Michigan issues cease-and-desist letters to 33 offshore gambling sites

Henry Williams sent thirty-three letters on Thursday. Each one told an offshore operator the same thing: Michigan residents are not an untapped market, and the state knows you are there.

The Michigan Gaming Control Board named the recipients publicly — Azartzona, BingoMania, Cryptoplay, Donbet, and twenty-nine others — a list that reads like a directory of everything a licensed operator is not supposed to be. Casino-style games, sweepstakes formats, sports betting, no Michigan license, no obligation to honor the state's self-exclusion database. That last point is the one that should concentrate attention. A person who has formally asked to be kept away from gambling can open an account on any of these sites, deposit money, and lose it, with no mechanism to recover it and no regulator who can help.

The American Gaming Association put a number on the broader problem in August 2025: Americans wager roughly $670 billion annually with illegal and unregulated operators, a figure that has grown by more than a fifth since the AGA's previous count. More striking is what happened to the licensed side. The share of online-casino players using only legal sites fell from just over half in 2022 to roughly a quarter. Nearly half now play on both. That is not a population drifting toward illegal markets — that is a population already there, using legal sites as one option among several.

Williams framed the cease-and-desist campaign as protection for self-excluded players, and it is that. But the enforcement context is harder to separate from what Michigan has been doing on the prediction market front in the same period. The state reached agreements with Coinbase and Robinhood to halt sports-event contracts, obtained a court injunction against Kalshi, and characterized all three as unlicensed operators offering sports wagering products. The MGCB is running two parallel enforcement tracks simultaneously — one against offshore casinos, one against CFTC-registered exchanges — and treating both under the same jurisdictional theory.

That consistency is either a strength or an overextension, and I think the consensus is reading it as the former when it may be the latter. The offshore casino cases are straightforward: no federal registration, no regulatory overlap, no circuit court proceedings that might displace state authority. The prediction market cases are none of those things. Coinbase's appeal before the Sixth Circuit is stayed but not resolved. The Supreme Court's engagement with the underlying question is accelerating. Michigan's theory that CFTC registration does not preempt state gambling enforcement may ultimately be correct, but it is not settled, and bundling the two enforcement campaigns as a single expression of state sovereignty papers over a distinction that the federal courts have not finished drawing.

I have a bias toward finding the tail risk in regulatory overreach, and I am adjusting for it here. The offshore casino enforcement is clean and defensible on any reading of the law. The prediction market enforcement may also survive — the Sixth Circuit has not moved against Michigan's position — but the legal foundation is structurally different from what Williams described Thursday. The thirty-three letters are not evidence that Michigan's broader enforcement theory is correct. They are evidence that the MGCB is willing to use every tool it has, whether or not each tool is grounded in the same legal authority.