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July 11, 2022

VIA EMAIL

Sherry Cordova, Chairwoman

Cocopah Indian Tribe

14515 S. Veterans Drive

Somerton, AZ 85350

Re: Cocopah’s Amended Gaming Ordinance

Dear Chairwoman Cordova,

This letter is in response to the Cocopah Indian Tribe’s request, dated May 13, 2022, to 

the National Indian Gaming Commission (“NIGC”) Chairman for review and approval of

amendments to the Tribe’s gaming ordinance.

Resolution CT-2022-11 replaces the Tribe’s current gaming ordinance, CTO-2016-2,

with a wholly revised and updated version. This newly amended ordinance reflects recent 

amendments to the Arizona State-Tribal Gaming Compact and NIGC regulation changes, and 

other updates deemed necessary by the Tribe in the 7 years since the last amendment.

The amendments are consistent with the requirements of the Indian Gaming Regulatory 

Act and NIGC regulations and are hereby approved. If you have any questions concerning this 

letter or the ordinance review process, please contact Mandy Cisneros at

mandy.cisneros@nigc.gov.

Sincerely,

E. Sequoyah Simermeyer

Chairman

cc: Judy Graham, Gaming Commission Chair, via email: sherry@cocopah.com

Glenn Feldman, Attorney, via email: glenn.feldman@procopi.com

Bonnie Atwell, Executive Director of Gaming, via email: batwell@cocopah-casino.com
ORDINANCE FOR THE REGULATION OF GAMING 

ACTIVITIES

WITHIN

THE COCOPAH INDIAN TRIBE

AMENDED AND ADOPTED ON 

 

 MAY 13, 2022 ________________________________________________________________________

 DATE 

 CT-2022-11 ___________________________________________________________________________

 

BY RESOLUTION NUMBER

 SUPERSEDES:

TRIBAL GAMING ORDINANCE ADOPTED APRIL 15, 1994 AND 

 AMENDED SEPTEMBER 20, 1999 AND NOVEMBER 21, 2016

 BY RESOLUTION NUMBER: _CT99-26 & CTO-2016-2 

TABLE OF CONTENTS

CHAPTER 1 FINDINGS AND PURPOSES..............................................................................................1

SECTION 101 LEGISLATIVE FINDINGS .......................................................................1

SECTION 102 PURPOSES ............................................................................................2

CHAPTER 2 DEFINITIONS..................................................................................................................2

SECTION 201 DEFINITIONS........................................................................................2

CHAPTER 3 TRIBAL OWNERSHIP AND USE OF NET REVENUE ........................................................8

SECTION 301 TRIBAL OWNERSHIP OF GAMING ACTIVITIES ......................................8

SECTION 302 USES OF NET REVENUES......................................................................8

CHAPTER 4 COCOPAH TRIBAL GAMING OFFICE ............................................................................8

SECTION 401 ESTABLISHMENT OF THE GAMING OFFICE ...........................................8

SECTION 402 PERSONNEL .........................................................................................8

SECTION 403 ESTABLISHMENT OF THE TRIBAL GAMING COMMISSION ...................10

SECTION 404 ISSUANCE OF REGULATIONS ..............................................................15

SECTION 405 PETITION FOR SELF-REGULATION......................................................17

CHAPTER 5 GAMING FACILITY OPERATOR'S LICENSE.................................................................17

SECTION 501 REQUIREMENT OF LICENSE................................................................17

CHAPTER 6 GAMING MANAGER'S LICENSE ..................................................................................17

SECTION 601 REQUIREMENT OF LICENSE................................................................17

CHAPTER 7 LICENSES FOR GAMING DEVICE MANUFACTURERS, DISTRIBUTORS,

SUPPLIERS OF GAMING SERVICES, AND FINANCERS .................................................18

SECTION 701 REQUIREMENT OF LICENSE................................................................18

SECTION 702 STANDARDS OF SUITABILITY.............................................................18

CHAPTER 8 GAMING EMPLOYEE'S LICENSE .................................................................................19

SECTION 801 REQUIREMENT OF LICENSE................................................................19

SECTION 802 STANDARDS OF SUITABILITY.............................................................19

CHAPTER 9 LICENSE APPLICATION PROCEDURE..........................................................................20

SECTION 901 APPLICATION REQUIREMENTS; PROCESSING .....................................20

SECTION 902 FEES ..................................................................................................24

SECTION 903 LICENSE TERMS; RENEWAL...............................................................26

SECTION 904 STATE CERTIFICATION.......................................................................27

CHAPTER 10 BACKGROUND INVESTIGATIONS; NOTIFICATION ......................................................27

SECTION 1001 BACKGROUND INVESTIGATIONS ........................................................27

SECTION 1002 NOTIFICATION TO THE NATIONAL INDIAN GAMING COMMISSION .....30
SECTION 1003 NATIONAL INDIAN GAMING COMMISSION REVIEW ............................31

SECTION 1004 NOTICE OF ELIGIBILITY AND LICENSEE’S RIGHT TO A HEARING..........31

CHAPTER 11 GAMING FACILITY LICENSE.......................................................................................32

SECTION 1101 REQUIREMENT OF LICENSE................................................................32

SECTION 1102 STANDARDS FOR ISSUANCE OF LICENSE ............................................32

SECTION 1103 APPLICATION FOR A NEW OR AMENDED LICENSE; PROCEDURE ........33

CHAPTER 12 FACILITY INSPECTION; INVESTIGATIONS; NOTICE OF VIOLATION;

JUDICIAL REVIEW.......................................................................................................35

SECTION 1201 FACILITY INSPECTION........................................................................35

SECTION 1202 INVESTIGATIONS................................................................................35

SECTION 1203 NOTICE OF VIOLATION ......................................................................36

SECTION 1204 JUDICIAL REVIEW..............................................................................38

CHAPTER 13 GAMING OPERATION ..................................................................................................39

SECTION 1301 SCOPE OF PERMISSIBLE GAMING .......................................................39

SECTION 1302 HOURS, DAYS AND OTHER STANDARDS ...........................................39

SECTION 1303 EMPLOYEE AND PLAYER AGE LIMIT..................................................39

SECTION 1304 MANAGEMENT; SECURITY.................................................................40

SECTION 1305 INTERNAL CONTROLS ........................................................................41

SECTION 1306 NOTIFICATION ...................................................................................43

SECTION 1307 ANNUAL INDEPENDENT AUDIT..........................................................43

SECTION 1308 PUBLIC DISCLOSURE OF PAYOFFS......................................................45

SECTION 1309 PATRON DISPUTES.............................................................................45

SECTION 1310 PLAY BY EMPLOYEES ........................................................................47

SECTION 1311 FINANCIAL SERVICES AT GAMING FACILITIES...................................47

SECTION 1312 ADVERTISING GUIDELINES ................................................................47

CHAPTER 14 VIOLATIONS AND REMEDIES ......................................................................................48

SECTION 1401 VIOLATIONS ......................................................................................48

SECTION 1402 CIVIL PENALTIES ...............................................................................48

SECTION 1403 CIVIL REMEDIES ................................................................................49

CHAPTER 15 TRANSITION PROVISIONS............................................................................................49

SECTION 1501 EXISTING GAMES LAWFUL ................................................................49

SECTION 1502 REPEAL OF PRIOR ORDINANCES AND RESOLUTIONS..........................49

CHAPTER 16 AMENDMENTS ..........................................................................................................49

SECTION 1601 AMENDMENT ................................................... ............49
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CHAPTER 1 FINDINGS AND PURPOSES

SECTION 101 LEGISLATIVE FINDINGS

The Tribal Council of the Cocopah Indian Tribe is empowered by the Tribe’s Constitution to enact 

ordinances, and hereby enacts this ordinance in order to govern and regulate the operations of 

Class II and/or Class III gaming operations on the Tribe’s Indian lands. The Council hereby enacts 

this Ordinance to promote Tribal Economic Development, Self-Sufficiency, and Sovereignty; to 

shield the operation of gaming from organized crime and other corrupting influences; and to ensure 

that gaming is conducted fairly and honestly by both the Operator and players. The Tribal Council 

of the Cocopah Indian Tribe hereby finds:

1) That the orderly and honest conduct of gaming activities within the Cocopah Indian Tribe 

has been and will continue to be of vital importance to the economy of the Tribe, and to the 

general welfare of its members;

2) That the continued growth and success of gaming within the Cocopah Indian Tribe are 

dependent upon public confidence and trust that such activities are conducted honestly and 

that they are free from criminal and corrupt elements, and that the facilities in which such 

activities are conducted are designed and maintained to assure the safety and comfort of 

patrons of the gaming activities;

3) That such public confidence and trust can only be maintained by the comprehensive 

regulation of all people, practices, and activities related to the operation of the Tribe's 

gaming facilities; and

4) All of the Tribe's establishments where gaming is conducted, and all people holding 

positions of responsibility with respect to any such activity, must therefore be licensed, and 

their activities monitored, to assure that the public health, safety, and general welfare of the 

inhabitants of the Tribe and the patrons of its gaming facilities are fully protected, and so as 

to assure the economic success of gaming activities within the Tribe.

5) Unless specifically indicated otherwise, all provisions of this ordinance shall apply to Class 

II and/or Class III gaming on the Tribe’s Indian lands.
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SECTION 102 PURPOSES

This Ordinance is therefore enacted, and shall be interpreted, so as to accomplish the following 

purposes:

1) The maintenance of the highest standards of honesty and integrity in the operation of any 

and all gaming activities within the Cocopah Indian Tribe;

2) The maintenance of public confidence and trust in the honesty and integrity of such gaming 

activities, and in the people engaged in such activities;

3) The maximum reasonable economic return to the Cocopah Indian Tribe as the owner of 

gaming facilities within the Tribe consistent with the fair and reasonable expectation of 

patrons of such activities and the assurance of their safety and comfort in participating in 

gaming activities; and

4) Class II and/or Class III gaming is authorized to be conducted on Cocopah Indian lands.

Such gaming shall be conducted in compliance with this Ordinance, the Indian Gaming 

Regulatory Act of 1988, NIGC Regulations, and any other applicable laws or regulations.

CHAPTER 2 DEFINITIONS

SECTION 201 DEFINITIONS

For purposes of this Ordinance:

(a) "Act" means the Indian Gaming Regulatory Act, Public Law 100-497, 25 U.S.C. §§ 

2701-2721 AND 18 U.S.C. §§ 1166-1168, and all regulations promulgated pursuant 

thereto.

(b) "Chairperson" means the Chairperson of the Cocopah Tribal Gaming Commission 

established by this Ordinance.

