Poker and Blackjack Gaming Authorization Act of 2025

MURIEL BOWSER
MAYOR
October 1, 2025
The Honorable Phil Mendelson
Chairman
Council of the District of Columbia
John A. Wilson Building
1350 Pennsylvania Avenue, NW, Suite 504
Washington, DC 20004
Dear Chairman Mendelson:
Enclosed for consideration and adoption by the Council of the District of Columbia is a bill
entitled "Poker and Blackjack Gaming Authorization Act of 2025".
This bill will amend the Law to Legalize Lotteries, Daily Numbers Games, and Bingo and
Raffles for Charitable Purposes in the District of Columbia to authorize wagering on poker and
blackjack at certain locations in the District. The bill will authorize the Alcoholic Beverage and
Cannabis Administration and the Office of Lottery and Gaming to regulate the issuance of
applicable licenses and provides for the imposition and collection of certain taxes and fees. In
addition, the bill authorizes the Chief Financial Officer to adopt rules regulating poker and
blackjack card gaming activities in the District.
Adoption of the bill will enable the District to recapture revenue from residents and visitors who
travel across the border to Maryland for legal card gaming. Additionally, adoption of the bill will
allow District businesses to create and host unique events (such as a World Series of Poker
event) that will draw new visitors into the District and its hotels, restaurants, and attractions.
I urge the Council to take prompt and favorable action on the enclosed bill.
; ~
3 at the request of the Mayor
4
5
6
7 AN BILL
8
9
10
11 IN THE COUNCIL OF THE DISTRICT OF COLUMBIA
12
13
14
15 To amend the Law to Legalize Lotteries, Daily Numbers Games, and Bingo and Raffles for
16 Charitable Purposes in the District of Columbia to authorize poker and blackjack, to
17 authorize the Alcoholic Beverage and Cannabis Administration (ABCA) to regulate the
18 issuing of applicable licenses and collection of applicable taxes, fees, or penalties, and to
19 authorize the Chief Financial Officer to adopt rules regulating card gaming in the
20 District; to amend Title 25 of the District of Columbia Official Code to authorize ABCA
21 to issue licenses for card gaming and games of skill; and to amend Section 16-1702 of the
22 District of Columbia Official Code to exempt card gaming.
23
24 BE IT ENACTED BY THE COUNCIL OF THE DISTRICT OF COLUMBIA, That this
25 act may be cited as the "Poker and Blackjack Gaming Authorization Act of 2025".
26 Sec. 2. The Law to Legalize Lotteries, Daily Numbers Games, and Bingo and Raffles for
27 Charitable Purposes in the District of Columbia, effective March 10, 1981 (D.C. Law 3-172;
28 D.C. Official Code passim), is amended as follows:
29 (a) Section 3 (D.C. Official Code§ 22-1716) is amended by striking the phrase "and
30 sports wagering" and insert the phrase "sports wagering, poker, and blackjack" in its place.
31 (b) Section 3 (D. C. Official Code § 22-1717) is amended by striking the phrase "game of
32 skill machines" and inserting the phrase "game of skill machines, poker, and blackjack" in its
33 place.
34 (c) A new title Vis added to read as follows:
35 "TITLE V. CARD GAMING; POKER AND BLACKJACK.
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“Sec. 501 Definitions. 36
“For the purposes of this title the term: 37
“(1) “ABCA” means the Alcoholic Beverage and Cannabis Administration. 38
“(2) “ABC Board” means the Alcoholic Beverage and Cannabis Board. 39
“(3) “Authorized establishment” means an eligible establishment where a card 40
gaming facility is authorized to operate under this title. 41
“(4) “Blackjack gross gaming revenue” means the total amount wagered by 42
players on blackjack, including any variations thereof, less total winnings paid out to players, not 43
including promotions, credits or other noncash items. 44
“(5)(A) “Card game” means blackjack or poker, including any authorized 45
variations of blackjack or poker, played in a physical location with physical cards. 46
“(B) The term “card game” does not include blackjack, poker, or any other 47
card game played online or, virtually or in any manner where the outcome is determined by an 48
electronic or other device. 49
“(6) “Card gaming” means wagering on a card game played at a physical location 50
with physical cards. 51
“(7) “Card gaming facility” means a location where wagering on card games is 52
authorized under this title. 53
“(8) “Card gaming operations” means the operation of an authorized card gaming 54
facility. 55
“(9) “CFO” means the Chief Financial Officer of the District of Columbia. 56
3
“(10) “Eligible establishment” means a business licensed by the Alcoholic 57
Beverage and Cannabis Board that holds an on-premises retailer’s license class C/H, D/H or 58
arena CX. 59
“(11) “MPD” means the Metropolitan Police Department. 60
“(12) “Office” means the Office of Lottery and Gaming. 61
“(13) “Operator” means a person who holds a card gaming facility operator 62
license. 63
“(14) “Person” means a natural person or entity. 64
“(15) “Poker gross gaming revenue” means the gross receipts generated from 65
poker, including any variations thereof, including rake, entry fees, commissions, and similar 66
amounts paid by players to participate in poker games. 67
“(16) “Supplier” means a person that: 68
“(A) Sells or leases, or contracts to sell or lease, card game equipment, 69
