Transcript for:
Sandra Douglass Morgan - Career and Insights on Gaming Regulation

hi sandra thanks very much for joining me today hi tim thanks for having me yeah it's uh absolute pleasure of ours um you've got a very interesting kind of story a career and i think we can we can kind of go straight in and you can kind of tell us a little bit about your your career overall in vegas and in law well sure so i am i'm a vegas native i've been here ever since i was about two my father retired at nellis air force base um here and and grew up here and i wasn't sure that i wanted to be an attorney until i actually went to the university of nevada reno for undergrad took a constitutional law class and knew that that was going to be my path um but i i didn't definitely start kind of in the gaming industry my mother worked in casinos kind of on and off when i was younger and i think um at that time you know a lot of children had one parent in the military maybe one parent in the gaming industry but i didn't really plan on going into law or regulation in the gaming industry it just kind of ended up there so i am i went to law school at unlv and worked at a firm initially for about three to four years and then had a great in-house opportunity at mgm which as a young lawyer i think was an opportunity you know of a lifetime because even though i was handling litigation matters uh for the company when you're working on those cases you do get a glimpse of the operations and why certain policies and procedures are in place and so it kind of gave me a different window into the industry other than the one that i heard from from my mom kind of growing up but at that time i realized i definitely wanted more a transactional experience and went on to the city of north las vegas i've worked there for about eight years and um ended up being the first african-american city attorney or person of color um in in the state of nevada to serve in that role and it was a deeply kind of gratifying position to be in public service i'm also at a very difficult time because when i joined the city was one of the top five fastest growing cities in the nation and by the time we i left we were on the verge of severe financial distress because of the unfortunate economic turn down at that time and um after that i went to a t and um you know obviously a big telecommunications company um and was appointed to the gaming commission at that time and that is a part-time commission because they meet once a month but are the final decision makers on all regulations and licensing approvals and i know it's kind of kind of interesting that i was at the commission appointed by then governor sandoval and then was appointed to chair the board um by governor sisilak because nevada and in the us it's a little bit rare because we have two kind of policy-making um regulatory boards but the gaming control board in nevada is a day-to-day regulator 24 7 with a you know a very strong and talented team of about 400 people across the state and um that's my immediate past position there um definitely um learned a lot from the great people that are there and and definitely had a better insight into the industry um and regulation and had a chance to meet wonderful regulators all across the u.s and the world too while i was there sure i mean it sounds like a very wonderful sort of um extensive career when it comes to uh being uh getting into gaming you mentioned kind of it wasn't your immediate kind of plan you didn't sort of wake up one day as a child and think i'll go into the gaming industry but do you think it was uh for kind of um top lawyers in nevada do you think it's almost almost destiny that you've got las vegas and gaming is kind of uh is going to attract kind of lawyers you know what i think i think that um my at the time i thought there's more than gaming in nevada and so as a young lawyer i wanted to try something outside of the industry that growing up here we we knew it's the dominant you know industry and it you know it's interesting when the law school opened here the first graduating class or the first graduating class was 2001. so i think they started in 1998 or 1999. the school was very focused on making sure they wanted to welcome students from everywhere that it wasn't just a kind of gaming um you know school and to encourage people to go there but what i think happened to me and as well as the unlv um law school the boy school of law is that they embrace the fact that we have this great resource of knowledge understanding integrated resorts how they're open we have more gaming licensees and in over you know i think 1200 in nevada than any other state so why not embrace something that we know very well and it has done great things um for our state and so as you know now there's a there's a master of laws at llm and gaming that the law school offers and i think you know now that i've been able to join an international firm as well i realize at covington and burling that you know there are certain things that we maybe take for granted in nevada that we're just so used to that we've seen such as you know regulated gaming or sports wagering those are things that we've all been accustomed to in nevada for quite some time that that states than the other states in the us are just now starting to legalize and regulate yeah certainly because obviously since passport is overturned um sports betting is all people in in kind of us uh us gaming essentially talk about but of course in nevada it's it's nothing new really it was it was always kind of regulated sports betting around there um obviously you mentioned mgm resorts uh a huge firm that you used to work with um how do you kind of reflect on reflect sorry on your time there kind of what were your key kind of learnings um i would say any interesting stories but i don't know from a legal perspective i'm not sure if uh if you're allowed to disclose the most interesting stories really um yeah i wouldn't be able to disclose kind of uh details about cases because of privilege but i will say that i was um to have the amount of resources especially when you're litigating a matter such as camera footage and i think most people should know that when you're at a gaming property you should assume that you're on camera but um i think some people maybe forget about that and so that was always great um to have access to to very helpful hopefully most of the times helpful evidence to kind of discount some of the allegations you know people come unfortunately to vegas sometimes um it's a good thing we want them to let their hair down and have fun in a safe way but sometimes their memories aren't exactly what um the footage showed so i'll kind of put it that way so it was great i think as a young lawyer to have great resources wonderful trained personnel that understand procedure that can kind of give us what we needed to be able to defend the company yeah absolutely and uh you you mentioned i mean you spoke kind of quite glowingly of uh you work with the regulator in nevada how do you kind of reflect on your time there and you mentioned as well there's there's the ngc and there's the ngcb um i mean again i'm not sure if other states might find that um confusing i'm not sure yeah and event is different because we created well the the state created this two-tiered system to ensure