Additional Standards for Class II Games Played Using Mobile Devices 

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FSST Interactive Additional Standards

for Class II Games Played Using Mobile 

Devices

Definitions –

• Authentication process – A method used by a system to verify the validity of software. Such method requires the calculation 

of an output digest, which is compared to a secure embedded value. The output digest shall be of 128-bit complexity, at a 

minimum. Software shall be deemed to have been authenticated if the calculated digest equals the secure embedded value.

• Authorized mobile game – Any game authorized by the TGRA for use with a Class II GamingSystem.

• Class II Mobile Device (C2MD) - A communications device, whether owned by the Tribe or a patron, that functions as a 

player interface by connecting to a Class II Mobile Gaming System via a secure wireless network, and which allows play ina 

Class II game if the patron is located within a TGRA approved Class II Mobile GamingArea.

• Class II Mobile Gaming – Class II gaming that occurs on a Class II Mobile Device located within a TGRA approved Class 

II Mobile Gaming Area.

• Class II Mobile Gaming Area (C2MGA) - The specifically defined geographic area solely comprised of “Indian lands” as 

that term is used in 25 U.S.C. §2703(a)(4), as amended or renumbered from time to time, once such area is authorized by the 

TGRA for the use of Class II Mobile Devices to participate in Class II MobileGaming.

• Class II Mobile Gaming System – A type of Class II gaming system that includes all components that utilizecommunication 

technology and function together to aid the wireless play of Class II games, including accounting and geolocation functions, 

within an authorized Class II Mobile Gaming Area.

• Communication Technology – Any method used and any components employed to facilitate the transmission of information, 

including, without limitation, transmission and reception by systems based on wireless network, wireless fidelity, wire, cable, 

radio, microwave, light, optics or computer data networks. This term does not include the Internet.

• Dormant mobile account – A mobile wagering account, which has had no activity for a period of time predetermined and 

approved by the TGRA.

• Funds on mobile game – The sum of pending wagers and funds transferred to a game not yet wagered less pendingwins.

• Mobile Wagering Account – An electronic ledger operated and maintained by the Tribe for a patron for use in connection 

with the patron’s gaming using a Class II Mobile Device. The ledger shall record information and provide printable reports 

relative to such play including, but not limited to the following types oftransactions:
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o Deposits;

o Withdrawals;

o Debits;

o Credits;

o Service or other transaction-related charges authorized by the patron; and

o Adjustments to the wagering account.

• Multi-factor authentication – A type of strong authentication that uses two of the following to verify a patron’sidentity:

o Information known only to the patron, such as a password, pattern or answers to challenge questions;

o An item possessed by a patron such as an electronic token, physical token or an identification card; or

o A patron’s biometric data, such as fingerprints, facial or voice recognition.

• Patron session – A period of time when a patron is logged on to a Class II Mobile Gaming System.

• Pending wager account – The account maintained by a Class II Mobile Gaming System that holds the total balance of all 

wagers pending disposition and all other funds attributable to uncompleted games.

• Return to Player or RTP – The portion of wagers returned to patrons during the game after a certain number of games played.

• Secure transaction file – A file that contains data, which is unalterable or cannot be modified without detection.

• Strong authentication – A method that has been demonstrated to the satisfaction of the TGRA to effectively provide higher 

security than a user name and password alone

• Suspended account – A Mobile Wagering Account that has been temporarily disabled from engaging in wageringactivity.

547A. Class II Mobile Gaming 

The gaming facility shall ensure that:

(1) A secure independent network shall be utilized solely for Class II Mobile Gaming;

(2) The Class II Mobile Gaming System shall authenticate the patron before a wager may be placed using aC2MD.

a. An approved authentication mechanism shall be utilized to verify that the C2MD is being operated by an authorized 

person who is at least 21 years of age;

b. During play, the authentication method shall be automatically initiated on a regular basis as determined bythe TGRA, 

such as a patron session timeout or periodic reapplication of the patron’s user identification and password; and

c. Authentication shall be capable of being initiated on demand.

