Public records requests have surfaced something troubling: Maryland’s gambling regulator appears to have borrowed heavily from the American Gaming Association when cracking down on prediction market platforms. The similarities raise a real question about independence.

The Paper Trail

Last April, the AGA handed Maryland officials a draft letter. It urged the Commodity Futures Trading Commission to ban sports-related event contracts offered by platforms like Kalshi and Polymarket. Days later, the Maryland Lottery and Gaming Control Agency issued its own cease-and-desist to Kalshi, using substantially similar language.

The timing alone is striking. Add in the textual overlap and you’ve got accusations flying that the MLGCA isn’t acting as an independent regulator at all, but rather as a tool for casino industry interests. Sean Patrick Maloney, president of the Coalition for Prediction Markets, didn’t mince words. “They’re clearly taking marching orders from casino lobbyists,” he said. “That’s not what the citizens of Maryland deserve.” He called the letter a “smoking gun” of regulatory capture.

More documents came to light. John Martin, director of the MLGCA, sent an email on 22 April noting that a proposed letter to CFTC commissioners had been “provided by the American Gaming Association.” It’s hard to miss that detail.

What’s Really at Stake

The conflict is straightforward enough. Maryland’s casinos pump substantial tax revenue into state coffers. Prediction market platforms? They could pull wagering activity away from traditional casinos. So it’s easy to see why a regulator tasked with maximizing state revenue might view these platforms as a threat. Whether that justifies the approach is another question entirely.

The AGA didn’t deny providing the template. A spokesperson defended the position, arguing that Congress intended sports betting regulation to remain with states and tribal governments. The letter simply reflected an effort to protect Maryland’s gambling laws, they said. For residents’ benefit, naturally.

A Wider Pattern

John Holden teaches business law at Indiana University and specializes in sports betting regulation. He offers some perspective. Trade associations supplying template letters and talking points to government officials? Not unusual. What’s changed is the regulatory environment itself. Legal sports betting has expanded rapidly across the US, creating a system where state regulators work closely with the very casino industry they’re supposed to oversee. That structural reality breeds genuine tensions.

The Maryland situation lays bare a real problem in gambling regulation. When the same agencies collect taxes and police the industry, conflicts of interest are baked in. This doesn’t necessarily mean regulators are acting in bad faith. But it does mean oversight bodies need robust independence mechanisms. Maryland’s apparent reliance on AGA talking points suggests those safeguards might be thinner than they should be.