Operational Assessment and Advisory


Having participated in prior capacities in every aspect of the gaming lifecycle, and having served in management positions substantially similar to that of many of our clients, GIS partners and subject matter specialists are uniquely equipped to observe an operation or assess a jurisdiction, to ask the right questions, to identify and digest the relevant information and to make a pragmatic and cost effective recommendation for action.  We likewise have the hands on management experience to guide the implementation of our recommendations - always working collaboratively with your team to achieve the desired result. 

GIS partner Lynwood B. Smith, a Certified Fraud Examiner since 1997 and former gaming executive with extensive operational, project development, investigative, and asset protection expertise, leads GIS' private sector practice. His portfolio includes serving as Corporate Vice President of Trump Casino Hotels and Chief Compliance Officer for Resorts International Casino Hotels, as well as extensive investigative and operational assessment projects with Carl Icahn (Sands Casino Hotel Atlantic City), Edward M. Tracy (Past President & CEO Sands China) and Sun International (Atlantis Paradise Island Resort, Bahamas). He served as President & CEO of True Gaming International, LLC, the parent company of True Native American Gaming, LLC, a private equity gaming management and development company and as a Director of Capital Gaming Management. While with Capital Gaming, he oversaw the development and corporate oversight of several very successful and impressive Native American gaming projects including Mazatzal Hotel & Casino, Payson, Arizona; Wildhorse Resort & Casino, Pendleton, Oregon; Seven Feathers Hotel & Casino Resort, Canyonville, Oregon; and Muckleshoot Indian Casino, Auburn, Washington.

GIS’ private sector services are customized for each client and include, but are not limited to:

§ Feasibility Studies 

§ Economic Impact Studies  

§ Operational Reviews/Games Protection Analysis

§ Asset Protection/Risk Assessments

§ Distressed Property Assessments

§ Technology Assessments 

Suitability/Casino Hotel Investigations and Due Diligence

Lynwood Smith is also President & CEO of Corporate Integrity Services, LLC, the licensed investigative arm of GIS. Having not only conducted gaming related background investigations for corporate and regulatory clients, but having also been personally the subject of rigorous investigations in connection with his own Nevada non-restricted gaming license and New Jersey Key Employee and Corporate Qualifier credentials, Lynwood is an expert in the prevailing eligibility and suitability standards as well as the investigative procedures and methods relied upon in highly regulated jurisdictions. He has completed thousands of investigations for US, Tribal, Asian Pacific Region and Caribbean clients and has trained the investigators of a number of gaming regulatory agencies in the core elements of a regulatory background investigations and intelligence gathering in an effort to position those regulators for a level of reciprocity with US regulators.   Lynwood is also an expert in games protection.  During his career, he investigated hundreds of casino related incidents & crimes to include cheating at the games. He provides clients with independent analysis of questionable gaming activity recorded by Casino Hotel Surveillance Departments.  

Recognizing that their officers, directors, senior management and major financial sources will all have to establish their suitability from a good character, honesty, integrity, and financial stability perspective to manage, influence or control a gaming operation, many clients find it helpful and cost effective to have GIS pre-screen such persons to a standard commensurate with that which will be applied by the relevant jurisdiction. Working with GIS, the applicant is guided through the application and interview process and deficiencies and issues, such as those related to net worth and source of funds, are identified early and, where possible, resolved. This allows the applicant to avoid the myriad of problems, and the unnecessary delay and expense, typically associated with a failure to disclose or fully explain to the regulator a potentially disqualifying attribute or event. 

Similarly, astute jurisdictions understand that gaming license suitability investigations are not criminal investigations and, for that reason, they often prefer not to utilize their law enforcement investigative arms for this purpose. These jurisdictions further appreciate, most notably with regard to iGaming and Sports Book, that complex source of funds analysis is frequently required to establish that an Applicant is funded by reputable persons or institutions and that a significant amount of technical analysis is often required with respect to operator, manufacturer or supplier license investigations involving the origins of and/or control over, source code, location of servers, risk management/odds, match monitoring and match results. As an alternative for these jurisdictions to developing specialized investigative resources in house, GIS has developed a suitability investigation practice that allows its jurisdictional clients to cost effectively outsource this function. GIS is positioned to provide all necessary technical and investigative expertise and to ensure that each suitability investigation is conducted and documented in compliance with the applicable statute or tribal ordinance and in accordance with procedures and methods utilized in top tier jurisdictions. 

GIS has the capability to either perform the suitability investigation or to train or support agency resources in the conduct of same. Under any scenario, any investigative report over which GIS has control will be fact based and will scrupulously avoid conjecture, innuendo or supposition.

Regulatory Advisory Services

With continued expansion, the ever-present prospect of market saturation and the increased sophistication of gaming technology, operators, governments and regulatory agencies have experienced profound difficulties cost effectively maintaining within their organizations the legal, operational and technical competencies necessary to do rulemaking and highly technical requests for proposals such as those associated with a central monitoring system. GIS partner Maureen D. Williamson is widely recognized for her expertise is these areas. 

