“The Force can have a strong influence on the weak-minded.” —Obi-Wan Kenobi
I now laugh at myself for thinking I knew anything about gaming regulation. I thought I had lived in it, studied it, done it in several jurisdictions, given speeches on it, taught it, and written on it. But I have come to discover I did not have a hint.
I sense the problem must be that I am not a lawyer. Two of the three members of the Nevada Gaming Control Board are lawyers, and four of the five members of the Nevada Gaming Commission are lawyers (and the fifth worked for a law firm). Of course, this was not the way the legislature wanted it when they drafted the laws that guided such things, but who cares about such silly constraints as the rules anymore? In gaming regulation in Nevada these days, it is new rules. And all of these regulators who felt it was ethically acceptable to vote (one did not)—voted to approve the transaction for Apollo to acquire the Venetian and related assets.
Here is what confuses me:
- I believe Apollo involved itself in this transaction to enhance shareholder value.
- I believe the largest personal shareholder in Apollo is Leon Black.
- I believe if David Sambur does not pull a repeat of what he and his colleagues did to Caesars, this transaction will result in an enhanced shareholder value for Apollo.
- I believe the person who seems to have the best chance of being enriched by this increased value is Leon Black—more than anyone else on the planet I can identify.
- I believe all of these lawyers seem to think Leon Black, who owns more than 11 percent of the shares of Apollo and could be the biggest beneficiary of this whole transaction, is not associated with the project.
I suggest that all of these lawyers believe that Leon Black is not associated with this project because, if he was, they would want him licensed, and I believe this because section (1.) subsection (c) of NRS 463.30129 states: “Public confidence and trust can only be maintained by strict regulation of all persons, locations, practices, associations and activities related to the operation of licensed gaming establishments…”
It seems to be the case, according to all of these Nevada lawyers, that Leon Black is not associated with a Nevada gaming establishment—a gaming establishment that could make Mr. Black a huge amount of money.
I guess Nevada has lost interest in that following the money thing.