(3) All wagering communications between the C2MD and the Class II Mobile Gaming System must meet the standards of25 C.F.R. 

§ 547.15.

a. Wireless communication between the Class II Mobile Gaming System and C2MD shall be conducted using a closed 
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security method that links the Class II Mobile Gaming System and the C2MD and authenticates both the C2MD and 

the Class II Mobile Gaming System as authorized to communicate over that link.

(4) The server and network infrastructure supporting the Class II Mobile Gaming System shall utilize a stand-alone firewall, which 

must isolate the access points (AP) fromother network components;

a. The firewall must maintain an audit log and shall immediately disable all communications and generate an error event 

if the audit log becomes full.

b. The audit log shall include the following information:

i. All changes to the firewall configuration;

ii. All successful and unsuccessful connection attempts through the firewall; and

iii. The source and destination IP address, port numbers and MAC addresses.

(5) The Class II Mobile Gaming System must provide a printable report of failed network access attempts, including time and 

date stamp, device name, and hardware identifier of all devices requesting access to the network.

(6) The location of the C2MD shall be monitored and recorded by a TGRA approved geolocation method embedded into the Class 

II Mobile Gaming System while the playeris logged in.

a. The geolocation method employed may include an connections through a public carrier or internal wireless fidelity 

network.

b. All initiated game play from the C2MD shall be immediately suspended and future game play disabled if the C2MD 

moves to a location beyond the TGRA authorized C2MGA or loses connectivity with the Class II Mobile Gaming 

System.

c. If suspended or disabled, all players shall be required to re-authenticate before resuming game play.

(7) The C2MD shall be sufficiently isolated within the Class II Mobile Gaming System so as to restrict the C2MD from 

unauthorized access to system components.

(8) The Class II Mobile Gaming System shall:

a. Ensure continued operation in the event of a temporary power failure via an Uninterrupted Power Supply(UPS);

b. Maintain the integrity of the hardware, software, and data contained therein in the event of a shutdown;

c. Ensure the system recovers to the state it was in prior to any system outage;

d. Have physical and logical controls, as appropriate, to ensure that only authorized hardware components are connected 

to the system;

e. Ensure only approved C2MD software is used to conduct gaming activity;

f. Ensure that the C2MD meet minimum compatibility requirements in order to conduct gamingactivity;

g. Be designed with a method for the TGRA to approve all game software installations before the game software may be 

offered to patrons;

h. Ensure the game software installed on the C2MD shall be designed such that it may only communicate with the 
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authorized Class II Mobile Gaming System;

i. Ensure the game software installed on the C2MD shall employ security methods including encryption and stronguser 

authentication methods;

j. Provide the administrator the capability to disable the C2MD at any time;

k. Ensure any mobile gaming software is designed with a method to permit the validation of software using a Gaming 

Authentication Tool (GAT) or other method approved by the TGRA;

l. Perform an authentication process on all control programs on demand and at least once every 24 hours;

m. Provide a mechanism to notify the operator whenever an authentication process has failed; and

n. Notify patrons, via the C2MD, of software that is scheduled for or ordered to be removed by the TGRA. Unless 

otherwise authorized by the TGRA, the system shall:

i. Immediately disable a game, which has been ordered to be removed by the TGRA; or

ii. Notify the patron that the game will be removed at the conclusion of the round of play.

(9) Class II Mobile Gaming Systems shall provide a patron with the ability to view the outcome and subsequent account balance 

changes for the previous game including a game completed subsequent to an outage (for example, network disconnection or 

C2MD malfunction).

(10) Game play shall be initiated only after a patron has affirmatively placed a wager and activated play.

(11) The Class II Mobile Gaming System shall not induce a patron to continue placing wagers when play is in session, when the 

patron attempts to end a session, or when the patron wins or loses a bet.