(c) "Class I Gaming" means all forms of gaming defined as Class I in Section 4(6) of the Act, 

25 U.S.C. § 2703(6).

(d) "Class II Gaming" means all forms of gaming defined as Class II in Section 4(7) of the 

Act, 25 U.S.C. § 2703(7).

(e) "Class III Gaming" means all forms of gaming defined as Class III in Section 4(8) of the 

Act, 25 U.S.C. § 2703(8), and permitted by Arizona State/Tribal Gaming Compact.
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(f) "Commission" means the Cocopah Tribal Gaming Commission established by this 

Ordinance, and has the same meaning as "Tribal Gaming Office" under the Compact.

(g) "Compact" means the Tribal-State Compact entered into between the Cocopah Indian 

Tribe and the State of Arizona pursuant to Section 11(d) of the Act, 25 U.S.C. § 2710(d).

(h) "Constitution" means the Constitution of the Cocopah Indian Tribe ratified by the 

Cocopah Tribe on October 8, 1964, and approved by the Assistant Secretary of the 

Interior on November 16, 1964, pursuant to Section 16 of the Act of June 18, 1934 (48 

Stat. 984).

(i) "Distributor" means a Person who distributes Gaming Devices, Gaming device software, 

host system software, or kiosk. 

(j) "Enrolled Tribal Member" members as designated in a tribal constitution or other 

document specifying enrollment criteria.

(k) "Executive Director" means the Executive Director of the Cocopah Tribal Gaming 

Commission established pursuant to this Ordinance.

(l) “Facility License” means a license issued by the Tribal Gaming Commission to each 

place, facility or location where the Tribe elects to allow class II or III gaming. 

(m) "Gaming Activities" means any forms of Class II and Class III Gaming conducted within 

the territorial jurisdiction of the Tribe.

(n) "Gaming Device" or "Electronic Game of Chance" means a fixed location or mobile

mechanical device, electro-mechanical device, a device controlled by an electronic 

microprocessor or in any other manner, whether that device would constitute Class II 

Gaming or Class III Gaming if operated on Indian Lands by an Indian tribe, that allows a 

player or players to play games of chance, whether or not the outcome of the game is also 

affected in some part by skill, and where the game includes the payment of consideration 

in the form of coins, tokens, bills, coupons, ticket vouchers, pull tabs, smart cards, 

electronic in-house accounting system credits or any other forms of consideration and, 

through the application of chance the player of the game may become entitled to a prize, 

which may be paid in coins, tokens, bills, coupons, ticket vouchers, smart cards, 

electronic in-house accounting system credits or any other forms of value. Gaming 

Device does not include any of the following:

1. Those technological aids used in live bingo games that function only as electronic 

substitutes for bingo cards and cannot substitute for the bingo caller. 
4

2. Devices that issue and validate paper lottery products and that are directly operated 

only by Arizona State Lottery licensed retailers and their employees.

3. Devices expressly authorized by Arizona statues and which are operated directly by a 

lottery player and that dispense paper lottery tickets, if the devices do not identify 

winning or losing lottery tickets, display lottery winnings or disburse lottery 

winnings.

4. Devices that are operated directly by a lottery player and that validate paper lottery 

tickets for a game that does not have a predetermined number of winning tickets, if:

(i) The device does not allow interactive gaming;

(ii) The device does not allow lottery player to play the lottery for immediate 

payment or reward;

(iii) The device does not disburse lottery winnings; and

(iv) The device is not Video Lottery Terminals, as defined in the Compact.

5. Player Activated Lottery Terminals, as defined in the Compact.

(o) "Gaming Employee" means any individual employed as a Primary Management Official 

or Key Employee of a Gaming Operation of the Tribe and any individual employed in the 

operation or management of a Gaming Operation, including, but not limited to, any 

individual whose employment duties require or authorize access to restricted areas of a 

Gaming Facility not otherwise open to the public.

(p) "Gaming Facility" means the building, room or rooms or that portion of a room in which 

Class II gaming or Class III gaming authorized under the Compact is conducted on the 

Cocopah Reservation.

(q) "Gaming Facility Operator" means the Cocopah Indian Tribe.

(r) "Gaming Operation" means any Gaming Activities conducted within a Gaming Facility.

(s) "Gaming Vendors " means any Person or entity which sells, leases, distributes or 

provides: (1) devices, machines, or equipment used directly in connection with Gaming 

Activity including that which has the capacity to affect the calculation, storage, 

collection, electronic security, or control of gaming revenues: (2) services which are 

unique to the operation of Gaming Activity, including, but not limited to, simulcasting 

and bookmaking: and (3) security or surveillance services or equipment for the Gaming 

Facility, Gaming Vendors include Persons who provide general construction contracting, 
5

payroll and locks and locksmith services for the Gaming Facility, as well as Persons who 

provide player tracking, player acquisition, promotional, and marketing services related 

to Gaming Activity. “House Banking game” means any game of chance that is played 

with the house as a participant in the game, where the house takes on all players, collects 

from all losers, and pays all winners, and the house can win. 

(t) "Indian Lands" means land as defined in 25 U.S.C. § 2703(4) (A) and (B), subject to the 

provisions of 25 U.S.C. § 2719.

(u) "Key Employee" means:

1. Any individual employed by the Gaming Facility Operator who performs one or more 

of the following functions:

(i) Bingo caller;

(ii) Counting room supervisor;

(iii) Chief of Security;

(iv) Custodian of gaming supplies or cash;

(v) Floor Manager;

(vi) Pit Supervisor;

(vii) Blackjack Dealer;

(viii) Approver of credit;

(ix) Custodian of Gaming Devices including any individual with access to cash and 

accounting records within Gaming Devices;

2. Any individual employed by the Gaming Facility Operator whose total cash 

compensation from his or her employment by the Gaming Facility Operator exceeds 

$50,000 per year; and

3. The four most highly compensated employees of the Gaming Facility Operator.

(v) "License" means an approval issued by the Tribal Gaming Office to any natural person or 

entity to be involved in the Gaming Operation as a Gaming Employee, Gaming Vendor

or in the providing of Ancillary Services to the Tribe.
6

(w) "Licensee" means any natural person or entity that has been licensed by the Tribal 

Gaming Office to be involved in the Gaming Operation or in the providing of Gaming 

Services to the Tribe.

(x) "Manufacturer" means a natural person or entity that manufactures Gaming Devices, 

gaming device software, host system software, or kiosk and who intends to furnish it to a

distributor, supplier or the Tribe "Net Revenues" means the gross gaming revenues of the 

Gaming Facility Operator less amounts paid out as, or paid for, prizes and total operating 

expenses, excluding management fees.

(y) "National Indian Gaming Commission (NIGC)" means the National Indian Gaming 

Commission established pursuant to 25 U.S.C. § 2704

(z) "Ordinance" means this Ordinance for the Regulation of Gaming Activities within the 

Cocopah Indian Tribe, which governs the conduct of Gaming Activities within the 

Cocopah Indian Tribe, all amendments thereto, and all regulations promulgated there 

under.

(aa) "Person" includes a corporation, company, partnership, firm, association or society, as 

well as a natural person. When “Person” is used to designate the violator or offender of 

any law, it includes a corporation, partnership or any association of Persons. Player 

Station” means a terminal of a Multi-Station Device through which the player plays an

electronic game of chance simultaneously with other players at other Player Stations of 

that Multi-Station Device, and which; 

1. Has no means to individually determine game outcome; 

2. Cannot be disconnected from the Gaming Device central processing unit that 

determines the game outcomes for all Player Stations without rendering that terminal 

inoperable; and 

3. Does not separately contain a random-number generator or other means of 

individually determine the game outcome. 

(bb) "Primary Management Official" means: (1) any individual who has authority to hire and 

fire employees or to set up working policy for a Gaming Operation; and (2) the chief 

financial officer or other individual who has financial management responsibility for a 

Gaming Operation.

(cc) "Principal" means with respect to any entity:

1. Each of its officers and directors;
7

2. Each of its principal management employees, including its chief executive officer, its 

chief financial officer, its chief operating officer, and its general manager;

3. Each of its owners or partners, if an unincorporated business;

4. Each of its shareholders who own more than ten (10) percent of the shares of the 

corporation, of a corporation.

5. Each Person other than a banking institution who has provided financing for the entity 

constituting more than ten (10) percent of the total financing of the entity; and

6. Each of the beneficiaries and trustees of a trust.

(dd) "Privacy Act" means of Privacy Act of 1974, as amended (P.L. 93-579, as amended; 5 

U.S.C. § 552 (a), and the obligations and responsibilities placed on the United States 

government under the Privacy Act as applied to the Commission pursuant to the Act.

(ee) "State" means the State of Arizona, and its Authorized officials, agents, and 

representatives.

(ff) “State Gaming Agency" means the agency of the State as the Governor may from time to 

time designate by written notice to the Tribe as the state agency primarily responsible for 

oversight of the Class III gaming as authorized by the Compact.

(gg) "Transfer Agreement" means a written agreement authorizing the transfer of Gaming 

Device Operating Rights between the Tribe and another Indian tribe, in accordance with 

the provisions of the Compact.

(hh) "Tribe" means the Cocopah Indian Tribe, its authorized officials, agents and 

representatives.

(ii) "Tribal Gaming Office" means the department, agency or commission designated by 

action of the Cocopah Tribal Council as the tribal entity, which shall exercise the civil 

regulatory authority of the Tribe over all gaming activities conducted on the Cocopah 

Indian Reservation whether by the Tribe or others.

(jj) "Tribal Police Department" means the department of the Cocopah Indian Tribe consisting 

of Arizona Police Officer Standard Training (POST) certified officers duly authorized to 

enforce the Tribal Law and Order Code, and applicable state and federal laws on the 

Cocopah Indian Reservation. 
8

CHAPTER 3 TRIBAL OWNERSHIP AND USE OF NET REVENUE

SECTION 301 TRIBAL OWNERSHIP OF GAMING ACTIVITIES

All Gaming Activities within the Tribe shall be owned entirely by the Tribe and conducted and 

operated by the Gaming Facility Operator.

SECTION 302 USES OF NET REVENUES

The net revenues received by the Tribe from all Gaming Activities shall be used exclusively for 

one or more of the following purposes:

1) To fund Tribal government operations and/or programs of the Tribe.

2) To provide for the general welfare of the Tribe and its members.

3) To promote the Tribe's economic development.

4) To donate to charitable organizations providing services benefiting the Tribe or its 

members.

5) To help fund operations of local government agencies.

