In October 2025, multiple news stories came out regarding cheating in private poker games operated outside of Washington State using multiple methods to include the reprogramming of shuffling devices. Shuffling devices are used in licensed card games across Washington State in Tribal casinos and non-Tribal cardrooms.
The purpose of this post is to explain the requirements of using shuffling devices in licensed card games in Washington State.
In Washington State, manufacturers and distributors of shuffling devices are required to be licensed by the Washington State Gambling Commission before selling or distributing shufflers to Tribal casinos and non-Tribal cardrooms. Per WAC 230-03-200 (Washington Administrative Code), shuffling devices are defined as gambling equipment. Further, WAC 230-06-050 requires manufacturers to submit shuffling devices for our review and approval. The Washington State Gambling Commission’s internal testing lab conducts tests on the shufflers to ensure that the shuffles are random, and the shufflers are operating properly. Additionally, these shufflers are tested by independent test labs that are licensed and approved by our agency. These testing labs conduct testing on gambling equipment for numerous other jurisdictions as well.
The Washington State Gambling Commission provides a software signature so the approved software can be verified for compliance. A software signature is just like a fingerprint, it is unique to that particular piece of software and if anything were to have changed with the software file, that signature would change. If questions arise regarding the shuffler’s integrity or operation, then software signatures on the shufflers can be verified.