A Term In Review: Reflecting on the Past, Looking Toward the Future 

By Chairwoman Tracie Stevens 

Over the past two and a half years, by working together, tribes and the National Indian 

Gaming Commission (NIGC) have furthered compliance with the Indian Gaming 

Regulatory Act (IGRA) and NIGC regulations throughout Indian Country by 

implementing the A.C.E. initiative, a three-step approach to regulation of Indian gaming. 

A.C.E. stands for Assistance, Compliance, and Enforcement, in that order. The 

Commission believes that the NIGC’s responsibility as the Federal prong of Indian 

gaming’s three-tiered regulatory structure is, first and foremost, to assist tribes to comply 

with Federal regulations and maintain high levels of security and integrity within their 

operations. Enforcement actions, though necessary in some circumstances, can be 

prevented in most cases with proper assistance. Thus, the Commission is dedicated to 

assisting tribes to prevent problems requiring NIGC enforcement action. 

One of the biggest challenges we faced at first was figuring out how to remedy problems 

before they became critical. To that end, we developed four priorities to implement the 

A.C.E. initiative: consultation and relationship building, training and technical assistance, 

regulatory review, and agency operations review. 

Because each of us came from Indian Country, we realized from the start that an open, 

candid relationship between tribes and the NIGC is integral to the success of anything we 

would do. Therefore, we made consultation and relationship building a major priority. 

In that effort, we began by asking tribes for feedback on basic issues, like how best to 

consult with tribes. Then, we asked tribes where we could improve our regulations from a 

practical standpoint in today’s evolving industry. And we listened to what tribes said, and 

talked about what we intended to do. We wanted open communication with tribes, 

whether through consultation, training, technical assistance, or other forms of guidance, 

because without it, the A.C.E. initiative would not work. 

We are still refining our consultation process to maximize tribal and Federal resources 

and to ensure honest, candid government-to-government communication. Most recently, 

we have updated our Draft Consultation Policy. The new Draft provides greater clarity 

and a more streamlined approach to consultation. We realize that tribes consult with 

many branches of the Federal government, which is taxing to tribal resources and can be 

a cumbersome process. We hope that our new Draft Consultation Policy helps ease those 

burdens on tribes. We welcome tribal comments on the Draft, which is available on our 

website at www.nigc.gov. 

The second, but equally important, priority that supports the A.C.E. initiative is training 

and technical assistance. Over the past two and a half years, our training and technical 

assistance courses, site-specific trainings, and guidance from our regional offices have 

helped prevent enforcement actions. For example, the NIGC staff noticed issues 

regarding late audits, licensing, and fees. Instead of recommending enforcement actions, 
our staff began to remind tribes in advance of approaching deadlines by sending written 

notices. Since then, timeliness has improved significantly. Indeed, in the past fiscal year, 

there were very few incidents of late audits and late fee worksheets. And in nearly all 

cases, after the issues were identified, the NIGC staff made efforts to reach out to the 

tribes, and in doing so, was able to work with the tribes to remedy the non-compliance. 

We have noticed high rates of compliance across regions. We attribute this directly to 

increases in training and technical assistance opportunities and staff interaction with 

tribes. We have experienced increases in the number of training requests received by 

tribes and fewer critical problems. These numbers show that working along-side tribes 

has a direct impact on compliance, and maintains the security and integrity of Indian 

gaming. 

The integrity of the industry does not rely only on following the rules, but also on having 

good, practical rules to follow. Therefore, two years ago, Commission committed to 

conducting a thorough regulatory review. We consulted with tribes, asked for guidance 

from a Tribal Advisory Committee, and dedicated significant agency resources to making 

sure that this industry, especially Tribal Gaming Regulatory Authorities, as the first line 

of defense, have the best regulations possible. 

All in all, we are proud of the success of our regulatory review effort, which has resulted 

so far in ten final rules, one repeal, and two notices of no action. We can see the A.C.E. 

initiative working through our regulatory review because our regional offices have 

already received requests for training and technical assistance on the new and updated 

regulations. This is exactly the type of cooperative, collaborative relationship that we 

envisioned when we came together as a Commission. 

As we look toward the future, we will continue to review and update our regulations 

where appropriate and remain committed to consultation and collaboration with tribal 

governments. 

Finally, we looked internally at our own agency operations in an effort to improve 

efficiency and effectiveness from within. We conducted an agency reorganization to 

improve work flow, get rid of redundancies, and better manage resources. As a result, we 

have seen improvement in the NIGC’s ability to respond to industry needs, as well as 

increased communication among Agency components. As we look forward, we will 

continue to improve the NIGC’s internal operations by updating and utilizing technology, 

maximizing existing agreements, and meeting staffing needs. We want to make sure that 

the NIGC is able to serve the industry to the best of its ability. 

For the past two and a half years, we have used the four priorities as guideposts to 

support the A.C.E. initiative. By working respectfully and openly with tribes and 

focusing on our four priorities, the A.C.E. initiative is working. As we move into the 

future, we will redouble our commitment to A.C.E. by consulting with tribes and 

maintaining candid, honest communication; helping tribes maintain compliance with 

Federal laws and regulations through training and technical assistance; revisiting our 
regulations periodically to ensure that they make sense in the ever-evolving gaming 

industry landscape; and continuing to improve our internal operations so that we are 

better able to serve tribes. 

Tracie Stevens is the Chairwoman of the National Indian Gaming Commission (NIGC) 

and a member of the Tulalip Tribes of Washington. She can be reached by calling (202) 

632-7003. For more information about the NIGC, visit www.nigc.gov.