proposal will cover important matters, such as what games should be legalized, what the licensing and tax fees for online operators should be and how Finland would protect consumers from harm.

Finland’s decision to explore the possibility of introducing licensed online gaming marks a historic turning point for the country and will align it with other EU member states that use similar models.

The move was praised by the European Betting and Gaming Association, which highlighted that a licensing model will bring many benefits to Finland, including improved channelization rates and better player protections.

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Finland is considering a possible modernization of its online gambling laws. The European country is currently considering a licensing model like the ones used by most modern gambling markets.

Finland’s intentions were announced by the country’s Ministry of the Interior. The ministry introduced a legislative project that, if advanced, could replace the current monopoly with a licensing system. The move was loudly praised by the European Gaming and Betting Association (EGBA), an industry body representing Europe’s top iGaming companies.

Finland’s legislative project would draft proposals needed to make the transition to a licensing system. As a result, it will cover a number of important aspects, such as what activities will be legalized, what the taxes and fees for operators will be and how Finland will prevent gambling harm.

According to the EGBA, the Ministry of the Interior’s project will run through December 31, 2025, and will lead to the introduction of a legislative proposal in spring 2025.

The Move Would Align Finland to Other EU Member States

For reference, Finland is the only member of the European Union that still sports a monopoly regime for online gambling activities. The system’s deficiencies have become apparent in recent years with customers demanding more varied content and migrating to offshore websites.

This tendency has caused the country to lose control of the iGaming market and miss out on potential tax money.

According to the EGBA, the transition to a licensing model would benefit the Finnish market. The association expressed its support for the newly introduced legislative project, saying that it has the potential to increase player protection while boosting tax revenues. At the same time, the move would create a level playing field for operators.

The EGBA’s secretary general, Maarten Haijer, commented on the matter, saying that it is a “welcome step toward meaningful and overdue gambling reform” in the country. He highlighted the multiple boons a licensing model would bring, noting that it would also align Finland with other EU member states.

We look forward to continuing dialogue with the Finnish Government and local stakeholders as the regulatory discussions develop.

Maarten Haijer, secretary general, EGBA

As Finland considers the introduction of a licensing model, Norway continues its efforts to protect its monopoly systems, proceeding with its DNS blocking plans.

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Curaçao, the Dutch Caribbean island that everybody in the iGaming world knows very well, is currently going through a transformation process when it comes to licensing online casinos as the government implements the National Ordinance for Games of Chance.

The new legislation comes with a new licensing process, which kicked off at the start of September, when the Gaming Control Board has officially opened the license application portal.

The new portal is processing new applications under the rules of the current legislation while also registering all sublicensees which want to continue their operations without interruptions when the National Ordinance for Games of Chance go into effect. Moreover, when the new law comes into force there will be a new regulator in charge: the Curaçao Gaming Authority.

The new law stipulates that only companies that are registered in Curaçao can receive licenses. That leads to two main obligations for online casino operators: have a registered Curaçao address and employ at least one director in the country.

Until the National Ordinance for Games of Chance comes into effect, the government will process all new applications under existing legislation, so for the moment the operators are not required to have a physical office on the island or local employees.

In fact, those two aspects are the main changes that affect online casino operators that apply for licenses in Curaçao and for current license holders that desire to continue their operations.

The portal set up by the government contains all necessary information on how to apply for a gaming license, along with guidance on the entire process. Operators can submit their application starting on November 15.

Application Process in Detail

The application process is not very complicated, companies have to fill in just three forms: an application form, a corporate disclosure and a personal disclosure. All three forms are available to download from the government portal.

The personal disclosure form must be filled out for every Ultimate Beneficial Owners which hold at least a 10 percent stake in the respective company. The form also applies to top-level executives such as Chief Executive Officers.

The government has set a processing interval of two months, but that is the case only for applications which are filled out correctly. Applicants that are successful will receive a provisional license for six months and during that period they must submit audited policies and procedures.

Once the National Ordinance for Games of Chance will come into effect, the government will proceed with transferring all existing applications over to the new format, regardless of the stage of the application.

Source: “What will Curaçao’s transition period look like?“. iGaming Business. September 15, 2023.

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In recent years the Isle of Man has become an increasingly important hub for online casino and sportsbook operators and for casino software and content providers, mainly thanks to its reputable licensing process.