devices, systems, or supplies to an operator; or 70
“(B) Provides, or contracts to provide, security or surveillance services 71
required by the Office to an operator; 72
“(C) Provides management services to an operator. 73
“(17) “Voluntary exclusion program” means a program operated by the Office 74
that allows individuals to voluntarily exclude themselves from engaging in card gaming. 75
“Sec 502. Authorization of card gaming. 76
“(a) The operation of facilities where wagering on card games occurs, and the wagering 77
on card games at such facilities, shall be lawful in the District if conducted in accordance with 78
this title and the rules issued pursuant to this title. 79
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“(b) This title does not authorize wagering: 80
“(1) On a card game that is played virtually or online; 81
“(2) On a card game where the outcome is determined by an electronic or other 82
device; 83
“(3) By a person other than a person playing the card game on which the wager is 84
placed. 85
“Sec. 503. Card gaming locations. 86
“(a) Card gaming shall be permitted under this title only at locations authorized by the 87
Office to be operated as card gaming facilities. 88
“(b) The Office shall authorize card gaming facilities to be operated only at eligible 89
establishments. 90
“(c) Card gaming facilities shall be authorized to be operated only as part of an operator’s 91
license issued under this title. 92
“(d) The Office shall, by rule, establish a limit on the number of card gaming facilities 93
that may be authorized to be operated in the District. In determining this limit, the Office shall 94
consider the sufficiency of the number of card gaming facilities to serve the public. 95
“Sec. 504. Operator’s license required; fee. 96
“(a) No person shall operate a card gaming facility unless the person holds an operator’s 97
license issued by the Office. An operator’s license shall authorize the licensee to operate card 98
gaming facilities only at such eligible establishments as shall be authorized on the license. An 99
operator shall not operate a card gaming facility at a location in the District other than an eligible 100
establishment authorized on its license. 101
“(b) To obtain an operator’s license a person shall: 102
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“(1) Complete and submit to the Office an application for an operator’s license in 103
the manner and form prescribed by the Office; 104
“(2) Submit any information and documents requested by the Office as part of the 105
licensing process; 106
“(3) Satisfactorily pass a background investigation, which may include the 107
investigation of owners, officers, directors and employees of the applicant; 108
“(4) Satisfactorily pass an onsite inspection of the location or locations where the 109
applicant proposes to conduct card gaming operations; 110
“(5) Meet such other standards as the Office may establish by rule; and 111
“(6) Pay a nonrefundable application fee of $5,000, plus $2,000 for each location 112
where the applicant proposes to conduct card gaming operations. 113
“(c) The term of an operator’s license shall be 2 years. 114
“(d) A licensee may renew an operator’s license by filing an application with the Office 115
and providing such information and documents as may be requested by the Office. The 116
application fee for the renewal of an operator’s license shall be $1,500 plus $500 for each 117
location where the licensee is currently licensed to operate a card gaming facility. 118
“(e) As part of a renewal application, a licensee may request authorization to conduct 119
card gaming operations at additional locations. The applicant shall pay an additional application 120
fee of $1,000 for each new location requested. 121
“(f) An operator’s license shall not be transferable to another person, unless approved by 122
the Office in accordance with rules issued by the Office. 123
“(g) A person convicted of a disqualifying offense shall not be licensed as an operator by 124
the Office. The Office shall define disqualifying offense by a rule issued pursuant to this title. 125
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“(h) No employee of the Office or ABCA or member of the ABC Board, or immediate 126
family member of an employee of the Office or ABCA or member of the ABC Board, may be an 127
applicant for, have an interest in, or obtain an operator’s license.”. 128
“(i) A person who has been denied an application for an operator’s license pursuant to 129
this section or rules issued pursuant this title shall have a right to a hearing before the Office and, 130
in the event of its affirmation of the denial, the right to appeal the decision of the Office to the 131
Superior Court of the District of Columbia. 132
“(j) Before issuing, renewing, or authorizing the transfer a license, the Office shall 133
determine that the applicant is not disqualified because of a conflicting interest in another license 134
or a supplier permit. The Office shall define conflicting interest and the standards for 135
disqualification by rules issued pursuant to this title. 136
“Sec. 505. Designated areas for card gaming operations within authorized establishments. 137
“(a) Each licensee shall locate its card gaming operations within the premises of an 138
