AationaI 3nbtan Qaming &ommi$$ion 

NOTICE OF VIOLATION 

To: Carl Venne 

Chairman (Agent for Service of Process) 

Crow Tribe 

Box 159 

Crow Agency, MT 59022 

1. The Chairman of the National Indian Gaming Commission (NIGC) hereby gives notice that 

the Crow Tribe (hereafter referred to as "Respondent"), located in Crow Agency, Montana, is 

W in violation of the Indian Gaming Regulatory Act (IGRA), 25 U.S.C. 4 2701 et seq., NIGC 

regulations, 25 C.F.R. $ 501 et seq., and its tribal gaming ordinance. 

2. These violations include: 

A. failing to submit annual audits for 2002 and 2003 for the Respondent's Little 

Big Horn Casino; 

B. failing to submit quarterly statements of gross assessable revenue for the 

Little Big Horn Casino for 2002 and 2003. 

3. Authoritv. Under regulations of the National Indian Gaming Commission, the Chairman 

of the NIGC (hereinafter "Chairman") may issue a Notice of Violation (hereinafter 

"WOV") to any person for violation of any provision of the Indian Gaming Regulatory 

Act, NIGC regulations, or any provision of a tribal gaming ordinance or resolution 

approved by the Chairman. 25 C.F.R. $573.3. 

4. Applicable Federal and Tribal Laws: 

A. 25 U.S.C. § 2710(b)(2)(C) - Pursuant to IGRA, an annual audit of each 

gaming operation is required. Further, a copy of the annual audit and its 

results must be submiti:d to the NIGC. 
B. 25 C.F.R. $5 57 1.12 and 571.13 - NIGC regulations require that a tribe cause 

to be conducted annual independent audits of the financial statements of each 

gaming operation on Indian lands and submit a copy of the audit report(s) and 

any management letter(s) setting forth the results of the annual audit(s) to the 

NIGC within 120 days after the end of each fiscal year of each gaming 

operation. 

C. 25 C.F.R. $ 5 14.1 - NIGC regulations require Tribes submit, for each gaming 

operation, quarterly statements showing assessable gross revenues for the 

previous year. These quarterly statements shall be filed no later than March 

3 1, June 30, September 30, and December 3 1, of each calendar year. 

D. Section 33(A) and (C) of the Crow Tribe's gaming ordinance - The approved 

gaming ordinance requires the Tribe obtain outside annual audits for all of its 

gaming operations and to submit the audit reports to the NIGC. 

5. Role of Independent Audit Report. Submission of the annual independent audit report by 

a firm of certified public accountants is critical to the NIGC's mission to protect the 

integrity of Indian gaming. A firm's ability to conduct an audit in accordance with 

generally accepted auditing standards and render an opinion on the financial statements 

prepared in conformity with generally accepted accounting principals provides a certain 

level of assurance as to the security of tribal gaming revenues. The audit report prepared 

and submitted on a timely basis is evidence of, among other things, the integrity of the 

gaming operation and, more specifically, of the adequacy of the books and records, the 

functioning of the internal financial controls, and the disclosure of information having a 

bearing on the financial statements. 

6. The circumstances of the violation are: 

A. Respondent is a federally recognized Indian Tribe with tribal headquarters in 

Crow Agency, Montana. 

B. Respondent operated its gaming facility, Little Big Horn Casino, during all or 

part of the following years: 2002 and 2003. 

C. Respondent did not submit quarterly statements showing gross assessable 

revenue for the Little Big Horn Casino in 2002 and 2003. 

D. To date the NIGC has not received audit reports or management letters for the 

Little Big Horn Casino for fiscal year 2002 and fiscal year 2003. 

7. IGRA requires that tribes submit annual audits of each gaming facility. 25 U.S.C. $ 

271O(b)(Z)(C). NIGC regulations require that a tribe cause to be conducted annual 

independent audits of the financial statements o,'each gaming operation on Indian lands and 

submit a copy of the audit report(s) and any management letter(s) setting forth the results of 

the annual audit(s) to the NIGC within 120 days after the end of each fiscal year. 25 C.F.R. 
$9 57 1.12-1 3. Respondent is therefore in violation of IGRA, 25 U.S.C. 9 27 10(b)(2)(C), 

NIGC regulations, 25 C.F.R. $8 57 1.12- 13, and Respondent's gaming ordinance at section 

33(C) for failure to submit annual independent audit reports for the Little Big Horn Casino. 

8. NIGC regulations require that tribes submit, for each gaming operation, quarterly statements 

showing assessable gross revenues for the previous year. See 25 C.F.R. 95 14.1. Thus, 

Respondent is in violation of NIGC regulations, 25 C.F.R. 5 14.1, for failure to submit 

quarterly statements showing gross assessable revenue for the Little Big Horn Casino. 

9. The NIGC has sought compliance from Respondent on several occasions through meetings 

and correspondence. 

10. To correct this continuing violation, Respondent shall: 

Submit independent audit reports, management letters, and quarterly statements of gross 

assessable revenue, within fifteen (1 5) days of receipt of this letter for the years listed in 

paragraph 6 of this notice. 

1 1 . Appeal. 

Within thirty (30) days after service of this Notice of Violation, Respondent may appeal to 

the full Commission under 25 C.F.R. Part 577 by submitting a notice of appeal and, if 

desired, request for hearing to the National Indian Gaming Commission, 1441 L Street, NW, 

Ninth Floor, Washington, DC 20005. Respondent has a right to assistance of counsel in such 

an appeal. A notice of appeal must reference this Notice of Violation. 

Within ten (10) days after filing a notice of appeal, Respondent must file with the 

Commission a supplemental statement that states with particularity the relief desired and the 

grounds therefore and that includes, when available, supporting evidence in the form of 

affidavits. If Respondent wishes to present oral testimony or witnesses at the hearing, 

Respondent must include a request to do so with the supplemental statement. The request to 

present oral testimony or witnesses must specify the names of proposed witnesses and the 

general nature of their expected testimony, whether a closed hearing is requested and why. 

Respondent may waive its right to an oral hearing and instead elect to have the matter 

determined by the Commission solely on the basis of written submissions. 

12. Fine--Submission of Information. 

The violation cited above may result in the assessment of a civil fine against Respondent in 

an amount not to exceed $25,000 per violation per day. Under 25 C.F.R. 3 575.5(a), 

Respondent may submit written information about the violation to the Chairman within 

fifteen (15) days after service of this notice of violation (or such longer period as the 

Chairman of the Commission may grant for good cause). The Chairman shall consider any 

information submitted in determining the facts surrounding the violation and the amount of 

the civil fine, if any. 
- Dated this a day of June, 2004 

National Indian Gaming Commission