CHAPTER 4 COCOPAH TRIBAL GAMING OFFICE

SECTION 401 ESTABLISHMENT OF THE GAMING OFFICE

There is hereby established the Cocopah Tribal Gaming Office (hereinafter "the Gaming Office"), 

as a department of the Cocopah Tribe, which shall have overall civil regulatory authority over 

Gaming Activities within the Tribe and the Gaming Facility Operator as specifically provided in 

this Ordinance.

SECTION 402 PERSONNEL

1) The Gaming Office shall consist of the Tribal Gaming Commission, its Executive Director, 

Inspectors and such assistants and other staff as the Executive Director shall determine are 

required from time to time, subject to funding provided by the Tribal Council. All 

employees of the Gaming Office shall act under the authority and supervision of the 

Executive Director. The Assistant Director of Gaming/Investigator shall act on behalf of 

the Executive Director in the absence of the Executive Director. No employee of the 
9

Gaming Office shall be employed by the Gaming Facility Operator. No employee of the 

Gaming Office shall be employed by or hold, directly or indirectly, a financial interest in an 

organization or entity which;

a. Has entered into a Management Contract with the Gaming Facility Operator;

b. A Manufacturer or Distributor;

c. A Provider of Gaming Services; or

d. Provides financing to the Tribe or the Gaming Facility Operator for purposes of 

conducting Gaming Operations within the Tribe. 

2) The Executive Director shall be the Tribe's designated agent for service of any official 

determination, order, or notice of violation, by a written notification to the Tribal Gaming 

Commission.

3) The Gaming Office shall have the right to inspect any Gaming Facility at any time and shall 

have immediate and unrestricted access to any and all areas of a Gaming Facility, which it 

may exercise directly or through such agents or employees as determined by the Executive 

Director. The Executive Director shall notify the Gaming Facility Operator of Persons 

authorized to have immediate and unrestricted access and the Executive Director shall 

periodically update its notification to the Gaming Facility Operator of Persons authorized to 

have immediate and unrestricted access. An Inspector shall be present in each Gaming 

Facility during all hours of Gaming Operation.

4) The Tribe shall not employ any individual in the Gaming Office unless the Tribal Gaming 

Commission has first issued the individual a Tribal Gaming Regulatory License. Before 

issuing a Tribal Gaming Regulatory License, the Tribal Gaming Commission shall conduct 

a background investigation of each applicant for a Tribal Gaming Regulatory License, 

which investigation shall comply with any requirements of the Act or the Compact, to 

ensure that the applicant is qualified for a Tribal Gaming Regulatory License. Any 

individual who is not an enrolled member of the Tribe also shall be certified by the Arizona 

Department of Gaming pursuant to the Compact before being employed by the Gaming 

Office. 

5) The Tribal Gaming Commission shall not issue a Tribal Gaming Regulatory License to any 

individual, and shall revoke any such license issued to any individual, whom it determines:

a. Has ever been convicted of any gaming offense. 
10

b. Has been convicted of a felony in the seven (7) years prior to submission of the 

application unless that felony has been set-aside.

c. Has ever been convicted of a felony relating to extortion, burglary, larceny, bribery, 

embezzlement, robbery, racketeering, money laundering, forgery, fraud, murder, 

voluntary manslaughter, sex offenses, rape or kidnapping. 

d. Has knowingly and willfully provided materially important false statements or 

information or omitted materially important information on his or her license 

application; or

e. Is an individual whose prior activities, criminal record, if any, or reputation, habits, and 

associations pose a threat to the public interest or to the effective regulation and control 

of gaming, or create or enhance the dangers of unsuitable, unfair, or illegal practices, 

methods, and activities in the conduct of gaming or the carrying on of the business and 

financial arrangements incidental thereto.

6) The Tribal Gaming Commission shall forward a copy of every application for a Tribal 

Gaming Regulatory License to the Arizona Department of Gaming in accordance with 

Section 5 of the Compact. If the application for a Tribal Gaming Regulatory License is 

denied by the Tribal Gaming Commission, a statement setting forth the grounds for denial 

shall be forwarded to the Arizona Department of Gaming together with all other documents 

relied upon by the Tribal Gaming Commission, to the extent allowed by law. The Tribal 

Gaming Commission shall afford the Arizona Department of Gaming an opportunity for a 

hearing before an appropriate forum of the Tribe, pursuant to Sections 5(q) (2) and 5(q) (3) 

of the Compact, to contest a licensing decision of the Tribal Gaming Commission or to 

recommend suspension or revocation of a license issued by the Tribal Gaming 

Commission. The decision of the tribal forum shall be final.

SECTION 403 ESTABLISHMENT OF THE TRIBAL GAMING COMMISSION

1) There shall be established a Cocopah Tribal Gaming Commission consisting of a Chairman 

with the advice and consent of the Tribal Council, at least two of whom shall be members 

of the Tribe, but none of whom shall be employees of the Gaming Operation. The members 

of the Tribal Gaming Commission shall serve on a part time basis and the compensation of 

members of the Commission shall be established by the Tribal Council. Members of the 

Tribal Gaming Commission may be removed for cause by a three-fourths (3/4) vote of the 

members of the Tribal Council then in office. Vacancies in the Tribal Gaming Commission 

may be filled by appointment by the Tribal Chairman with the advice and consent of the 
11

Tribal Council. No member or employee of the Tribal Gaming Commission shall 

participate as a player in any gaming activity conducted by the Tribe.

2) Powers and duties of the Tribal Gaming Commission.

The Commission shall have the following powers and duties:

a. The Commission shall have primary responsibility for oversight of the Tribal Gaming 

Operation to assure the integrity of such operation and shall, for that purpose, employ 

non-uniformed inspectors who may be present in all gaming facilities during all hours 

of operation and who shall be under the sole supervision of the Commission and not 

under the supervision of any management employees of the Tribal Gaming Operation. 

Such inspectors shall have unfettered access to all areas of the Gaming Facilities at all 

times, and personnel employed by the Gaming Operation shall for such purposes 

provide such inspectors access to locked and secured areas of the gaming facilities in 

accordance with the standards of operation and management promulgated pursuant to 

the Compact. Such inspectors shall report to the Commission regarding any failure by 

the Gaming Operation to comply with any of the provisions of the Compact or this 

Ordinance and any other applicable laws and ordinances. Inspectors assigned by the 

Commission may also receive consumer complaints within the gaming facilities and 

shall assist in seeking voluntary resolution of such complaints. Inspectors appointed by 

the Commission shall be licensed as gaming employees in accordance with the 

Compact.

b. The Commission may on its own initiative investigate any aspect of the Gaming 

Operation in order to protect the public interest in the integrity of such gaming activities 

and to prevent improper or unlawful conduct in the course of such gaming activities, 

and shall investigate any report of a failure of the Gaming Operation to comply with the 

provisions of the compact or this Ordinance and may require the Gaming Operation 

take any corrective action deemed necessary by the Commission upon such terms and 

conditions as the Commission may determine appropriate. The Commission may 

compel any person employed by or doing business with the Gaming Operation to 

appear before it and to provide such information, documents or other materials as may 

be in their possession to assist in any such investigation.

c. The Commission shall carry out each of the responsibilities and duties set forth for the 

Tribal Gaming Office in the Compact.
12

d. The Commission shall prepare a plan for the protection of public safety and the physical 

security of patrons in each of its gaming facilities, setting forth the respective 

responsibilities of the Commission, the security department of the Gaming Operation, 

any Tribal police agency, and if appropriate, any State or local policy agency.

e. The Commission shall review and approve floor plans and surveillance systems for 

each gaming facility and may confer with the State Gaming Agency or other 

organizations regarding the adequacy of such plans and systems.

f. The Commission may promulgate, review and revise (as necessary) regulations to 

govern the operation and management of the Gaming Operation in accordance with the 

Compact.

g. The Commission may issue and revoke licenses for Class III Gaming employees as 

provided for in this Ordinance.

h. The Commission may issue and revoke licenses for Class II gaming employees as 

provided for in this Ordinance.

i. The Commission shall establish a list of persons banned from the gaming facilities 

because of their criminal history or association with career offenders or career offender 

organizations that poses a threat to the integrity of the gaming activities of the Tribe.

j. The Commission shall promulgate, review, and revise (as necessary) the Technical 

Standards and rules of each game of chance operated by the Tribe pursuant to the 

Compact and shall in accordance with the provisions of the Compact notify the State 

Gaming Agency of such rules and any change in such rules.

k. The Commission shall enforce the health and safety standards applicable to the Gaming 

Facilities as provided for in this Ordinance. Prior to the opening of any facility for Class 

III gaming the Gaming Operation shall obtain a certificate of compliance from the 

Commission relating to the Class III Gaming Facilities. The Commission shall issue a 

certificate of compliance to the Gaming Operation upon a determination that the 

Gaming Facilities comply with such standards.

l. The Commission may impose penalties for violations of this Ordinance, Tribal-State 

Compact, and Tribal Minimum Internal Controls Standards, Casino Policies and 

Procedures or federal laws.
13

m. The Commission may in the name of the Tribe bring any civil action or criminal 

complaint in the courts of the Tribe, State or the United States to enforce the provisions 

of this Ordinance, the Act or the Compact or to enjoin or otherwise prevent any 

violation of this Ordinance, the Act or the Compact, occurring on the Reservation.

n. The Commission may receive any complaint from an employee of the Gaming 

Operation or any member of the public who is or claims to be adversely affected by an 

act or omission of the Gaming Operation or any employee thereof which is asserted to 

violate this Ordinance or the Compact, and may impose such remedial action as it 

deems appropriate to bring the Gaming Operation into compliance with such 

provisions. The Commission may for this purpose, in its sole discretion, conduct a 

hearing and receive evidence with regard to such complaint if it deems an evidentiary 

proceeding useful in the resolution of such complaint.

o. The Commission shall adopt an annual operating budget which shall be subject to the 

approval of the Tribal Council and may in accordance with said budget employ such 

staff from time to time as it deems necessary to fulfill its responsibilities under this 

Ordinance, and may retain legal counsel, consultants and other professional services 

including investigative services to assist the Commission with respect to any of the 

issues over which the Commission exercises jurisdiction. The expenses of the 

Commission in accordance with such budget shall be assessed against the Gaming 

Operation and the Gaming Operation shall pay such assessments to the Tribe.

3) Chairman. The Chairman of the Commission or any other member of the Commission 

acting in the absence of the Chairman may, whenever he/she deems it necessary to protect 

the public interest in the integrity of the Gaming Operation, issue in the name of the 

Commission any order, which the Commission has the power to issue, to the Gaming 

Operation or to any employee or contractor of the Gaming Operation or to any other person 

within the jurisdiction of the Tribe, to take any action or cease and desist from any action as 

may be required to protect the public interest; provided, that such order shall be subject to 

review by the Commission at its earliest opportunity, whereupon it may be confirmed or 

vacated by the Commission.