(12) No auto play feature shall be permitted in game software unless authorized by the TGRA.

(13) A C2MD used for mobile gaming shall not contain patron account information or game logic that determines the outcome of 

any game.

(14) C2MD software used for mobile gaming shall not contain unauthorized data collection, file extraction, malware, or anyother 

feature that compromises the integrity of the C2MD or the data contained therein.

547B. Class II Mobile Gaming System standards

(1) The Class II Gaming System shall utilize sufficient security to ensure patron access is appropriately limited to the account 

holder. Unless otherwise authorized by the TGRA, security measures shall include at a minimum:

a. A Username;

b. Password of sufficient length and complexity to ensure its effectiveness;

c. Upon account creation the option for users to choose “strong authentication” log in protection;

d. Method for securely issuing, modifying, and resetting a patron’s account password, Personal Identification Number 

(PIN), or other approved security feature, where applicable; and

e. Electronic notification to the patron’s registered e-mail address, cellular phone or other device each time a Mobile 
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Wagering Account or security features modified is accessed provided however that a patron may opt out of such 

notification.

(2) The Class II Gaming System shall be designed with a methodology approved by the TGRA to ensure secure communications 

between a C2MD and the Class II Mobile Gaming System.

(3) The Class II Gaming System shall be designed to detect, report, and disable accounts when the following activity is identified:

a. Suspicious behavior, such as cheating, theft, embezzlement, collusion, money laundering, or any other illegal activities; 

and

b. Participation or attempted access by Excluded persons or any person who is prohibited from entering a tribal casino.

(4) Patron account access information shall not be permanently stored on a C2MD used with the Class II Mobile Gaming System. 

Such information shall be masked after entry, encrypted immediately after entry is complete, and may be temporarily stored 

or buffered during patron entry provided that the buffer is automatically cleared asfollows:

a. After the patron confirms that the account access entry is complete; or

b. If the patron fails to complete the account access entry within one minute.

(5) Unless otherwise approved by the TGRA, the Class II Mobile Gaming System shall associate a patron’s account with a single 

C2MD during each patron session.

(6) Each patron session shall have a unique identifier assigned by the Class II Mobile Gaming System.

(7) The Class II Mobile Gaming System shall immediately terminate a patron session whenever:

a. Required by the TGRA or gaming facility;

b. The patron ends a session;

c. The patron fails any authentication during a game or patron session; or

d. A system error impacts game play.

(8) Class II Mobile Gaming Systems shall employ a mechanism that can detect and prevent any patron-initiated wagering or 

withdrawal activity that would result in a negative balance of a Mobile Wagering Account.

(9) Class II Mobile Gaming Systems shall disable a patron’s account after three failed login attempts and require strong 

authentication to recover or reset a password or username.

(10) Class II Mobile Gaming System shall require at a minimum, a patron to re-enter his or her username and password after 15 

minutes of user inactivity, as measured by the Class II Mobile Gaming System.

(11) Class II Mobile Gaming Systems shall employ a mechanism that places a Mobile Wagering Account in a suspendedmode:

a. When requested by the patron for a specified period of time, which shall not be less than 72 hours;

b. When required by the TGRA; or

c. When initiated by the gaming facility that has evidence that indicates:

i. Unauthorized play, including wagering by an excluded or banned patron;

ii. Illegal activity;
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iii. A negative patron account balance; or

iv. A violation of the terms of service has taken place on an authorized patron’s Mobile Wagering Account.

(12) When a Mobile Wagering Account is in a suspended mode, the gaming facility shall not remove funds from the account 

without prior approval from the TGRA and the system shall:

a. Prevent the patron from engaging in mobile gaming;

b. Prevent the patron from depositing funds;

c. Prevent the patron from withdrawing funds from his or her Mobile Wagering Account, unless the suspended mode was 

initiated by the patron;

d. Prevent the patron from making changes to his or her Mobile Wagering Account;

e. Prevent the removal of the Mobile Wagering Account from the gaming system; and

f. Prominently display to the authorized patron that the account is in a suspended mode, the restrictions placed on the 

account, and any further course of action needed to remove the suspended mode.

