Due to series of amendments to applicable Federal Law, i.e. the Johnson Act in 1992 and the Gambling Ship Act in 1994, United States and foreign flag vessels were permitted to engage in gambling on the high seas during so-called "cruises to nowhere." These amendments also granted the individual states the authority to enact statues prohibiting such cruises from departing and arriving in their waters. New York State did not choose to exercise this option. As a consequence, it became legal for ships to engage in gambling activities beyond the three-mile territorial water limit while leaving from and returning to New York Harbor.

The City of New York enacted Local Law 57 of 1997 creating the Gambling Control Commission ("GCC") to protect consumers and the general public in New York City from fraudulent practices and other acts of criminal predation, to assure public safety during such voyages, and to prevent businesses from being infiltrated and controlled by organized crime. The GCC is comprised of five members: three are appointed directly by the Mayor and two are appointed by the Mayor in consultation with the City Council. It is empowered to:

• license shipboard gambling businesses, their vendors after conducting extensive background investigations to determine their good character, honesty and integrity; and,
• devise and implement and extensive regulatory scheme governing the conduct of shipboard gambling businesses operating from New York City waters;
• conduct studies and investigations into matters related to gambling to assist the city in formulating related policies.