4) Executive Director. The Commission shall appoint an individual to serve as Executive 

Director of the Commission to administer its responsibilities as necessary and to oversee 

inspectors appointed by the Commission as well as such other staff as the Commission may 

from time to time employ. The Executive Director shall be responsible for coordination of 

the functions of the Commission with the State Gaming Agency and other federal, state, 

and local agencies as necessary. The Chairman may request the Executive Director to 

conduct a preliminary investigation and render a recommendation to the Commission with 
14

respect to the grant or denial of any license, the imposition of any penalty, the investigation 

of any complaint, or any other action within the jurisdiction of the Commission. The 

Executive Director shall have the power, in the name of the Commission, to conduct any 

hearing, investigation or inquiry, compel the production of any information or documents, 

and otherwise exercise the investigatory powers of the Commission, which the Commission 

may exercise under this Ordinance.

5) Procedures of the Commission

a. Regular meetings of the Commission may be held upon such notice, or without notice, 

and at such time and place as shall from time to time be fixed by the Commission. 

Unless otherwise specified by the Commission, no notice of such regular meetings shall 

be necessary.

b. Special meetings of the Commission may be called by the Chairman or the Executive 

Director. The person or persons calling the special meeting shall fix the time and place 

thereof. Neither the business to be transacted at, nor the purpose of, any regular or 

special meeting of the Commission needs to be specified in the notice of the meeting.

c. At any meeting of the Commission, a majority of the members then in office shall 

constitute a quorum for the transaction of business. The vote of a majority of the 

members present at a meeting at which a quorum is present shall be the act of the 

Commission. The Chairman shall preside at all meetings of the Commission unless the 

Chairman designates another member to preside in his/her absence.

d. Any action required or permitted to be taken at a meeting of the Commission may be 

taken without a meeting if all of the members sign written consents setting forth the 

action taken or to be taken, at any time before or after the intended effective date of 

such action. Such consents shall be filed with the minutes of the Commission, and shall 

have the same effect as a unanimous vote or resolution of the Commission at a legal 

meeting thereof.

e. Members of the Commission may participate in a meeting of the Commission by means 

of conference telephone or similar communications equipment by means of which all 

persons participating in the meeting can hear each other, and participation in a meeting 

in such matter by any member who does not object at the beginning of such meeting to 

the holding thereof in such manner shall constitute presence in person at such meeting.
15

f. No action of the Commission to impose a penalty pursuant to Chapter 14 of this 

Ordinance, or to revoke a license for a gaming employee previously issued by the 

Commission, shall be valid unless the person affected is given at least seven days’ 

notice of the proposed action and the opportunity to appear and be heard before the 

Commission, either in person or through a representative or legal counsel, and to submit 

such evidence as the Commission deems relevant to the matter at issue; provided, that if 

the Commission deems it necessary to protect the public interest in the integrity of the 

gaming activities, the Commission may take such action with immediate effect as it 

deems required, and shall thereupon provide notice and an opportunity to be heard to 

the affected person as soon as it is reasonably practicable following such action. Any 

person who is denied an initial gaming employee license or who is banned from the 

gaming facilities by action of the Commission may request a hearing before the 

Commission by written request submitted within thirty days following receipt of notice 

of the action of the Commission, and the Commission shall thereupon afford an 

opportunity to appear and be heard before the Commission, either in person or through 

a representative or legal counsel, and to submit such evidence as the Commission 

deems relevant to the matter at issue and thereafter the Commission shall either affirm 

or reconsider its decision. Any hearing conducted under this sub-section may at the 

direction of the Commission be conducted by the Executive Director or by one or more 

members of the Commission designated by the Commission for that purpose.

g. The Commission may adopt such additional procedures and rules as it deems necessary 

or convenient to govern its affairs and which are consistent with this Ordinance and the 

Compact.

SECTION 404 ISSUANCE OF REGULATIONS

1) The Tribal Gaming Commission shall from time to time promulgate and issue regulations 

governing any aspect of its responsibilities under this Ordinance, which, so long as they are

in furtherance of and not in conflict with any provision of this Ordinance, shall have the 

force of law. Without limitation, the matters to be addressed by such regulations may 

include the following:

a. The time and manner for applying for a Gaming Facility License under this Ordinance, 

and the specific information to be provided in connection with such application, 

including information necessary for adequate assessment of the applicant's background, 

and the manner in which such applications will be processed;
16

b. The procedure by which applicants for Tribal Gaming Licenses under this Ordinance 

shall apply for such licenses, including the information to be provided by the applicant 

necessary for adequate assessment of the applicant's background, and the manner in 

which such applications will be processed; and

c. The specific types of accounting, security, accessibility to non-public areas, 

recordkeeping and reporting measures required by this Ordinance, the Compact or the 

Act to be in place and functioning at any Gaming Facility licensed under this 

Ordinance.

2) Except in emergency situations addressed in Section 404 (3) below, prior to promulgating a 

final regulation the Gaming Office shall publish the regulation in proposed form. The 

proposed regulation shall be provided directly to the Chairperson of the Tribe, and the 

General Counsel for the Tribe, the Gaming Facility Operator and to any other interested 

Person or interested office or agency of the Tribe. The proposed regulation shall be 

accompanied by a notice stating that the Gaming Office will accept written comments on 

the proposed regulations for a set period of time, which shall be no less than thirty (30) 

days following the date the Gaming Office publishes the proposed regulations. As used in 

this section, the term "publish" shall mean publication in newspaper(s) of general 

circulation within the Tribe and posting in the Tribal Headquarters. In the event of 

significant public interest with respect to any regulation, the Gaming Office may hold one 

or more public hearings prior to issuing a final regulation. The Gaming Office shall give 

notice of any hearing in the manner set forth above, and also shall mail a notice directly to 

any person submitting comments on the proposed regulations. Except as provided in 

Section 404 (3) of this section, the Gaming Office shall not issue a final regulation until it 

has reviewed all comments received by the close of the comment period, as well as all 

presentations made at any hearing held pursuant to this subsection.

3) In the event the Gaming Office determines that an immediate rule-making is necessary to 

avoid serious jeopardy to the integrity of any Gaming Activities within the Tribe, or 

otherwise to deal with an emergency situation affecting the responsibility of the Gaming 

Office, the Gaming Office may, upon making an express written finding as to such 

emergency, issue a final regulation to take effect immediately; provided, that the Gaming 

Office shall publish notice and request comments on such regulation in the same manner as 

is provided above, and upon consideration of any comments received, shall make such 

amendments to such final regulation as the Gaming Office deems appropriate.
17

4) All final regulations adopted by the Gaming Office shall be officially filed with the 

Secretary of the Tribal Council, and the Office of the Chairperson.

5) Any regulation modified in accordance with Section 1305 (4) are exempt from the 

provisions of subsections (2) and (3) of this Section.

SECTION 405 PETITION FOR SELF-REGULATION

As soon as the Gaming Office determines that the Tribe is eligible therefore, the Gaming Office 

shall submit to the Commission an application for a Certificate of Self-Regulation, under the 

provisions of 25 U.S.C. § 2710 (c) (4). The Gaming Office shall do everything necessary and 

appropriate to obtain such Certificate and to maintain the Certificate in good standing.

CHAPTER 5 GAMING FACILITY OPERATOR'S LICENSE

SECTION 501 REQUIREMENT OF LICENSE

Before the Cocopah Tribe designated as the Gaming Facility Operator may conduct Gaming 

Activities, it shall first obtain a Gaming Facility Operator's License from the Gaming Office and 

annually thereafter. The licensing of the Gaming Facility Operator shall include the licensing of 

each Principal, Primary Management Official and Key Employee. A separate license is required 

for each place, facility, or location where the Cocopah Indian Tribe allows class II or class III 

gaming.

CHAPTER 6 GAMING MANAGER'S LICENSE

SECTION 601 REQUIREMENT OF LICENSE

No Person shall function as the General Manager of the Gaming Facility Operator without first 

obtaining a Gaming Manager's License from the Gaming Office. In the case of a Person other than 

an individual, each Principal of such entity must obtain a Gaming Manager's License from the 

Gaming Office. The authorized Tribal Official shall conduct an investigation sufficient to make an 

eligibility determination and shall not issue a Gaming Manager's License under this Chapter to an 

individual if it determines that the individual:

1) Has been convicted of any felony or gaming offenses;
18

2) Has knowingly and willfully provided materially important false statements or information 

or omitted materially important information on his or her license application; or

3) Is an individual whose prior activities, criminal record, if any, or reputation, habits, and 

associations pose a threat to the public interest or the effective regulation and control of 

gaming, or create or enhance the dangers of unsuitable, unfair, or illegal practices, methods, 

and activities in the conduct of gaming or the carrying on of the business and financial 

arrangements incidental thereto.

4) The authorized Tribal Official shall not issue a Gaming Manager's License under this 

Chapter to any corporation, partnership, or other entity.

CHAPTER 7 LICENSES FOR GAMING DEVICE MANUFACTURERS, DISTRIBUTORS,

SUPPLIERS OF GAMING SERVICES, AND FINANCERS

SECTION 701 REQUIREMENT OF LICENSE

The Gaming Office shall license each Manufacturer and each Distributor of Gaming Devices 

before selling or leasing any Gaming Devices to the Gaming Facility Operator. Each supplier of 

Gaming Services shall be licensed by the Gaming Office before providing Gaming Services to the 

Gaming Facility Operator. In addition, any Person extending or guarantying financing for a 

Gaming Operation or Gaming Facility shall be licensed by the Gaming Office, unless the Person is 

an agency of the United Stated or a lending institution licensed and regulated by the State or the 

United States.

SECTION 702 STANDARD OF SUITABILITY

1) Individuals. The Gaming Office shall not issue a license under this Chapter to an individual 

if it determines that the individual:

a. Has been convicted of any felony or gaming offense;

b. Has knowingly and willfully provided materially important false statements or 

information or omitted materially important information on his or her license 

application; or

c. Is an individual whose prior activities, criminal record, if any, or reputation, habits, and 

associations pose a threat to the public interest or the effective regulation and control of 

gaming, or create or enhance the dangers of unsuitable, unfair, or illegal practices, 
19

methods, and activities in the conduct of gaming or the carrying on of the business and 

financial arrangements incidental thereto.