(13) The Class II Mobile Gaming System shall be capable of allowing a patron to voluntarily establish the following responsible 

gaming limits. Any decrease to these limits shall be effective no later than the patron’s next log in. Any increase to these limits 

shall become effective only after the time period of the previous limit has expired and the patron reaffirms the requested 

increase.

a. A deposit limit shall be offered on a daily, weekly, and monthly basis and shall specify the maximum amount of money 

a patron may deposit into his or her Mobile Wagering Account during a particular period oftime.

b. A spend limit shall be offered on a daily, weekly, and monthly basis and shall specify the maximum amount of patron 

deposits that may be put at risk during a particular period of time.

c. A time-based limit shall be offered on a daily basis and shall specify the maximum amount of time, measured hourly 

from the patron’s log in to log off, a patron may spend playing on the Class II Mobile Gaming System, provided, 

however, that if the time-based limit is reached a patron will be permitted to complete any round of play in progress, 

or active or prepaid tournament.

(14) The Class II Mobile Gaming System shall implement automated procedures to identify and prevent the following persons 

from placing a wager:

a. Persons under the age of 21;

b. Persons on the self-exclusion list;

c. Persons on the exclusion list;

d. Patrons who have had their account closed;

e. Patrons who have had their account suspended; and

f. Patrons who have exceeded their self-imposed or voluntary spend or time-based limit.

(15) The Class II Mobile Gaming System shall provide a patron with the ability to view the outcome and subsequent account balance 
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changes for the previous game, including a game completed subsequent to an outage (for example, network disconnection or 

C2MD malfunction).

(16) Unless otherwise approved by the TGRA, a record of all bonus and promotional wagering offers related to mobile gaming shall 

be maintained in an electronic file that is readily available to the TGRA. All bonus and promotional wagering offers shall be

stated in clear and unambiguous terms and shall be readily accessible by the patron. Offer terms and the record of all offers 

shall include at a minimum:

a. The date and time presented;

b. The date and time the offer is active and expires; and

c. Patron eligibility and redemption requirements.

(17) Manual adjustments by the gaming facility to mobile gaming data shall only be made by a software application approved by the

TGRA.

547C. Class II Mobile Gaming System Logging

(1) Class II Mobile Gaming Systems shall:

a. Employ a mechanism capable of maintaining a separate copy of all of the information required to be logged in this 

section on a separate and independent logging device capable of being administered by an employee with no 

incompatible function. If the gaming system can be configured such that any logged data is contained in a secure 

transaction file, a separate logging device is not required.

b. Provide a mechanism for the TGRA to query and export, in a format required by the TGRA, all gaming systemdata.

c. Electronically log the date and time any Mobile Wagering Account is created or terminated (Account CreationLog).

d. Maintain all information necessary to recreate patron game play and account activity during each patron session, 

including any identity or location verifications, for a period of no less than one (1) year.

(2) Unless otherwise authorized by the TGRA, when mobile gaming software is installed on or removed from the Class II Gaming 

System, such action shall be recorded in a secure electronic log (Software Installation/Removal Log), which shallinclude:

a. The date and time of the action; 

b. The identification of the software; and

c. The identity of the person performing the action.

(3) Unless otherwise authorized by the TGRA, when a change in the availability of mobile game software is made on the Gaming 

System, the change shall be recorded in a secure electronic log (Game Availability Log), which shall include:

a. The date and time of the change;

b. The identification of the software; and

c. The identity of the person performing the change.

(4) Unless otherwise exempted by the TGRA, the Class II Gaming System shall record all promotional offers (Promotions Log) 
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issued through the system. Such log shall provide the information necessary to audit compliance with the terms and conditions

of current and previous offers.

