Gaming’s legal eagle

By Gambling Insider
Sandra Douglass Morgan tells us about her background, and lends her unique insight into gaming and regulation on the GI Huddle.

What led you to pursue a career in law and why gaming?

I’m a Vegas native. I’ve been here since I was about two. My father retired at Nellis Air Force Base and I grew up here. I wasn’t sure that I wanted to be an attorney until I went to the University of Nevada, Reno for my undergrad. I took a constitutional law class and knew it was going to be my path.

My mother worked in casinos on and off when I was younger. At that time, a lot of children had one parent in the military and one parent in the gaming industry. But I didn’t really plan on going into law or regulation in the industry, I just kind of ended up there.

I went to law school at UNLV and worked at a firm for about three to four years; I then had a great in-house opportunity at MGM Resorts, which as a young lawyer, was the opportunity of a lifetime. It gave me a different window into the industry than the one I heard about from my mum growing up. I realised I definitely wanted a more transactional experience and went on to the city of North Las Vegas.

I worked there for about eight years and ended up being the first African American/person of colour city attorney in the state of Nevada. To be in public service was deeply gratifying, but it was also a very difficult period. When I joined, the city was one of the top five fastest-growing cities in the nation; but when I left, we were on the verge of severe financial distress because of the unfortunate economic downturn at that time.

From there, I went to AT&T and was then appointed to the Nevada Gaming Commission (NGC). It’s a part-time commission, because they meet once a month, but they are the final decision makers on all regulations and licensing approvals. I was appointed to the Commission by then Governor Brian Sandoval, and was promoted to Chair by Governor Steve Sisolak. Nevada is a little bit weird because we have two regulatory bodies. The Nevada Gaming Control Board (NGCB) is a day-to-day regulator, with a very strong and talented team of about 400 people across the state. That was my most recent position.

Do you think it’s almost destiny that, being from Las Vegas, you ended up working in gaming?

At the time, I thought there’s more than gaming in Nevada, and as a young lawyer, I wanted to try something outside of the industry. When the law school opened here, it wanted to make sure it wasn’t just a gaming school. But what I think happened to me, and UNLV law school — the Boyd School of Law — is that we embraced the fact that we have this knowledge and understanding.

We have more gaming licensees in Nevada than any other state, so why not embrace something we know very well? And it has done great things for our state. Now, the school offers a Masters of Law in gaming. I realised at Covington & Burling there are certain things we maybe take for granted in Nevada, such as regulated gaming and sports wagering.

You mentioned working for the NGCB; how do you reflect on your time there? What were your key takeaways?

I miss it. It has a great team and I don’t think people really understand how much that team does. Some of the people have been there for 20 years, and then there are newer people bringing in fresh insights with respect to technology. With Covid, they’ve been able to pivot and still function, whether it be enforcement investigations or technology approvals. And just as we’ve seen operators expedite payment modernisation, I think the board has also embraced technology to its benefit.

In recent years, there has often been discussion about regulators not quite keeping up with technology’s change of pace. Would you agree?

Regulators should be commended for the work they’re doing because these investigations take time. When you’re doing an investigation, a lot of them require interviews, and if you can’t travel, that’s a difficult thing to do. Regulators receive funding from the Government, and governments are always looking for new revenue sources. That’s why we’ve seen an increase in the legalisation of sports wagering.

So it goes both ways. It is the operators, suppliers and manufacturers’ job to have the most up-to-date technology because that’s what customers expect. Everyone would like regulators to have more resources to be able to expedite those approvals but, unfortunately, due to the limited resources at their disposal, sometimes that falls behind.

You recently joined Caesars; how’s that going and what does your role entail?

I’m on the Board of Directors for Caesars. I serve with a very talented group that assists strategic initiatives and the company’s vision. I also help ensure that the executive management team and board are aligned. They’re incredibly talented and have allowed Caesars to continue to grow and redefine itself.

You’re also on a couple of other boards, if I’m not mistaken; how do you strike the right balance?

Time management. Besides Caesars, I’m on the board of the Allegiant travel company, which is also based in Las Vegas. They’re a growing airline that’s mostly based in the south, with a lot of airports and routes in Florida as well. They have a great management team and company.

I was also excited to join the law firm of Covington & Burling. I thought I could bring some expertise to its gaming practice group. The firm is headquartered in DC and has such a wide breadth of talented lawyers. A lot of former regulators are there too.

What was the transition like from operator to regulator, and more recently, from regulator to operator?

There was a significant gap between leaving MGM Resorts and joining the Gaming Commission; but when I joined its composition was very different. I was one of the few lawyers, but there are a lot more now. I was actually on the Nevada Athletic Commission, which governed and regulated boxing and mixed martial arts, so I did have somewhat of a regulatory background before joining the Commission.

I think the transition was probably harder for me going from a regulator to the private sector.Sometimes I’m focused on, ‘okay, what does my client need to get the best results they can within the parameters of the regulation.’ So I’m still working on that adjustment, but things are going well.

What’s your overall take on the main regulatory issues in the US today?

There are a lot of laws and regulations that are being passed, and you see comments made like 'State X' is going to make sure this is done before the Super Bowl, and things like that. So things are moving quickly, and I think it’s important to have sound regulatory counsel or legal advice when any business is partnering with a regulated entity to make sure rules are being followed. Every state has different regulations and gaming licences are all privileged licences; so when you’re entering a market, it’s really important that you understand the nuances of each state.

I also think we’re going to see consistent themes and discussions about responsible gaming. With the convenience of being able to use your phone and other non-cash forms of payment come potential regulations; or at least policies that will, for example, allow people to limit the amount they wager. 

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