authorized establishment only in specific areas approved by ABCA and the Office. 139
“(b) Each licensee shall post a warning sign clearly visible at each point of entry to the 140
designated areas where card gaming is located in an authorized establishment. The warning sign 141
shall include: 142
“(1) The minimum age required to participate in card gaming; 143
“(2) The contact information for the District’s gambling hotline; 144
“(3) Information on the voluntary exclusion program; and 145
“(4) The contact information for the Office for purposes of filing a licensee or 146
card gaming facility. 147
“Sec. 506. Card gaming by minors prohibited. 148
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“(a) Neither a licensee nor an authorized establishment shall permit a person under the 149
age of 18 to participate in card gaming. 150
“(b) The Office may suspend or revoke a license and issue a fine, in accordance with 151
section 512, against a licensee that knowingly allows a person under the age of 18 to participate 152
in card gaming. 153
“Sec. 507. Voluntary exclusion program. 154
“Each licensee shall participate in the voluntary exclusion program operated by the 155
Office. 156
“Sec. 508. Taxation of card gaming. 157
“(a) A tax is imposed on all operators licensed by the Office for the operation of a card 158
gaming facility. 159
“(b) The rate of tax shall be 25% of the poker gross gaming revenue and 25% of the 160
blackjack gross gaming revenue from each card gaming facility the operator is authorized to 161
operate. 162
“(c) On or before the 20th calendar day of each month, each operator shall file a return 163
with the CFO, on forms and in the manner prescribed by the CFO, indicating the amount of 164
poker gross gaming revenue and blackjack gross gaming revenue from the operator’s authorized 165
card gaming facilities for the preceding calendar month and the amount of tax for which the 166
operator is liable, and shall make payment to the District of the amount for which the operator is 167
liable. 168
“(d) Of the total amount of tax revenue collected by the District under this section in each 169
fiscal year: 170
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“(1) The first $250,000 shall be deposited in the Lottery, Gambling, and Gaming 171
Fund established by section 4; and 172
“(2) The remaining amount shall be deposited in the General Fund of the District 173
of Columbia. 174
“(e) All funds owed to the District under this section shall be held in trust for the District 175
in a federally insured depository institution that maintains an office in the District until the funds 176
are paid to the District. 177
“(f) Each operator shall keep a record of the poker gross gaming revenue and blackjack 178
gross gaming revenue in such form as the CFO may require. 179
“(g) An operator who fails to pay the tax imposed by this section shall be subject to all 180
collection, enforcement, and administrative provisions applicable to unpaid taxes or fees, as 181
provided in Chapters 41, 42, 43, and 44 of Title 47 of the District of Columbia Official Code. 182
“(h) Notwithstanding section 47-4406 of the District of Columbia Official Code, the CFO 183
may disclose the total amount of poker gross gaming revenue and blackjack gross gaming 184
revenue collected in the periodic estimates and reports of revenues. 185
“Sec. 509. Rules governing card gaming. 186
“(a) The CFO, pursuant to title I of the District of Columbia Administrative Procedure 187
Act, approved October 21, 1968 (82 Stat. 1204; D.C. Official Code § 2-501 et seq.), shall adopt 188
rules governing the conditions under which card gaming shall be conducted in the District and 189
such other rules it deems appropriate to implement or further the purposes of this title. 190
“(b) The rules issued by the CFO pursuant to subsection (a) of this section shall include: 191
“(1) Minimum internal control standards, including: 192
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“(A) Financial controls, including rules regarding the proper handling of 193
cash, accounting procedures, and auditing requirements; 194
“(B) Security and surveillance requirements, including rules regarding the 195
monitoring of gaming areas, protecting against theft and cheating, surveillance camera standards, 196
and recording and monitoring requirements; 197
“(C) Game integrity standards designed to ensure fair play, accurate 198
payouts, and compliance with card game rules; 199
“(D) Employee-related standards and requirements, including 200
occupational licensing, background checks, training, and ethical conduct requirements; and 201
“(E) Information technology and data security standards and requirements 202
designed to protect player information and ensure system integrity. 203
“(2) Minimum and maximum wager amounts; 204
“(3) The method of accounting to be used by operators; 205
“(4) Requirements and methods of age verification; 206
“(5) Requirements regarding records required to be maintained by an operator; 207
“(6) Advertising guidelines, including specific language concerning individuals 208
under the age of 18; and 209
“(7) Penalties for a violation of this title or rule issued pursuant to this title.”. 210
“Sec. 510. Supplier permit. 211
“(a) No person shall operate as a supplier unless the person holds a supplier permit issued 212