In fact, an operator which holds an Isle of Man B2C License can be regarded as a trustworthy entity as it must stick to strict rules and regulations in order to obtain the aforementioned license. Authorities in this jurisdiction also offer B2B licenses, with top providers like Yggdrasil already applying and obtaining such certification.

There are major changes happening to iGaming jurisdictions all over the world, but the Isle of Man license has remained a symbol of reputation for online casino operators, certifying their compliance both with industry standards and legal requirements.

Moreover, any operator holding an Isle of Man B2C License is required to safeguard the deposits of players and make sure they receive their winnings if they prove to be true and fair.

Operators holding a license in the Isle of Man are also required to uphold principles of fairness, transparency, and security, making sure that they protect the interests of all parties involved. License holders have to submit reports to the Isle of Man Supervision Commission every three months, and in those reports they have to include vital information in regard to Anti-Money Laundering/Combating the Financing of Terrorism reporting, as well as financial data.

Access to Multiple Markets

Holding a license in the Isle of Man allows online casino and sports betting operators to enter multiple markets on different continents, including Asia, Africa and South America. These are pre-regulated markets which can be very lucrative for operators.

Moreover, the Isle of Man has a special status, and it can offer appealing financial incentives, which include corporation and capital gains tax of 0%. Dividend taxes are also non-existent in this jurisdiction.

Operators licensed in the Isle of Man can choose any software provider they like with no restrictions whatsoever, and they are also free to pick between the numerous payment service providers available on the market.

In general, an operator which applies for a license in the Isle of Man should not have to wait more than twelve weeks between making the submission and the actual hearing regarding the respective license.

Among the most popular online casinos which hold an Isle of Man B2C License we can mention 188Bet Casino, 5Dimes, Luckbox Casino, King Dice Casino, CasiYou Casino and Spin-Ace Casino.

Source: “The Crucial Role of the Isle of Man B2C License“. European Gaming. September 11, 2023.

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The Curaçao Gaming Control Board (GCB), Curaçao’s gaming regulatory body, has taken an important step in regulating the country’s online gambling by officially opening the application process for those operators looking for new online gambling licenses.

Latest online portal

From Friday, September 1, interested operators may access the GCB’s newly launched online portal, which provides guidance to new applicants on the licensing procedure. Once inside, they may fill out a license application form and see instructions and downloads, which are there to make sure everything goes smoothly. Additionally, submission of finalized applications will begin in November of this year.

The portal isn’t only open to the newest operators, but also to those who already own existing sub-licenses. However, those operators can operate unhindered and “under their current arrangements.” What’s more, the latest opening of the portal represents a preparation for the National Ordinance for Games of Chance (LOK).

However, the latest licensing process does not “reform the National Ordinance on Offshore Games of Hazard, Curaçao’s existing legislation, but adds to it.”

Temporary license

As soon as the submission of finalized applications is completed by the end of November, those who have been officially accepted for a license will receive a temporary license from the aforementioned regulator. Additionally, this will be subject to the adoption of revised policies as well as procedures during a period of 6 months of its issuance.

However, the most important benefit is that those operators who have officially received the mentioned license will not have to apply again under the aforementioned LOK, because their position will be “transferred to the new authority.”

LOK to change the excising regulatory framework for online gambling

The goal of LOK is to update and simplify the regulatory framework for online gambling, ranking it with the best global standards and practices. In addition, it will present the newest licensing requirements, improved oversight to make sure the continued fairness and integrity of Curaçao’s online gambling segment, and compliance measures. In addition, this new law will certainly be “monumental for the market”, although it was once defined as “passive when it comes to regulation.” Relatedly, after it was pointed out that the newest, updated licensing standards could lead to the removal of excising operators from the region, the Minister of Finance of Curacao, Javier Silvania, commented that “he saw no issue with the matter.”

Because the country’s excising law requires operators to submit application for 1 out of 4 “existing master licensees” to obtain a sub-license, once the LOK comes into effect, the holders of the above sub-licenses will have a period of 3 months to file new application to the regulator to receive a “direct operator license.” 

Speaking about the details of the newest licensing process, Curaçao’s Finance Ministry legal advisor, Sixiènne Jansen, said at the iGB L!VE held in July: “The application process consists of three forms. Each of the forms will require relevant supporting documentation. The first is an online gaming application, in which the applicant will provide projections for business operations and strategic targets. The second is a personal declaration, detailing information about key figures involved in the business. A source of funds check will be carried out on any involved person with more than 10% control of the business. The final form consists of corporate and business disclosures.”

