The Silver State’s Global Reach: Navigating Nevada’s New Grey Market Scrutiny

As a B2B supplier, your goal is simple: get your games onto as many platforms  as possible. But the regulatory landscape just shifted. On January 16, the Nevada Gaming Control Board (NGCB) issued a formal guidance memo that fundamentally changes the stakes for any entity with a Nevada license, or any partner doing business with one.

Historically, so-called “grey markets” where online gambling was neither legal nor explicitly illegal were, for many suppliers, a  comfortably blurry middle ground. If a country didn’t explicitly ban online gaming, or if they had a law but never enforced it, many suppliers felt safe to proceed knowing that they could justify their offerings even to historically strict U.S. state regulators. That era is over.

In the wake of new guidance,  the Nevada regulator now requires proactive, documented proof of legality. This isn’t just a Nevada problem; it’s a global supply chain mandate.

Beyond "No Enforcement": The New Nevada Standard

For years, many operators and suppliers  followed a  2016 New Jersey guidance memo: a market was only "black" if there was an express prohibition plus concrete enforcement. Nevada has now set a higher bar.

Under the new NGCB guidance, a jurisdiction can be deemed prohibited if it has laws expressly forbidding online gambling, regardless of whether the government actually enforces them. Furthermore, Nevada has identified "presumptively prohibited" jurisdictions - including major countries  like Australia, China and India—where the burden of proof lies with a Nevada licensee to prove that online gaming is not illegal. 

The Impact: * You can no longer rely on the absence of cease-and-desist orders or other enforcement actions as a green light. You must conduct sufficient due diligence and be able to demonstrate  why a market is legal before you enter, not just react when things go wrong.

The March Deadline and the "Always-On" Audit

The urgency is immediate. Nevada-licensed companies have until March 17 to provide the NGCB with a complete list of all international markets where their products are live. But this isn't a one-time filing.

The regulator now expects:

• Bi-annual Reviews: A legal status check of every jurisdiction every two years.
• The Compliance Register: A formal, documented paper trail showing exactly how you determined a market was suitable.
• Contractual Overhauls: B2B contracts between operators, suppliers and aggregators must now include specific compliance assurances and "kill switches" (termination clauses) if regulatory concerns arise.

If you are an aggregator or a studio partnering with a  Nevada-licensed giant, expect a call. They will need your legal due diligence to satisfy their regulator.

The Bottom Line: Nevada’s move signals a global shift toward "Suitability 2.0." Whether you are a small studio or a massive aggregator, being able to provide evidence-based compliance is no longer a luxury - it’s existential. 

Technical Lift vs. Regulatory Risk

The biggest pain point for product teams has always been the "lift and shift"; trying to figure out which markets require the least technical modification to enter. Now, they have to overlay that with an intense legal filter.

Entering a market because it's technically easy is a massive risk if that market sits on Nevada’s prohibited list. This is where Vixio becomes an essential part of the tech stack.

With Vixio, you can conduct threshold due diligence as to the legality or otherwise of different forms of online gambling across more than 200 jurisdictions worldwide. Using our enforcement tracker, blocklist monitoring solution and other Vixio tools, you’ll be able to evaluate how jurisdictions may be actively enforcing their laws - and all of this initial comparative due diligence can be done in minutes all within one platform.

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