POKAGON BAND GAMING COMMISSION (2026)
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POKAGON BAND GAMING COMMISSION
REGULATIONS
PBGC Regulations Approved 7-08-2026
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Table of Contents
CHAPTER I.
GENERAL PROVISIONS .................................................................................................................. 9
Section 1.01 Legal Authority. ............................................................................................................................ 9
Section 1.02 Short Title..................................................................................................................................... 9
Section 1.03 Definitions. ................................................................................................................................... 9
Section 1.04 General Purposes. ...................................................................................................................... 25
Section 1.05 Scope and Applicability. ............................................................................................................. 25
Section 1.06 Rules of Interpretation............................................................................................................... 25
Section 1.07 Words and Terms. ...................................................................................................................... 26
Section 1.08 Areas Not Covered by the Regulations. ..................................................................................... 26
Section 1.09 Access to Records. ..................................................................................................................... 26
Section 1.10 Communications; Notices. ......................................................................................................... 26
Section 1.11 Restrictions for Gaming Enterprises. ......................................................................................... 27
Section 1.12 Enforcement Provisions. ............................................................................................................ 28
CHAPTER II.
SUPPLIER LICENSING ................................................................................................................... 29
Section 2.01 Restrictions on Doing Business. ................................................................................................. 29
Section 2.02 Determining the Need for a Gaming Supplier License............................................................... 29
Section 2.03 Granting a Gaming Supplier or Non-Gaming Supplier License. ................................................. 29
Section 2.04 Initial License Application. ......................................................................................................... 30
Section 2.05 Duration of License. ................................................................................................................... 30
Section 2.06 License Renewal Application. .................................................................................................... 31
Section 2.07 License Fees and Investigative Costs. ........................................................................................ 31
Section 2.08 Disqualification Criteria.............................................................................................................. 31
Section 2.09 Supplier License Qualification Requirements. ........................................................................... 32
Section 2.10 Individual Person License Qualification Requirements. ............................................................ 32
Section 2.11 Investigations; Supplementary Information; Approval of Change. ........................................... 33
Section 2.12 Revocation, Suspension, or Non-Renewal of License. ............................................................... 33
Section 2.13 Temporary License. .................................................................................................................... 34
Section 2.14 Reciprocity. ................................................................................................................................ 34
Section 2.15 Non-Gaming Suppliers. .............................................................................................................. 35
Section 2.16 Records. ..................................................................................................................................... 37
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Section 2.17 Obligation to Pay the Fees; No Refund of Fees Paid.................................................................. 37
Section 2.18 Master Vendors List. .................................................................................................................. 37
Section 2.19 Carrying of Gaming Licenses and Credentials for Suppliers. ..................................................... 37
CHAPTER III.
EMPLOYEE LICENSING............................................................................................................. 38
Section 3.01 Employee License Requirements. .............................................................................................. 38
Section 3.02 Application for a Gaming Employee License.............................................................................. 38
Section 3.03 Background Investigation. ......................................................................................................... 40
Section 3.04 Persons Who Must Obtain an Employee License. ..................................................................... 41
Section 3.05 Scope and Applicability of the Licensing of Natural Persons. .................................................... 44
Section 3.06 Requirements for Granting an Employee License. .................................................................... 44
Section 3.07 Provisional Employee License. ................................................................................................... 46
Section 3.08 Initial Employee License Application Processing. ...................................................................... 46
Section 3.09 Standards for Issuance of a Gaming Employee License. ............................................................ 47
Section 3.10 Eligibility Determination. ........................................................................................................... 48
Section 3.11 Approval of a Level 1 or Level 2 Gaming Employee License. ..................................................... 48
Section 3.12 Denial of a Gaming Employee License. ...................................................................................... 49
Section 3.13 Form of License. ......................................................................................................................... 49
Section 3.14 Employee License Duration. ...................................................................................................... 50
Section 3.15 Suspension or Revocation of a License. ..................................................................................... 50
Section 3.16 Show Cause Hearing for Primary Management Official. ............................................................ 52
Section 3.17 Date to Submit Employee License Renewal Application. .......................................................... 52
Section 3.18 Employee License Renewal Application..................................................................................... 52
Section 3.19 Employee License Renewal Application Processing. ................................................................. 53
Section 3.20 Documentation, Disclosure and Cooperation Requirements. ................................................... 53
Section 3.21 Identification of the Applicant. .................................................................................................. 54
Section 3.22 Prohibition of Employment with Expired License. ..................................................................... 54
Section 3.23 Obligation to Pay the Fees; No Refund of Fees Paid.................................................................. 54
Section 3.24 Application Fees and Miscellaneous Administrative Fees. ........................................................ 55
Section 3.25 Change of Position or Place of Work. ........................................................................................ 55
Section 3.26 Carrying of Employee Licenses and Credentials. ....................................................................... 55
Section 3.27 Authority. ................................................................................................................................... 55
Section 3.28 Employee License Reports. ........................................................................................................ 55
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Section 3.29 License Reconsideration. ........................................................................................................... 55
Section 3.30 Disclosure of Applicant and License Information and Documents. ........................................... 56
CHAPTER IV.
MINIMUM INTERNAL CONTROL STANDARDS ........................................................................ 58
Section 4.01 Accounting. ................................................................................................................................ 58
Section 4.02 Organizational Structure. ........................................................................................................... 62
Section 4.03 Forms, Records and Documents. ............................................................................................... 71
Section 4.04 Record Retention Requirements. .............................................................................................. 71
Section 4.05 Table Games............................................................................................................................... 73
Section 4.06 Bill Validator; Bill Acceptor Canister. ......................................................................................... 83
Section 4.07 Cage Operations Standards. ...................................................................................................... 85
Section 4.08 Complimentary Services. ........................................................................................................... 92
Section 4.09 Standards for Credit. .................................................................................................................. 94
Section 4.10 Procedures for Wire Transfers. .................................................................................................. 98
Section 4.11 Financial Reports and Information Technology Standards. ..................................................... 100
Section 4.12 Key Controls. ............................................................................................................................ 105
Section 4.13 Gaming Operations Compliance. ............................................................................................. 107
Section 4.14 Bingo. ....................................................................................................................................... 108
Section 4.15 Pull Tabs. .................................................................................................................................. 127
Section 4.16 Marketing, Gaming Promotions, and Player Tracking Systems. .............................................. 129
Section 4.17 Food and Beverage. ................................................................................................................. 131
Section 4.18 Keno. ........................................................................................................................................ 132
Section 4.19 Pari-Mutuel Wagering.............................................................................................................. 137
Section 4.20 Card Games. ............................................................................................................................. 140
Section 4.21 Kiosks. ...................................................................................................................................... 143
Section 4.22 Revenue Audit. ......................................................................................................................... 144
Section 4.23 Internal Audit. .......................................................................................................................... 148
Section 4.24 External Audit. ......................................................................................................................... 151
CHAPTER V.
GAMING DEVICES...................................................................................................................... 152
Section 5.01 Possession of Gaming Devices. ................................................................................................ 152
Section 5.02 Transportation and Movement of Gaming Devices................................................................. 152
Section 5.03 Master List of Approved Gaming Devices. ............................................................................... 153
Section 5.04 Official Seals or Asset Identifiers. ............................................................................................ 154
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Section 5.05 Gaming Device Bill Acceptor Canister Drop and Count. .......................................................... 154
Section 5.06 Kiosks Drop and Count. ............................................................................................................ 157
Section 5.07 Testing and Approval of Gaming Devices. ............................................................................... 159
Section 5.08 Gaming Device Operation in Conformity with Approved Model............................................. 159
Section 5.09 Ticket-In Ticket-Out Controls. .................................................................................................. 160
Section 5.10 Jackpot Verifications. ............................................................................................................... 161
Section 5.11 Computerized Gaming Machine Systems. ............................................................................... 161
Section 5.12 Jackpot and Accumulated Credit Payouts................................................................................ 162
Section 5.13 In-House Progressive Gaming Device Standards...................................................................... 163
Section 5.14 Wide Area Progressive Gaming Device Standards................................................................... 164
Section 5.15 Standards for Evaluating Theoretical and Actual Hold Percentages ....................................... 164
Section 5.16 EPROM Control Standards ....................................................................................................... 165
Section 5.17 Gaming Machinge Department Funds Standards .................................................................... 166
CHAPTER VI.
GAMING EQUIPMENT ........................................................................................................... 167
Section 6.01 Card Controls. .......................................................................................................................... 167
Section 6.02 Dice Controls. ........................................................................................................................... 171
Section 6.03 Gaming Chips. .......................................................................................................................... 175
Section 6.04 Gaming Equipment - Table Games Controls. ........................................................................... 180
CHAPTER VII.
RULES OF THE GAMES........................................................................................................... 183
Section 7.01 General Rules of the Games. ................................................................................................... 183
Section 7.02 New Games; Requirements and Procedures for Application. ................................................. 183
CHAPTER VIII.
BANK SECRECY ACT / TITLE 31 .............................................................................................. 185
Section 8.01 Currency Transaction Reporting. ............................................................................................. 185
Section 8.02 Suspicious Activity Reporting. .................................................................................................. 189
Section 8.03 CTR and Suspicious Activity Report Filings by the Commission. .............................................. 191
Section 8.04 Title 31 Risk Assessment and Controls. ................................................................................... 191
CHAPTER IX.
EXCLUSIONS .......................................................................................................................... 193
Section 9.01 Exclusion for Cause. ................................................................................................................. 193
Section 9.02 Compulsive Gambling and Voluntary Exclusion. ...................................................................... 195
CHAPTER X.
MISCELLANEOUS PROVISIONS .................................................................................................. 199
Section 10.01 Sanctions. ............................................................................................................................... 199
Section 10.02 Patron Complaints. ................................................................................................................ 200
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Section 10.03 Patron Complaint Hearing Review. ........................................................................................ 201
Section 10.04 Insurance Coverage. .............................................................................................................. 201
Section 10.05 Notice to Patrons. .................................................................................................................. 202
Section 10.06 Site Improvements. ................................................................................................................ 202
CHAPTER XI.
RULES OF PROCEDURE FOR HEARINGS................................................................................. 204
Section 11.01 Scope of Rules of Procedure. ................................................................................................. 204
Section 11.02 Notice of Hearing. .................................................................................................................. 204
Section 11.03 Ex Parte Communications. ..................................................................................................... 204
Section 11.04 Appearance through Counsel. ............................................................................................... 205
Section 11.05 Discovery Procedures for Enforcement Hearings. ................................................................. 205
Section 11.06 Confidential Materials. .......................................................................................................... 206
Section 11.07 Hearing Procedures. .............................................................................................................. 207
Section 11.08 Evidence. ................................................................................................................................ 208
Section 11.09 Burden of Proof...................................................................................................................... 209
Section 11.10 Commission Decisions. .......................................................................................................... 209
Section 11.11 Sanctions. ............................................................................................................................... 209
CHAPTER XII.
LABOR ORGANIZATIONS LICENSING ..................................................................................... 211
Section 12.01 General Provisions. ................................................................................................................ 211
Section 12.02 Licensing Requirements. ........................................................................................................ 212
Section 12.03 Individual Disclosure Requirements. ..................................................................................... 213
Section 12.04 Enforcement. ......................................................................................................................... 220
CHAPTER XIII.
SPORTS WAGERING .............................................................................................................. 222
Section 13.01 Sanctions. ............................................................................................................................... 222
Section 13.02 Incorporation by Reference Regarding Sports Wagering and Paid Fantasy Sports Games on
Pokagon Band Gaming Lands located within the State of Indiana. .............................................................. 222
Section 13.03 Authorized Sports Wagering Activities. ................................................................................. 222
Section 13.04 Prohibited and Restricted Sports Wagering Activities. .......................................................... 238
Section 13.05 Persons Prohibited from Engaging in Sports Wagering Activities. ........................................ 238
Section 13.06 Sports Wagering Definitions. ................................................................................................. 238
Section 13.07 Testing and Approval. ............................................................................................................ 239
Section 13.08 Wagering Device Requirements. ........................................................................................... 238
Section 13.09 Self-Service Kiosks and Point of Sale System Requirements. ................................................ 238
Section 13.10 Ticket/Voucher Requirements. .............................................................................................. 240
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Section 13.11 Ticket/Voucher Redemption. ................................................................................................. 240
Section 13.12 Sports Wagering System General Requirements................................................................... 238
Section 13.13 Sports Wagering Accounting and Internal Controls. ............................................................. 238
Section 13.14 Sports Wagering Internal Controls. ....................................................................................... 238
Section 13.15 Surveillance System. .............................................................................................................. 240
Section 13.16 House Rules............................................................................................................................ 238
Section 13.17 Terms and Conditions. ........................................................................................................... 238
Section 13.18 Information to be Displayed or Provided. ............................................................................. 238
Section 13.19 Sports Wagering Organizational Structure. ........................................................................... 238
Section 13.20 Risk Management. ................................................................................................................. 238
Section 13.21 Integrity Monitoring. ............................................................................................................. 238
Section 13.22 Records/Data Retention Requirement. ................................................................................. 238
Section 13.23 Required Reports. .................................................................................................................. 238
Section 13.24 Sports Wagering Marketing, Advertisement and Promotions. ............................................. 240
Section 13.25 Compulsive and Problem Gambling Requirement. ............................................................... 238
Section 13.26 Self-Excluded Persons. ........................................................................................................... 238
CHAPTER XIV. INTERNET AND MOBILE GAMING .............................................................................................. 238
Section 14.01 Definitions .............................................................................................................................. 238
Section 14.02 Incorporation by Reference Regarding Internet/Mobile Gaming Conducted on Pokagon Band
Gaming Lands within the State of Indiana.................................................................................................... 240
Section 14.03 General Requirements for Internet and Mobile Gaming ...................................................... 240
Section 14.04 Geofence Requirements ........................................................................................................ 245
Section 14.05 Internet Gaming Platform and Internet Games Technical Standards ................................... 245
Section 14.06 Standards for Approval of Slot Machine Internet Games and Random Number Generators246
Section 14.07 Standards for Approval of Table Internet Games .................................................................. 248
Section 14.08 Table Internet Game Rule Submission Process ..................................................................... 248
Section 14.09 Location of Servers, Security, and Cloud Storage .................................................................. 249
Section 14.10 Communication Standards for Gaming Systems ................................................................... 249
Section 14.11 Mandatory Gaming System Logging ...................................................................................... 250
Section 14.12 Self-Monitoring of Internet Gaming Platform Critical Components...................................... 251
Section 14.13 Change Approval .................................................................................................................... 251
Section 14.14 Internet Gaming Platform Assessment .................................................................................. 251
Section 14.15 Gaming Operation/Internet gaming intermediary Technical and Security Standards (Controls)
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...................................................................................................................................................................... 252
Section 14.16 Progressive Jackpots .............................................................................................................. 257
Section 14.17 Internet Gaming and Mobile Gaming Accounts .................................................................... 258
Section 14.18 Internet Gaming System or Mobile Gaming System Standards and Operational Controls... 260
Section 14.19 Server-Based Gaming System; Server-Based Games (Table Games, Slot Machines, and Peerto-Peer Gaming)............................................................................................................................................ 263
Section 14.20 Required Reports; Reconciliation; Test Accounts .................................................................. 266
Section 14.21 Bank Secrecy Act Compliance ................................................................................................ 269
Section 14.22 Integrity Monitoring/Suspicious Behavior ............................................................................. 270
Section 14.23 Voiding of Internet Wagers.................................................................................................... 270
Section 14.24 Negative Internet Gaming Account Balance Prohibited ........................................................ 270
Section 14.25 Tournament/Contests, Bonus and Promotional Wagering, Advertising, and Player Loyalty
Programs ....................................................................................................................................................... 270
Section 14.26 Data Security of Age and Identity Verification Information .................................................. 271
Section 14.27 Handling of Internet Gaming Accounts Found to be Used in a Fraudulent Manner ............. 272
Section 14.28 Failed ACH Deposits ............................................................................................................... 272
Section 14.29 Transfer of Funds Prohibited ................................................................................................. 272
Section 14.30 Internet Gaming Account Withdrawal ................................................................................... 272
Section 14.31 Internet Gaming Account Closure ......................................................................................... 273
Section 14.32 Internet Gaming Dormant Accounts...................................................................................... 273
Section 14.33 Internal Control Standards and Requirements ...................................................................... 273
Section 14.34 Amendments to Internal Controls ......................................................................................... 275
Section 14.35 Emergency Procedures .......................................................................................................... 276
Section 14.36 Compliance with Internal Controls ........................................................................................ 276
Section 14.37 Records Retention.................................................................................................................. 276
Section 14.38 Accounting Records ............................................................................................................... 277
Section 14.39 Responsible Internet Gaming ................................................................................................ 277
Section 14.40 Prohibited Persons ................................................................................................................. 278
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EMPLOYEE LICENSING
Employee License Requirements.
