Perhaps more than most states, Michigan’s battle to force out unauthorized operators has played out in public.
The Michigan Gaming Control Board (MGCB) takes firmer and more proactive steps than many of its fellow regulators in sending cease-and-desist letters and trying to ensure that all online gambling activity in the state falls under its oversight.
What does that process look like, and how is the regulator looking to keep up with the evolution of online gaming?
At the recent International Masters of Gaming Law (IMGL) Spring Conference in Vancouver, the MGCB Deputy Director of Licensing and Investigations Tina Alagna reflected on how the MGCB looks to combat the presence of unapproved actors in the state.
A shifting role for regulators
The MGCB has a criminal investigations unit with a manager and nine investigators. The bulk of that unit’s job used to comprise probing and clamping down on unauthorized physical machines located in businesses such as restaurants, bars, liquor stores and laundromats.
Alagna noted that has been very effective and since 2022, the MGCB has sent more than 670 cease-and-desist-related letters to brick-and-mortar operations. All but three respondents complied.
Nowadays, that land-based side of things is only roughly 30% of the unit’s work, Alagna said. The 70% majority is investigating illegal, unlicensed offshore operators.
To do so, the board’s investigations unit goes undercover.
“We have difficulty getting the undercover Social Security numbers and undercover credit cards, but we’ve been successful buying in with cryptocurrency,” Alagna detailed. “We very carefully log in the investigative report snapshots of the money going up and down as we win and lose.”
Michigan’s letter writers have been busy
While that is not necessarily the process that leads to the MGCB sending every single one of its C&Ds, Alagna stressed that the approach has proven to be very successful.
Whichever way it manages to identify what the organization deems a bad actor and verify that it is indeed able to take Michiganders’ money, the next step is to send a C&D. That is something the state has certainly not been shy in doing.
The MGCB helped to lead the high-profile charge against Curaçao-based Bovada last year and has targeted a range of operators in recent times. This year, it has already sent more than 50 notices to and in April alone, it sent C&Ds to more than two-dozen operators, accusing them of “deceptively” targeting Michigan citizens and breaking state laws.
Not every operator contacted by Michigan acquiesces, but plenty do.
“We have sent 200 related offshore cease-and-desist letters, and that’s really been since last year,” added Alagna. “And we have received about a third of the compliance in that area,” she added.
Data shared by GeoComply, in collaboration with Rightlander, suggests that the firm hand is working.
Data assessed between March 2023 and March 2025 shows what the geocompliance firm calls “a sharp and steady decline” in Michigan-originating Google searches and a “significant drop” in Michigan-based traffic to unlicensed gambling brands such as Bovada, BetUS, BetWhale and MyBookie, all of which have been sent C&Ds by the MGCB.
New online gambling brings new challenges
Some of the C&Ds sent by states such as Michigan have been issued to operators of online sweepstakes, operators of social games or companies partaking in other relatively emergent forms of online gambling.
With so many newcomers to the space looking to innovate, Alagna was asked whether the MGCB has seen an increased number of applications from operators of more unconventional forms of gambling.
“We have received a number of inquiries and what we have found is that they either don’t apply or they don’t complete the licensing process once they find out what we’re all about,” Alagna noted. She pointed to the board’s extensive application and licensing requirements and opined that a lot of operators back down at the amount of work required. Any who choose to operate anyway without a license will continue to be pursued, as has been the Michigan regulator’s modus operandi.
Offshore suppliers next in the crosshairs
The MGCB is prepared to look beyond unlicensed operators in its bid to shut down black-market activity.
Next on the hit list are parties that help to facilitate unlicensed online gambling, such as offshore host entities or payment processors.
“We don’t have jurisdiction to send a cease-and-desist letter, but we’ll most likely be sending a strongly worded letter — I don’t know if I’ll call it a request or not — and say, ‘Hey, you’re dealing with unlicensed, illegal entities.’
“We’ll be saying ‘Hey, stop this, you’re dealing with an unreputable company and you are a reputable company’ and hope they’ll comply and stop dealing with them. In some cases, they may not know that they’re involved in that, so that’s going to be our next step.”