(5) Results of all authentication attempts shall be retained in an electronic log (Authentication Log) and accessible for a period at 

minimum of 90 days.

(6) All adjustments to gaming system data made using stored procedures shall be recorded in an electronic log (AdjustmentsLog), 

which lists:

a. The date and time;

b. The identification and user ID of user performing the action;

c. A description of the event or action taken; and

d. The initial and ending values of any data altered as a part of the event or action performed.

547D. Class II Mobile Gaming Required Reports; Reconciliation;

(1) The Class II Mobile Gaming System shall be designed to generate reports as specified by the TGRA that shall include at a 

minimum:

a. The report title;

b. The version number of the current system software and report definition;

c. The date or time period of activity, or description “as of” a point in time;

d. The date and time the report was generated;

e. Page numbering, indicating the current page and total number of pages;

f. Subtotals and grand totals as required by the TGRA;

g. A description of any filters applied to the data presented in the document;

h. Column and row titles, if applicable; and

i. The name of the gaming facility.

(2) All required reports shall be generated by the Class II Mobile Gaming System, even if the period specified contains no data

to be presented. The report generated shall indicate all required information and contain an indication of “No Activity” or 

similar message if no data appears for the period specified.

(3) The Class II Mobile Gaming System shall provide a mechanism to export the data generated for any report to a format 

approved by the TGRA.

(4) The Class II Mobile Gaming System shall generate the following daily reports, at a minimum, for each gaming day in order 

to calculate the taxable revenue:

a. A Patron Account Summary Report, which shall include transaction information for each patron account for the 

following categories:

i. Beginning balance;
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ii. Total amount of deposits;

iii. Total amount of non-cashable bonuses deposited;

iv. Total amount of non-cashable bonuses wagered;

v. Total amount of non-cashable bonuses expired;

vi. Total amount of transfers to games;

vii. Total amount of transfers from games;

viii. Total amount of withdrawals;

ix. Total amount of funds on mobile game at the beginning of the gaming day (the amount of pending wagers at 

the end of the prior gaming day);

x. Total amount of funds on mobile game at the end of the gaming day (the amount of pending wagers plus 

funds transferred to a game but not yet wagered);

xi. Win or loss, calculated as the amount of transfers from games and beginning funds on mobile game less the 

amount of transfers to games and ending funds on mobile game; and

xii. Ending balance;

b. Wagering Summary Report, which shall include the following by authorized game:

i. Total amounts wagered;

ii. Total amounts won;

iii. Total amounts due to or from a mobile gaming network; and

iv. Win or loss calculated as the net of the total amounts wagered and total amounts won plus and amounts due 

to or a mobile gaming network; and

c. A Non-cashable Promotional Account Balance Report, which shall include the ending non-cashable promotional 

balance in each patron account.

(5) The Class II Mobile Gaming System shall generate the following daily reports for each gaming day in order to reconcilethe

daily mobile gross gaming revenue:

a. A Patron Account Summary Report, which shall include the following transaction information for each patronaccount:

i. Patron identification number;

ii. Total amount of transfers to games;

iii. Total amount of transfers from games;

iv. Win or loss statistics; and

b. A Wagering Summary Report, which shall include the following game activity by authorized game or pokervariation:

i. Total amounts wagered;

ii. Total amounts won; and

iii. Win or loss statistics, calculated as the net of the total amounts wagered and total amounts won.
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(6) A gaming facility shall utilize the Wagering Summary Report to calculate mobile gaming gross revenue on a daily basis for 

reporting purposes. In addition, the gaming facility shall:

a. Prepare a Variance Report documenting the win/loss amounts from the Patron Account and Wagering Summary 

Reports;

b. Calculate the variance between the two amounts;

c. Document the reason for the variance; and

d. Report a manual adjustment to increase revenue by the amount of the variance whenever the total of the Patron Account 

Summary Report is greater than the total of the Wagering Summary Report, unless the reason for the variance is 

sufficient to support a determination that revenue was properly reported.