CHAPTER III.
Section 3.01
CHAPTER I.
GENERAL PROVISIONS
Section 1.01 Legal Authority.
Pursuant to the authority conferred on us by Section 3.03 and subsection 3.15(c) of the Gaming
Regulatory Act of the Pokagon Band of Potawatomi Indians, the Pokagon Band Gaming Commission approves
and promulgates the following Games of Chance Regulations, which shall be applicable to all Gaming subject
to regulation under the Gaming Regulatory Act.
Section 1.02 Short Title.
These Regulations shall be known and may be cited as the "Pokagon Band Gaming Commission
Regulations" (referred to herein as the “Regulations”).
Section 1.03 Definitions.
Unless a different meaning is set forth below, the terms used in these Regulations shall have the same
meaning as defined in the Gaming Regulatory Act and, to the extent consist with the Act, 'IGRA and any
regulations promulgated thereunder.
• “Account Access Card” means an instrument used to access customer accounts for wagering at a Gaming
Machine. Account Access Cards are used in connection with a computerized account database. Account
Access Cards are not “smart cards.”
• “Accountability” means all items of cash, Chips, Coins, Tokens, plaques, receivables, and Customer Deposits
constituting the total amount for which the bankroll custodian is responsible at a given time.
“Accumulated Credit Payout” means credit earned in a Gaming Machine that is paid to a customer
manually in lieu of a machine Payout.
• ''Act'' or ''Gaming Regulatory Act'' means the Pokagon Band of Potawatomi Indians Gaming Regulatory Act,
as amended from time to time.
• “Actual Hold Percentage” means the percentage calculated by dividing the Win by the Drop or Coin-in
(number of credits wagered). Can be calculated for individual tables or Gaming Machines, type of Table
Games, or Gaming Machines on a per day or cumulative basis.
• “Agent” means a person authorized by the Gaming Operation, as approved by the Commission, to make
decisions or perform assigned tasks or actions on behalf of the Gaming Operation.
• “Ante” means a player's initial wager or predetermined contribution to the pot before the dealing of the
first hand.
• “Any Offense” shall mean any criminal offense other than a gambling-related offense, Fraud or
Misrepresentation, whether committed in Michigan or any other jurisdiction, that is, or would be, a crime
under the provisions of the Michigan Penal Code, Act No. 328 of the Public Acts of 1931, as amended,
being MCL 750.1 to 750.568, or the controlled substance provisions of the Public Health Code, Act No. 368
of the Public Acts of 1978, as amended, being MCL 333.7101 to 333.7545, or any other criminal offense
(other than a gambling-related offense, Fraud or Misrepresentation) that involves theft, dishonesty, Fraud
or Misrepresentation arising under the laws of Michigan or another State or jurisdiction, that was
committed as an adult or prosecuted as an adult offense, and which has not been effectively removed
from the employee's criminal record by executive pardon, State court order, or operation of law.
• “Any Offense” shall also mean any criminal offense whether committed in Indiana or any other jurisdiction,
that is, or would be,a crime under the provisions of the Title 35 of the Indiana Code, Criminal Law and
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EMPLOYEE LICENSING
CHAPTER III.
Employee License Requirements.
Section 3.01
Procedure, as amended, or any other criminal offense not specified in subsection 4(I)(3) involving
gambling, theft, dishonesty, or Fraud or Misrepresentation arising under Indiana law or the law of another
state or jurisdiction, that was committed as an adult or prosecuted as an adult offense, and which has not
been effectively removed from such person’s criminal record by executive pardon, state or federal court
order, or operation of law.
• “Applicant” means any Person, applying for, or requesting renewal of, any License required by this Act.
• “Application” or “License Application” means a request for the issuance or renewal of a License required by
the Act and these Regulations.
• “Audit Finding” means the result from a process that evaluates audit evidence and compares it against
audit criteria. Audit Findings can show that audit criteria are being met (conformity) or that they are not
being met (nonconformity). They can also identify best practices or improvement opportunities. Audit
Findings include external audits, external investigation findings, internal procedural violation report
findings, internal Audit Findings, and internal/external compliance Audit Findings.
• “Automated Payout” means payment issued by a machine.
• “Betting Station” means the area designated in a pari-mutuel area that accepts wagers and pays winning
bets.
• “Betting Ticket” means a printed, serially numbered form used to record the event upon which a wager is
made, the amount and date of the wager, and sometimes the line or spread (odds).
• “Bill Acceptor” means the device that accepts and reads cash by denomination in order to accurately
register customer credits.
• “Bill Acceptor Canister” means the box attached to the Bill Acceptor used to contain cash received by Bill
Acceptors, whether in Gaming Machines, Gaming Devices, or functioning as a Financial Instrument Storage
Component used in connection with Player Interfaces.
• “Bill Acceptor Drop” means cash contained in Bill Acceptor Canisters.
• “Bill-in Meter” means a Meter included on a Gaming Machine accepting cash that tracks the number of bills
put in the machine.
• “Boxperson” means the first-level supervisor who is responsible for directly participating in and supervising
the operation and conduct of a craps Game.
• “Breakage” means the difference between actual bet amounts paid out by a racetrack to bettors and
amounts won due to bet payments being rounded up or down. For example, a winning bet that should pay
$4.25 may be actually paid at $4.20 due to rounding.
• “Cage” means a secure work area within the Gaming Operation for cashiers, which may include a storage
area for the Gaming Operation bankroll.
• “Cage Accountability form” means an itemized list of the components that make up the Cage
Accountability.
• “Cage Credit” means advances in the form of cash or Gaming Chips made to customers at the Cage.
Documented by the players signing an IOU or a Marker similar to a Counter Check.
• “Cage Marker Form” means a document, signed by the customer, evidencing an extension of Credit at the
Cage to the customer by the Gaming Operation.
• “Calibration Module” means the section of a weigh scale used to set the scale to a specific amount or
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EMPLOYEE LICENSING
CHAPTER III.
Employee License Requirements.
Section 3.01
number of Coins to be counted.
• “Call Bets” means a wager made without cash or Chips, reserved for a known customer and includes
marked bets (which are supplemental bets made during a hand of play). For the purpose of settling a call
bet, a hand of play in craps is defined as a natural winner (e.g., seven or eleven on the come-out roll), a
natural loser (e.g., a two, three or twelve on the come-out roll), a seven-out, or the player making his
point, whichever comes first.
• “Card Game” means a Game in which the Gaming Operation is not party to wagers and from which the
Gaming Operation receives compensation in the form of a Rake, a time buy-in, or other fee or payment
from a player for the privilege of playing.
• “Card Room Bank” means the operating fund assigned to the card room or main Card Room Bank.
• “Cash Equivalent(s)” means documents, Financial Instruments other than cash, or anything else of
representative value to which the Gaming Operation has assigned a monetary value. A Cash Equivalent
includes, but is not limited to, Tokens, Chips, Coupons, Vouchers, Payout slips and tickets, and other items
to which a Gaming Operation has assigned an exchange value.
• “Cashless System” means a system that performs Cashless Transactions and maintains records of those
Cashless Transactions.
• “Cashless Transaction” means a movement of funds electronically from one component to another, such as
to or from a Patron Deposit Account.
• “Cash-out Ticket” means an instrument of value generated by a Gaming Machine representing a cash
amount owed to a customer at a specific Gaming Machine. This instrument may be wagered at other
machines by depositing the Cash-out Ticket in the machine Bill Acceptor.
• “Chair” means the Chair of the National Indian Gaming Commission.
• “Chips” means cash substitutes, in various denominations, issued by a Gaming Operation and used for
wagering.
• ''Class I Gaming'' shall have the definition that term is given in the Indian Gaming Regulatory Act at 25
U.S.C. § 2703 (6).
• ''Class II Gaming'' means Class II Gaming as defined in the Indian Gaming Regulatory Act at 25 U.S.C. § 2703
(7) and any Regulations promulgated thereunder.
• ''Class III Gaming'' means Class III Gaming as defined in the Indian Gaming Regulatory Act at 25 U.S.C. §
2703 (8) and any regulations promulgated thereunder but excluding any Class III Gaming that is not
authorized by the relevant Compacts.
• “Class II Gaming System” means all components, whether or not technologic aids in electronic, computer,
mechanical, or other technologic form, that function together to aid the play of one or more Class II
games, including accounting functions mandated by these Regulations or 25 C.F.R. § 547.
• “Coin” means a small piece of metal, usually flat and circular, authorized by the United States government
for use as money, or Tokens issued by the Gaming Operations for use as a monetary equivalent.
• “Commission” or “Gaming Commission” means the Pokagon Band Gaming Commission, established by the
Pokagon Band of Potawatomi Indians Gaming Regulatory Act. Also, generically referred to as the “Tribal
Gaming Regulatory Authority” or “Commission”.
• “Commissioner” means a Commissioner of the Pokagon Band Gaming Commission as appointed by the
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EMPLOYEE LICENSING
CHAPTER III.
Employee License Requirements.
Section 3.01
Pokagon Band Tribal Council pursuant to the Act.
• ''Compacts'' means those compacts with the State of Michigan and the State of Indiana, defined
respectively as “Michigan Compact” and the “Indiana Compact”.
• “Complimentary Services and Items means a service or item provided at no cost, or at a reduced cost, to a
Patron as set forth in 25 C.F.R. §543.2.
• ''Control Person'' means any person who has the power to direct or cause direction of the management
and policies of the business operations of a Gaming Supplier or Non-Gaming Supplier as verified by the
Gaming Supplier's or Non-Gaming Supplier’s ownership and organization structure described in the
documents establishing the existence of the Gaming Supplier or Non-Gaming Supplier and the designation
of persons authorized to act on behalf of the Gaming Supplier or Non-Gaming Supplier. A person shall be
presumed to have control when such person owns shares of any corporation that is not a publicly-traded
corporation and such person owns, controls or holds the power to vote ten percent (10%) or more of the
voting securities of the corporation. Control Persons include members of the board of directors, chief
executive officer, chief operating officer, and any person with the responsibility and authority to manage
the contract on behalf of the Gaming Supplier or Non-Gaming Supplier with respect to the goods or
services being provided to a Gaming Operation.
• “Count” means the act of counting and recording the Drop and/or other funds. Also, the total funds
counted for a Game, Player Interface, Shift, or another period.
• “Count Room” means a secured room where the Count is performed in which the cash and Cash
Equivalents are counted.
• “Count Team” means personnel that perform the Count.
• “Counter Check” means a form provided by the Gaming Operation for the customer to use in lieu of a
personal check.
• “Counter Game” means a Game in which the Gaming Operation is a party to wagers and wherein the
Gaming Operation documents all wagering activity. The term includes, but is not limited to, bingo, Keno,
and pari-mutuel race books. The term does not include Table Games, Card Games and Gaming Machines.
• “Coupon” means a Financial Instrument of fixed wagering value that can only be used to acquire noncashable credits through interaction with a Voucher System. This does not include instruments such as
printed advertising material that cannot be validated directly by a Voucher System.
• “Credit” means the right granted by a Gaming Operation to a customer to defer payment of debt or to
incur debt and defer its payment.
• “Credit Limit” means the maximum dollar amount of Credit assigned to a customer by the Gaming
Operation.
• “Credit Slip” means a form used to record either:
(a)
The return of Chips from a Gaming table to the Cage; or
(b)
The transfer of IOUs, Markers, or negotiable checks from a Gaming table to a Cage or bankroll.
• “Currency Cassette” means a compartment that contains a specified denomination of currency. Currency
Cassettes are inserted into Kiosks, allowing them to dispense currency.
• “Customer Deposits” means the amounts placed with a Cage cashier by customers for the customers' use
at a future time.
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EMPLOYEE LICENSING
CHAPTER III.
Employee License Requirements.
Section 3.01
• “Deal” means a specific Pull Tab Game that has a specific serial number associated with each Game.
“Dealer” means an Employee who operates a Game, individually or as a part of a crew, administering
house rules and making payoffs.
• “Dedicated Camera” means a video camera that continuously records a specific activity.
• “Deskman” means a person who authorizes payment of winning tickets and verifies Payouts for Keno
games.
• “Draw Ticket” means a blank Keno ticket whose numbers are punched out when balls are drawn for the
Game. Used to verify winning tickets.
• “Drop” (for Gaming Machines) means the total amount of cash, Cash-out Tickets, Coupons, Coins, and
Tokens removed from Drop Buckets and/or Bill Acceptor Canisters. Drop (for Table Games) means the
total amount of cash, Chips, and Tokens removed from Drop Boxes, plus the amount of Credit issued at
the tables.
• “Drop Box” means a locked container in which cash or Cash Equivalents are placed at the time of a
transaction, typically used in Card Games or Table Games. It is affixed to the Gaming table into which the
Drop is placed. The Game type, table number, and Shift are indicated on the box.
• “Drop Bucket” means a container located in the Drop Cabinet (or in a secured portion of the Gaming
Machine in coinless/cashless configurations) for collecting Coins, Tokens, Cash-out Tickets, and Coupons
from the Gaming Machine.
• “Drop Cabinet” means the wooden or metal base of the Gaming Machine that contains the Gaming
Machine Drop Bucket.
• “Drop Period” means the period of time that occurs between sequential Drops.
• “Drop Proceeds” means the total amount of Financial Instruments removed from Drop Boxes, Bill Accepter
Canisters, and Financial Instrument storage components.