Source: “Curaçao opens license application portal”. IGB. September 1, 2023

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Changes are coming to the online gambling jurisdiction of Curacao with a new law coming into effect soon. For background and a frame of reference, readers can find more information at the end of this article.

Beginning September 1, all new licenses will be issued by the Curaçao Gaming Control Board (GCB).

At a recent iGB LIVE (iGaming Business conference) Curaçao’s Ministry of Finance, Sixienne Jansen laid out how the online gaming licenses issued by the jurisdiction of Curacao will function beginning on September 1, 2023, under Curacao’s National Ordinance for Games of Chance (LOK).

LOK is Not Yet the Law of the Land

It’s important to note that the LOK is not yet the “law of the land” but binding agreements exist between Curacao and Amsterdam for its content and full implementation. After August this year, new licenses will be issued to the Master License holders under new rules, even though the LOK has not been introduced into parliament yet. In order to ensure continuity, all four Master License holders will automatically receive one of the new licenses on September 1. The license will be provisional and valid for one calendar year.

The LOK will reform how online gambling licensing will work for foreign operators. Nearly all licensed offshore casinos accessible to players in the United States are licensed in and regulated by Curacao.

Under the current law, there are four Master License holders in Curacao and those license holders can issue “sub-licenses” for operators of any game of chance or skill – whether it is poker, table games, bookmaking, online casinos, lottery, or any other form of remote gambling. By some estimates there could be as many as 12,000 gambling operators licensed in Curacao. However, the number of active operators is most likely much smaller

The Curacao government plans to change the entire system in a phased reform without disrupting current business operations.

According to Jansen: “No operator is going to have to pause or stop any business as a result of anything done by the Ministry. One of the primary elements of the transitions into the new regime is to facilitate uninterrupted continuity of all operations of sublicense holders.”

When the LOK actually becomes law, all “sub-licensed” operators will only have 90 days to apply for a new license without regard to any time remaining on their former license. However, Master Licensers will no longer issue any new permits and all interim or provisional licenses will be issued directly by the Curaçao Gaming Control Board (GCB). Those licenses will automatically convert into LOK licenses later on.

New Regime to Comply With International Standards

However, the new regime will be a bit tighter to conform more to international standards. While current license holders already have specific obligations and are investigated by the Master License holders, three forms must be submitted by operators under the LOK whereas the application process under the current regime has never been fully explained to the public.

• Online Gambling Application:
• Personal Declaration:
• Corporate Disclosures:

“Once an applicant has satisfied the GCB in terms of the forms and documentation submission, then a license will be issued,” Jansen said.

“Within 6 months of that license audited policies and procedures will need to be submitted for evaluation.”

The same regulations that apply now will continue to be binding during a 9-month transitional phase so there should be no disruption of business practices for operators.

Jansen explained that operators who don’t wish to participate in the new regime will have ¾ of a year to wind up their businesses under existing regulations: “For those operators who do not wish to move to the new licensing regime, they can continue to conduct business up until the date the relevant master license expires,” said Jansen.

A summary of points regarding the new licenses includes the following:

• Licenses issued from September 1 will be issued by the GCB under current legislation and regulations and will not immediately be controlled by the LOK as it is not yet the “law of the land”.
• Sub-licenses will not be issued by the GCB, however, they will still be available from master License holders from September 1, 2023, until the LOK is implemented.
• New provisions addressing anti-money laundering and responsible gambling will become known to the public as they will be part of the new licenses.
• Current license holders or those with approval in process should consult with their master licenser for more information on how to proceed – this includes operators whose licenses are currently “on hold”.

Business as Usual – For Now – As Operators Go – New Process Coming

“Contrary to much speculation, there has been no change whatsoever to the legislation or permissions since the minister publicly announced the drafting of the new legislation last November,” said Jansen.

One point bears repeating:
Beginning September 1, all new licenses will be issued by the Curaçao Gaming Control Board (GCB).

The Minister is expected to issue further guidance and more updates in September as well as a new fee structure for operators.