by the Office. 213
“(b) The Office shall establish by rule the requirements and standards for issuance of a 214
supplier permit and may establish a fee for the application for and issuance of a supplier permit. 215
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“(c) No employee of the Office or ABCA or member of the ABC Board, or immediate 216
family member of an employee of the Office or ABCA or member of the ABC Board, may be an 217
applicant for, have an interest in, or obtain a supplier’s permit.”. 218
“Sec. 511. Occupational license. 219
“(a) All persons employed to be engaged in activities related to poker and blackjack shall 220
be required to be licensed by the Office and, when employed, shall maintain a valid occupational 221
license and be employed in the capacity reported to the Office. 222
“(b)(1) An applicant for an occupational license under this section shall submit an 223
application, in such form and format as shall be required by the Office, and pay a nonrefundable 224
fee of $100, which may be paid on behalf of the applicant by a prospective employer. 225
“(2) An applicant for an occupational license under this section shall be subject to 226
a background investigation by the Office to determine suitability. 227
“(3) The term of an occupational license under this section shall be 2 years from 228
the date of issuance by the Office. 229
“(4) To renew a license issued under this section, the holder of an occupational 230
license issued pursuant to this section shall, at least 30 days before the expiration of their license, 231
file a renewal application with the Office and pay a renewal fee of $100, which may be paid on 232
behalf of the licensed employee by the holder’s employer. 233
“Sec. 512. Penalties. 234
“(a) For a violation of this title or a rule issued pursuant to this title, the Office may take 235
one or more of the following actions: 236
“(1) Impose a fine of not more than $50,000; 237
“(2) Revoke an operator’s license or a supplier’s permit; or 238
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“(3) Suspend an operator’s license or supplier’s permit. 239
“(b) A person who has been fined or whose license has been revoked or suspended 240
pursuant to this section shall have a right to a hearing before the Office and, in the event of its 241
affirmation of the fine, revocation or suspension, whichever applies, the right to appeal the 242
decision of the Office to the Superior Court of the District of Columbia. 243
“Sec. 513. Audits, investigations, and inspections. 244
“(a) The Office may conduct audits, investigations, searches, seizures, and other 245
investigatory and inspection activities appropriate to the implementation and enforcement of this 246
title and the rules issued pursuant to this title. 247
“(b) Each applicant for a license, each licensee, each authorized establishment and each 248
eligible establishment that is seeking to become an authorized establishment shall allow an 249
authorized member of the Office, an ABCA investigator, or any member of the MPD full 250
opportunity to examine at any time during business hours: 251
“(1) The area of the authorized establishment or eligible establishment where card 252
gaming operations are conducted or are requested to be authorized to be conducted; and 253
“(2) The books and records of the applicant, licensee, authorized establishment, or 254
eligible establishment, including video and audio recordings, wherever stored. 255
“Sec. 514. Other enforcement authority; seizures. 256
“(a) The Office, ABCA, or MPD may request and check the identification of a person 257
who has played, is playing, or is attempting to play a card game. The Office or MPD may seize 258
evidence that substantiates a violation under this title, which may include seizing the cash awards 259
issued to a person under the age of 18 and fake identification documents used by a person under 260
the age of 18. 261
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“(b) The Office or MPD may seize card gaming equipment, devices, systems, or supplies 262
from a business if: 263
“(1) A card gaming facility is not authorized to be operated in the business; 264
“(2) The license of the operator allowing the operator to operate a card gaming 265
facility at the business has been suspended, revoked, or canceled by the Office; 266
“(3) The business is no longer in existence; or 267
“(4) The business has been closed by another District government agency. 268
“Sec. 515. Action by the Attorney General 269
The Attorney General for the District of Columbia, in the name of the District of 270
Columbia, may bring an action in the Superior Court of the District of Columbia to enjoin a 271
person from violating this title or a rule issued pursuant to this title or to seek a civil penalty of 272
up to $50,000 for a violation of this title or a rule issued pursuant to this title. 273
“Sec. 516. Other powers and duties of the Office. 274
“In addition to the other authorities of the Office under this title, the Office shall have the 275
power to: 276
“(a) Oversee all card gaming operations authorized under this title, including all persons 277
conducting or participating in any card gaming operation; 278
“(b) Employ or contract for such persons to be present during card gaming operations as 279
