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SB 2499

Justice court; increase limit of jurisdiction.

2025 Regular Session Introduced by Brice Wiggins

The bill would bar Illinois from licensing interactive gaming operators that knowingly take revenue from FATF blacklisted countries or U.S. state sponsors of terrorism, with potent

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Bill Summary · SB 2499

SB 2499 — Summary (Introduced version)

Note: There are inconsistencies in the header metadata provided (a different short title and several date entries). This summary reflects the bill text as introduced by Sen. Bill Cunningham (LRB10412248LNS22356b), which would add Section 5.5 to the Illinois Gambling Act and concerns licensing for Internet (interactive) gaming.

Main purpose

To prohibit the Illinois Gaming Board from licensing — and to authorize revocation of licenses for — interactive (Internet) gaming operators that knowingly accept revenue derived from certain high‑risk foreign jurisdictions: (1) jurisdictions on the Financial Action Task Force’s “Black List of Money Laundering Countries,” and (2) jurisdictions designated by the United States as state sponsors of terrorism.

Key provisions

  • Adds Section 5.5 to the Illinois Gambling Act (230 ILCS 10).
  • Applicability: only applies when the Illinois Gaming Board is otherwise authorized to issue Internet gaming licenses.
  • Pre-licensing prohibition:
    • The Board shall not approve an interactive gaming licensee to commence operations if the Board determines the applicant or any affiliate (including entities under common control) is knowingly accepting, directly or indirectly, revenue derived from:
    • Any jurisdiction on the FATF “Black List of Money Laundering Countries,” or
    • Any jurisdiction designated by the United States as a state sponsor of terrorism.
  • Post-licensing enforcement:
    • If during licensure the Board determines a licensee or any affiliate is knowingly accepting revenue derived from the above jurisdictions, the Board may impose license revocation after providing notice and an opportunity for a hearing, if the Board determines revocation would further the public interest.
  • Effective date: upon becoming law.

Who would be affected

  • Primary: applicants for and holders of Illinois interactive (Internet) gaming licenses and their affiliates (including entities under common control).
  • Secondary: payment processors, account aggregators, financial institutions, joint venture partners, and other third parties whose revenue streams could be linked to the covered jurisdictions.
  • State regulator: Illinois Gaming Board — required to make determinations about revenue origins and to carry out notice/hearing processes and potential revocations.
  • Potentially affected entities would need enhanced anti‑money‑laundering (AML) and sanctions screening to demonstrate revenue does not derive from prohibited jurisdictions.

Expected impacts and considerations

  • Compliance implications: operators would face increased due diligence and monitoring costs to verify that revenue sources are not derived from the listed jurisdictions.
  • Market access: companies with financial ties to the listed jurisdictions (directly or via affiliates) could be barred from licensing in Illinois even if other activities are lawful elsewhere.
  • Enforcement: relies on the Board’s factual findings and exercise of discretion (including a public‑interest standard) after administrative hearings.
  • Legal risk: could prompt challenges regarding scope, due process, or extraterritorial application of the prohibition.
  • Policy goal: reduce risk of money laundering and terrorist financing flowing through Illinois’s interactive gaming market.

Legislative status and timeline (as provided)

  • Introduced by Sen. Bill Cunningham (filed 2/7/2025).
  • Multiple committee referrals and procedural entries recorded; companion bill: HB 5209.
  • Status: Failed (the provided actions show votes, amendments, motions to reconsider, and ultimately failure). If enacted, the bill would take effect immediately.

If you want, I can produce a one‑page fact sheet focused on compliance steps interactive gaming operators would need to take to conform with this bill.

Compiled from official sources — confirm details with the bill’s official record.

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