Washington, D.C.

Trade press cites an estimated $700 million wagered by DC residents on unlicensed sweepstakes-model platforms in 2024, cited as the commercial rationale underlying B26-0656's proposed iGaming legalization and its accompanying ban on dual-currency sweepstakes platforms. This figure, sourced from secondary trade coverage rather than a primary DC government estimate, suggests a substantial pool of unmet demand that a legalized online casino framework could redirect into the regulated market if the bill advances.

DC operates a three-tier sports wagering licensing structure under D.C. Code § 36-621.15, durable primary legislation. Class A licences are taxed at 20% of gross sports wagering revenue, Class B at 10%, and Class C — the mobile licence class capped at up to seven citywide and each tied to a partnership with a DC professional sports team — at 30%, with a $2 million fee for a five-year term and a $1 million renewal fee. This structure has underpinned the market since the Sports Wagering Amendment Act of 2024 opened it to FanDuel, DraftKings, BetMGM, Caesars, Fanatics and theScore Bet. Separately, authority over Game of Skill retail licensing transferred from the Office of Lottery and Gaming to the Alcoholic Beverage and Cannabis Administration effective October 1, 2025 under D.C. Act 26-146, a mixed-durability change that splits DC's gambling-adjacent regulatory perimeter across two agencies.

Entry into the DC sports-wagering market proceeds via direct application to the OLG under three operator licence classes: Class A, Class B, and Class C, each carrying a distinct GGR tax rate (20%, 10%, and 30% respectively) set by primary legislation at D.C. Code § 36-621.15. Sports-wagering technology and supplier entities require a separate OLG supplier licence with qualifier-level due diligence under D.C.

The OLG operates a district-wide voluntary Self-Exclusion Program covering all OLG-licensed gaming activities, including Lottery, Sports Wagering, Charitable Gaming, and Games of Skill, as confirmed by the OLG's own published programme page — a fragile regulatory-instrument level source. Participation in the self-exclusion scheme is mandatory for operators in the sense that they must honour exclusion requests; the scheme itself is voluntary for players. Deposit and time limits are player-set and voluntary rather than regulator-mandated. Account registration requires KYC identity and age verification.

Social-responsibility advertising standards apply across regulated verticals, and OLG has issued public warnings against endorsement of unlicensed offshore sportsbooks — a fragile standard. The practical player-protection burden is assessed by the Interpreter as moderate: the mandatory self-exclusion scheme participation obligation is real, but the absence of regulator-mandated deposit or spend limits keeps the operational lift below the significant threshold. No DC-specific age-verification standard beyond general KYC at registration was evidenced.

The DC Attorney General settled fraud allegations against Intralot and subcontractor VSC over the GambetDC contract for $6.5 million, the most significant confirmed enforcement event this cycle. The action targeted the vendor that built and operated the District's original state-run sports betting platform, demonstrating the Attorney General's willingness to pursue contractor-level false-claims liability in gaming even against parties central to the government's own historical betting infrastructure. This raises the compliance bar for future public-private gaming contracts and vendor oversight generally.

No enforcement action was identified this cycle against the Class A/B/C licensed sports wagering operators themselves, and the underlying tiered licensing and tax statute remains durable primary legislation unaffected by the settlement. The Game of Skill licensing-authority transfer to ABCA, while structural rather than an enforcement action, is a mixed-durability development that operators with GOS-adjacent exposure should track as the new agency relationship settles administratively.

Washington DC does not maintain a jurisdiction-specific AML/CFT regime for gambling operators. No DC-specific FATF or mutual evaluation report citation, STR or CTR reporting threshold, or designated-reporting-entity determination was located this cycle. The only identified AML-relevant instrument is the federal UIGEA overlay embedded in the sports-wagering statute at D.C.

Licensed operators and their employees involved in Lottery and Sports Wagering sales must complete responsible-gambling training at onboarding and at annual refreshers, and retailers must provide problem-gambling handouts to players, per regulatory obligations under 30 DCMR §§ 2025.1(a), 2022.1(g), and 2022.6 — fragile regulatory-circular level instruments.

The headline GGR tax rate is confirmed at 20% for Class A operators, 10% for Class B, and 30% for Class C, applied to monthly gross gaming revenue under primary legislation at D.C. Code § 36-621.15. The effective post-deduction rate cannot be computed this cycle: no bonus or free-bet deductibility rule against the GGR tax base was sourced, and the field is explicitly held as unresolved. Specific application and annual licence fee dollar amounts were also not located.

Across the three Interpreter-assessed compliance dimensions, AML/CFT compliance lift is moderate, responsible-gambling compliance lift is moderate, and technical compliance lift is moderate. The AML/CFT burden rests on the general federal BSA and UIGEA overlay in the absence of any DC-specific reporting threshold or designated-entity determination. Responsible-gambling obligations — mandatory staff training and problem-gambling handout provision — are real but not prohibitive, with deposit and spend limits remaining voluntary. Technical compliance centres on GPS geofencing and KYC without a recurring third-party recertification regime. The cumulative compliance picture is manageable for an operator with existing US-state infrastructure.

Permitted funding methods for DC sports-wagering accounts include card and online deposit via licensed platforms and cash deposit via retail kiosks operated by licensed sportsbook brands. All six licensed operators — FanDuel, BetMGM, DraftKings, Caesars, Fanatics, and theScore Bet — are available on iOS and Android district-wide with GPS-based geo-gating enforced. No DC-specific withdrawal-timeframe obligation was sourced this cycle, representing a persistent gap. The sports-wagering statute at D.C.

Code § 36-621.02 embeds a federal UIGEA routing-location deeming clause, confirming that intermediate electronic-data routing does not determine wager location for payment-flow characterisation purposes — a durable primary-legislation provision. No DC-specific banking-access disruption or cross-border capital control was identified. The extraterritorial risk level is assessed as low, derived from the statutory UIGEA overlay in the absence of any DC-specific MLAT, FIU-cooperation, or FinCEN-advisory activity this cycle.

The Sports Wagering Amendment Act of 2024 ended the Intralot/GambetDC monopoly, restructuring DC's sports wagering market from a single state-run mobile app into a competitive field open to FanDuel, DraftKings, BetMGM, Caesars, Fanatics and theScore Bet under the new Class A/B/C tax tiers. This is a structural shift in market composition rather than an incremental change: DC moved directly from monopoly to a multi-operator competitive model within a single legislative act, materially altering the licensing scope and competitive calculus for any entrant.

B26-0656, the Internet Gaming and Consumer Protection Act of 2026, was introduced April 9, 2026 by Councilmember Wendell Felder and referred to the Committee on Human Services. A public hearing was held May 4, 2026, drawing operator testimony from DraftKings, FanDuel and BetMGM. The bill would authorize OLG-licensed online slots, table games and poker, reportedly at a proposed tax rate in the 25-29% range, while banning dual-currency sweepstakes-model gaming platforms.

Trade press cites the estimated $700 million wagered on unlicensed platforms in 2024 as the commercial rationale. The bill's durability is fragile: it remains in committee with passage timing uncertain, and primary DC Council bill text was not directly retrieved this cycle, so reform-horizon tracking here relies on secondary trade-press summaries of hearing status.