are necessary to ensure that such gaming operations are conducted in an orderly fashion and the 280
highest degree of integrity; and 281
“(c) Issue subpoenas for the attendance of witnesses before the Office, administer oaths, 282
and compel production of records or other documents and testimony of such witnesses whenever 283
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in the judgment of the Office it is necessary to do so for the effectual discharge of its duties 284
under this title.”. 285
Sec. 3. Title 25 of the District of Columbia Official Code is amended as follows: 286
(a) The table of contents is amended as follows: 287
(1) The section designation Ҥ 25-786. Game of skill machine operating 288
requirements.” is repealed. 289
(2) A new subchapter and section designations are added to read as follows: 290
“Subchapter IX-A. Games of skill and card gaming. 291
Ҥ 25-788. Game of skill machine operating requirements. 292
“§ 25-789. Card gaming operating requirements.”. 293
(b) Chapter 1 is amended as follows: 294
(1) Section 25-101 is amended by adding a new paragraph (13A) to read as 295
follows: 296
“(13A) “Card gaming” has the meaning set forth in section 501(6) of the Law to 297
Legalize Lotteries, Daily Numbers Games, and Bingo and Raffles for Charitable Purposes in the 298
District of Columbia, effective March 10, 1981 (D.C. Law 3-172; D.C. Official Code passim).”. 299
(2) Section 25-113.01 is amended by adding a new subsection (i) to read as 300
follows: 301
“(i)(1) A licensee under an on-premises retailer’s license class C/H, D/H, multipurpose 302
facility class CX or DX, or arena CX, shall, in order for a portion of the premises of the licensed 303
establishment to be operated as a card gaming facility: 304
“(A) Obtain a card gaming endorsement from the Board; and 305
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“(B) Be listed as an authorized card gaming facility on a card operator’s 306
license issued by the Office of Lottery and Gaming pursuant to title V of the Law to Legalize 307
Lotteries, Daily Numbers Games, and Bingo and Raffles for Charitable Purposes in the District 308
of Columbia, effective March 10, 1981 (D.C. Law 3-172; D.C. Official Code passim). 309
“(2)(A) Card gaming shall not be allowed on outdoor public or private space; 310
except, that the Board, in its discretion, may allow for card gaming on outdoor public or private 311
space if, in the Board’s determination, activity associated with the card gaming is: 312
“(i) Not visible from a public street or sidewalk; 313
“(ii) Adequately secured against unauthorized entrance; and 314
“(iii) Accessible only by patrons from within the establishment. 315
“(B) Subparagraph (A) of this paragraph shall not apply to a licensee 316
operating a passenger-carrying marine vessel in accordance with § 25-113(h).”. 317
(c) The tabular array in section 25-508 of Chapter 5 is amended by adding the following 318
row at the end: 319
“Card gaming endorsement $500/year”. 320
(d) Chapter 7 is amended as follows: 321
(1) Section 25-762 is amended by adding a new subsection (d) to read as follows: 322
“(d)(1) A card gaming endorsement, other than a card gaming endorsement described in 323
paragraph (2) of this subsection, shall constitute a substantial change under this section. 324
“(2) A card gaming endorsement shall not constitute a substantial change under 325
this section if applied for by an arena CX license holder or by a licensee whose establishment is 326
located in the Capitol Gateway (CG), Downtown (D), Northern Howard Road (NHR), or 327
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Southeast Federal Center (SEFC) zone as described in Title 11 of the District of Columbia 328
Municipal Regulations.”. 329
(1) Section 25-763(g) is amended by striking the phrase “game of skill machines” 330
and inserting the phrase “game of skill machines or card gaming” in its place. 331
(2) Section 25-765(c) is amended by striking the phrase “game of skill machines” 332
and inserting the phrase “game of skill machines or card gaming” in its place. 333
(3) Section 25-786 is repealed. 334
(e) Section 25-801 is amended by adding a new subsection (i) to read as follows: 335
“(i) An ABCA investigator may request and check the identification of a person who has 336
participated in, is participating in, or is attempting to participate in card gaming. An ABCA 337
investigator may seize fake identification used by a person under 18 years of age and may seize 338
such records related to card gaming operations as the investigator considers appropriate to 339
investigate the participation in card gaming by a person under 18 years of age.”. 340
(e) A new subchapter IX-A is added to read as follows: 341
“Subchapter IX-A. Game of skill machines and card gaming. 342
Ҥ 25-788. Game of skill machine operating requirements. 343
“A licensee with a game of skill machine endorsement shall: 344
“(1) Not allow or permit a person under 18 years of age to play a game of skill 345
machine and shall designate an employee to regularly monitor the designated area where game of 346
skill machines are played to ensure that no person under 18 years of age is playing or attempting 347
to play a game of skill machine; 348
“(2) Verify that each person playing a game of skill machine is lawfully permitted 349