2) Corporations, Partnership, and Other Entities.

a. The Gaming Office shall not issue a license under this Chapter to any corporation, 

partnership, or other entity unless the Gaming Office is satisfied that the entity:

(i) Is organized and in good standing under the laws of the jurisdiction 

where it was established, and is qualified to do business within the Tribe 

and the State of Arizona;

(ii) Is in sound financial condition, as shown (at a maximum) by a financial 

statement certified by the entity's chief executive officer (or equivalent) 

to be a fair presentation in all material respects of the financial position 

and results of operations of the entity;

(iii) Has established a reputation for financial integrity and sound business 

practices, or, if the entity was recently formed, that all Persons having a 

role in its formation, including its Principals, are qualified to be licensed 

individually under the terms of this Chapter; and

(iv) Is in all other respects reliable and trustworthy, and whose involvement 

in Gaming Activities within the Tribe will be in the best interest of the 

Tribe as set forth in this Ordinance.

b. The Gaming Office shall not issue a license under this Chapter to any corporation, 

partnership, or other entity unless the entity agrees to give the Gaming Office notice 

within ten days of any change in its Principal, of any change in the location of its 

office(s), and of any material change in the information disclosed in its application 

for its license.

CHAPTER 8 GAMING EMPLOYEE'S LICENSE

SECTION 801 REQUIREMENT OF LICENSE

Every Gaming Employee of the Gaming Facility Operator shall be licensed by the Gaming Office 

before commencing employment. For purposes of this Chapter, the Gaming Facility Operator may 
20

compensate a potential employee for attending basic training and orientation sessions conducted 

outside of a Gaming Facility without that individual being considered to have commenced 

employment.

SECTION 802 STANDARDS OF SUITABILITY AND ELIGIBILITY DETERMINATION

The authorized Tribal Official shall conduct an investigation sufficient to make an eligibility 

determination and shall not issue a Gaming Employee License under this Chapter to a Primary 

Management Official or a Key Employee if it determines that the individual:

1) Has ever been convicted of any gaming offense;

2) Has been convicted of a felony in the seven (7) years prior to submission of the Application 

unless that felony has been set-aside. 

3) Has ever been convicted of a felony relating to extortion, burglary, larceny, bribery, 

embezzlement, robbery, racketeering, money laundering, forgery, fraud, murder, voluntary 

manslaughter, sex offenses, rape or kidnapping. 

4) Has knowingly and willfully provided materially important false statements or information 

or omitted materially important information on his or her license or employment 

application; or

5) An individual whose prior activities, criminal record, if any, or reputation, habits, and 

associations pose a threat to the public interest or to the effective regulation and control of 

gaming, or create or enhance the dangers of unsuitable, unfair, or illegal practices, methods, 

and activities in the conduct of gaming or the carrying on of the business and financial 

arrangements incidental thereto.

CHAPTER 9 LICENSE APPLICATION PROCEDURE

SECTION 901 APPLICATION REQUIREMENTS; PROCESSING

1) Each applicant for a license under Chapters 5, 6, 7, and 8 of this Ordinance shall submit an 

application to the Gaming Office on the appropriate form prescribed by the Gaming Office 

accompanied by the required fee and such supporting information as the Gaming Office 

may require.
21

a. The following notice shall be placed on the Tribe’s license application form for a key 

employee or a primary management official before it is filled out by an applicant:

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 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 gaming operation. Failure 

to consent to the disclosures indicated in this notice will result in a tribe being 

unable to license you for a primary management official or key employee position.

b. The following additional notice shall be placed on the application form for a key 

employee or a primary management official before it is filled out by an applicant:

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. The Tribe shall perform the background investigation for each Primary Management 

Official and Key Employee of the Gaming Operation. The Tribe shall request 

fingerprints for each Primary Management Official and Key Employee. Fingerprints 

shall be obtained by the Tribal Regulatory Authority and forwarded to the Arizona State 

Gaming Agency for processing. A Suitability Letter shall then be forwarded to NIGC. 

The Gaming Office shall request from Primary Management Officials and Key

Employees all of the following information:

(i) Full name, including any aliases (oral or written) by which applicant has 

ever been known;

(ii) Social security number; the disclosure of your Social Security Number 

(SSN) is voluntary. However, failure to supply a SSN may result in 

errors in processing your application. [25C.F.R. § 556.2 (a)].
22

(iii) Date and place of birth, gender, current citizenship, and all languages 

spoken or written;

(iv) Currently and for the five previous years: business and employment 

positions held, affiliations or relationships with any business or ventures 

including positions as officers or directors, ownership interests in any 

business or venture, business and residence addresses, and drivers 

license numbers;

(v) The names and current addresses of at least three personal references, 

including one personal reference who was acquainted with the applicant 

while he/she resided at each address listed on the application;

(vi) Educational history;

(vii) Current business and residence telephone numbers, and all cellular 

telephone numbers;

(viii) A description of any existing and previous business relationships with 

Indian Tribes, including ownership interests in those businesses;

(ix) A description of any existing and previous business relationships with 

the gaming industry generally, including ownership interests in those 

businesses;

(x) The name and address of any licensing or regulatory agency with which 

the individual has filed an application for a license or permit related to 

gaming, whether or not such license or permit was granted;

(xi) The name and address of any licensing or regulatory agency with which 

the individual has filed an application for an occupational license or 

permit, whether or not such license or permit was granted;

(xii) For each felony for which there is an ongoing prosecution or a 

conviction, the charge, the name and address of the court involved, and 

the date of disposition, if any;

(xiii) For each misdemeanor conviction or ongoing misdemeanor prosecution 

(excluding minor traffic violations) within ten (10) years of the date of 

the application, the name and address of the court involved and date of 

disposition, if any;
23

(xiv) For criminal charge (excluding minor traffic charges), whether or not 

there is a conviction, if such criminal charge is within ten (10) years of 

the date of the application, and is not otherwise listed pursuant to

paragraphs (xii) (xiii) of this section, the criminal charge, the name and 

address of the court involved, and the date of disposition, if any;

(xv) The name and address of the licensing or regulatory agency with which 

the person has filed an application for an occupational license or permit, 

whether or not such license or permit was granted;

(xvi) A current photograph; and 

d. In addition to any other information the Gaming Office may deem pertinent, the 

Gaming Office may require a corporation, partnership, or other entity applying for a 

license to provide the following information with an application for a license:

(i) The name, address, and other additional pertinent background 

information on each of its Principals;

(ii) The name, address, and other additional pertinent background 

information on each of its related, associated, or affiliated Persons;

(iii) A description of any previous experience that the entity and each 

Principal has had with other Indian tribes involving gaming (including 

under any management contracts) or with the gaming industry generally, 

including specifically the name and address of any licensing or 

regulatory agency with which such individual has had contact relating to 

gaming; and

(iv) A complete financial statement of each Principal.

2) The Gaming Office and its staff may assist any applicant in assembling all information 

required for processing of the application, but shall not be required to process any 

application until it is complete. The Gaming Office may, at any time after an application is 

submitted, make a written request that an applicant supply any additional information the 

Gaming Office deems necessary to complete the processing of the application and the 

applicant shall comply with such a request forthwith.

3) The application forms used by the Gaming Office shall contain the notice required under 

the Privacy Act and the notice regarding false statements in the form required by the 

Commission under 25 C.F.R. Part 556, and each applicant shall consent in writing to the 

release of any information that may be relevant to the Gaming Office's inquiry into the 
24

applicant's background from any Person. The Gaming Office shall keep confidential any 

and all information it obtains in the course of investigating an application (including the 

identity of all individuals interviewed in the course of the investigation) and shall comply 

with all applicable laws pertaining to the confidentiality of such information. The Gaming 

Office shall not release such information to any other individual or agency (other than to 

appropriate Federal, Tribal, State, local, or foreign law enforcement and regulatory 

agencies when relevant to civil, criminal or regulatory investigations or prosecution or 

when pursuant to a request by a tribe or the Commission in connection with the hiring or 

firing of an employee, the issuance or revocation of a gaming license, or investigations of 

activities while associated with a tribe or gaming operation) without the applicant's consent, 

or pursuant to an order of court or other body of competent jurisdiction.

4) The Gaming Office shall issue a written decision on each application. The written decision 

of the Gaming Office shall constitute final action of the Gaming Office on such application. 

If the Gaming Office denies an application for a license, the decision shall specify the 

reason for such denial.

5) When a Primary Management Official or Key Employee is employed by the Tribe, a 

complete application file, containing all of the information listed in Section 901 (c), shall be 

maintained.

SECTION 902 FEES

The Gaming Office shall collect the following fees in connection with the processing of 

applications and the issuance of Tribal Gaming Licenses and/or State Certifications:

1) Gaming Facility Operator’s Tribal Gaming License:

a. There shall be no fee required.

2) General Manager, Assistant General Manager and Finance Director:

a. Initial State Certification/Recommendation $500

(Plus, Current Tribal Gaming Fees and adjustments in Arizona State fees.)

b. Renewal of State Certification $250

(Plus, Current Tribal Gaming Fees and adjustment in Arizona State fees.
25

3) Gaming Employee's State Certification:

a. Initial State Certification/Recommendation $250

(Plus, Current Tribal Gaming Fees and adjustment in Arizona State fees.)

b. Renewal of State Certification $125

(Plus, Current Tribal Gaming Fees and adjustment in Arizona State fees.)

4) Employees who are not required to have a State Certification (Compact Section 4.b):

a. Initial Tribal Gaming License $56 

(Plus, Current Tribal Gaming Fees and adjustment in Arizona State fees)

b. Renewal of Tribal Gaming License $56

(Plus, Current Tribal Gaming Fees and adjustment in Arizona State fees)

The following positions (but not limited to) are required to have a Tribal Gaming License

but not a State Certification as defined in the Compact, Section 4.b. 