(7) The Class II Mobile Gaming System shall generate, on a daily basis commencing one year after the creation of the first Mobile 

Wagering Account, a Dormant Account Report, which shall list all patron accounts including the PendingWager Account that 

have had no activity for a period of one year. The report shall include:

a. The patron name and account number;

b. The date of the last transaction; and

c. The account balance.

(8) No voids of completed wagering transactions shall occur without TGRA approval.

(9) The Class II Mobile Gaming System shall generate a Performance Report, which compares the theoretical RTP to the actual 

RTP of each game offered by a gaming system. The report shall also provide the total number of rounds of play for each game 

and shall be generated and reviewed monthly by the gaming facility to evaluate the performance of all games offered to the 

public. The Performance Report shall include the data required by this subsection from the first day mobile gaming was 

offered to the date of the report.

(10)The Class II Mobile Gaming System shall generate a Patron Account Adjustments Report, which shall be reviewed on adaily 

basis to evaluate the legitimacy of patron account adjustments. Unless otherwise authorized by the TGRA, the report shall at 

a minimum include:

a. The patron’s name;

b. An account number;

c. The date and time of the adjustment;

d. The person who performed the adjustment;

e. The reason for the adjustment; and

f. The amount of the adjustment.

(11) The Class II Mobile Gaming System shall be capable of generating a Pending Transaction Account Report, which shall include 

and separately itemize all pending transactions for each patron account, including, but not limited to, funds on mobile game 

and deposits and withdrawals not yet cleared.
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547E. Mobile Wagering Accounts

(1) Wireless communication between the Mobile Wagering Account and the C2MD shall be conducted using a method that securely 

links the Mobile Wagering Account and the C2MD and authenticates both the C2MD and the Mobile Wagering Account as 

authorized to communicate over that link.

(2) Prior to engaging in mobile gaming, a patron shall establish a Mobile Wagering Account. The Class II Mobile GamingSystem 

shall be required to display in the terms and conditions that those casino key employees and casino employees prohibited from 

wagering shall not be permitted to establish a mobile account.

(3) In order to establish a Mobile Wagering Account, the gaming facility shall:

a. Create an electronic patron file, which shall include at a minimum:

i. Patron’s legal name;

ii. Patron’s date of birth;

iii. Entire or last four digits of the patron’s Social Security number, if voluntarily provided, or equivalent for a 

foreign patron such as a passport or taxpayer identification number;

iv. Patron’s mobile account number;

v. Patron’s address;

vi. Patron’s electronic mail address;

vii. Patron’s telephone number;

viii. Any other information collected from the patron used to verify his or her identity;

ix. The method used to verify the patron’s identity; and 

x. Date of verification.

b. Encrypt all of the following information contained in an electronic patron file:

i. Patron’s Social Security number or equivalent for a foreign patron such as a passport or taxpayeridentification 

number;

ii. Patron’s passwords and/or PINs; and

iii. Credit card numbers, bank account numbers, or other personal financial information.

c. Verify the patron’s identity in accordance with Tribal law and record the document number of the government 

issued credential examined. Alternatively, the other methodology for remote multi-sourced authentication 

approved by the TGRA, which may include third-party and governmental databases, may also be used.

d. Require the patron to establish a password or other access security feature as approved by the TGRA and advise 

the patron of the ability to utilize “strong authentication” log in protection;
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e. Verify that the patron is of the legal age of 21, not self-excluded, on the exclusion list, or otherwise prohibited from 

participation in gaming;

f. Record the patron’s acceptance of the gaming facility’s terms and conditions to participate in mobile gaming;

g. Record the patron’s certification that the information provided by the individual who registered is accurate;

h. Record the patron’s acknowledgement that the legal age for mobile gaming is 21 and that he or she is prohibited 

from allowing any other person to access or use his or her Mobile Wagering Account; and

i. Notify the patron of the establishment of the account via electronic mail or regular mail.