More Information on Curacao Gambling Law

Curacao is an online gambling website license provider and casino regulator with an antiquated and semi-transparent framework that is little understood by laymen and government officials in other nations. In a nutshell, the government has issued “Master Licenses” to four Master Licensers who then accept or reject individual gambling operators and issue “sub-licenses” to online casinos, bookmakers, and other remote gambling providers.

More background on the former “Netherlands Antilles” island shows the difficulty in whether to even call it a country or to explain its relationship with the Netherlands, its independence, or its obligations to the Dutch government.

The following is from Wikipedia and is known to be a true statement: “Following a referendum, and as a result of constitutional change, Curaçao became a constituent country within the Kingdom of the Netherlands on October 10, 2010.”

The further background shows that since that time the kingdom and the government in Amsterdam have wrestled with how to modernize gambling law there and more recently, to bring it more in line with how regulation and gambling law enforcement functions in other jurisdictions.

The Netherlands is a parliamentary democracy. Dutch people can choose who represents them in parliament. The Netherlands is also a constitutional monarchy.

Further complicating the push for reforms from the Dutch government includes the following fact:
“Curaçao has full autonomy on most matters, with the exceptions summed up in the Charter for the Kingdom of the Netherlands under the title “Kingdom affairs”.

It wasn’t until the small island constituency needed assistance from Amsterdam during the world health emergency of the Covid pandemic that the Dutch government was able to exert enough influence over Curacao to “encourage” them to change the way gambling regulation and enforcement is handled and to get them on a timeline to implement those changes.

It is also important to note that the Netherlands itself has only recently reformed its online gambling laws.

The UK’s Law Review is a well-known and trusted website with specific and well-cited information on gambling law around the world. Lawyers there state the following about Dutch online gambling law:
“As of 1 April 2021, remote gambling licenses are available for casino games and sports and horse race betting.”

A more transparent regulatory framework with public and private assurances that it is in line with international standards can only be a good thing for Curacao. More accountability in regard to responsible gambling measures can only improve the player experience. However, until a process for complaints is outlined by the CGB and it is shown to be working on behalf of players, perceptions are not likely to change much.

If the CGB is no more responsive than most of the Master License holders have been to “small” complaints, it will have been an exercise in futility and lip service to the problem of murky terms and conditions including “gotcha” and “God” clauses. As it stands now, only a serious breach of licensing terms will be investigated and the public has no direct knowledge of what those terms might be and rarely if ever learns the result of an intervention.

Source: Curaçao: All master licences to get one-year extension, iGaming Business, July 12, 2023

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This comes after the Nebraska Racing and Gaming Commission granted a license to Caesars Entertainment, Harrah’s owners, and the company’s local investors and representatives, the necessary licenses to press on with the opening.

Harrah’s Nebraska to Open Temporary Venue as Construction Lasts

This is going to be the third commercial gaming venue in the state. As the constriction of the property lasts, however, the company will be able to operate a temporary casino out of Platte County Agricultural Park in Columbus. The permanent venue is expected in 2024.

Caesars Entertainment and local investors spent a considerable amount to ensure that the project will come to fruition. The project has cost $75 million and the casino will cover an area of 40,000 square feet. Right now, the casino is supposed to commence operations with 500 slot machines and 20 table games, but expansions may be available later on.

The casino and hotel will be managed separately, with the gaming floor falling within the remit of a local partner whereas the hotel will be run by Marriott International. The temporary property is set to open on Monday, June 12, at 9 am. Harrah’s Nebraska is already looking up to fill various positions and ensure that its project is feasible.

Meanwhile, Nebraska has seen a mounting interest in casinos with WarHorse Casino Lincoln opening back in September and the Grand Island Casino at Fonner Park launching in December. The quick succession in openings is indicative of the state’s increased and sustained interest in gaming as well as the liberalization of the activity.

Expansion in Nebraska’s Casino Landscape Continues

WarHorse is presently to also expand its reach with a new $300 million project, the WarHorse Casino Omaha at Horsemen’s Park, which will be forthcoming either later this year, or as a more likely timeline puts it – in 2024. The fact that there have been so many casino projects recently is not surprising at all.

The state voted to back commercial gaming during the November 2020 election and essentially expanded racetrack casinos to Vegas-style casino resorts that feature slots, sports betting and table games, a major stride forward for the state which has long pushed back against the idea of expanding regulated gambling in any capacity. Things are now changing with Harrah’s Nebraska almost on the horizon.  

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