to do so by checking the person’s government-issued identification document upon entry into 350
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either the licensed establishment or the designated area where the game of skill machines are 351
located and where the person seeks to cash out his or her winnings, if any; except, that the failure 352
of a licensee to verify a person’s identification shall not be a violation of this paragraph if the 353
person whose identification was not checked is 18 years of age or older; 354
“(3) Not allow or permit a person that appears intoxicated or under the influence 355
of a narcotic or other substance to play a game of skill machine; 356
“(4) Not share revenue from the licensee’s sale of alcohol with a manufacturer or 357
distributor of a game of skill machine, unless approved by the Board as an owner of the license; 358
“(5) Not allow or permit the placement of a game of skill machine on an outdoor 359
public or private space that has not been approved by the Board; 360
“(6) Not allow or permit the placement of a game of skill machine outside of the 361
designated areas contained on the applicant’s diagram provided as part of the license application 362
or outside the areas approved by the Board; 363
“(7) Not have more than 5 game of skill machines on the licensed premises; and 364
“(8) Install security cameras that are operational and record for 30 days, in the 365
areas designated for game of skill machines, near the cash register or terminal where cash 366
winnings of game of skill machines are processed, and where the licensee’s money is stored. 367
Ҥ 25-789. Card gaming operating requirements. 368
“A licensee with a card gaming endorsement shall: 369
“(1) Not allow or permit a person under 18 years of age to participate in card 370
gaming and shall designate an employee to be present in the designated area at all times where 371
card gaming is located when card gaming is occurring to ensure that no person under 18 years of 372
age is participating or attempting to participate in card gaming; 373
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“(2) Verify that each person participating in card gaming is lawfully permitted to 374
do so by checking the person’s government-issued identification document upon entry into either 375
the licensed establishment or the designated area where card gaming is located and where the 376
person seeks to cash out his or her winnings, if any; except, that the failure of a licensee to verify 377
a person’s identification shall not be a violation of this paragraph if the person whose 378
identification was not checked is 18 years of age or older; 379
“(3) Not allow or permit a person that appears intoxicated or under the influence 380
of a narcotic or other substance to participate in card gaming; 381
“(4) Not share revenue from the licensee’s sale of alcohol with a card gaming 382
operator, unless approved by the Board as an owner of the license; 383
“(5) Not allow or permit card gaming outside of the areas approved by the Board; 384
“(6) Install security cameras that are operational and record for 30 days, in the 385
areas designated for card gaming, near the cash register or terminal where cash winnings of card 386
gaming are processed, and where the licensee’s money is stored. 387
Sec. 4. Section 16-1702 of the District of Columbia Official Code is amended by adding 388
a new subsection (e) to read as follows: 389
“(e) This section shall not apply to card gaming authorized by Title V of the Law to 390
Legalize Lotteries, Daily Numbers Games, and Bingo and Raffles for Charitable Purposes in the 391
District of Columbia, as introduced on April __, 2025 (Bill 26-___).”. 392
Sec. 5. Fiscal impact statement. 393
The Council adopts the fiscal impact statement in the committee report as the fiscal 394
impact statement required by section 4a of the General Legislative Procedures Act of 1975, 395
approved October 16, 2006 (120 Stat. 2038; D.C. Official Code § 1-301.47a). 396
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Sec. 6. Effective date. 397
This act shall take effect following approval by the Mayor (or, in the event of veto by the 398
Mayor, action by the Council to override the veto), a 30-day period of Congressional review as 399
provided in section 602(c)(1) of the District of Columbia Home Rule Act, approved December 400
24, 1973 (87 Stat. 813, D.C. Official Code § 1-206.02(c)(1)), and publication in the District of 401
Columbia Register. 402
2
GOVERNMENT OF THE DISTRICT OF COLUMBIA
OFFICE OF THE ATTORNEY GENERAL
BRIAN L. SCHWALB
ATTORNEY GENERAL
LEGAL COUNSEL DIVISION
ME
MORANDUM
TO: R
yan Nicholas
Legislative Director
Office of the Deputy Director for Economic Planning & Development
FROM: Adele El-Khouri
Deputy Attorney General
Legal Counsel Division
DATE: September 26, 2025
SUBJECT: Legal Sufficiency Review of Draft Legislation, the “Poker and Blackjack Gaming
Authorization Act of 2025”
(AE-25-54)
_____________________________________________________________________________________
This is to Certify that the Office of the Attorney General has reviewed the
above-referenced legislation and found it to be legally sufficient. If you have any questions in this
regard, please do not hesitate to call me at (202) 262-6402.
_________________________________
Ade
le El-Khouri

