11 CSR 45-20.200
Surveillance Requirements for Retail Licensees
PURPOSE: This rule establishes surveillance requirements for Retail licensees.
(1) All equipment that is used to monitor or record shall be
solely accessible to the surveillance personnel, except when
that equipment is being repaired or replaced.
(2) The interior of the surveillance room shall not be visible to
the public.
(3) The commission shall at all times be afforded immediate
access to the surveillance room and all records relating to that
surveillance.
(4) Each surveillance room shall have a minimum of four (4)
monitors, with appropriate switching capability to ensure that
all surveillance cameras are accessible.
(5) While the sportsbook cage is open, surveillance shall observe ticket writer transactions periodically to ensure internal
control procedures are followed and wagers are accepted and
winnings are paid appropriately.
(6) Each kiosk drop process, including the transportation of
drop devices, and the kiosk count process shall be continuously
monitored and recorded by surveillance personnel, including
emergency drops and counts.
(7) The surveillance camera views shall be recorded. All video
recordings shall be maintained for at least thirty (30) days.
(8) Surveillance room personnel shall maintain a surveillance
shift log of all surveillance activities. The surveillance shift log
shall—
(A) Be continuously maintained by surveillance personnel;
(B) Be chronological;
(C) Include entries for—
1. The notification of any maintenance or repair of any
kiosk, point of sale equipment, or money handling equipment;
2. Any detention or questioning of patrons or employees
by the security department, including the identity of—
A. The patrons or employees; and
B. The security personnel involved;
3. The beginning, end, and any interruptions of all required drop and count processes, including emergency drops;
4. Any observed procedural or internal control violations;
5. Any observed criminal activity;
6. Any surveillance conducted on anyone or any activity
that appears—
A. To be abnormal, suspicious, illegal, or an emergency;
or
B. To violate the rules of the commission;
7. Any surveillance conducted at the request of—
A. An employee; or
B. A commission agent;
8. All persons reviewing surveillance recordings;
9. All persons entering and exiting the surveillance room,
excluding surveillance personnel and commission personnel;
10. All surveillance personnel entering and exiting the
surveillance room only at the beginning and ending of their
shifts; and
11. Any other notations deemed necessary by surveillance
personnel or the commission to ensure compliance with the
statutes, regulations, and internal controls;
(D) Be provided to the commission daily; and
(E) Be retained for at least one (1) year.
(9) A surveillance incident report shall be completed for any
activity involving unusual or criminal activity and any violation of the statutes, regulations, or internal controls and shall—
(A) Be made by the employee responsible for monitoring the
activity;
(B) Contain the report number and details of the incident
observed;
(C) Be provided to the commission daily; and
(D) Be retained for at least one (1) year.
(10) All recordings of surveillance incident reports shall be
retained for one (1) year and shall be listed on a surveillance
recording retention log by surveillance personnel with the
date, times, and identification of the person monitoring the
recording. Original recordings shall be released to the commission upon request.
(11) Any recording that records illegal or suspected illegal activity or suspicious wagering activity shall, upon completion
of the recording, be transferred to a read-only, non-erasable
format. The recording shall be placed in a separate, secure area
and the commission shall be notified.
(12) A surveillance release log shall be maintained to record
who receives a copy of video recordings. Video recordings of
criminal or regulatory investigations or violations shall not be
released to anyone without the approval of the commission or
pursuant to a lawful court order.
(13) Any malfunction of surveillance equipment shall necessitate the immediate replacement or repair. If immediate
replacement or repair is not possible, the commission shall be
notified.
(14) Any Retail licensee, who is not a Class B licensee, operating
on an excursion gambling boat may contract with the Class B
licensee to provide the surveillance requirements for the sports
wagering operation through its approved surveillance system.
(15) Any Retail licensee who is a Class B licensee may utilize
its existing surveillance operation to provide the surveillance
requirements for the sports wagering operation.
(16) The Retail licensee shall maintain a closed surveillance
system. Remote access to the surveillance system is prohibited.
(17) Each Retail licensee shall submit a surveillance plan to the
commission prior to commencing sports wagering operations.
The plan shall include a floor plan that shows the placement
of all surveillance cameras and a detailed description of the
procedures utilized in the operation of the surveillance system
and its equipment.
(18) The Retail licensee shall, in its surveillance department,
maintain a copy of its surveillance system plan, which shall
be kept current, documenting any changes to the surveillance
system, placement of equipment, or the description of procedures utilized in its operation. Surveillance system plans or a
copy thereof shall be made immediately available to any agent
of the commission upon request.
AUTHORITY: section 39(g) of Article III, Mo. Const., section 313.004,
RSMo 2016, and sections 313.800–313.850, RSMo 2016 and Supp.
2025.* Original rule filed May 14, 2025, effective Nov. 30, 2025.
*Original authority: 313.004, RSMo 1993, amended 1994, 2014, and 313.800-313.850,
see Revised Statutes of Missouri, 2016 and Supp. 2025.
GAMING COMMISSION