(4) Each Mobile Wagering Account shall be assigned a unique account identifier.

(5) Patron shall be required to authenticate his or her identity prior to accessing the mobile wagering account. A personal 

identification number is an acceptable form of verifying information.

(6) The Mobile Wagering Account shall create a record of all transactions, including amount, date and time of transaction and 

location of C2MD at time of transaction.

(7) A patron shall have only one Mobile Wagering Account. Each Mobile Wagering Account shall be:

a. Non-transferable;

b. Unique to the patron who establishes the account; and

c. Distinct from any other account number that the patron may have established with the gaming facility.

(8) A patron’s Mobile Wagering Account may be funded through the use of:

a. A patron’s deposit account;

b. A patron’s credit or debit card;

c. A patron’s deposit of cash, gaming chips, or slot tokens at a cashiering location approved by the TGRA.

d. Promotional credits or bonus credits;

e. Winnings;

f. Adjustments made by the gaming facility with documented notification to the patron; or

g. Any other means approved by the TGRA.

(9) Prior to any withdrawal, if a patron used a credit or debit card to fund a Mobile Wagering Account, any remaining balance

in the account up to the amount of the deposit shall be refunded to the patron’s credit or debit card account used to fund the 

Mobile Wagering Account provided that a credit or debit card issuer permits the return of a withdrawal from a Mobile Wagering

Account funded by the credit or debit card of the issuer.

(10) Funds may be withdrawn from a patron’s Mobile Wagering Account for the following:

a. The funding of game play;

b. Cash-out at the cashier’s cage immediately upon patron request;

c. A cash-out transfer to a patron’s deposit account;

d. A cash-out transfer to a patron’s reloadable prepaid cash card, which has been verified as being issued to the patron and 
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is non-transferable;

e. Adjustments made by the gaming facility with documented notification to the patron;

f. Cash-out transfers directly to the patron’s individual account with a bank or other financial institution (banking account) 

provided that the gaming facility verifies the validity of the account with the financial institution; or

g. Any other means approved by the TGRA.

547F. Geolocation Method

(1) Each C2MD must pass a geolocation check prior to the first wager in a patron session.

(2) The geolocation method shall provide the latitude and longitude coordinates of theC2MD.

(3) The location of the C2MD shall be verified no less than once every 20 minutes, immediately upon the detection of a change of 

the C2MD IP address, or every 5 minutes if the C2MD is utilizing a mobile Internet connection (e.g. 3G/LTE).

(4) If the geolocation method determines the CM2D is not located within the C2MGA after no more than 2 rechecks within 5 

minutes, all initiated game play from the C2MD shall be immediately suspended and future game play disabled until the C2MD 

is determined to be inside the C2MGA and the patron has re-authenticated his or heridentity.

a. The following warning message shall displayed:

“We have detected that you are attempting to wager outside the approved mobile gaming area. This conduct is in violation of federal 

and tribal law. You must immediately cease and desist from attempting to wager from this device. We have retained your user 

information and future attempts could result in enforcement action and cancellation of your Mobile Wagering Account.”

b. The date and time of the warning message shall be logged.

(5) If the geolocation method determines the C2MD is using anti-spoofing software, a known Virtual Private Network or proxy 

service, all initiated game play from the C2MD shall be immediately suspended and future game play disabled and a log created.

a. The following warning message shall be displayed:

“We have detected that you are accessing the Internet through a proxy, VPN, or other service which has the ability to bypass the 

geographic location checks or misrepresent the geographic location of a mobile device. While your use of this service may be 

inadvertent, we are not able to confirm your location, which is a legal requirement for mobile wagering. Please contact our customer 

service department so we can assist you with resolving this problem.”