• “Earned and Unearned Take” means race bets taken on present and future race events. Earned take means
bets received on current or present events. Unearned take means bets taken on future race events.
• ''Emergency Operation Plan'' means the plan required by Section 2.05, of the Health and Safety Act, which
shall be included with an Application for a Gaming Operation License under Section 6.03 of the Act.
• “EPROM” means erasable programmable read-only memory or other equivalent Game software media.
• “Exception Report” A listing of occurrences, transactions or items that fall outside a predetermined range
of acceptability.
• “Excluded Person” means any Patron or other person whose name has been added to an Exclusion List in
accordance with the requirements set forth in Section 10.14 of the Act.
• “Exclusion List” means the list of Excluded Persons created and maintained under the requirements set
forth in Section 10.14 of the Act.
• “Fill” means a transaction whereby a supply of Chips, Coins, or Tokens is transferred from a bankroll to a
table Game.
• “Fill Slip” means a document evidencing a Fill.
• “Financial Instrument” means any tangible item of value tendered in Game play, including, but not limited
to bills, Coins, Vouchers, and Coupons.
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• “Financial Instrument storage component” means any component that stores Financial Instruments, such
as a Drop Box, but typically used in connection with Player Interfaces.
• “FinCEN” means the Financial Crimes Enforcement Network of the United States Department of the
Treasury.
• ''Fiscal Year'' for the Tribe means the period ending on December 31st of each year and for the Pokagon
Gaming Authority and the Four Winds Casino Resort means the period ending on the last Sunday of each
calendar year.
• “Flare” means the information sheet provided by the manufacturer that sets forth the rules of a particular
Pull Tab Game and that is associated with a specific Deal of Pull Tabs. The Flare shall contain the following
information:
(a)
Name of the Game;
(b)
Manufacturer name or manufacturer's logo;
(c)
Ticket Count; and
(d)
Prize structure, which shall include the number of winning Pull Tabs by denomination, with their
respective winning symbols, numbers, or both.
• ''Fraud or Misrepresentation'' shall mean a criminal offense committed in Michigan, Indiana, or any other
jurisdiction, involving, theft, fraud or misrepresentation, which is a felony or would be a felony if
committed in Indiana or Michigan, and which was committed as an adult or prosecuted as an adult
offense, and which has not been effectively removed from such person’s criminal record by executive
pardon, state court order, or operation of law.
• “Future Wagers” means bets on races to be run in the future (e.g., Kentucky Derby).
• ''Game'' means any Game of chance, however conducted, operated, or played, that comes within the
definition of Gaming provided in this Section.
• “Game Server” means an electronic selection device, utilizing a Random Number Generator.
• ''Gaming'' means any Class II Gaming or Class III Gaming activity, either individually or collectively and
whether authorized or unauthorized.
• ''Gaming Device'' means any mechanical, electromechanical or electronic equipment, contrivance,
component, or machine, whether used remotely or directly in connection with any Gaming that affects the
result of a wager by determining or predicting the outcome of a Game or the odds of winning or losing a
Game. This term shall be broadly construed to promote the purposes of the Act and shall also include any
devices, machines, components, or contrivances which do affect, or are capable of affecting, in any way,
the playing of any Game, provided that this term shall not be construed to expand the meaning of
''electronic games of chance'' set forth in Section (3) subsection (A) (5) of the Michigan Compact for the
purpose of affecting the calculation of net win under Sections 17 and 18 of the Michigan Compact. This
term shall not be construed to expand the meaning of “Electronic Game of Chance” set forth in Subsection
2(H) of the Indiana Compact.
• “Gaming Enterprise” means the entities through which the Band conducts, regulates, and secures Gaming
on Indian Lands within the Band’s jurisdiction pursuant to IGRA.
• ''Gaming Employee'' means any Primary Management Official, Key Employee, any other person employed
by a Gaming Operation whose employment requires access to restricted areas of the Gaming Operation,
and any other employee of a Gaming Operation deemed by the Gaming Commission to be engaged in
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Section 3.01
Gaming-related activities during his or her employment.
• ''Gaming Equipment or Supplies'' means:
(a)
Any machine, mechanism, device, or implement that may affect the result of a Game by determining
Win or loss, including without limitation, any of the following:
(1)
Any Gaming Device
(2)
Software used with any Gaming Device
(3)
Cards; and
(4)
Dice
(b)
Layouts for live Table Games and representatives of values, including without limitation, Chips, Tokens,
or electronic debit cards and related hardware or software that affect the result of the Game; and
(c)
Services to maintain, repair, or renovate any equipment or supplies described in subsections (a) or (b)
and any other services that directly relate to the conduct of Gaming, security, or surveillance at a
Gaming Operation, including without limitation, casino credit reporting services.
• ''Gaming Establishment'' means any facility or premises where Class II or Class III Gaming is conducted and
includes all buildings, structures and other appurtenances required for the operation or maintenance of
such facility or used in connection with such Gaming.
• “Gaming Machine” means an electronic or electromechanical machine that allows a player to play games of
chance, some of which may be affected by skill, which contains a microprocessor with Random Number
Generator capability for outcome selection or computer terminal that accesses an outcome that is
subsequently and randomly selected in drawings that are electronically conducted by central computer or
other such methods of chance selection, whether mechanical or electronic. The machine is activated by
the insertion of cash or Cash Equivalents and which awards cash, Cash Equivalents, merchandise, or a
written statement of the player's accumulated credits, which written statements may be redeemable for
cash.
• “Gaming Machine Analysis Report” means a report prepared that compares theoretical to actual Hold by a
Gaming Machine on a monthly or other periodic basis.
• “Gaming Machine Booths and Change Banks” means a booth or small Cage in the Gaming Machine area
used to provide change to players, store change aprons and extra Coin, and account for jackpot and other
Payouts.
• “Gaming Machine Pay Table” means the reel strip combinations illustrated on the face of the Gaming
Machine that can identify Payouts of designated Coin amounts.
• “Gaming Official or Employee” means regarding Class III gaming activities at each Gaming Operation:
(a)
Primary Management Officials;
(b)
Key Employees;
(c)
All other employees whose regular job duties require access to restricted areas or involvement in Class
III gaming activities at a Gaming Operation; and
(d)
Consultants providing gaming-related services directly to a Class III Gaming Operation (except legal
counsel).
• “Gaming Operation” means any business owned by the Tribe or a Tribal entity, the revenues of which are
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primarily derived from Gaming or from any Gaming Establishment.
• “Gaming Operation Accounts Receivable” (for Gaming Operation Credit) means Credit extended to Gaming
Operation customers in the form of Markers, returned checks, or other Credit instruments that have not
been repaid.
• “Gaming Promotion” means any promotional activity or award that requires Game play as a condition of
eligibility.
• “Gaming Supplier” means any Person who sells, leases, or otherwise supplies any Gaming Equipment or
Supplies to a Gaming Operation.
• “Generally Accepted Accounting Principles (GAAP)” means a widely accepted set of rules, conventions,
standards, and procedures for reporting financial information, as established by the Financial Accounting
Standards Board (FASB), including, but not limited to, the standards for casino accounting published by the
American Institute of Certified Public Accountants (AICPA).
• “Generally Accepted Auditing Standards (GAAS)” means a widely accepted set of standards that provide a
measure of audit quality and the objectives to be achieved in an audit, as established by the Auditing
Standards Board of the American Institute of Certified Public Accountants (AICPA).
• “Governmental Accounting Standards Board (GASB)” means Generally Accepted Accounting Principles used
by state and local governments.
• “Gross Gaming Revenue” means annual total amount of cash wagered on class II and class III games and
admission fees (including table or card fees), less any amounts paid out as prizes or paid for prizes
awarded.
• ''Gross Revenue'' means the total of all the following, less the total of all cash paid out as winnings to
Patrons and any amounts made deductible from Gross Revenues as Patron winnings or otherwise:
(a)
Cash received as wagers;
(b)
Cash received in payment for Credit extended by a Licensee to a Patron for the purposes of Gaming;
and
(c)
Compensation received for conducting any Game in which the Licensee is not a party to a wager. For
the purposes of this definition, cash or the value of non-cash prizes awarded to Patrons in a contest or
tournament are not winnings. The term “winnings”, as used in this definition, does not include:
(1)
Counterfeit money, Chips, Tokens, wagering instruments, or wagering credits;
(2)
Coins of other countries that are received in Gaming Equipment or Supplies;
(3)
Cash taken in fraudulent acts perpetrated against a Licensee for which the Licensee is not
reimbursed; or
(4)
Cash received as entry fees for contests or tournaments in which the Patrons compete for prizes.
Calculation of Gross Revenues - certain expenses not deductible.
(d)
In calculating Gross Revenue, any prizes, premiums, drawings, benefits, or tickets which are redeemable
for money or merchandise or other promotional allowance, except money or Tokens paid at face value
directly to a Patron as the result of a specific wager and the amount of cash paid to purchase an annuity
to fund winnings, must not be deducted as Patron winnings.
(e)
In calculating Gross Revenue from Gaming Devices, the actual cost to the Licensee of any personal
property distributed to a Patron as the result of a legitimate wager may be deducted as a Patron
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winning, but not travel expenses, food, refreshments, lodging or services. For the purposes of this
Section, ''as the result of a legitimate wager'' means that the Patron must make a wager prior to
receiving the personal property, regardless of whether the receipt of the personal property is
dependent on the outcome of the wager.
• “Health and Safety Act” means the Tribe’s Health and Safety Act (formerly known as the Health,
Environmental Protection, and Building Codes Ordinance and the Health, Environmental Protection and
Building Codes Act), as may be amended from time-to-time.
• “Hearing Examiner” means an official appointed by the Commissioners to conduct an investigation or
administrative hearing so that the Commissioners can exercise their statutory powers. A Hearing Examiner
has the power to administer oaths, receive evidence, take testimony, and make initial findings of fact or
law.
• “Hold” means the relationship of Win to Coin-in for Gaming Machines and Win to Drop for Table Games.
• “Hub” means the person or entity that is licensed to provide the operator of a pari-mutuel wagering
operation information related to horse racing that is used to determine winners of races or payoffs on
wagers accepted by the pari-mutuel wagering operation.
• “Independent” means the separation of functions to ensure that the Agent or process monitoring,
reviewing, or authorizing the controlled activity, function, or transaction is separate from the Agents or
process performing the controlled activity, function, or transaction.
• ''Indian Gaming Regulatory Act'' or “IGRA'' means P.L. 100-497, 102 Stat. 2467, enacted on Oct. 17, 1988
and codified at 25 U. S.C. § 2701 et seq.
• “Indiana Compact” means the Compact dated January 21, 2021 between the Pokagon Band of Potawatomi
and the State of Indiana negotiated and entered into pursuant to IGRA § 2710(d)(3) to govern Class III
gaming and shall include any renewals and amendments.
• “Internal Audit” means persons who perform an audit function of a Gaming Operation that are
Independent of the department subject to audit. Independence is obtained through the organizational
reporting relationship, as the Internal Audit department shall not report to management of the Gaming
Operation. Internal Audit activities should be conducted in a manner that permits objective evaluation of
areas examined. Internal Audit personnel may provide audit coverage to more than one operation within
a Tribe's Gaming Operation holdings.
• “Issue Slip” means a copy of a Credit instrument that is retained for numerical sequence control purposes.
• “Keno” means a Class III Game of chance similar to lotto, based on the drawing of numbers that must
correspond with selected numbers on cards.
• “Key Employee” means:
(a)
Any person employed by a Gaming Operation who performs one or more of the following functions:
(1)
Bingo caller,
(2)
Counting Room supervisor,
(3)
Chief of security,
(4)
Floor Manager,
(5)
Pit boss,
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(6) Dealer,
(7)
Croupier,
(8)
Approver of Credit, or
(9)
Custodian of Class II Gaming Systems as defined in 25 C.F.R. §547.2 and similar Class III Gaming
systems, Gaming cash or Gaming cash equivalents, Gaming Equipment or Supplies, or Class II
Gaming systems records or Class III Gaming systems records; or
(10) Custodian of surveillance systems or surveillance system records.
(b)
Any Gaming Employee authorized by the Gaming Operation for unescorted access to secured gaming
areas designed as secured gaming areas by the Commission;
(c) If not otherwise licensed as a Key Employee or Primary Management Official, the four most highlycompensated persons employed in any Gaming Operation; or
(d)
Any other employee of any Gaming Enterprise as documented by the Commission as a Key Employee.
• “Lammer Button” means a type of chip that is placed on a Gaming table to indicate that the amount of
Chips designated thereon has been given to the customer for wagering on Credit before completion of the
Credit instrument. Lammer Button may also mean a type of chip used to evidence transfers between table
banks and Card Room Banks.
• “Kiosk” means a device capable of redeeming Vouchers and/or wagering credits or initiating are physically
separate and not regulated by the same Tribal Gaming regulatory authority.
• ''License'' means a limited grant of authority by the Commission, pursuant to the Act, to a specific Person to
perform certain acts or engage in certain activities that are regulated under the Act and cannot be
performed or engaged in without a License. Neither the filing of an Application nor the Commission's
decision to grant or not grant a License to an Applicant shall create a property interest or due process
rights in favor of the Applicant except as may be explicitly provided by the Act, these Regulations, or other
Tribal Laws. Licenses shall be structured according to the type of Applicant; as provided in the table below:
License Type
Category
Description
License Term
Gaming Operation
N/A
N/A
two (2) years
Level 1
Primary Management Officials
one (1) year
Level 2
Key Employees
two (2) years
Level 4
Non-Gaming Employees
three (3) years
N/A
Gaming Supplier
two (2) years
N/A
Non-Gaming Supplier
three (3) years
Employee
Supplier
• ''Licensee'' means any Person who has been issued a valid and current License pursuant to the provisions of
this Act.
• “Lines of Credit” means the privilege granted by a Gaming Operation to a Patron to:
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(a) Defer payment of debt; or
(b)
EMPLOYEE LICENSING
Employee License Requirements.
Incur debt and defer its payment under specific terms and conditions.
• “Logic Box” means a housing unit containing multiple processing units required for EGD operation;
processing units may include, but is not limited to, Random Number Generators, stand-alone progressive
controllers, graphics processing units, and central processing units.
(a)
At a minimum, Logic Boxes require the following security features before an EGD is offered to the public
(1)
A lock provided by the Operation that is keyed separately from any other locking device utilized
within the Gaming Operation
(2)
A Commission-approved tamper evident pre-numbered seal
• “Main Card Room Bank” means a fund of cash, Coin, and Chips used primarily for poker and pan Card Game
areas. Used to make even cash transfers between various games as needed. May be used similarly in other
areas of the Gaming Operation.
• “Management Contract” means any contract, agreement or other document, including all collateral
agreements, that delegates managerial responsibilities to any Person in or for any Gaming Operation and
that requires approval by the NIGC pursuant to the Indian Gaming Regulatory Act.
• “Management Contractor” means any Person to whom managerial responsibilities in or for any Gaming
Operation have been assigned by a Gaming Operation under a Management Contract.