Building Maintenance Lead Host/Hostess Lead Sous Chef

Building Maintenance Host/Hostess Lead Line Cook

Janitorial Maintenance Lead Waiter/Waitress Line Cook

Janitorial Maintenance Bartender Prep Cook

Groundskeeper Lead Cocktail Server Hotel Personnel

Groundskeeper Dishwasher Gift Shop Cashier

5) Manufacturers and Distributors of Gaming Devices, Gaming Vendors, and providers of 

Ancillary Services. Each Manufacturer and Distributor of Gaming Devices, each Gaming 

Vendor, and each provider of Ancillary Services within or without the Gaming Facility, 

may be required to be licensed at the discretion of the Tribal Gaming Office. 

a. Each Manufacturer and Distributor of Gaming Devices and each Gaming Vendor 

providing goods or services in excess of $10,000 to the Tribe in any single month, 

shall be certified by the Arizona State Gaming agency prior to the sale, lease or 

providing of any goods or services. The form of Application of certification shall be 

determined by the Arizona State Gaming Agency. 
26

b. Each Gaming Vendor providing goods or services between $1,000 and $10,000 to 

the Tribe in any single month, and each provider of Ancillary Services in an amount 

in excess of $2,500 to the Tribe in any single month, shall be certified by the 

Cocopah Tribal Gaming Office and Arizona State Gaming Agency using a Short 

Form Application. A Short Form Application shall be submitted by such providers 

to Cocopah Tribal Gaming Office and the Arizona State Gaming Agency no later 

than one (1) business day after providing any goods or services. 

c. Without the need to amend this Ordinance the $1,000, $2,500 and $10,000 threshold 

amounts applicable to Gaming vendors and providers of ancillary Services, as set 

forth in the Arizona/Cocopah Compact Sections 4 and 5, shall be automatically 

increased by 10% on each five-year anniversary of the Effective Date of the 

Compact. 

d. Gaming fee for ancillary services 

e. Initial Application fee (2 year) $100

f. Renewal fee $50

Each Gaming Vendor providing goods or services between $1,000 and $10,000 to the Tribe 

in any single month

a. Initial Application fee (2 year) $250

b. Renewal fee $150

a. Initial application for a Tribal License fee (2 year):

(i) Manufacturer/Distributor of Gaming Devices $2,000

(ii) Supplier of Gaming Services in excess of $10,000 to the Tribe in any 

single month not to exceed: $2,000

b. Renewal fee:

(i) Manufacturer/Distributor of Gaming Devices $1,500

(ii) Supplier of Gaming Services, excess of $10,000 to the Tribe in any 

single month not to exceed: $1,000

6) Other Fees. The Gaming Office may by regulation modify the schedule of fees in this 

Section or prescribe such other fees as it deems appropriate.
27

SECTION 903 LICENSE TERMS; RENEWAL

1) Each Gaming Employee's License issued by the Gaming Office shall have a primary term 

of (2) years and may be renewed for subsequent two-year periods upon the timely 

submission of a completed application on the forms specified by the Gaming Office. Each 

license issued by the Gaming Office for Management Contractors, Financiers, 

Manufacturers and Distributors of Gaming Devices, and Persons providing Gaming 

Services, shall be effective for two (2) years from the date of issuance and may be renewed 

for subsequent two-year periods upon the timely submission of a completed application on 

the forms specified by the Gaming Office. No licensee shall have any vested right to 

renewal of any license issued under this Ordinance.

2) The Gaming Office shall issue a temporary license to an applicant within 20 days after 

receiving a completed application for licensing under Chapters 5, 6, 7, or 8 of this 

Ordinance, unless;

a. Grounds sufficient to disqualify the applicant are apparent on the face of the 

application,

b. The background investigation undertaken by the Gaming Office discloses that the 

applicant may have a criminal history sufficient to disqualify the applicant from holding 

a license, or

c. The background investigation undertaken by the Gaming Office discloses other 

information that may be sufficient to disqualify the applicant from holding a license. A 

temporary license shall become void and shall be of no effect upon either the issuance 

of a license or upon the issuance of a notice of denial of the license in accordance with 

the provisions of this Ordinance.

SECTION 904 STATE CERTIFICATION

Every Person required to be licensed under this Ordinance also shall comply with the state 

certification requirements of the Compact, if those requirements are applicable to the Person. 

Within the time requirements established by the Compact, the Gaming Office shall forward to the 

Arizona Department of Gaming a report of final disposition of the licensing actions of the Gaming 

Office. The Gaming Office shall afford the Arizona Department of Gaming an opportunity for a 

hearing before an appropriate forum of the Tribe, pursuant to Sections 5(q) and 5(q)(3) of the 

Compact, to contest a licensing decision of the Gaming Office or to recommend suspension or 

revocation of a license issued by the Gaming Office. The Decision of the tribal forum shall be 

final, except as provided in Section 5(q) (4) of the Compact.
28

CHAPTER 10 BACKGROUND INVESTIGATIONS; NOTIFICATIONS

SECTION 1001 BACKGROUND INVESTIGATIONS

1) The Gaming Office shall at all times have in place, and shall regularly update and improve, 

a system for conducting background investigations of every applicant for licensing under 

this Ordinance. The system shall comply with the requirements of this Ordinance, the 

Compact and the Act, and shall include, at a minimum, the use of records of all available 

tribal, state, and federal law enforcement agencies, resources of the Commission, 

communications with other Indian tribes engaged in gaming activities, and any and all other 

sources of information reasonably accessible to the Gaming Office for this purpose. The 

system shall ensure that all applicants are notified of their rights under the Privacy Act as

specified in 25 C.F.R. Part 556.

2) Every applicant for licensing under this Ordinance shall be subjected to a thorough 

background investigation, and such investigations shall be updated upon application for 

renewal of a license, and at such other times as the Gaming Office may determine 

appropriate.

3) The investigation shall be sufficient to allow the Tribal Gaming Regulatory Authority to 

make an eligibility determination. The Investigator shall:

a. Verify the applicant’s identity through items such as a social security card, driver’s 

license, birth certificate or passport;

b. Contact each personal and business reference provided in the license application, when 

possible;

c. Conduct a civil history check for past or outstanding judgments, current liens, past or 

pending lawsuits, and any other information deemed to be relevant;

d. Conduct a criminal history records check by submitting the applicant’s fingerprints to 

the Arizona Department of Gaming for forwarding to the FBI to perform a criminal 

history records check utilizing the FBI’s database;

e. Based on the results of the criminal history records check, as well as information 

acquired from an applicant’s self-reporting or from any other source, obtain information 

from the appropriate court regarding any past felony and/or misdemeanor convictions 

or ongoing prosecutions within the past ten (10) years;
29

f. Inquire into any previous or existing business relationships with the gaming industry, 

including with any tribes with gaming operations, by contacting the entities or tribes;

g. Verify the applicant’s history and current status with any licensing agency by 

contacting the agency; and

h. Take other appropriate steps to verify the accuracy of the information, focusing on any 

problem areas noted.

4) The Gaming Office shall prepare and maintain a background investigation report on every 

applicant for licensing under this Ordinance which shall include all of the following:

a. Steps taken in conducting a background investigation;

b. Results obtained;

c. Conclusions reached; and

d. The basis for those conclusions.

5) If the Gaming Facility Operator pays the initial application fees required by Section 902 (3)

of this Ordinance and the initial application fees required by Section 5(1) of the Compact 

for each Gaming Employee hired by the Gaming Facility Operator and if an individual 

applicant for a Gaming Employee license or certification fails to report to work for the 

Gaming Facility Operator or leaves the employment of the Gaming Facility Operator within 

one year of initial hire, the Gaming Facility Operator may recover from the applicant the 

fees it paid for the applicant's initial licensing and certification, by setting off any sums it 

owes to the applicant against the fees paid, by bringing suit in the Cocopah Indian Tribe 

Judicial Court to recover the fees, or by any other lawful manner. If an individual applies 

for a Gaming Employee license or certification more than once, whether because the 

individual did not complete the application process, because the individual failed to renew a 

license or certification, or otherwise, the Gaming Facility Operator may require the 

individual applicant to pay the license and certification fees incurred for the subsequent 

applications. 

6) The Gaming Facility Operator shall pay any required renewal fees for licensing and 

certifications for each Gaming employee who remains and meets required standards of 

performance in the employment of the Gaming Facility Operator as set forth in the Gaming 

Operations General Policy and Procedures Manual.
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a. The Gaming Office shall maintain files containing the employee’s application for 

licensing, investigative reports, eligibility determination, and results of any 

background investigations conducted by it for the longer of; 

b. Three years from the date of a Gaming Employee's termination of employment, 

with respect to the files for a Gaming Employee, or

c. The term of record retention required by the Compact. Such files shall contain 

systems designed to safeguard the identities of confidential informants from 

inadvertent disclosure.

d. The Gaming Office, and its investigators, shall keep confidential the identity of 

each person interviewed in the course of conducting a background investigation. 

SECTION 1002 NOTIFICATION TO THE NATIONAL INDIAN GAMING COMMISSION

1) Prior to issuing a license to Primary Management Officials and Key Employees the Gaming 

Office shall submit a notice of results (Suitability Determination Letter) of the applicant’s 

background investigation to the National Indian Gaming Commission (NIGC) no later than 

sixty (60) days after the applicant begins work, to include.

a. The applicant’s name, date of birth, and Social Security Number;

b. Date on which the applicant began or will begin work as a Primary Management 

Official or Key Employee;

c. A summary of the information presented in the investigative report, including;

i. License(s) that have previously been denied;

ii. Gaming licenses that have been revoked, even if subsequently reinstated;

iii. Every known criminal charge brought against the applicant within the last 

10 years of the date of the application; and

iv. Every felony of which the applicant has been convicted or any ongoing 

prosecution.

d. After the Gaming Office has provided a Suitable Determination Letter of results 

of the background check to NIGC, the Gaming Office may license a Primary 

Management Official or Key Employee. 
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e. Within thirty (30) days after the issuance of the license, the Gaming Office shall 

notify NIGC of its issuance.

f. The Gaming Operation shall not employ a Primary Management Official or Key 

Employee who does not have a license after ninety (90) days.

i. If the Gaming Office does not license an applicant;

ii. The Gaming Office shall notify NIGC; and 

iii. Shall forward copies of its eligibility determination and notice of results to 

NIGC for inclusion in the Indian Gaming Individuals Record System.

SECTION 1003 NATIONAL INDIAN GAMING COMMISSION REVIEW

1) Upon receipt of complete notice of results for a Primary Management Official or Key 

Employee, NIGC has thirty (30) days to request additional information from the Gaming 

Office concerning the applicant or licensee and to object.

2) If NIGC has no objection to issuance of a license, it shall notify the Gaming Office within 

thirty (30) days of receiving notice of results. 

3) If, within that thirty (30) day period, NIGC provides the Gaming Office with a statement 

itemizing objections to the issuance of a license to a Primary Management Official or Key 

Employee applicant for who the Gaming Office has provide a notice of results, the Gaming 

Office shall reconsider the application, taking into account the objections itemized by 

NIGC. 

4) The Gaming Office shall make the final decision whether to issue a license to such 

applicant. 

5) If the Gaming Office has issued the license before receiving NIGC statement of objections, 

a notice of hearing shall be provided to the licensee. 

SECTION 1004 NOTICE OF ELIGIBILITY AND LICENSEE’S RIGHT TO A HEARING

1) If, after the issuance of a gaming license, NIGC receives reliable information indicating 

that a Primary Management Official or Key Employee is not eligible for employment. 