Government of the District of Columbia
Office of the Chief Financial Officer

Glen Lee
Chief Financial Officer

1350 Pennsylvania Avenue, NW, Suite 203, Washington, DC 20004 (202)727 -2476
www.cfo.dc.gov
MEMORANDUM

TO: The Honorable Phil Mendelson
Chairman, Council of the District of Columbia

FROM: Glen Lee
Chief Financial Officer

DATE: September 30, 2025

SUBJECT: Fiscal Impact Statement – Poker and Blackjack Gaming Authorization
Act of 2025

REFERENCE: Draft Bill as provided to the Office of Revenue Analysis on September
29, 2025

Conclusion

Funds are sufficient in the fiscal year 2026 through fiscal year 2029 budget and financial plan to
implement the bill.

Background

The bill legalizes poker and blackjack card games, including any au thorized variations thereof, and
requires the Office of Lottery and Gaming (OLG) to regulate card gaming in the District.
Establishments holding certain types of retailers’ licenses issued by the Alc oholic Beverage and
Cannabis Administration (ABCA)1 that obtain a license and are au thorized by OLG are eligible
establishments where card games may be wagered on. To obtain a two-year license, operators must
submit to OLG an application with supporting documentation, pass a background check, receive an
onsite inspection , and pay an application fee of $5,000 plus $2,000 per card gaming location.
Licensees can renew their licenses for $1,500 plus $500 for each location. Licensees can request
additional locations during the renewal process by paying an additional $1,000 fee for each new
location. Card game suppliers must also be granted a permit by OLG to operate in the District. The
bill also requires any employee engaged in poker or blackjack to obtain and maintain an occupational
license from OLG.