• ''Management Fee” means any monies paid by a Gaming Operation from Gaming Revenue to any Person
pursuant to a Management Contract, but excluding monies permitted under the Management Contract to
be paid to the Management Contractor as reimbursement for Operating Expenses, capital replacement
costs, or in fulfillment of other obligations of such Gaming Operation.
• “Manager” means the person designated by the Gaming Operation as having management responsibility
for a Gaming Operation.
• “Manual Payout” means any non-automated Payout.
• “Marker” means a document, signed by the customer, evidencing an extension of Credit to him/her by the
Gaming Operation.
• “Marker Inventory Form” means a form maintained at Table Games or in the Gaming Operation pit that are
used to track Marker inventories at the individual table or pit.
• “Marker Transfer Form” means a form used to document transfers of Markers from the pit to the Cage.
• “Master Game Sheet” means a form used to record, by Shift and day, each table Game's winnings and
losses. This form reflects the opening and closing table inventories, the fills and credits, and the Drop and
Win.
• “Meter” means an electronic (soft) or mechanical (hard) apparatus in a Gaming Machine. May record the
number of Coins wagered, the number of Coins Dropped, the number of times the handle was pulled, or
the number of Coins paid out to winning players.
• “Michigan Compact” means the Compact dated December 3, 1998, including all renewals, amendments,
appendices, exhibits and other attachments thereto, between the Pokagon Band of Potawatomi Indians
and the State of Michigan providing for the Conduct of Tribal Class III Gaming by the Pokagon Band of
Potawatomi Indians, which was deemed approved by the Secretary of the Interior by operation of law
under the IGRA (25 U.S.C. § 2710(d)(8)(C)) and became effective on upon publication in the Federal
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Section 3.01
Register (64 Fed, Reg. 8111, February 18, 1999).
• “MICS” means the minimum internal control standards promulgated by the National Indian Gaming
Commission.
• “Motion Activated Dedicated Camera” means a video camera that, upon its detection of activity or motion
in a specific area, begins to record the activity or area.
• “Multi-Game Machine” means a Gaming Machine that includes more than one type of Game option.
“Multi-Race Ticket” means a Keno ticket that is played in multiple games.
• ''Net Revenue'' means Gross Revenue of any Gaming Operation minus amounts paid for, or paid out as
prizes, winnings and related Operating Expenses, excluding Management Fees.
• “Network Communication Equipment” means a device or collection of devices that controls data
communication in a system including, but not limited to, cables, switches, hubs, routers, wireless access
points, landline telephones and cellular telephones.
• “NIGC” means the National Indian Gaming Commission.
• ''Non-Gaming Employee'' means any employee of a Gaming Operation who is not a Gaming Employee. For
purposes of Licensing, Level 4 shall be comprised of all Non-Gaming Employees.
• ''Non-Gaming Supplier'' means any Person who is not a Gaming Supplier and who provides goods or
services to a Gaming Operation, the aggregate annual value of which exceeds an amount established by
Commission Regulation as determined from all written and oral contracts between the Non-Gaming
Supplier and the Gaming Operation to supply such goods or services within any twelve-month period of
time. For purposes of licensing, Level B shall be comprised of all Non-Gaming Suppliers.
• “On-line Gaming Machine Monitoring System” means a system used by a Gaming operation to monitor
Gaming Machine Meter readings and/or other activities on an on-line basis.
• On-line Gaming Machine Monitoring System “Order for Credit” means a form that is used to request the
transfer of Chips or Markers from a table to the Cage. The order precedes the actual transfer transaction
that is documented on a Credit Slip.
• ''Operating Expense'' means any expense incurred in the operation of Gaming that is specifically designated
as an Operating Expense in any Management Contract or which otherwise is so treated by Application of
Generally Accepted Accounting Principles.
• “Outstation” means areas other than the main Keno area where bets may be placed, and tickets paid.
• “Par Percentage” means the percentage of each dollar wagered that the house wins (i.e., Gaming
Operation advantage).
• “Par Sheet” means a specification sheet for a Gaming Machine that provides machine Hold percentage,
model number, hit frequency, reel combination, number of reels, number of Coins that can be accepted,
and reel strip listing.
• “Pari-Mutuel Wagering” means a system of wagering on horse races, jai-alai, greyhound, and harness
racing, where the winners divide the total amount wagered, net of commissions and Operating Expenses,
proportionate to the individual amount wagered.
• ''Patron'' means any person who participates in Gaming as a customer or who is physically present on the
premises where Gaming is conducted as a customer of the Gaming Operation. Also, may be referred to as
a “player”.
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Section 3.01
• “Patron Deposit Account” means an account maintained on behalf of a Patron, for the deposit and
withdrawal of funds for the primary purpose of interacting with a Gaming activity.
• “Payment Slip” means that part of a Marker form on which customer payments are recorded. “Payout”
means a transaction associated with a winning event.
• ''Person'' means any business, proprietorship, association, partnership, syndicate, corporation, firm, joint
venture, trust or other form of business association or entity, labor organization, state, local government,
government instrumentality or entity, as well as any individual person. The term “person'', without an
initial capital ''P'', refers exclusively to an individual person.
• “Person Having a Direct or Indirect Financial Interest in a Management Contract” means:
(a)
When a Person is a party to a Management Contract, any Person having a direct financial interest in
such Management Contract;
(b)
When a trust is a party to a Management Contract, any beneficiary or trustee;
(c)
When a partnership is a party to a Management Contract, any partner;
(d)
When a corporation is a party to a Management Contract, any Person who is a director or who holds at
least 5% of the issued and outstanding stock alone or in combination with another stockholder who is a
spouse, parent, child or sibling; or
(e)
When an entity, other than a Person, has an interest in a trust, partnership, corporation or Person that
has an interest in a Management Contract, all parties of that entity are deemed to be persons having a
direct financial interest in a Management Contract.
• “Petition” means a formal written request appealing to authority, usually the Commission, with respect to a
particular case.
• “PIN” means the personal identification number used to access a player's account.
• “Pit Podium” means a stand located in the middle of the tables used by Gaming Operation supervisory
personnel as a workspace and a record storage area.
• “Pit Supervisor” means the employee who supervises all games in a pit.
• “Player Interface” means any component(s) of a Class II Gaming System, including an electronic or
technologic aid (not limited to terminals, player stations, handhelds, fixed units, etc.), that directly enables
player interaction in a Class II Game.
• “Player Tracking System” means a system typically used in Gaming Machine departments that can record
the Gaming Machine play of individual customers. Also, may be referred to as a “Patron Management
System”.
• “Post Time” means the time when a pari-mutuel track stops accepting bets in accordance with rules and
regulations of the applicable jurisdiction.
• “Primary and Secondary Jackpots” means promotional pools offered at certain Card Games or Table Games
that can be won in addition to the primary pot.
• ''Primary Management Official'' means:
(a)
Any person having Management responsibility for a Management Contract;
(b)
Any person who has authority:
(1)
to hire and fire employees of a Gaming Operation; or
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Section 3.01
(2) to establish policy for a Gaming Operation
(c)
The chief financial officer or a position with duties similar to a chief financial officer;
(d)
The Manager, or a position with duties similar to the Manager, or any person having Management
responsibility over all or any part of any Gaming Operation; or
(e)
Any other employed management official of the Gaming Enterprise as documented by the Commission
as a Primary Management Official.
• “Prize Payout” means a payment to a player associated with a winning or qualifying event.
• “Progressive Gaming Machine” means a Gaming Machine, with a payoff indicator, in which the payoff
increases as it is played (i.e., deferred Payout). The payoff amount is accumulated, displayed on a
machine, and will remain until a player lines up the jackpot symbols that result in the progressive amount
being paid.
• “Progressive Jackpot” means deferred Payout from a progressive Gaming Machine. “Progressive Table
Game” means Table Games that offer Progressive Jackpots.
• “Promotional Payout” means merchandise or awards given to players by the Gaming Operation based on a
wagering activity.
• “Promotional Progressive Pots and/or Pools” means funds contributed to a Game by and for the benefit of
players that are distributed to players based on a predetermined event.
• “Rabbit Ears” means a device, generally V-shaped, that holds the numbered balls selected during a Keno or
bingo Game so that the numbers are visible to players and employees.
• “Rake” means a commission charged by the house for maintaining or dealing a Game such as poker. “Rake
Circle” means the area of a table where Rake is placed.
• “Random Number Generator (RNG)” means a device that generates numbers in the absence of a pattern.
May be used to determine numbers selected in various games such as Keno and bingo. Also, commonly
used in Gaming Machines to generate Game outcome.
• “Reel Symbols” means symbols listed on reel strips of Gaming Machines.
• “Registered Non-Gaming Supplier” means a Non-Gaming Supplier that has filed a Registration form with
the Commission and has received written confirmation from the Commission that the registration process
is complete and that it is a Registered Non-Gaming Supplier.
• ''Regulation(s)'' means any regulations promulgated by the Commission pursuant to the Act. Also referred
to as Tribal Internal Control Standards, or “TICS”.
• ''Rehabilitation Hearing'' means a hearing conducted by and before the Commission under the
requirements of the Act and these Regulations concerning any Applicant for a Level 2, or Level 4 Gaming
Employee License who is a Tribal citizen and who was convicted of or entered a plea of guilty or no contest
to Any Offense within the preceding five (5) years in order to determine whether the Applicant is not
eligible for a Level 2, or Level 4 Gaming Employee License under the standards set forth in the Act and
these Regulations.
• ''Reservation'' means, pursuant to 25 U.S.C. § 1300j-5 or other applicable Federal law, (i) all lands, the title
to which is held in trust by the United States for the benefit of the Pokagon Band of Potawatomi Indians;
and (ii) all lands proclaimed by the Secretary of the Interior to be part of the Tribe's Reservation. The term
Reservation includes any rights-of-way running through the Reservation.
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CHAPTER III.
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Section 3.01
• “Schedule of Fees” means the schedule of fees for each type of License, which is established by the
Commission under Section 5.11 of the Act, and as may be amended from time-to-time.
• “Runner” means a Gaming Employee, Independent of the Table Games department and the Cage
department, who transports Chips/cash to or from a Gaming table and a cashier.
• “SAM” means a screen-automated machine used to accept pari-mutuel wagers. SAMs also pay winning
tickets in the form of a Voucher, which is redeemable for cash.
• “SAR” see Suspicious Activity Report.
• “Secretary” means the Secretary of the United States Department of the Interior, unless the context clearly
indicates otherwise.
• “Self-Exclusion” see Voluntary Exclusion.
• “Series Number” means the unique identifying number printed on each sheet of bingo paper that identifies
the bingo paper as a series or packet. The series number is not the free space or center space number
located on the bingo paper.
• “Shift” means a time period, unless otherwise approved by the Commission, not to exceed 24 hours. “Shill”
means an Agent financed by the Gaming Operation and acting as a player.
• “Short Pay” means a payoff from a Gaming Machine that is less than the listed amount. “SICS” See “System
of Internal Control Standards (SICS)”.
• “Smart Card” means a card with embedded integrated circuits that possesses the means to electronically
store or retrieve account data.
• “Soft Count” means the Count of the contents in a Drop Box, Bill Acceptor Canister, or Kiosk Financial
Instrument storage components and Currency Cassettes.
• “Statistical Drop” means total amount of money, Chips and Tokens contained in the Drop Boxes, plus pit
Credit issued, minus pit Credit payments in cash in the pit.
• “Statistical Win” means closing bankroll, plus Credit Slips for cash, Chips or Tokens returned to the Cage,
plus Drop, minus opening bankroll, minus fills to the table, plus Marker Credits.
• “Sufficient Clarity” means the capacity of a Surveillance System to record images at a minimum of 20 frames
per second or equivalent recording speed and at a resolution sufficient to clearly identify the intended
activity, person, object, or location.
• “Surveillance Operation Room(s)” means the secured area(s) where surveillance takes place and/or where
active surveillance equipment is located.
• “Surveillance System” means a system of video cameras, monitors, recorders, video printers, switches,
selectors, and other equipment used for surveillance.
• “Suspicious Activity Report” means a report of any suspicious transaction the Gaming Operation are
required to, or believes is relevant to, the possible violation of any law or regulation using FinCEN Form
111.
• “System of Internal Control Standards (SICS)” means an overall operational framework for a Gaming
Operation that incorporates principles of independence and segregation of function, and is comprised of
written policies, procedures, and standard practices based on overarching regulatory standards specifically
designed to create a system of checks and balances to safeguard the integrity of a Gaming Operation and
protect its assets from unauthorized access, misappropriation, forgery, theft, or Fraud.
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• “Table Game(s)” means a Game(s) banked by the house or a pool whereby the house or the pool pays all
winning bets and collects from all losing bets.
• “Table Inventory” means the total Coins, Chips, and Markers at a table.
• “Table Inventory Form” means the form used by Gaming Operation supervisory personnel to document the
inventory of Chips, Coins, and Tokens on a table at the beginning and ending of a Shift.
• “Table Tray” means the container located on Gaming tables where Chips, Coins, or cash are stored that are
used in the Game.
• “Take” means the same as Earned and Unearned Take.
• “Theoretical Hold” means the intended Hold percentage or Win of an individual Gaming Machine as
computed by reference to its Payout schedule and reel strip settings or EPROM.
• “Theoretical Hold Worksheet” means a worksheet provided by the manufacturer for all Gaming Machines
that indicate the theoretical percentages that the Gaming Machine should Hold based on adequate levels
of Coin-in. The worksheet also indicates the reel strip settings, number of credits that may be played, the
Payout schedule, the number of reels and other information descriptive of the Gaming Machine.
• “TICS” See “Tribal Internal Control Standards (TICS)”.
• “Tokens” means a Coin-like cash substitute, in various denominations, used for gambling transactions.
''Tribal Chairperson'' means the duly-elected Chairperson of the Tribe.
• ''Tribal Council'' means the Tribal Council of the Pokagon Band of Potawatomi Indians, established under
Article X of the Pokagon Band Constitution as the governing body of the Tribe.
• ''Tribal Court'' means the Pokagon Band Tribal Court and the Pokagon Band Court of Appeals. “Tribal
Gaming Regulatory Authority (Commission)” See “Commission”.
• “Tribal Internal Control Standards (TICS)” means internal control standards established by the Commission
that are at least as stringent as the applicable MICS standards set forth by the NIGC. Also referred to as
“Regulations”.
• ''Tribe'' means, and ''Tribal'' shall refer to, the Pokagon Band of Potawatomi Indians. “Vault” means a
secure area where cash and Cash Equivalents are stored.
• “Voluntary Exclusion” means the policy or program enacted by Section 10.15 of the Act as a method of
addressing the issue of addictive and compulsive gambling. Any person who meets the requirements to
voluntarily participate shall have their name placed on the Exclusion List, and the requirements of
subsections 10.14(e) and (f) of the Act shall apply.
• “Voucher” means a Financial Instrument of fixed wagering value, usually paper, that can be used only to
acquire an equivalent value of cashable credits or cash through interaction with a Voucher System.
• “Voucher System” means a system that securely maintains records of Vouchers and Coupons; validates
payment of Vouchers; records successful or failed payments of Vouchers and Coupons; and controls the
purging of expired Vouchers and Coupons.