it and there's strict statutes on that you know prohibit association or participation with political parties and obviously gifts donations no other source of income for gaming control board members to ensure that the regulator is completely focused on gaming and that there's not going to be any outside influence and i can tell you that the you know the board members and the chairs that i've interacted with in the past um and even to this day take that very seriously they understand that any type of threat to the integrity of the board is obviously a threat on the industry which you know provides significant amount of resources and employment i'm in the state and i'm confident that you know other regulators in other states feel the same way but my time there i think that it's i miss them it's a great team and i don't think people really understand how much that that team there does some of the people have been there for 20 years and then you have some people obviously that are new that are bringing in new insights with respect to technology um you know and you know being able to use you know apps and obviously with covid the kind of um virtual working environment people they've been able to pivot and still do you know the business of the board whether it be enforcement investigations and technology approvals um as needed and i think just as you've seen with um payment modernization kind of being expedited or at least a greater understanding that we need to be able to allow other forms of payment has been somewhat expedited because of covet i think the board has also embraced and many other regulators who have also embraced kind of using technology to their benefit whether it be streaming meetings and providing electronic documents um for review just on that point there um i remember when i first when i first joined gaming insider um you know a few years back there was there was often talk from companies that regulators don't quite keep up with not specifically in the us or in nevada or anything but regulators don't quite keep up with technological change of pace as much i mean given the point you've made there do you think it's maybe uh uh the nevada regulator and others in the us have actually shown quite a good aptitude recently especially with covert and as you say kind of expedition of kind of cashless technology and that kind of thing you know i think they're definitely everyone should be commanded all the regulators should be commended for the work that they're doing because these investigations take time and when you're doing an investigation a lot of them require you know interviews if you can't travel that's that's a difficult thing to do in the broader context even beyond regulators you know there could be a lot of discussion and i think that the criticism you mentioned is definitely a fair point but these are usually regulators that are receiving funding from the from the government right and so obviously governments are looking for new revenue sources that's why you've seen kind of an increase i think in the legalization of sports wagering so it goes both ways yes i think the operators and and suppliers and manufacturers their job is to be to have you know the most up-to-date technology because they know that that's what the customer is expecting um we we would love i think everyone would like regulators to have more resources to be able to expedite those approvals but unfortunately due to the limited resources that they have sometimes they you know it falls a little bit behind back to sort of kind of your career and your path more recently obviously there was a you joined caesars and um just wanted to kind of ask you um i mean i mean how's that going first of all but also how uh what exactly does your role cover that what do you do for the with the company well i'm on the board of directors for caesar so i'm not um an employee and so i serve with a very talented group that um basically assists with you know strategic um initiatives and the vision for the company and you know making sure that the executive management team which is incredibly talented and has been able to kind of allow caesars to continue to grow and redefine itself you know to making sure that um the vision that the board has is aligned with what a management has been executing and of course you mentioned the management team because uh obviously the caesars brand is uh is is so strong but uh it's interesting to think that a couple of years ago it was the management team was effectively el dorado resorts and caesars and now you've kind of had this i guess this uh mega combination of the two and it was a historic kind of um merger at the time may still be kind of the highest fee um you know how do you kind of how do you describe working with that kind of management team at the moment they're they're incredible um gary carano is our executive chairman and he's um obviously his family was you know founded kind of the eldorado brand and right now our our ceo is tom reed an exceptional exceptional brilliant um ceo with i think a vision when he came in and the decision was made to acquire caesar's how that would be done and how it would be executed and i think the team's done a great job um you know anthony carano's the president and ceo you have brett younker cfo and they really took over at a very difficult time because um that merger was i think ultimately approved maybe in the in the spring or summer of of 2020 um but i think that this launch of caesar sports book and in so many states has been great and um i'm sure you've heard that you know gaming revenue for the land-based properties um have been have been well and met or exceeded expectations as well um i think that the timing of this interview works well because in new york um numbers just came out that caesars is right at the top in terms of market share for for mobile sportsbooks so i mean that certainly kind of backs up your point um when it comes to your your role with caesar's i mean you're also on a if i'm not mistaken on a couple of other board of directors at the moment how do you kind of balance all of that and i mean it sounds like you you juggle quite a lot really well it's time management and i think that's kind of i will continue to work on that but i the boards that um i'm a member of obviously caesars that the elder washington el dorado family the caesars family i think that they understood um me and what i could bring to the table as a nevada and obviously with my compliance and kind of risk management background and um i believe that you know they saw that value in me and i saw the vision that they had for the company which is why i decided to join them i'm also on the board of allegiant travel company that is also based in las vegas um a wonderful great um kind of growing airline that's mostly kind of based in the south obviously a lot of um a lot of um airports and routes in florida as well and also going to the midwest uh just a great management team and a great company that's kind of continuing to to grow its brand um so you know balancing those positions they um you know there's obviously meetings and i'll balance that um but i definitely was excited to join the law firm of covington and burling as well i definitely thought i could bring some expertise there in their gaming practice group and and that