NIGC shall notify the Gaming Office of the information. 

2) Upon receipt of such notification, the Gaming Office shall immediately suspend the license 

and shall provide the licensee with written notice of suspension and proposed revocation. 
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3) The Gaming Office shall notify the licensee of a time and place for a hearing on the 

proposed revocation of their license.

4) A right to a hearing shall vest only upon receipt of a license granted under an ordinance 

approved by NIGC. 

5) After a revocation hearing, the Gaming Office shall decide to revoke or to reinstate their 

gaming license. 

6) The Gaming Office shall notify NIGC of its decision within forty-five (45) days of 

receiving notification from NIGC.

CHAPTER 11 GAMING FACILITY LICENSE

SECTION 1101 REQUIREMENT OF LICENSE

No Gaming Activities shall be conducted in any Gaming Facility unless the Gaming Office first 

has issued a Gaming Facility License for the Gaming Facility under the provisions of this Chapter. 

The Gaming Facility Operator shall not offer any new or different Gaming Activities, as defined by 

regulations to be issued by the Gaming Office, at any facility or location that is already licensed, 

without first obtaining an amended license for such new and different Gaming Activities from the 

Gaming Office.

SECTION 1102 STANDARDS FOR ISSUANCE OF LICENSE

Each Gaming Facility shall be constructed, maintained, and operated in a manner that adequately 

protects the environment and the health and safety of the public. The Gaming Office shall not issue 

a Gaming Facility license for any facility at which Gaming Activities are to be offered unless the 

Gaming Facility meets the following requirements:

1) The physical facility within which the Gaming Activities are to be conducted is designed 

and constructed in compliance with the laws of the Tribe, the requirements of the Compact 

and the requirements of the Act, including but not limited to the Clean Water Act and Clean 

Air Act, so as to ensure the health and safety of all employees and patrons of such 

activities, and the protection of the natural and cultural environment from any 

contamination due to any discharge of any waste including but not limited to any garbage, 

trash, rubbish, waste tire, refuse, sludge from a waste treatment plant, water supply 

treatment plant, pollution control facility, hazardous waste and other discarded material, 
33

including solid, liquid, semisolid, contained gaseous material; or, unreasonable disturbance 

of the land surface;

2) The Gaming Activities to be conducted within the Gaming Facility will lawfully be carried 

on by the Tribe under the Compact and the Act, and the facilities are appropriate to the 

carrying on of such activities;

3) The Gaming Facility Operator will adequately staff and equip the Gaming Facility to 

ensure the safety, comfort and convenience of the patrons thereof, and the Gaming Facility 

Operator has taken adequate measures to provide for traffic, emergency service 

accessibility, food, drink and sanitary needs for patrons and employees, security, law 

enforcement and other concerns raised by the type of Gaming Activities proposed to be 

undertaken in compliance with this Ordinance, the Compact and the Act;

4) In all other relevant respects, the Gaming Facility will be operated in a way that is fully 

consistent with the provisions of the Ordinance, and that its operation will further the 

interests of the Tribe with respect to its operation of Gaming Activities.

SECTION 1103 APPLICATION FOR A NEW, RENEWAL OF OR AMENDED LICENSE; PROCEDURE

1) The Gaming Facility Operator shall obtain a new, renewal of or amended Gaming Facility 

License before commencing operations at a new facility or commencing new activity at a 

licensed facility for which an amended license is required.

2) The Gaming Office shall prescribe the information required to be submitted with such 

applications, but at a minimum, such application for licensing a new facility shall include 

the following:

a. The name, specific position and job description of all individuals to be employed as 

Primary Management Officials or Key Employees at the facility;

b. Job descriptions for every other position in which individuals will be employed at the 

facility;

c. A detailed description of the Gaming Activities to be engaged in at the facility, together 

with expected payouts to winners (i.e. bankroll formula);

d. A description of the internal controls, plan of organization and all coordinate methods 

and measures for the safeguarding of assets, ensuring the accuracy and reliability of its 

accounting data, promoting operational efficiency and encouraging adherence to 

prescribed managerial policies;
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e. Detailed plans for the facility, including landscaping, traffic controls, parking, food and 

drink services, and other physical aspects of the building;

f. A detailed description of how security will be maintained at the facility, identifying the 

Persons, agencies or entities that will provide such security;

g. A detailed description of how gaming proceeds will be accounted for and disposed of 

on a daily basis;

h. A description of provisions for dealing with fire or other potential emergencies at the 

facility;

i. A detailed description of how sewage and other waste products from the facility will be 

handled and disposed of; and

j. Any other information relevant to the proposed operation of the facility or requested by 

the Gaming Office as part of the application.

3) An application for an amended license to conduct new or different Gaming Activities at a 

licensed location or to otherwise alter the terms or conditions of an existing license, shall, at 

a minimum, include the following information:

a. Any change in information previously provided in the original license application or 

any previous application for an amended license for the Gaming Facility;

b. A detailed description of the changes in the Gaming Facility or in the activities to be 

carried on therein for which the amended license is required, together with a statement 

of the reasons for such change;

c. Any other information relevant to the changes or new activities requiring the 

amendment.

4) Each Gaming Facility License issued by the Gaming Office shall be for a term of one year. 

Such license may be renewed for subsequent one-year terms upon proper application on 

forms specified by the Gaming Office.

5) In its decision to license any Gaming Facility, or to amend any existing license to permit 

the conduct of new or different Gaming Activities at a licensed facility, the Gaming Office 

may specify, consistent with the provisions of the Ordinance, terms or conditions it believes 

necessary or appropriate to ensure the health and safety of patrons and employees of any 

such facility, the integrity of the Gaming Activities carried on at such facility, the Gaming 
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Facility Operator’s ability to account for and protect its assets, and the security of gaming 

proceeds.

If dissatisfied with any such condition, the applicant may request that the Gaming Office 

reconsider its determination. Upon such request for reconsideration, the Gaming Office 

shall issue a written decision within 15 days of its receipt of the request for reconsideration. 

The written decision of the Gaming Office shall constitute final action of the Gaming 

Office.

CHAPTER 12 FACILITY INSPECTION; INVESTIGATIONS; NOTICE OF VIOLATION;

JUDICIAL REVIEW

SECTION 1201 FACILITY INSPECTION

The Gaming Office shall, no less than semi-annually and at such other times as required by

applicable law, cause detailed inspections to be made of each Gaming Facility licensed under the 

provisions of this Ordinance, to assure that such facility is being operated in accordance with the 

terms of the license and of the provisions of the Ordinance, the Compact and the Act.

SECTION 1202 INVESTIGATIONS

1) The Gaming Office shall investigate any reported violation of this Ordinance, the Compact 

or the Act. The Gaming Office shall also investigate any reported violation of the 

Compact’s appendices when the Gaming Office determines that an investigation is 

reasonably necessary to ensure the integrity of gaming, the protection of persons and 

property, and compliance with the Compact.

2) The Gaming Office shall make a written record of reported violations in accordance with 

the requirements of Section 6(e) of the Compact. The Gaming Office shall make reports of 

its investigations to the Arizona Department of Gaming in accordance with the 

requirements of Section 6(g) of the Compact.

3) The Gaming Office shall issue a written warning of its preliminary determination of 

violation to any licensee alleged to have committed a violation and to the Gaming Facility 

Operator. The warning shall require the licensee and/or the Gaming Facility Operator, as 

appropriate, to correct the violation upon such terms and conditions as the Gaming Office 

determines are necessary and proper under the provisions of this Ordinance.
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4) If a licensee fails to correct a violation within the time set forth in a warning issued under 

Section 1202 (3), the licensee shall file, and the Gaming Facility Operator may file, with 

the Gaming Office a written response to the warning within 7 days of receiving the 

warning. Following receipt of the responses, the Gaming Office shall complete its 

investigation into the alleged violation. The Executive Director shall issue a notice of 

violation if the Gaming Office determines that a licensee violated or is violating the 

Ordinance, the Compact or the Act and has failed to correct the violation within the time set

forth in a warning issued under Section 1202 (3). The Executive Director also may issue a 

notice of violation if the Gaming Office determines that a Person other than a licensee 

violated or is violating the Ordinance, the Compact or the Act.

SECTION 1203 NOTICE OF VIOLATION

1) The Gaming Office shall deliver the notice of violation to the Person the Gaming Office is 

charging with a violation of this Ordinance, the Compact or the Act.

The Gaming Office shall also deliver a copy of each notice of violation relating to a 

Gaming Facility (including any violation alleged to have been committed by an 

employee, vendor, or patron) to the Gaming Facility Operator, with any redactions 

necessary to avoid disclosure to any information which the Gaming Office is obligated to 

keep confidential under any applicable privacy laws, including Section 901(3) of this 

Ordinance.

2) A notice of violation shall contain:

a. A citation to the Ordinance, regulation, Compact provision, minimum internal control 

standard, or federal law that has been or is being violated;

b. A description of the circumstances surrounding the violation, set forth in common and 

concise language;

c. Notice of any action that the Gaming Office proposes must be taken to correct the 

violation, if the Gaming Office determines that the violation is capable of being 

corrected;

d. Notice of the time frame within which any action to correct the violation must be taken, 

unless the Gaming Office determines that the violation is incapable of being corrected;

e. Notice of any civil fine or other enforcement action that the Gaming Office proposes to 

impose;
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f. Notice that a written response to the notice of violation must be submitted to, and 

received by, the Gaming Office within 15 days of the receipt of the notice of violation; 

and

g. Notice that, if no written response to the notice of violation is submitted to the Gaming 

Office within the time prescribed in Section 1203(2) (f), the Gaming Office may issue 

its final decision regarding the violation alleged in the notice and impose a civil fine or 

take the enforcement action set forth in the notice without hearing from the Person to 

whom the notice was issued or from the Gaming Facility Operator.

3) The Person(s) to whom a notice of violation is issued and the Gaming Facility Operator 

each may submit a written response to the Gaming Office together with any additional 

written information the Gaming Office should consider. A Person desiring to submit a 

written response and any supporting documentation must do so within 15 days after 

receiving notice of the alleged violation. The Gaming Office shall issue a written decision 

with 15 days after receiving all written responses or, if no party submits a written response 

in a timely manner, with 15 days after the deadline for the submission of written responses. 

The written decision shall constitute final action of the Gaming Office with respect to any 

notice of violation. Except as provided in Section 1203(2)(g), the Gaming Office shall take 

no action to enforce a notice of violation until it issues its written decision.