• “Wide area progressive (WAP) Gaming Machine” means a progressive Gaming Machine that is linked to
machines in other operations and play on the machines affect the progressive amount. As wagers are
placed, the progressive meters on all the linked machines increase.
• “Win” means the net Win resulting from all Gaming activities. Net Win results from deducting all Gaming
losses from all wins prior to considering associated Operating Expenses.
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Section 3.01
• “Win-to-Write Hold Percentage” means Win divided by Write to determine Hold percentage. “Write”
means the total amount wagered in Keno, bingo, Pull Tabs, and pari-mutuel operations.
• “Writer” means an employee who writes Keno, bingo, Pull Tabs, or pari-mutuel tickets. A Keno Writer
usually also makes Payouts.
Section 1.04 General Purposes.
These Regulations are promulgated with the intention of implementing the provisions of the Gaming
Regulatory Act, and their purpose is to establish rules and standards applicable to the operation of Gaming
Operations within the jurisdiction of the Tribe.
These purposes should be construed and interpreted within the framework and scope of the powers,
ends and objectives of the Tribal Council and the Commission set forth in the Pokagon Band Constitution and
the Act.
Section 1.05 Scope and Applicability.
These Regulations shall apply to all administrative procedures for licensing, granting of Licenses,
overseeing, supervision and regulation related to the operation of the Gaming within the jurisdiction of the
Tribe and the Commission.
Section 1.06 Rules of Interpretation.
(a)
These Regulations shall be liberally interpreted in order to allow the Commission to carry out its duties
and to ensure that all the objectives of the Act and these Regulations are achieved.
(b)
In special cases, and for just cause, the Commission may relax or permit deviations from the provisions
of these Regulations when strict and literal compliance therewith defeats its purpose, provided that the
Commission’s grant of permission to deviate from specific requirements in the Regulations must be
made in writing by a duly issued order of the Commission and shall apply exclusively to those Persons
identified in the order.
(c)
Resolving inconsistency between governing documents.
(1)
Inconsistency between the Compact and these Regulations:
(i) If there is a direct conflict between an internal control standard established in the Compacts
and a standard or requirement set forth in these Regulations, then the internal control standard
established in the Compacts shall prevail.
(ii) If an internal control standard in the Compacts provides a level of control that equals or
exceeds the level of control under an internal control standard or requirement set forth in
these Regulations, then the Compact standard shall prevail.
(iii) If an internal control standard or a requirement set forth in these Regulations provides a level
of control that exceeds the level of control under an internal control standard established in the
Compacts, then the internal control standard or requirement set forth in these Regulations
shall prevail.
(2)
Inconsistency between the Act and the Regulations:
(i) If there is a direct conflict between an internal control standard established in the Act and a
standard or requirement set forth in these Regulations, then the internal control standard
established in the Act shall prevail.
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(ii) If an internal control standard in the Act provides a level of control that equals or exceeds the
level of control under an internal control standard or requirement set forth in these
Regulations, then the Act standard shall prevail.
(iii) If an internal control standard or a requirement set forth in these Regulations provides a level
of control that exceeds the level of control under an internal control standard established in the
Act, then the internal control standard or requirement set forth in these Regulations shall
prevail.
(3)
(d)
Conflicts of audit and accounting standards. When establishing SICS, the Gaming Establishment
should review, and consider incorporating, other external standards such as GAAP, GAAS, and
standards promulgated by GASB and FASB. In the event of a conflict between the MICS and the
incorporated external standards, the external standards prevail.
The Commission shall have sole authority to interpret the provisions of the Regulations and determine
whether or not any inconsistency with the Compacts or the Act exists, subject to the right of any
Person to challenge final orders of the Commission as provided in the Act.
Section 1.07 Words and Terms.
(a) When interpreting the provisions of these Regulations, except where otherwise expressly stated, or if it is
clearly understood to the contrary from the text:
(1)
Words conjugated in the present tense shall be understood to include the future tense.
(2)
Words used in their masculine form shall also include the feminine and neutral forms.
(3)
Words in the singular shall include the plural and vice versa.
Section 1.08 Areas Not Covered by the Regulations.
The Commission shall exercise its discretion in any matter not covered by these Regulations to achieve
the objectives of the Compacts, Act, and these Regulations. If a practice or procedure is not specifically
addressed in these Regulations, or the Commission does not exercise its discretion, such practice or
procedure is prohibited.
Section 1.09 Access to Records.
(a)
No original of any official record or document shall leave the custody of the Commission, except by
express written order of the Executive Director or a court of competent jurisdiction.
(b)
The Commission, through its Executive Director and other authorized Commission personnel shall have
access to all areas of any Gaming Establishment and to all records, files, information, and data of any
Gaming Establishment, wherever located, and may interview any employee, Agent or representative of
any Gaming Establishment with respect to matters relating to the operation of any Gaming
Establishment. Advance notice to the Gaming Establishment or any employee, Agent or representative
of the Gaming Establishment shall not be required for the Commission to exercise the authority
described in this Paragraph.
Section 1.10 Communications; Notices.
(a)
Except when otherwise provided, any document or correspondence addressed to the Commission shall
be sent to, or personally delivered at, the principal office of the Commission.
(b)
Said documents or correspondence shall be deemed to have been delivered or filed from the date the
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same were received at the principal office of the Commission.
(c)
Except as otherwise provided in these Regulations, all notices and other communications from the
Commission shall be sent to a Licensee and an Applicant by regular or certified mail to the address
which appears in the most recent Application or in a change of address notice received from such
person.
(d)
Any notice or any other communication from the Commission shall be deemed to have been served or
received when the same is deposited, postage prepaid, in the mail of the United States of America and
the time specified in said notice shall commence to run from that date.
(e)
Applicants shall immediately notify the Commission of any change of address.
Section 1.11 Restrictions for Gaming Enterprises.
(a)
Minimum age for players.
No person below the age of twenty-one (21) years on the date of Gaming shall be permitted in any
Gaming enterprise Licensed under the provisions of this Ordinance, except in designated areas
approved by the Commission. If any person below the age of twenty-one (21) years plays and
otherwise qualifies to Win any prize or winnings, the prize or winnings may be subject to forfeiture.
(b)
Prohibition on Firearms.
(1)
A person may not carry a firearm or other weapon in a Gaming Establishment, except for the
following persons with valid authorization under law:
(i) “law enforcement officers”, as that term is defined in Section 1.L of the Pokagon Band Code of
Offenses, which shall be limited to:
(A) Pokagon Band police officers;
(B) Federal law enforcement officers, as defined in 5 U.S.C. §8331(20);
(C) State “law enforcement officers”, as that term is defined in Section 2 of Michigan Public Act
203 of 1965 and Indiana Code Section 5-2-1-2(1), as amended, but only to the extent
expressly authorized by an intergovernmental agreement or otherwise authorized by the
Tribal Council and only while such law enforcement officers are on duty and acting within
the scope of their employment as law enforcement officers;
(ii) Armored car personnel picking up or delivering currency at secured areas: and
(iii) Security personnel employed by a Gaming Operation may carry handcuffs or similarly restrictive
restraint devices and pepper spray, to the extent expressly authorized by the Gaming
Operation.
(2)
(c)
All law enforcement officers shall, to extent practicable, advise the Manager and the Commission,
or their agents, prior to conducting any official law enforcement activities within a Gaming
Establishment.
Unauthorized Class III Gaming Activity in Indiana
The following forms of Class III gaming are not authorized in Gaming Operations located on Pokagon
Band Gaming Lands in the State of Indiana:
(1)
(2)
Any form of wagering on live simulcast horse racing or dog racing; and
Lottery games as defined in Indiana statute 65 IAC 1-1-1, except to the extent such games are
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authorized as approved gambling activities under IC 4-32.3.
Section 1.12 Enforcement Provisions.
Each Gaming Establishment shall continuously adhere to the minimum requirements set forth by the
Regulations. Non-compliance with any applicable regulation or control procedure is a violation.
(a) The Commission will monitor violations of such said laws and rules by written notices to individuals,
Gaming Establishments, and suppliers. Under most non-emergency circumstances and based on the
severity of offense, prior to the issuance of a fine or penalty, the individual or entity receiving the fine or
penalty will probably, but not necessarily, have been issued a written notice to take immediate actions to
resolve the situation.
(b) The notice shall contain:
(1)
Citing of regulation and/or policy violated;
(2)
Description of the violation;
(3)
Dates of prior notifications (if applicable);
(4)
Date violation must be corrected (if applicable);
(5)
Proposed imposition of a civil fine and/or other penalty and payment schedule (if applicable); and
(6)
Notice of right to a hearing before the Commission (if fine or penalty is assessed).
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Employee License Requirements.
CHAPTER III.
Section 3.01
CHAPTER II.
SUPPLIER LICENSING
Section 2.01 Restrictions on Doing Business.
(a)
No Person shall sell, lease, or otherwise supply any Gaming Equipment or Supplies to a Gaming
Operation, related to a Gaming Operation, or the Games, or in another manner shall carry on business
related with activities of a Gaming Operation, its employees or Agents, unless it holds a current Gaming
Supplier License validly issued by the Commission in accordance with the Act and these Regulations or
is a Registered Non-Gaming Supplier, except as provided in this Chapter.
(b)
No Gaming Supplier shall manufacture, sell or lease, distribute, repair or provide maintenance services
to Gaming Devices in a Gaming Operation unless it holds a current Gaming Supplier License validly
issued by the Commission in accordance with the Act and these Regulations.
(c)
The Gaming Commission reserves the right to compel any Non-Gaming Supplier to be licensed if the
Commission feels circumstances warrant such action.
Section 2.02 Determining the Need for a Gaming Supplier License.
(a)
Any Gaming Supplier which meets one or more of the following criteria shall be considered a Gamingrelated vendor and, unless otherwise authorized by the Commission or unless otherwise set forth in
these Regulations, shall obtain a Gaming Supplier License to do business with the Gaming Operation.
(1)
Gaming Suppliers shall include, but not be limited to, any Person that meets the following criteria:
(i) The Person manufactures, sells or leases, supplies or distributes devices, machines, equipment,
accessories, objects or articles which:
(A) Are designed specifically for use in a Gaming Operation;
(B) Are needed to carry out an authorized Game;
(C) Have the capacity to affect the result of the play of an authorized Game; or
(D) Have the capacity to affect the calculation, storage, collection or control of the Gross
Revenues.
(ii) Junket representatives, junket operators and tour groups bringing Patrons to the Gaming
Operation would be Gaming Suppliers.
(b)
(2)
The Person provides maintenance services or repairs Gaming Equipment, including Gaming Devices;
(3)
The Person provides services directly related to the operation, Regulation or administration, among
others, of a Gaming Operation;
(4)
The Person provides those other articles or services that the Commission has determined are used
in or are incidental to Gaming, or to an activity of a Gaming Operation and that, therefore, require a
License from the Commission in order to protect the trust, credibility and integrity of Gaming within
the jurisdiction of the Tribe;
(5)
Credit reports service providers for Gaming Operations and suppliers of security services for
Gaming Operations.
The list contained in paragraph (a) above is not all inclusive, but illustrative.
Section 2.03 Granting a Gaming Supplier or Non-Gaming Supplier License.
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Section 3.01
(a) All Gaming Supplier and Non-Gaming Supplier License Applicants shall submit to the Commission the
information, documentation and guarantees necessary to establish through clear and convincing
evidence:
(1)
The financial stability, integrity and economic responsibility of the Applicant;
(2)
The good character, honesty and integrity of the Applicant;
(3)
That the owners, administrative and supervisory personnel, principal employees and sales
representatives of the Applicant comply with the parameters provided in these Regulations;
(4)
The integrity of the investors, mortgage creditors, guarantors and holders of bonds, notes and
other evidences of debt which are in any way related to the Applicant;
(5)
The integrity of all the officers, directors and trustees of the Applicant; and
(6)
The licensing criteria as set forth in the Act.
(7)
If the Applicant is not a publicly traded company, the Applicant shall produce proof of beneficial
ownership. Stock ownership shall be issued to bona fide individuals or entities and shall not be in
the form of nominee or bearer shares.
Section 2.04 Initial License Application.
(a)
The initial Application for a Gaming Supplier License shall consist of:
(1)
An original and a copy of the following documents:
(i) Business Entity Disclosure Form - Gaming Supplier or Business Entity Disclosure Form NonGaming Supplier, as appropriate, are to be completed by the Applicant;
(ii) Personal History Disclosure Form(s) shall be completed by each person who must be qualified by
the Applicant in accordance with these Regulations.
(2)
The fees to be paid, as set forth in the Schedule of Fees.
(b)
The Commission may request the holding company of the Applicant to submit documents described in
(a)(1)(i-ii) above.
(c)
Every initial Application shall be filed at or mailed to the Commission at its address of record.
(d)
The Commission shall not evaluate an initial Gaming Supplier and Non-Gaming Supplier License
Application unless the same is accompanied by all the information required in these Regulations,
including all documents requested in paragraphs (a) and (b) above; provided that any incomplete
Application filed with the Commission shall be deemed to be as if the same had not been filed.
(e)
It shall be the responsibility of the Gaming Supplier and Non-Gaming Supplier Applicant and its
principals to provide information and or documentation and to demonstrate their qualifications by
clear and convincing evidence relative to the character, honesty and integrity of its directors, officers,
stockholders and principal employees to the Commission.
Section 2.05 Duration of License.
(a)
Each Gaming Supplier License issued by the Commission shall be for a period not to exceed two(2)
years.
(b)
Each Non-Gaming Supplier License issued by the Commission shall be for a period not to exceed three
(3) years.
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(c) Notwithstanding the provisions of paragraph (a) and (b) above, the Commission may, as it may deem
necessary, issue any Gaming Supplier or Non-Gaming Supplier License for a shorter period.
Section 2.06 License Renewal Application.
(a)
Each Gaming Supplier License Renewal Application shall be filed no later than sixty (60) days prior to
the expiration date of said License.
(b)
The Gaming Supplier and Non-Gaming Supplier License Renewal Application shall include:
(1)
A duly-completed original and a photocopy of:
(i) A renewal Application for Gaming Suppliers or Non-Gaming Suppliers, as appropriate, which
shall contain all the information that has changed from the date of the Application for the initial
Gaming Supplier or Non-Gaming Supplier License or of the last renewal, to be completed by the
Applicant and by each holding company of the Applicant;
(ii) Personal History Disclosure Form to be completed by each person who must be qualified in
accordance with the Act, and who has not been qualified by the Commission; and
(2)
The amount of fees to be paid is as set forth in the Schedule of Fees.
Section 2.07 License Fees and Investigative Costs.
(a)
The fees to be paid for the initial Application for a Gaming Supplier and Non- Gaming Supplier
Registration shall be determined by the Commission and set forth in the Schedule of Fees.
(b)
As set forth in the Schedule of fees, Applicants for Gaming Supplier Licenses will also be billed for the
costs of the background investigations necessary to complete a background investigation to the
standards set forth in these Regulations.
