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Pennsylvania regulators have issued a deadline for online gaming operators and suppliers to come into compliance with a series of new requirements for virtual dealer table games and a specific version of online blackjack.
In May, the Pennsylvania Gaming Control Board (PGCB) issued guidelines for iGaming licensees offering online table games using virtual dealers, which are described as “interactive games that simulate the play of table games that replicate a live casino experience using pre-recorded video footage of dealers”.
The games also replicate live casinos using computer-generated imagery and green screen technology but are determined by a random number generator (RNG) rather than the actions of a live dealer.
To maintain compliance with PGCB standards, online casino operators will be prohibited from listing virtual dealer games under the “Live Dealer” category on any gaming platform, while clear disclaimers must be displayed both on the game loading screen and within the game's rules that the dealer video is pre-recorded and all outcomes are determined by an RNG.
In a memo, PGCB executive director Kevin O’Toole reminded licensees that the guidelines also require a message to be displayed on the loading screen for each virtual dealer game enabling players to check an acknowledgement box before proceeding.
The message must include the “following or substantially similar” language: “This game features pre-recorded video footage of dealers. All game results are generated by an approved and independently tested random number generator.”
The PGCB also requires game rules or help screens to specify that virtual dealer table games merely replicate a live casino experience and “game outcomes are determined by an approved and independently tested random number generator, rather than by physical table game devices”.
Besides new guidance on virtual dealer table games, the PGCB has also issued new guidelines for operators and suppliers offing blackjack games that include the bet behind feature.
The bet behind feature allows a player to place a wager on the outcome of a seated player’s hand instead of playing their own hand. Bet behind participants share in the seated player’s results without influencing the seated player’s decisions, according to the PGCB.
O’Toole explained that these games are permitted in live-dealer and RNG blackjack games online but can only be offered in games with limited seating and may be offered regardless of whether all seats at the table are occupied.
Among the list of PGCB requirements, seated player setting may be defaulted to allow bet behind wagers, but they must have the ability to disable their seat from accepting those wagers, and seated players cannot bet behind wagers on their own hands, although they may place bet behind wagers on other seated players.
Regulators also required operators to establish direct minimum and maximum wagers for seated players and bet behind players, with the limits clearly displayed to players. In total, the PGCB laid out 15 requirements that licensees must follow to offer the bet behind feature on online blackjack games.
O’Toole made it clear in both memoranda that the purpose of issuing guidelines for both virtual dealers and bet from behind games was to “ensure consistency and compliance” with control board standards.
The requirements are effective immediately for games that have not yet been approved by the PGCB, including those that are currently pending certification by the board or an independent testing lab.
O’Toole added that virtual dealer and bet from behind games that have been approved by the control board, including those currently offered on iGaming sites, must comply with the requirements, including testing and board approval, by August 20.
Promotional Play Eligibility On Live Dealer Games
Before the launch of the first live gaming studio in Pennsylvania in October 2020, PGCB staff reviewed requests to allow promotional play wagers on table games, but initially decided against allowing licensees to deduct the free bets.
Almost five years later, the PGCB has notified operators that they will be able to deduct promotional wagers in live dealer games from gross interactive table game revenue, provided certain conditions are met.
Promotional play may only be utilized on main wagers that have payout odds of one to one, the PGCB noted .An exception is allowed for payout odds of three to two on player blackjack outcomes in blackjack or similar authorized blackjack-like games as approved by the control board.
Promotional wagers must result in unrestricted cash payouts that players can withdraw immediately, and promotions must be submitted to the control board as required by state gaming regulations regarding iGaming promotions.
The Gaming Act puts no restriction on the amount of promotional play that can be offered for live table games, according to the PGCB.
“Operators must update their internal controls to describe how their interactive gaming system is configured to ensure compliance with these requirements,” the notice added.