firm um is obviously well known as headquartered in dc's but just has such a wide breadth of talented lawyers and a really true depth of all regulatory experience not just gaming um but a lot of former regulators are there and so i think that it was it was a good fit for me because they understood what background i bring and how we can continue to assist and provide advice to policymakers absolutely so i mean you've kind of got a lot of areas covered um branched out of gaming certainly as well if we're to focus specifically on gaming um obviously uh mgm resorts um then kind of the the nevada regulators and now caesars what was the transition like from operator to regulator and more recently having been on the regulator side and sort of i guess being back on the operator side sure well i had about um there was a significant gap in time from when i left mgm before i joined um the gaming commission but um at the time that i joined the commission the the composition was much different and i was actually one of the few lawyers on the commission now i think they're they're significantly more but um and before then i was actually on the nevada athletic commission that governed and regulated boxing and mixed martial arts so i did have somewhat of a regulatory background before joining um the commission um but uh you know just working um and meeting with industry understanding what their issues their concerns are obviously meeting with people that have been at the board and and you know the chiefs and and the managers and the supervisors that have been at the border for a while understanding what their challenges were and making sure as the public policy mandates that there was going to be continued stability of the industry um and i think you know stability of the industry includes looking at other ways that the industry can you know safely provide additional kind of gaming experiences obviously in a safe manner being in tune with responsible gaming measures um and being able to do things more remotely or digitally as well but it was definitely was a transition and i think the transition was probably harder for me going from a regulator going back to um to the private sector because um you know for was obviously very rule-based and and sometimes i'm you know now focused on okay what does my client need obviously to get the best result that they can you know obviously within the parameters of the regulations so i'm still working on that adjustment but things are things are going well and i think you you've mentioned that there's a cooling off period um from uh leaving the uh the commission and joining caesars yes yes of course in nevada we have a cooling off period it's actually um in statute and you know any concerns about that actually there's a separate nevada ethics commission that kind of addresses those type of issues but there is a one-year cooling off period and so for that time um anyone that would actu i shouldn't say anyone anyone i think it's a a public officer um and there's a definition for that nevada law that um you cannot kind of go directly to the industry or to the um to the industry that you would have regulated or would have provided some type of advice for before so there was a one-year cooling off period um obviously i and many others um whether the the public officials or regulators when are not able to kind of go directly to the private sector yeah yeah it's an interesting rule but i think i think it's a good rule i think it's um uh i mean is that common practice kind of for states or is that something nevada just does quite well oh no i think it's i think it's pretty standard for for most states in the u.s i i you know i don't know i just do i know that i've spoken to some other regulars in other states and they're you know kind of um you know working on some other matters before they could go into the gaming industry or honestly when i was city attorney for example i couldn't necessarily go directly to work for a company that maybe received an approval from the city so it just it just depends circumstance yeah yeah yeah sure definitely makes sense um thanks very much for kind of all your analysis and answers so far so it's been a really interesting conversation i've got a final sort of overall topic um and it's quite broad really as someone who works in in gaming and and has worked in regulation and law at the moment kind of what are your kind of what's your overall take on on the main kind of regulatory issues of today in the us because obviously sports betting is is really accelerating um you know there's always there's always plenty of regulatory talking points but what are kind of the main ones uh for someone who's in the industry at the moment such as yourself and you know how do you kind of feel it's all where is it all going at the moment well i think it's going very quickly um and i think that um obviously there's there's a lot of laws and regulations that are being passed um and you see kind of comments made that you know state x is going to make sure this is done before the super bowl and things like that but as those happen and how those partnerships and sponsorships happen um they're happening quickly and i think that it's important to really have good sound regulatory counsel or legal advice when they're entering in when any regulated entity or even any business is partnering with a regulated entity to make sure that the rules are being followed because as you know and as we've discussed every state does have different regulations right and then and gaining likes these are all privileged licenses and so when you're entering a market it's really important to make sure that you understand the nuances of each state which is why um i think regulatory council is also important i also think um you're going to see consistent themes and discussions about responsible gaming as you know with the convenience of being able to use your phone or you know other um non-cash ways of payment also come you know potential regulations or at least some type of policies that will allow people to kind of limit the amount that they wager or notices and and things like that and so i think a lot of the responsible operators suppliers and manufacturers will also be focusing on um responsible uh wagering as well i know that's a big focus of the american gaming association yeah yeah absolutely um i mean as someone who sort of sits here on this side of the atlantic ocean the the uk market quite mature in terms of online and sports betting and there's a lot of regulatory issues that we're kind of experiencing at the moment a lot of focus on responsible gambling it's interesting to see kind of uh when and how that kind of hits the us market and maybe maybe the operators can do a better job of kind of leading that rather than maybe waiting till it's uh till regulators step in but it's it's it's all remains to be seen and and but as you say it's definitely going to be a big focus i think that's uh undeniable at this point absolutely absolutely with the us being such a nation in nascent industry with respect to online certainly things that can be learned from the uk as well yeah absolutely well sandra thanks very much for your analysis and and talking us through your career and it's been a pleasure having you on the jai huddle great thanks for having me you