(c)
As set forth in the Schedule of fees, Applicants submitting a renewal Application shall be billed for a
Gaming Supplier Renewal Application and for each Control Person; and for the costs of the background
investigations necessary to complete the licensing process to the standards set forth in these
Regulations.
Section 2.08 Disqualification Criteria.
(a)
The Commission may deny a Gaming Supplier and Non-Gaming Supplier License to any Applicant that,
in the opinion of the Commission:
(1)
Has not proven through clear and convincing evidence that the Applicant and any of the persons
required to be qualified in accordance with these Regulations are in fact duly-qualified; or
(2)
Has violated any of the provisions of the Act, the Compacts or these Regulations; or
(3)
Has failed to qualify under Subsection 6(B) of the Indiana Compact; or
(4)
Has failed to provide information or documentation requested in writing by the Commission in a
timely manner, which shall not exceed thirty (30) business days from the date of request by the
Commission without reasonable justification; or
(5)
Does not consent to investigations, inspections and searches, or to have photographs and
fingerprints taken for investigative purposes; or
(6)
Has been convicted of any felony or misdemeanor involving moral turpitude, in the State of
Michigan, the State of Indiana, or any other jurisdiction, providing that this disqualifying criterion
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shall not automatically apply in case of convictions that have been expunged from such the
Applicant’s criminal record upon a court order; or
(7)
Is being prosecuted or has pending charges in any jurisdiction for any crime previously specified;
however, at the request of the Applicant or the person being prosecuted, the Division may
postpone the decision concerning such Application while said charges are pending; or
(8)
Is identified as a career offender or is a member of a criminal organization, or as being associated to
a career offender or a criminal organization; or
(9)
The Commission may also deny this License by applying the criteria listed above to those persons
related to the Applicant that must be qualified pursuant to these Regulations as a condition of
licensure.
Section 2.09 Supplier License Qualification Requirements.
(a)
The Commission shall not issue a Gaming Supplier and Non-Gaming Supplier License to any Applicant
who has failed to establish in advance the individual qualifications of each one of the following Control
Persons:
(1)
Every owner of the Applicant who has, directly or indirectly, any interest in or is the owner of more
than five percent (5%) of the Applicant;
(2)
Every owner of the Applicant entity that the Commission deems necessary to promote the
purposes of the Act and the Regulations;
(3)
Any director of the Applicant, except such director who, in the opinion of the Commission, is not
significantly involved in or connected with the administration of the Applicant;
(4)
Every representative of the Applicant who is significantly involved in or who has authority over the
manner in which the business dealing with the activities of a Gaming Operation is conducted and
any officer who the Commission considers necessary to protect the good character, honesty and
integrity of the Applicant;
(5)
Any officer of the holding company of the Applicant who the Commission considers necessary to
protect the good character, honesty and integrity of the Applicant;
(6)
Any employee who supervises the national office that employs the sales representatives who shall
solicit business from or negotiate directly with the Gaming Operation; and
(7)
Any other person who the Commission considers should be qualified in conjunction with the
Application.
(b)
In addition to the above, a Gaming Supplier shall file a Level 2 License Application for any employee
who shall be regularly dedicated to soliciting business from the Gaming Operation and any
technological employee who has access to the Gaming Operation floor in the performance of his job
duties.
(c)
To establish the individual qualifications, the entity or entities specified in subparagraphs (a) and (b) of
this Section shall complete Business Entity Disclosure Form - Gaming Suppliers and Business Entity
Disclosure Form for Non-Gaming Suppliers, as appropriate.
(d)
To establish the individual qualifications, the persons specified in subparagraphs (a)(2-7) of this Section
shall complete Personal History Disclosure Form(s).
Section 2.10 Individual Person License Qualification Requirements.
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Section 3.01
(a) Any person who is required to qualify, because of his/her relationship with a Gaming Supplier or NonGaming Supplier License Applicant, shall provide the Commission with information, documentation and
assurances necessary to establish, through clear and convincing evidence:
(1)
His/her relationship with the Applicant;
(2)
That he/she is older than eighteen (18) years of age;
(3)
That he has not been convicted by a State or Federal court of justice or a court of justice of any
other jurisdiction of:
(i) Committing, intending to commit or conspiring to commit a crime of moral turpitude, illegal
appropriation of funds or robbery, or any violation of a law related to Games of chance, or a
crime which is contrary to the declared policy of the Tribe with respect to the Gaming industry;
or
(ii) Committing, intending to commit, or conspiring to commit a crime which is a felony on the
Reservation or a misdemeanor in another jurisdiction which would be a felony if committed on
the Reservation.
(b)
Failure to comply with one of the requirements set forth in paragraph (a) above shall be sufficient cause
for the Commission to deny a Gaming Supplier License or Non-Gaming Supplier License.
(c)
The Commission shall deny any person required to qualify in conjunction with a Gaming or NonGaming Supplier License that does not satisfy the standards for entity licensing set forth in the Act or
these Regulations.
Section 2.11 Investigations; Supplementary Information; Approval of Change.
(a)
The Commission may, at its discretion, conduct any investigation with respect to an Applicant or any
person related to an Applicant that it deems pertinent, either at the time of the initial Application or at
any subsequent time.
(b)
It shall be the continuing duty of any Applicant or holder of a Gaming Supplier or Non-Gaming Supplier
License to fully cooperate with the Commission during any investigation and to provide any
supplementary information that the Commission requests.
(c)
The Applicant shall file with the Commission for its approval, within ten (10) business days, any change
in the Applicant or holder of a Gaming Supplier or Non-Gaming Supplier License the original state of
which was a condition imposed by the Commission for the granting of the initial Gaming Supplier
License or the renewal of said License; provided that any change in the ownership of the Applicant or
the holder of a Gaming Supplier or Non-Gaming Supplier License or any change in the ownership of any
holding or intermediary company of the Applicant that represents five percent (5%) or more of the
total shares issued and outstanding or of the total participation in the same, except when the holding
or intermediary company is a publicly-traded corporation, not approved by the Commission shall be
sufficient cause for invalidating any License or prior approval granted by the Commission. The proposed
new owner shall submit to the Commission an initial Gaming Supplier License or Non-Gaming Supplier
Application and evidence that he is qualified to receive the same.
Section 2.12 Revocation, Suspension, or Non-Renewal of License.
(a)
Any of the following reasons shall be considered sufficient cause for the suspension, denial of renewal
or revocation of a Gaming Supplier License or a Non-Gaming Supplier registration:
(1)
Violation of any provision of the Compacts, the Act or the Regulations;
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(2) Conduct that would disqualify the Applicant, or any other person, required to be qualified by the
Commission;
(3)
Failure to comply with any applicable laws or regulations;
(4)
The material deviation of any representation made in the Application for the Gaming Supplier or
the Registered Non-Gaming Supplier.
(b)
Notwithstanding the provisions of subparagraph (a) above, any other cause that the Commission deems
reasonable shall be considered sufficient cause for the suspension, denial of renewal or revocation of a
Gaming Supplier License.
(c)
A suspension or revocation of a License shall not take effect until:
(1)
Execution of a settlement agreement;
(2)
Execution of an Order by the Executive Director; or
(3)
The Executive Director determines an immediate suspension or revocation of a License just and
proper. The Commission may immediately suspend or revoke a Person’s License or Permit for the
following reasons but not limited to:
(i) When a Person’s actions pose an immediate threat to the integrity of Gaming or the safety of
the general public, patrons, or other employees and for which suspension is the only
reasonable means to mitigate such threat; or
(ii) When a Person fails to cooperate with the Commission’s licensing policies and procedures.
Section 2.13 Temporary License.
(a)
The Commission, at its discretion, may issue a Temporary License to a Supplier License Applicant to
permit the Applicant to carry out a commercial transaction with a Gaming Operation before said
Applicant has obtained a permanent Gaming Supplier License, provided that:
(1)
The Applicant has filed with the Commission a completed Application for a Gaming Supplier
License;
(2)
At least fifteen (15) days has passed since the filing of said completed Application with the
Commission; and
(3)
The Gaming Operation submits to the Commission a Petition for special authorization to carry out a
commercial transaction in the absence of a permanent Gaming Supplier License that contains:
(i) Sufficient reasons to convince the Commission to grant the temporary License; and
(ii) A copy of the contract or proposed contract describing the commercial transaction that it
desires to carry out.
(b)
The Commission shall evaluate the Application and said Petition for a temporary License and shall
promptly notify the Applicant and the petitioning Gaming Operation of its decision in writing.
(c)
Any commercial transaction conducted under a temporary License shall be noticed to the Commission
by the temporary Licensee and the Gaming Operation within ten (10) days following the carrying out of
the commercial transaction. The notification shall at least contain the date of the transaction and the
description of the commercial transaction carried out.
Section 2.14 Reciprocity.
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CHAPTER III.
Employee License Requirements.
Section 3.01
(a) The Commission may recognize and accept the licensing determinations of other Gaming regulatory
agencies regarding any Gaming Supplier or Non-Gaming Supplier License Applicant and persons
determined to be Control Persons of the Applicant pursuant to these Regulations. The Applicant for a
Gaming Supplier or Non-Gaming Supplier License shall Petition the Commission and such Petition shall
include the following:
(b)
(1)
Jurisdictions in which the Applicant has valid Gaming license or other service industry licenses;
(2)
Certification that the license held by the Gaming Supplier or Non-Gaming Supplier License Applicant
is in good standing in other jurisdictions in which it is licensed; and
(3)
If also licensed by the State of Michigan or the State of Indiana, a certification that the license is in
good standing in that state.
The Commission shall determine that one or more of the jurisdictions in which the Gaming Supplier or
Non-Gaming Supplier Applicant has been licensed has Licensing standards that are at least as stringent
and a background investigation process at least as rigorous as set forth in the Act and these
Regulations.
Section 2.15 Non-Gaming Suppliers.
(a)
No Non-Gaming Supplier shall provide goods or services to the Gaming Operation on a regular and
continuing basis unless it is a Registered Non-Gaming Supplier in accordance with these Regulations
except as otherwise expressly provided in this Section. The following standards shall apply to
determine whether a Non-Gaming Supplier must be a Registered Non-Gaming Supplier. Any NonGaming Supplier who provides, or should know that it will provide, in excess of $300,000 of goods or
services to a Gaming Operation in any twelve-month period must file a Non-Gaming Supplier
Registration Form and receive written confirmation from the Commission that it is duly registered
before it may engage in business or continue to engage in business with a Gaming Operation.
(b)
Notwithstanding the above, the Commission may exempt a Person from the requirement of obtaining a
Non-Gaming Supplier Registration under this Section 2.15. The following Persons shall be automatically
exempt from the registration requirement and shall not be required to submit an Exemption
Application, provided that the Commission may condition the granting of such exemption on the
submission of non-public information that is necessary to verify that such Person meets the criteria in
one of the exemption provisions in this subsection:
(1)
Local, State, and Federal governmental agencies, including the United States Postal Service, to the
extent the entity provides services related to its governmental agency function to a Gaming
Operation.
(2)
A Person or field of commerce that is subject to regulatory oversight and a due diligence
investigation by another regulatory agency that is satisfactory to the Commission, including public
utilities and accredited higher education institutions, to the extent that the services provided to the
Gaming Operation involve regulated activities.
(3)
An insurance company licensed or authorized to transact business to the extent that it provides
insurance related services to a Gaming Operation.
(4)
A publicly traded United States corporation under the regulation of the United States Securities and
Exchange Commission, or a wholly owned subsidiary of such a corporation.
(5)
A professional entertainer, sports figure, or other celebrity engaged by a Gaming Operation to
appear at a special entertainment or promotional event sponsored by the Gaming Operation to the
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CHAPTER III.
Employee License Requirements.
Section 3.01
extent that such Person provides entertainment or promotional services to a Gaming Operation.
(6)
A federally chartered depository financial institution to the extent that it provides financial- related
services to a Gaming Operation.
(7)
A Person or entity that provides professional legal or accounting services to a Gaming Operation to
the extent that it provides financial related services to a Gaming Operation.
(8)
A medical corporation, partnership, sole proprietorship, or other business entity, to the extent that
the Applicant provides medical related services to a Gaming Operation.
(9)
An Agent or promoter of a professional entertainer, sports figure, or celebrity, provided that such
Agent or promoter does not otherwise provide services to the Gaming Operation on a regular and
continuing basis.
(10) A Person who provided facilities, promotion, or advertising to a Gaming Operation and is one of the
following:
(i) A media outlet (defined as a newspaper, a magazine, an outdoor advertising business, or a
radio or television outlet).
(ii) A provider of a facility or a host or sponsor of an event that presents advertising on behalf of or
promotes a Gaming Operation, including but not limited to theaters, ballrooms, halls, arenas,
parks, stadiums, golf courses, and other entertainment, recreational, and sports facilities.
(iii) A provider of a facility that provides entertainment, recreational, or hospitality services to a
Gaming Operation and is a theater, ballroom, hall, arena, park stadium, golf course, or special
event venue.
(c)
Any Person that meets the exemption criteria in subsections 2.15(b)(ii-iv) and wishes to apply for an
exemption from the Non-Gaming Supplier registration requirements under this Section shall apply in
writing to the Commission for said exemption.
(d)
The Exemption Application required by subsection 2.15(c) shall contain the following information:
(e)
(f)
(1)
Name, address and detailed description of the service offered by the Applicant;
(2)
Name of the owners, directors, officers and managerial employees of the Applicant;
(3)
Dollar amount of the transactions; and
(4)
Evidence that fulfills the specific requirements of one of the subsections 2.15(b)(ii-iv).
Every Gaming Operation shall submit a report to the Commission on a monthly basis summarizing all
transactions with vendors for the previous month, and cumulatively, for the past twelve months to
assist the Commission in assessing regular and continuing business by Non-Gaming Suppliers. Said
report shall contain the following:
(1)
Name of Vendor
(2)
Nature of goods or services provided
(3)
Dollar Amount
(4)
Any further information deemed necessary by the Commission
The Executive Director may waive, on a case-by-case basis for good cause shown, one or more specific
requirements of this Section 2.15 for a Non-Gaming Supplier, provided that the Commission reserves
the authority to reinstate such requirements for the Non- Gaming Supplier at the Commission’s
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Section 3.01
discretion.
EMPLOYEE LICENSING
Employee License Requirements.
Section 2.16 Records.
(a)
All Gaming Suppliers and Non-Gaming Suppliers Licensed by the Commission shall maintain in a place
secure against robbery, loss or destruction the records corresponding to the business operations, which
shall be available to, and be produced for, the Commission, should they be requested. Said records
shall include:
(1)
Any correspondence with the Commission and other governmental agencies;
(2)
Any correspondence related to the business with a Gaming Operation, whether proposed or
existing;
(3)
Copies of any publicity and promotional materials;
(4)
The personnel files for every employee of the Licensed Gaming Supplier or Non- Gaming Supplier
Person, including those for the sales representatives;
(b)
The financial records for all the transactions related to the business with a Gaming Operations, whether
proposed or existing.
(c)
The records listed in subparagraph (a) above shall be kept at least for a period of five (5) years.
Section 2.17 Obligation to Pay the Fees; No Refund of Fees Paid.