Maureen leads GIS' regulatory advisory services/government relations practice. She is among the very few practitioners in gaming today with the proven ability to design, expand, repurpose, implement and/or advise with regard to the enforcement of a regulatory scheme. Her regulatory roots are deep. She served for many years as a Deputy Attorney General handling regulatory prosecutions for the NJ Division of Gaming Enforcement and was the Pennsylvania Gaming Control Board's first Deputy Chief Counsel - Operations   (the position now known as the Director of Gaming Operations).  As a consultant, she played a significant role in the drafting of Maryland’s operating regulations, for more than nine years oversaw for a US client the operations of a large resort casino in the Dominican Republic, has advised and provided litigation support to regulators of California cardrooms, along with Lynwood & Ken McCabe (see below) guided the Tinian Casino Gaming Control Commission through volatile times in the Asia Pacific Region, has authored a widely applauded commercial gaming enabling statute for the New Hampshire Gaming Regulatory Oversight Authority and has designed a competitive gaming license award process for the Maine Legislative Council. She also lead GIS’ efforts to assist The Bahamas in implementing a 2014 gaming statute that has successfully “regularized” a previously unregulated domestic iGaming sector. 

GIS’ regulatory advisory services are customized for each client and include, but are not limited to:

§ Consultation/drafting of Statutes, Regulations, Technical Standards and Agency Requests for Proposal 

§ Development and Implementation of Audit and Compliance Testing Plans

§ Agency Organizational Design and Minimum Staffing Objectives

§ Training

§ Investigative Support

§ Litigation Support

§ Feasibility Studies 

§ Economic Impact Studies  

§ Compliance Testing and Sector Risk Assessments

Pre-Opening Services

The regulatory schemes of the vast majority of jurisdictions typically enumerate a broad array of prerequisites to an operations certificate or other form of authorization to commence gaming operations. The skill sets required to draft these “one of” submissions, which can range from comprehensive inaugural systems of accounting and internal control to access matrixes, and to efficiently negotiate any accompanying regulatory review, while unique typically are not priorities for the organization once the pre-opening prerequisites have been satisfied. For this reason, pre-opening regulatory requirements are particularly well suited to a consulting relationship. This phenomenon applies to both the operator and the regulator. GIS, for example, recently developed and implemented on behalf of its client The Gaming Board For The Bahamas the pre-opening protocols pursuant to which The Baha Mar Resort and Casino, now the largest casino in the Caribbean, was authorized to commence operations in April 2017. 

Bringing GIS in to supplement your operations team by curating pre-opening deliverables for the regulator frees your team up to concentrate on construction, hiring, training and other aspects of actual operational readiness.  With GIS you ensure that property wide procedures and controls are internally consistent across all participating departments and you minimize the resources devoted to what is often a very time consuming editing and revision process that is frequently complicated by multiple submission drafters.

Collectively, GIS' partners have an unparalleled level of development and pre-opening experience. When you choose GIS as an operator, you can be assured that your pre-opening deliverables will meet or exceed any regulatory expectations.  When you choose GIS an a regulator, you can be assured that our recommendations will position your agency to evaluate the compliance and operational readiness of your operators and applicants consistent with the most current and respected regulatory best practices.  

AML Compliance

Today operators are obligated to prioritize their efforts to ensure that gaming is not utilized as a conduit for money laundering and terrorist financing.  In keeping with this, the extent and efficacy of their commitment to this obligation is a factor for the regulator in determining both an operator's initial and ongoing suitability to hold a gaming license.    

Former Pennsylvania Gaming Control Board Commissioner Kenneth T. McCabe, Sr. leads GIS’ AML practice. His resume includes having served as SAC for a number of high profile FBI Offices. While assigned to the Miami Office, he supervised all drug related money laundering investigations. The combination of Ken's criminal enforcement experience and the diverse gaming experience of Lynwood and Maureen have allowed GIS to develop considerable, industry specific expertise in sector assessment, specialized investigative support and AML policies and procedures, including those relevant in the Caribbean and Asia Pacific Region.   

By choosing to draw upon GIS, an operator or regulator can serve multiple purposes.  By retaining GIS to pre-screen its operations, for example, a licensee positions itself to establish that there are no material deficiencies in its operations.  By retaining GIS to advise with regard to compliance in non-US jurisdictions, a regulator immediately onboards an understanding of, and an appreciation for, the distinctions between US, Tribal and Caribbean Financial Action Task Force requirements. Finally, there is the reasonable expectation that a regulator will find assuring the disclosure that a licensee has retained, as part of its internal AML due diligence, a firm with the reputation for excellence enjoyed by GIS.  

Tribal Gaming

As sovereign nations, Tribal governments have been incredibly successful at utilizing gaming as an engine of economic development. The ability to succeed at this endeavor depends greatly on the proper structure of the Tribal government and its management and regulatory oversight of gaming related Tribal enterprises.  GIS’ partners have proven expertise not only in project development but in representing and guiding responsible developers, investors and managers through the development and management agreement negotiation and review process.


GIS recognizes that many Tribal governments and enterprises are now on par with the largest gaming operators in the commercial sector and, as a result, are more than able to compete for licenses and authorizations at the State level and in foreign jurisdictions. To that end, GIS is well equipped to assist Tribes in navigating what are often highly nuanced State or foreign background investigation and regulatory authorization practices. We are also well positioned to assist with the preparation of compliant pre-opening deliverables and to in general assist with the introduction of our Tribal clients and their Qualifiers to these regulators accurately, transparently and in their best light.



Horse Racing

Although it is undoubtedly one of the greatest sporting traditions in history, US horse racing nonetheless finds itself fighting for its very survival.  In many jurisdictions, racetracks are facing declining revenues and a resultant inability to generate the purses necessary to fund horsemen. Many jurisdictions are turning to alternative gaming operations, including slots, table games and advance deposit wagering to supplement and bolster their racing industry and to offset the cost of racetrack and breeding operations.  Because GIS’ partners have a full appreciation for horse racing and its impact on revenue in those jurisdictions that have integrated gaming operations into existing racetracks, it is uniquely positioned to advise operators, governments and regulators with regard to the efficacy of solutions and opportunities involving racing.