1 The bill defines eligible establishments as those that hold an on-premises class C/H, D/H, or arena CX
retailer’s license issued by the Alcoholic Beverage and Cannabis Board.
The Honorable Phil Mendelson
FIS: “Poker and Blackjack Gaming Authorization Act of 2025,” Draft Bill as provided to the Office of Revenue
Analysis on September 29, 2025
Page 2 of 3

The bill ensures that virtual and online events with outcomes generated by an electronic device are
not authorized under the bill.

The bill establishes a 25 percent tax on all gross gaming revenue collected through poker and
blackjack. Operators must file a monthly return to the Chief Financial Officer (CFO) indicating the
amount of revenue collected for the prior month. The bill dedicates the first $250,000 of related tax
revenues to the Lottery, Gambling, and Gaming Fund (Fund),2 while the remaining revenues are
directed to the District’s General Fund.

The CFO will establish rules governing card gaming, including internal control standards, financial
controls, security and surveillance requirements, game integrity, employee -related standards,
information technology standards, minimum and maximum wager am ounts, and age verification
standards. The bill requires operators to adhere to certain operating procedures and prohibits
persons under the age of 18 from participating in card gaming. The bill allows OLG to issue fines and
penalties to card game operators who violate the card gaming laws or rules. OLG may conduct audits,
investigations, searches, seizures, and other investigatory and inspection activities appropriate to
the implementation and enforcement of card gaming. The Office of the Attorney General may also
bring an action in Superior Court against a person violating card gaming laws or rules.

Eligible establishments must obtain an ABCA endorsement to operate a card gaming facility. The bill
establishes that ABCA should not consider an applica tion for an endorseme nt to be a substantial
change3 to an eligible establishmen t’s ABCA license if the licensee holds an arena CX license or is
located in a Capital Gateway, Downtown, Northern Howard Road, or Southeast Federal Center zone.4
A card gaming endorsement will cost $500 per year. An establishment with a card gaming
endorsement must have an employee in the card gaming area at all times while gaming is occurring,
to ensure no person under the age of eighteen is participating or attempting to participate.

The bill also updates the statutory operating requirements for game of skill machines in licensed
establishments. The bill requires an employee to regularly monitor a game of skill machine , such as
ensuring no person under the age of eighteen5 or intoxicated plays a machine, machines are only in
designated areas, and no establishment has more than five machines.

Financial Plan Impact

Funds are sufficient in the fiscal year 2026 through fiscal year 2029 budget and financial plan to
implement the bill. There is no information available to estimate the number of potential card gaming
sites, but if an eligible establishment wants to host these activities, it must obtain the proper
authorizations from OLG and ABCA. No additional revenue is estimated as a result of the bill due to
the uncertainty around the number of establishments and how card gaming activity will displace
other existing taxable sales. If tax revenues are received, the bill designates the first $250,000 of the
tax revenues to the Fund. OLG will absorb the cost of any initial licensing activities. If activity becomes

2 Law to Legalize Lotteries, Daily Numbers Games, and Bingo and Raffles for Charitable Purposes in the
District of Columbia, effective March 10, 1981 (D.C. Law 3-172; D.C. Official Code § 36-601.12).
3 Title 25, D.C. Code Enactment and Related Amendments Act of 2001, effective May 3, 2001 (D.C. Law 13-298;
D.C. Official Code § 25-762).
4 As defined in Zoning Regulations of 2016 (11 DCMR §§ 11-I & 11-K).
5 GOS Machine License Requirements, effective March 26, 2021 (33 DCMR § 2205 et seq.).
The Honorable Phil Mendelson
FIS: “Poker and Blackjack Gaming Authorization Act of 2025,” Draft Bill as provided to the Office of Revenue
Analysis on September 29, 2025
Page 3 of 3

more significant, OLG will use the tax revenue directed toward the Fund to hire additional regulatory
staff.