(a)
Any obligation for payment of fees arising from these Regulations shall be paid in full even when the
Applicant withdraws its Application for a Gaming Supplier or Non-Gaming Supplier License.
(b)
All fees arising from these Regulations shall not be refunded.
Section 2.18 Master Vendors List.
(a)
The Commission shall maintain a master vendor list of all vendors doing business with the Gaming
Operation.
(b)
An approved master vendors list will be maintained by the Commission and will be comprised of all
vendors with temporary or permanent License approval or confirmed Registration to engage in
business transactions with the Gaming Operation.
(c)
The Commission shall also maintain a prohibited vendor list, which shall include all vendors who are not
licensed or who are otherwise prohibited from conducting business with a Gaming Operation. The
Commission shall provide this list to each Gaming Operation on a monthly basis.
(d)
Engaging in business with a vendor on the prohibited vendor list by a Gaming Operation may result in
monetary fines not to exceed $5,000, regulatory sanctions, or both.
Section 2.19 Carrying of Gaming Licenses and Credentials for Suppliers.
(a)
All employees of licensed suppliers to whom the Commission has issued a Gaming License shall carry
the Gaming License visibly displayed on their person at all times while on property unless such
requirement is waived by the Executive Director.
(b)
No Gaming Operation shall permit a person to work in its Gaming Operation without said person
complying (carrying their Gaming License as provided in) with paragraph (a) above.
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CHAPTER III.
Section 3.01
CHAPTER III.
EMPLOYEE LICENSING
Employee License Requirements.
EMPLOYEE LICENSING
Section 3.01 Employee License Requirements.
No Person may work as an employee of a Gaming Operation or provide services to a Gaming Operation
unless the person has a current employee License validly issued by the Commission, as provided in the Act
and this Chapter. The employee License requirement applies to managerial employees as well as nonmanagerial employees who work in or for a Gaming Operation, regardless of whether or not the employee is
an employee of the Gaming Operation.
Section 3.02 Application for a Gaming Employee License
The Commission shall require each prospective Key Employee, Primary Management Official, and
Gaming Employee to submit a sworn Application to the Commission on the forms and in the manner required
by the Commission. The Application for Level 1 Licenses or if not Level 1, any Primary Management Official or
Key Employee, shall include, at a minimum, the forms, information, other requirements described hereunder.
(a)
Application Form. The Application form shall require, at a minimum, the following information:
(1)
Full name, other names used (oral or written), social security number(s), birth date, place of birth,
citizenship, gender, and all languages (spoken or written);
(2)
Currently and for the previous ten (10) years:
(i) business and employment positions held,
(ii) ownership interests in those businesses,
(iii) business and residence addresses; and
(iv) driver’s license numbers, including issuing state;
(b)
(3)
The names and current addresses of at least three personal references, including one personal
reference that was acquainted with the Applicant during each period of residence listed under
subsection (a)(2) paragraph (iii) of this Section;
(4)
Current business and residence telephone numbers; and
(5)
If the Applicant is a Tribal citizen applying for a Level 2 Gaming Employee License and, if so, the
Applicant’s Tribal enrollment number.
Application Form Notices. The notices set forth below shall be placed on the front of every Application
so that the Applicant will read the notices prior to filing out the Application form.
(1)
Privacy Act Notice.
“In compliance with the Privacy Act of 1974, the following information is provided: Solicitation of the
information on this form is authorized by 25 U.S.C. 2701 et seq. The purpose of the requested
information is to determine the eligibility of individuals to be granted a gaming license. The
information will be used by the Tribal gaming regulatory authorities and by the National Indian
Gaming Commission (NIGC) members and staff who have need for the information in the
performance of their official duties. The information may be disclosed by the Tribe or the NIGC to
appropriate Federal, Tribal, State, local, or foreign law enforcement and regulatory agencies when
relevant to civil, criminal or regulatory investigations, or prosecutions, or when pursuant to a
requirement by a tribe or the NIGC in connection with the issuance, denial, or revocation of a
gaming license, or investigations of activities while associated with a tribe or a gaming operation.
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Section 3.02
Application for a Gaming Employee License.
Failure to consent to the disclosures indicated in this notice will result in a tribe’s being unable to
license you for a primary management official or key employee position. The disclosure of your
Social Security Number (SSN) is voluntary. However, failure to supply a SSN may result in errors in
processing your application.”
(2)
False Statements Notice.
“A false statement on any part of your license application may be grounds for denying a license or
the suspension or revocation of a license. Also, you may be punished by fine or imprisonment (U.S.
Code, title 18, section 1001).”
(c)
(d)
Application Form Authorizations and Acknowledgements. Every Application form shall require the
Applicant to sign an authorization and an acknowledgement that are substantially similar in substance
to the following:
(1)
Authorization permitting the Commission to investigate the Applicant’s background, including his
criminal and civil records, credit and financial history, business relationships and activities, records
of all previous license Applications, and tax records; and
(2)
A signed acknowledgement that the Applicant consents to the personal jurisdiction of the Tribe, the
Commission, and the Tribal Court and that the Applicant waives all available defenses against such
jurisdiction.
Personal History Disclosure. The Personal History Disclosure shall require, at a minimum, the following
information:
(1)
Relationship with other tribes. A description of any existing and previous Gaming-related or other
business relationships with any Indian tribe, including ownership interests in those businesses;
(2)
Gaming history. A description of any existing and previous business relationships with the gaming
industry generally, including ownership interests in those businesses;
(3)
Prior Gaming applications. The name and address of any licensing or regulatory agency with which
the person has filed an application for a license or permit related to gaming, the current status of
the application, and whether or not such license or permit was granted.
(4)
Felony charges. A list of all felony charges and dispositions against the Applicant, if any, and for
each felony for which there is ongoing prosecution or a conviction, the charge, the name and
address of the court involved, and the date and disposition if any, including identification of any
conviction, or plea of guilty or no contest, to a gambling related offense, Fraud or
Misrepresentation at any time;
(5)
Misdemeanor charges. A list of all misdemeanor charges and dispositions against the Applicant, if
any, (excluding traffic charges for which incarceration was not a possible punishment, referred to
hereunder as “minor” traffic charges), and for each misdemeanor conviction or ongoing
misdemeanor prosecution (excluding minor traffic charges), within ten (10) years of the date of the
Application, the name and address of the court involved and the date and disposition, including
identification of any conviction, or plea of guilty or no contest, to a gambling related offense, Fraud
or Misrepresentation at any time;
(6)
Convictions. For each criminal charge (excluding minor traffic charges), whether or not there is a
conviction, if such criminal charge was within ten (10) years of the date of the Application and is not
otherwise listed pursuant to subsections (d)(4) or (d)(5) of this Section, the criminal charge, the
name and address of the court involved, and the date and disposition; and
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Section 3.02
Application for a Gaming Employee License.
(7) Prior business applications. The name and address of any licensing or regulatory agency with which
the person has filed an application for a business or occupational license or permit, whether or not
such license or permit was granted.
(e)
Current Photographs. The Applicant shall provide a current photograph in such form as the Commission
may require.
(f)
Personal Financial Questionnaire. The Personal Financial Questionnaire shall include a statement of
assets and liabilities and shall include, at a minimum, the following information:
(1)
Complete financial statement, along with income tax returns for the previous three (3) years,
showing all sources of income for the previous three (3) years, and assets, liabilities, and net worth
as of the date of the Application; and
(2)
A list of all professional or business licenses the Applicant has applied for, whether or not those
licenses where granted and the name, address and phone number of the regulatory agency
involved. The Personal Financial Questionnaire shall also include a sworn statement to be signed by
the Applicant stating that neither the Applicant nor any member of the Applicant’s immediate
family has a past or current financial interest, other than a salary interest, in any gaming-related
activity or business anywhere. If the Applicant has any relative who has such a relationship, the
Applicant shall fully disclose his name and the nature of the relationship.
(g)
Fingerprints. All Applicants for a Level 1 or Level 2 Gaming Employee License shall submit one or more
complete sets of original fingerprints to be taken by the Commission in such manner and form as the
Commission may require, which shall be processed in accordance with this Act and the Regulations.
The Gaming Commission is the Tribal agency that is authorized to take all fingerprints required to be
taken under this Act and the IGRA. The Commission may also require the submission of one or more
additional sets of fingerprints, which the Commission may submit to be processed by any governmental
agency’s criminal history check system as the Commission deems necessary.
(h)
Other Information. The Applicant shall complete any other forms and disclose and submit any and all
other information required by Regulation or reasonably requested by the Commission.
(i)
Application Fees and Costs. The Applicant shall pay all fees and costs required by the Commission to
process the Application.
Section 3.03 Background Investigation.
(a)
The Commission shall conduct, or cause to be conducted, an investigation sufficient to make the
determinations required under Sections 3.10, 3.11 and 3.12. In conducting background investigations,
the Commission shall seek to ensure that Gaming Operations shall not employ persons whose prior
activities, reputation, habits and associations pose a threat to the public interest or to the effective
regulation of Gaming, or create or enhance the dangers of unsuitable, unfair or illegal practices and
methods and activities in the conduct of such Gaming. Such investigations shall be conducted according
to requirements at least as stringent as those set forth at 25 C.F.R. Parts 556 and 558, the Compacts,
and this Chapter. The Commission shall establish procedures to protect confidential information
generated by the investigation or submitted by the Applicants from any unauthorized disclosure. The
background investigation shall, at a minimum, consist of the following:
(1)
Verify Identity. Verify the Applicant’s identity through primary sources, such as government- issued
identification and other documents, including without limitation social security cards, driver’s
licenses, birth certificates, or passports.
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Section 3.03
Background Investigation.
(2) References. Contact each reference provided in the License Application and, when warranted,
contact other references and sources identified in the Application in order to verify and supplement
the information submitted by the Applicant/Licensee and to resolve any discrepancies encountered
through the background investigation.
(3)
Financial Information. Review the Applicant’s credit history and, when the Application is for a Level
1 License or when required by the Regulations or otherwise warranted, verify the financial
information provided by the Applicant by contacting financial institutions and other sources and
investigate the Applicant’s financial background based on the Applicant’s Personal Financial
Questionnaire.
(4)
Civil History. Conduct a civil history check.
(5)
Criminal History. Conduct a criminal history check.
(i) Applicant for a Level 1 or a Level 2. Submit the Application and fingerprints to the NIGC, which
will forward the fingerprints to the Federal Bureau of Investigation and the NCIC to search and
report on the Applicant’s criminal history, if any, and
(ii) All Applicants for a Gaming Employee License. Obtain information from law enforcement
agencies and courts in the jurisdictions where the Applicant has resided regarding all felony
convictions during the Applicant’s lifetime and misdemeanor convictions and criminal charges
within the last ten years;
(6)
Prior Business Relationships. Inquire into the Applicant’s previous or existing business relationships.
(7)
Agency History. Verify and evaluate the Applicant’s history and status with licensing agencies in
other jurisdictions.
(i) Investigative Report. The investigator shall create an investigative report that includes, at a
minimum, the following:
(ii) Steps taken in conducting a background investigation;
(iii) Results obtained;
(iv) Conclusions reached; and
(v) The basis for those conclusions.
(b)
In the absence of disqualifying information, the investigator shall prepare for Commission purposes in a
separate report factual findings regarding each licensing standard to the extent that there is clear and
convincing evidence to support a finding. The Gaming Commission shall keep confidential the identity
of each person interviewed in the course of the investigation, except to the extent that disclosure is
permitted under applicable federal or Tribal law or the Compacts.
Section 3.04 Persons Who Must Obtain an Employee License.
(a)
Unless otherwise approved by the Commission, any Person who carries out or will carry out, or has or
will have any of the functions mentioned in paragraphs (b) through (e) of this Section, shall obtain an
employee License before commencing to work in the Gaming Operation; provided that the list
contained in paragraphs (b) through (e) of this Section is not all-inclusive, but illustrative, being the
guiding rule for determining the necessity of having an employee License and the type or level of
License that may be required.
(b)
Primary Management Official (Level 1):
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Section 3.04
Persons Who Must Obtain an Employee License.
(1) The person who has Management responsibility for a Management Contract.
(2)
Any person who has authority to:
(i) Hire or fire employees of a Gaming Operation; or
(ii) Establish working policies for a Gaming Operation and an ability to control or direct a Gaming
Operation.
(3)
In addition, the following individuals will be deemed to be Primary Management Officials:
(i) The chief financial officer or other person who has financial Management responsibility for a
Gaming Operation; and
(ii) The Manager or any person having Management responsibility over all or part of a Gaming
Operation.
(4)
(c)
Any other person who has the authority to direct, control, manage or engage in discretionary
decision-making over a Gaming Operation.
Any person who is going to be employed by the Gaming Operation in a position that includes any of the
following responsibilities or powers, regardless of the title, shall obtain a Key Employee License (Level
2):
(1)
The supervision of specific areas of the Gaming Operation, including, but not limited to, any person
who:
(i) Functions as a bingo caller;
(ii) Supervises a count room;
(iii) Functions as custodian of Gaming Equipment or Supplies, or cash;
(iv) Functions as a floor Manager;
(v) Functions as a pit boss;
(vi) Functions as a Dealer;
(vii) Functions as an approver of Credit;
(viii) Functions as a custodian of gambling terminals or other devices operated by the Management
of any Gaming Operation, including Persons with access to cash and accounting records for
such devices;
(ix) Functions as a Shift Manager;
(x) Functions as a supervisor of a Gaming table section;
(xi) Functions as a poker Shift supervisor;
(xii) Functions as Shift Manager or supervisor of the slot machine operation;
(xiii) Supervises the repair and maintenance of the Gaming Devices and the bill validators;
(xiv) Supervises the operation of the surveillance department during a Shift;
(xv) Supervises security investigations or the operation of the security department during a Shift;
(xvi) Functions as Manager or supervisor of any Cage;
(xvii) Supervises any Count Room; or
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Section 3.04
Persons Who Must Obtain an Employee License.
(xviii)Supervises the collection unit of the Gaming Establishment.
(2)
Authority to develop or administer policy or long-term plans or to make discretionary decisions
relative to the operation of the Gaming Operation shall be considered a Key Employee (Level 2) and
shall include, but not be limited to, any person who:
(i) Functions as the Gaming device section Manager;
(ii) Functions as director of surveillance;
(iii) Functions as director of security;
(iv) Functions as controller;
(v) Functions as credit Manager;
(vi) Functions as an audit Section executive;
(vii) Functions as Manager of the IT ("Information Technology") section or of any information
system of a similar nature;
(viii) Manages a marketing department;
(ix) Manages the Gaming Operation administrative operations; or
(x) Functions as hotel general Manager.
(d)
Any person who is going to be employed by the Gaming Operations in a position that includes any of the
following responsibilities related to the operation of the Gaming Operations, or whose responsibilities
predominantly involve the maintenance or the operation of Gaming activities or equipment and assets
associated with the same, or who is required to work regularly in a restricted area shall obtain a Key
Employee License (Level 2). Such persons shall include, but not be limited to, any person who:
(1)
Functions as a croupier;
(2)
Conducts or supervises any table Game;
(3)
Conducts surveillance investigations and operations in a Gaming Operation;
(4)
Repairs and maintains Gaming Equipment, including, but not limited to, Gaming Devices and bill
validators;
(5)
Functions as Cage cashier, cashier supervisor or Gaming Device cashier;
(6)
Assists in the operation of Gaming Devices and bill validators, including, but not limited to, persons
who participate in the payment of jackpots and in the process of filling hoppers, or who supervise
said persons;
(7)
Identifies Patrons for the purpose of offering them Complimentaries based on the actual volume of
play of the Patron, authorizes said Complimentaries or determines the amount of such
Complimentaries;
(8)
Analyzes Gaming data and makes recommendations to key personnel of the Gaming Operation
relating to marketing, Complimentaries, Gaming, special events and player ratings, among others;
(9)
Enters data into the Gaming-related computer systems or develops, maintains, installs or operates
Gaming related computer software systems;
(10) Collects and records Patron checks and personal checks which are dishonored and returned by a
bank;
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Section 3.04
Persons Who Must Obtain an Employee License.
(11) Develops marketing programs to promote Gaming in the Gaming Operation;
(12) Processes or maintains information on Gaming Credit Applications;
(13) Processes Coins, currency, Chips or Cash Equivalents of the Gaming Operation;
(14) Repairs or maintains the closed-circuit television system equipment as an employee of the
surveillance section of the Gaming Operation;
(15) Is a surveillance department trainee or a surveillance room technician;
(16) Controls or maintains the slot machine inventory, including replacement parts, equipment and tools
used to maintain the same;
(17) Has responsibilities associated with the installation, maintenance or operation of computer
hardware for the Gaming Operation computer system; and
(18) Security Officer.
(e)
Any person employed by a Gaming Operations who is not required under the Act or these Regulations
to obtain a Level 1 or Level 2 License shall obtain a Level 4 License.
Section 3.05 Scope and Applicability of the Licensing of Natural Persons.
(a)
(b)
In determining whether a person who provides services to a Gaming Operation should hold an
employee License, it shall be presumed that such person shall be required to hold an employee License
if the services provided by that person are characterized by any of the following factors, which are
indicative that an employment relationship exists:
(1)
The person will, for a period of time unrelated to any specific project or for an indefinite period of
time, directly supervise one of more employees of the Gaming Operations;
(2)
The Gaming Operations will withhold local and federal taxes or make regular deductions for
unemployment insurance, social security, or other deductions required by law from the payments
made to the person;
(3)
The person will be given the opportunity to participate in any benefit plan offered by the Gaming
Operations to its employees, including, but not limited to, health insurance plans, life insurance
plans or pension plans;
(4)
The person will not, during the time that services are rendered to the Gaming Operation, maintain
an autonomous business person, seek or provide services to other clients, or practice a trade or
profession other than for the benefit of the Gaming Operations; or
(5)
The person has an Employee License Application pending before the Commission or will submit
such an Application during the time the services are being rendered to the Gaming Operations, and
the cost of the License has been or will be paid for or reimbursed by the Gaming Operation.
The Commission may, after considering the factors in paragraph (a) of this Section and any other
applicable information, require that the person obtain an employee License before providing or
continuing to provide any service to the Gaming Operations even if an agreement to the contrary exists
between the Gaming Operations and the person.
Section 3.06 Requirements for Granting an Employee License.
(a)
In addition to the specific employee licensing standards stated in Section 7.04 of the Act, each
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Section 3.06
Requirements for Granting an Employee License.
employee License Applicant shall provide the Commission with the necessary information,
documentation and guarantees that establish through clear and convincing evidence that he/she:
(1)
Is eighteen (18) years of age or older;
(2)
Is a citizen of the United States of America or is authorized in accordance with the applicable
Federal laws or regulations to work in the United States of America;
(3)
Possesses good character and reputation, in addition to being honest and having integrity;
(4)
Has no physical or mental disability which hinders adequate performance of his work; and
(5)
Has passed the training for croupiers offered by a Gaming Operation in the event that he or she will
be working at a table or has a valid certificate of completion of training in specific Table Games in
any Gaming jurisdiction in the United States; or
(6)
For any such Applicant that is a Gaming Official or Gaming Employee who is or may be working in
Gaming Operations located on Pokagon Band Gaming Lands in the State of Indiana: has not been
convicted of or entered a plea of guilty or no contest to Any Offense within the immediately
preceding five years; this provision shall not apply if that person is Tribal citizen and has been
determined by the Commission to be a person who is not likely again to engage in any offensive or
criminal course of conduct and the public good does not require that the applicant be denied a
license as a Gaming Official or Employee.
(b)
In addition to the general Licensing requirements stated in subsection (a), the Commission shall not
grant a Level 4 employee License to any Applicant who has been convicted of or entered a plea of guilty
or no contest to any felony involving a violent crime, or Any Offense involving theft, dishonesty, Fraud
or Misrepresentation or a drug- related offense within the immediately preceding five (5) years that
was committed as an adult or prosecuted as an adult offense.
(c)
The right of Tribal citizens to a Rehabilitation Hearing under Section 11.03(a) of the Act shall also extend
to Tribal citizens who are Applicants for a Level 4 Gaming employee License.
(d)
Notwithstanding the provisions of subsection (b) of this Section, the Commission shall have the
discretion to waive any Level 4 employee License standard for any Applicant consistent with the public
policy of the Act and upon a finding that the interests of justice so require, provided that the Applicant
has affirmatively demonstrated the Applicant’s rehabilitation based on a consideration of the following
factors:
(1)
The nature and duties of the Applicant’s position;
(2)
The nature and seriousness of the offense or conduct;
(3)
The circumstances under which the offense or conduct occurred;
(4)
The date of the offense or conduct;
(5)
The age of the Applicant when the offense or conduct was committed;
(6)
Whether the offense or conduct was an isolated or repeated incident;
(7)
Any social conditions which may have contributed to the offense or conduct; or
(8)
Any evidence of rehabilitation, including good conduct in prison or in the community, counseling or
psychiatric treatment received, acquisition of additional academic or vocational schooling,
successful participation in correctional work- release programs, or the recommendation of persons
who have or have had the registrant under their direct supervision.
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CHAPTER III.
EMPLOYEE LICENSING
Section 3.06
Requirements for Granting an Employee License.
(e) Failure to comply with the applicable licensing standards stated in Section 7.04 of the Act or the general
requirements stated in paragraph (a) above shall provide adequate grounds for the Commission to
deny an Application for an employee License.
Section 3.07 Provisional Employee License.
(a)
The Commission may issue a provisional employee License in accordance with the following rules:
(1)
The Commission determines that the Applicant has filed with the Commission a completed
Application for an employee License;
(2)
The Applicant would meet the Licensing standards set forth in the Act and these Regulations; and
(3)
Granting the provisional License would not pose a threat to the public interest or to the effective
regulation of Gaming and would not create or enhance the dangers of unsuitable, unfair, or illegal
practices and methods and activities in the conduct of Gaming.
(b)
A provisional License may be issued for a period of time not to exceed ninety (90) days.
(c)
The Commission shall make a determination whether or not to issue a provisional License to all
Applicants for Level 1, or Level 2 Licenses. Applicants for a Level 4 License may commence employment
without a License provided that the Commission determines that the Applicant has filed a complete
Application with the Commission before commencing employment.
Section 3.08 Initial Employee License Application Processing.
(a)
If the Commission determines that the initial Application does not comply with all the requirements
provided in the Act and these Regulations, it shall notify the Applicant of the deficiency (ies) within
twenty (20) days following the filing of the Application. The Commission shall not evaluate any
incomplete initial Application.
(b)
If the Commission has determined that the Application filed is complete, the Commission shall:
(1)
Accept the Application and initiate the procedure for considering the same;
(2)
Notify in writing all License Applicants that the Application has been accepted for consideration.
Said notice shall also include:
(i) The date of said acceptance;
(ii) The file number of the Application; and
(iii) An admonishment to the Applicant that the fact that the Application has been accepted for
consideration does not mean that the Applicant has complied with the requirements of the Act
or the Regulations for a License;
(c)
(3)
Analyze and evaluate the information offered in the Application and any other information
necessary to determine if the requested License should be granted;
(4)
Make a decision with respect to the requested License; and
(5)
Notify the Applicant of the decision taken. If the decision consists of a denial of the License, the
Commission shall inform the Applicant the reason or reasons for the denial and of his right to
request a hearing pursuant to the Act.
The Commission, at any time, may request from an Applicant for an Employee License any other
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CHAPTER III.
EMPLOYEE LICENSING
Section 3.08
Initial Employee License Application Processing.
information it may deem necessary in order to make a decision with respect to the Application.
Section 3.09 Standards for Issuance of a Gaming Employee License.
(a)
The Commission shall not grant a Gaming Employee License to any person who does not meet the
applicable standards set forth below:
(1)
Standards Applicable to All Gaming Employees. The Commission shall not grant a Gaming Employee
License to any person who:
(i) Is a member of the Tribal Council, a Tribal Judge, or a Tribal Law Enforcement Officer;
(ii) Is under the age of 18;
(iii) Has been convicted of or entered a plea of guilty or no contest to a gambling-related offense,
Fraud or Misrepresentation;
(iv) Is determined by the Commission
(A) to have participated in organized crime or unlawful gambling or
(B) whose prior activities, criminal records, reputation, habits, and/or associations pose a
threat to the public interest or to the effective regulation and control of Gaming, or
(C) create or enhance the dangers of unsuitable, unfair, or illegal practices, methods and
activities in the conduct of Gaming or to the carrying on of the business and financial
arrangements incidental to the conduct of Gaming;
(v) Lacks good character, honesty, integrity, financial stability, or the ability and experience
required for the position being sought;
(vi) Has knowingly and willfully provided materially false and misleading statements or information
to the Commission or refused to respond to questions material to the suitability determination
that have been asked by the Commission.
(vii) Was denied a license by the Indiana Gaming Commission or had his or her license revoked by
the Indiana Gaming Commission to the Band, and such person remains ineligible for a license
from the Indiana Gaming Commission or had his or her license revoked as verified by the
Indiana Gaming Commission to the Band.
(2)
Additional Standards Applicable Only to Level 1. In addition to the standards set forth in subsection
(a), the Commission shall not grant a Gaming Employee License to any person in Level 1 that:
(i) Has been convicted of or entered a plea of guilty or no contest to any felony;
(ii) Has been convicted of or entered a plea of guilty or no contest to Any Offense not specified in
subsection (3) of Paragraph (a) within the immediately preceding ten (10) years; or
(iii) Has shown a lack of financial integrity or stability in personal finances or in business affairs.
(3)
Additional Standards Applicable Only to Level 2. In addition to the standards set forth in subsection
(a), the Commission shall not grant a Gaming Employee License to any person in Level 2 that has
been convicted of or entered a plea of guilty or no contest to Any Offense not specified in
subsection (3) of paragraph (a) within the immediately preceding five (5) years; provided that this
provision shall not apply if the applicable Compact states otherwise or, if the Applicant is a Tribal
citizen, the Commission has determined through a Rehabilitation Hearing that such conduct does
not require that the Applicant be denied a Gaming Employee License.
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PBGC Regulations Approved 7-08-2026
CHAPTER III.
Section 3.09
EMPLOYEE LICENSING
Standards for Issuance of a Gaming Employee License.
Section 3.10 Eligibility Determination.
(a)
Commission Review and Determination. Within fifteen (15) days following the completion of the
background investigation described in Section 3.03 but not more than fifty (50) days from the date it
issues a Provisional License, the Commission shall review the Application, the investigative reports, and
any objections to the issuance of a License and shall make a determination of eligibility under the
standards set forth in Section 3.09.
(b)
Level 1 or Level 2 License; Preliminary Determination. If the Application is for a Level 1 or a Level 2
License, the Commission shall also consider any information provided by the NIGC before making a
determination of eligibility and shall comply with the additional requirements of Section 3.11. Pending
the outcome of the process set forth in Section 3.11, the Commission’s eligibility determination
regarding Applicant’s for a Level 1 or a Level 2 License shall be a preliminary determination.
(c)
For the Gaming Operation located on Pokagon Band Gaming Lands within the State of Indiana, the
Commission shall within (30) days of receiving a request from the Indiana Gaming Commission, provide
the Indiana Gaming Commission copies of the Commission’s eligibility determination and investigative
reports on any and all gaming officials and casino employees required to be licensed under 25 C.F.R.
Part 556, the Act, and the Compact with the State of Indiana to allow the State to make an independent
determination as to the suitability of these individuals, consistent with the standards set forth in
Subsection 4(I) of the Indiana Compact.
Section 3.11 Approval of a Level 1 or Level 2 Gaming Employee License.
(a)
Preliminary Eligibility Determination. If the Commission makes a preliminary eligibility determination
that the Applicant for a Level 1 or a Level 2 Gaming Employee License qualifies for the issuance of a
License, the Commission shall, within seven (7) business days of the date such determination is made,
but not longer than sixty (60) days from the date the Commission issues a Provisional License, prepare
and forward to the NIGC, in such form and to the extent the NIGC may require, a notice of results of
the Applicant’s background investigation, which notice shall, at a minimum, include the following:
(1)
Applicant's name, date of birth, and social security number;
(2)
Date on which Applicant began or will begin work as Key Employee or Primary Management
Official;
(3)
A summary of the information presented in the investigative report, which shall at a minimum
include a listing of:
(i) Licenses that have previously been denied;
(ii) Licenses that have been revoked, even if subsequently reinstated;
(iii) every known criminal charge brought against the Applicant within the last ten (10) years of the
date of the Application; and
(iv) every felony of which the Applicant has been convicted or any ongoing prosecution.
(4)
(b)
A copy of the eligibility determination made under Section 3.08. The Commission shall request that
the NIGC issue within thirty (30) days any objections it determines are warranted to the issuance of
a License.
Requirements for Final Determination. A final determination regarding the eligibility of an Applicant for
a Level 1 or a Level 2 Gaming Employee License may only be made after the Commission provides the
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CHAPTER III.
EMPLOYEE LICENSING
Section 3.11
Approval of a Level 1 or Level 2 Gaming Employee License.
NIGC with the Applicant’s fingerprints and any other materials required under this Act and by the NIGC
under applicable federal law and after one of the following has occurred:
(1)
The NIGC Has No Objections or Thirty Days Have Elapsed. Notice has been received from the NIGC
that it has no objection to the issuance of the License or thirty (30) days have elapsed since the
Commission provided the NIGC the required materials and the NIGC has not responded; or
(2)
NIGC Objections Are Resolved. If, within the thirty (30) day period the NIGC provides the
Commission with a statement itemizing objections to the issuance of a License to the Applicant, the
Commission shall reconsider the Applicant’s eligibility, taking into account the objections itemized
by the NIGC. If, within that thirty (30) day period the NIGC requests additional information
concerning the Applicant, the Commission shall promptly respond to such request. The receipt of
the NIGC’s request shall suspend the thirty (30) day period referred to in this Section until the NIGC
receives the additional information requested.
(c)
Final Determination of Eligibility. Upon compliance
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