4) Notwithstanding the requirements of Section 1202(3), if the Gaming Office determines that 

the Ordinance, the Compact, or the Act have been violated and the continued licensing of, 

or conduct by, a Person constitutes an immediate and substantial threat to: the public health, 

safety or welfare; the integrity of Gaming Activities; the integrity of the Gaming Facility 

Operator; the Gaming Facility Operator’s ability to account for and protect its assets; or to 

the security of gaming proceeds, the Gaming Office may:

a. Summarily suspend any license issued under this Ordinance;

b. Summarily eject any Person who has violated the Ordinance, the Compact, or the Act 

from a Gaming Facility or the surrounding premises controlled by the Gaming Facility 

Operator, using such force as may be reasonably necessary under the circumstances;

c. Summarily seize the proceeds of any Gaming Activities not conducted by the Gaming 

Facility Operator;

d. Summarily seize, remove, or impound any equipment, supplies, business records, books 

of account, or any and all other financial records or documents pertaining to the 

business operations of a Gaming Facility (regardless of where those records or 

documents may be located). If the Gaming Office seizes, removes, or impounds any 
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business records, books of account, or other financial records or documents of the 

Gaming Facility Operator, it shall provide the Gaming Facility Operator with a copy of 

any such items upon receiving a written request for copies from the Gaming Facility 

Operator; or

e. Upon consultation with the Tribe’s General Counsel, initiate in the Cocopah Tribal 

Court a civil action or criminal complaint to enforce the Ordinance, the Compact, or the 

Act, which action may include a request for an order permitting the Gaming Office to 

seize a Gaming Facility or to seize the proceeds from Gaming Activities.

5) After the Gaming Office renders a decision in accordance with Section 1203(3), if the 

Gaming Office has determined that the Ordinance, the Compact, or the Act have been 

violated, it may take one or more of the following actions, as may be appropriate under the 

circumstances:

a. Require remedial action to correct the violation and/or prevent future violations;

b. Suspend or revoke the license of the Person to whom the notice of violation was 

directed;

c. Assess a civil penalty in accordance with the provisions of this Ordinance; or

d. Upon consultation with the Tribe’s General Counsel, initiate in the Cocopah Tribal 

Court a civil action or criminal complaint to enforce the Ordinance, the Compact, or the 

Act, which action may include a request for an order permitting the Gaming Office to 

seize a Gaming Facility or to seize the proceeds from Gaming Activities.

SECTION 1204 JUDICIAL REVIEW

1) Any person who has been issued a notice of violation by the Executive Director of the 

Gaming Office and who has submitted a written response to the Gaming Office in 

compliance with the provisions of Section 1203(3) of this Chapter may apply to the 

Cocopah Tribal Court for review of the Gaming Office’s written decision regarding the 

alleged violation. If the Gaming Facility Operator submits a written response to the 

Gaming Office in compliance with the provisions of Section 1203(3), it also may apply to 

the Cocopah Tribal Court review of the Gaming Office’s written decision regarding the 

alleged violation.
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2) Any applicant for a license under this Ordinance, any Person licensed pursuant to this 

Ordinance, and any patron of a Gaming Operation aggrieved by a final action of the 

Gaming Office may apply to the Cocopah Tribal Court for review of the final action of the 

Gaming Office.

3) Any Person desiring to appeal a final decision of the Gaming Office must file an 

application for judicial review within 60 days after receiving notice from the Gaming 

Office of its final decision.

4) A Person aggrieved by a summary action taken by the Gaming Office under Section 

1203(4) may seek an interlocutory review of the Gaming Office’s action by filing an 

application for judicial review. The application for judicial review must be filed within 15

days after receiving notice of the Gaming Office’s action.

5) The reviewing court shall decide all relevant questions of law presented, interpret 

constitutional and statutory provisions, and determine the basis for the action of the Gaming 

Office. The reviewing court shall uphold the action of the Gaming Office unless the court 

determines that the Gaming Office’s action was:

a. Arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law;

b. Contrary to constitutional right, power, privilege, or immunity;

c. In excess of statutory jurisdiction, authority, or limitations, or in violation of statutory 

right;

d. Without observance of procedure required by law; or

e. Unsupported by substantial evidence.

CHAPTER 13 GAMING OPERATIONS

SECTION 1301 SCOPE OF PERMISSIBLE GAMING

The Gaming Facility Operator may conduct only those Gaming Activities that may lawfully be 

carried on by the Tribe under applicable provisions of federal law including, but not limited to, the 

Act, subject to any limitations that may be imposed by the Compact and this Ordinance.
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SECTION 1302 HOURS, DAYS AND OTHER STANDARDS

Consistent with the provisions of the Compact, the Gaming Office may by regulation establish the 

permissible hours and days of operation of Gaming Activities. The regulations may authorize the 

Gaming Facility Operator to operate Gaming Facilities and conduct Gaming Activities twenty-four 

hours a day, seven days a week. The Gaming Office also may, by regulation, establish other 

standards of operation for such Gaming Facilities, as the Gaming Office deems appropriate.

SECTION 1303 EMPLOYEE AND PLAYER AGE LIMIT

Effective June 1, 2003, individuals under 21 years of age shall not play or place any wager, directly 

or indirectly, in any Gaming Activities. The Gaming Facility Operator shall take reasonable steps 

to prevent underage individuals from playing or placing wagers in Gaming Activities. Neither the 

Gaming Office nor the Gaming Facility Operator shall employ individuals under 18 years of age. 

The Gaming Facility Operator shall not permit any individuals under 18 years of age to serve 

alcoholic beverages at any Gaming Facility. The Gaming Office may by regulation establish 

measures by which the Gaming Facility Operator shall enforce the provisions of this section.

SECTION 1304 MANAGEMENT; SECURITY

1) The Gaming Facility Operator shall have the responsibility for the on-site operation, 

management and security of each Gaming Facility, and shall comply with all requirements 

of this Ordinance, the Compact and the Act. The Gaming Facility Operator shall adopt 

reasonable procedures, consistent with this Ordinance, the Compact and the Act, designed 

to provide for the following: the physical safety of its employees; the physical safety of 

patrons in each Gaming Facility; the physical safeguarding of, and accountability for, assets 

transported to and from each Gaming Facility and each cashier’s cage department; and the 

protection of the patrons’ and the Gaming Facility Operator’s property from illegal activity. 

The Gaming Facility Operator shall adopt reasonable procedures, consistent with Section 

3(v) (2) of the Compact, to advise individuals who inquire about the self-exclusion 

procedures established by the State. The Gaming Facility Operator shall, consistent with 

Section 3(v)(2) of the Compact: remove all self-excluded persons from all mailing lists and 

revoke any slot or player’s cards; take reasonable steps to ensure that cage personnel check 

a person’s identification against the Arizona Department of Gaming list of self-excluded 

persons before allowing the person to cash a check or complete a credit card cash advance 

transaction; take reasonable steps to identify self-excluded persons who may be in a 

Gaming Facility and, once identified, promptly escort the self-excluded person from the 
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Gaming Facility; and not pay any hand-paid jackpot to a person who is on the Tribal or 

State self-exclusion list. Any jackpot won by a person on the self-exclusion list shall be 

donated by the Gaming Facility Operator to an Arizona-based non-profit charitable 

organization.

2) The Gaming Facility Operator and/or Gaming Office may temporarily or permanently ban 

individuals from the Tribe’s Gaming Facilities and the surrounding premises controlled by 

the Gaming Facility Operator for such reasons, as the Gaming Facility Operator shall 

determine appropriate. The Gaming Facility Operator may detain individuals briefly for 

purposes of obtaining identification from the individuals in connection with the issuance of 

a banning notice and may detain individuals who may be involved in illegal activities, for 

purposes of notifying and summoning appropriate law enforcement authorities. If the 

Gaming Facility Operator requests that an individual leave a Gaming Facility or the 

surrounding premises for any reason and the individual refuses to do so, the Gaming 

Facility Operator may eject the individual using such force as may be necessary under the 

circumstances or request the Cocopah Tribal Police Department to remove the individual.

3) The Gaming Facility Operator shall pay to the Arizona Department of Gaming the Tribe’s 

regulatory costs and tribal contributions required under Section 12 of the Compact, in 

accordance with the directions of the Tribal Council.

4) The Gaming Facility Operator shall designate an agent for service of any official 

determination, order or notice of the Commission.

SECTION 1305 INTERNAL CONTROLS

1) The Gaming Office shall by regulation establish minimum standards of internal control 

applicable to the Gaming Facility Operator and the Gaming Facilities that provide a level of 

control that equal or exceed the standards required by the Act and the Compact to provide 

reasonable assurance that the following objectives will be maintained:

a. Assets are safeguarded and accountability over assets is maintained;

b. Liabilities are properly recorded and contingent liabilities are properly disclosed;

c. Financial records including records relating to revenues, expenses, assets, liabilities, 

and equity/fund balances are accurate and reliable;

d. Transactions are performed in accordance with the general or specific authorization of 

the Gaming Facility Operator’s management;
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e. Access to assets is permitted only in accordance with specific authorization of the 

Gaming Facility Operator’s management;

f. Recorded accountability for assets is compared with actual assets at frequent intervals 

and appropriate action is taken with respect to any discrepancies; and

g. Functions, duties and responsibilities are appropriately segregated and performed in 

accordance with sound practices by qualified personnel.

2) The Gaming Facility Operator shall operate each Gaming Facility pursuant to a written 

internal control system in accordance with the requirements of Section 11 of the Compact. 

The Gaming Facility Operator shall adopt policies and procedures and a plan of 

organization to implement the minimum internal control standards established by the 

Gaming Office. The Gaming Office shall ensure that the Gaming Facility Operator’s 

policies and procedures are consistent with the approved minimum internal control 

standards prior to implementation of the policies and procedures by the Gaming Facility 

Operator. The policies and procedures shall include a detailed system for counting cash 

receipts at least daily, and shall be appropriate to the types of Gaming Activities carried on 

at each Gaming Facility and the physical characteristics of the systems used for collecting 

cash. The plan of organization shall provide appropriate segregation of functional 

responsibilities and shall require sound practices to be followed in the performance of those 

duties by competent and qualified personnel. The plan of organization shall be 

diagrammatic and narrative describing the interrelationship of functions and the division of 

responsibilities upon which the system of internal control relative to gaming operations is 

based.

3) The Gaming Facility Operator shall provide the Gaming Office with copies of its policies 

and procedures and plan of organization and any proposed changes before implementation. 

Within 7 days after submission by the Gaming Facility Operator, the Gaming Office shall 

issue a letter approving the policies and procedures and a plan of organization or any 

approved changes unless the policies and procedures and plan of organization or any 

proposed changes (or any part thereof) are inconsistent with the minimum internal control 

standards. If the policies and procedures and plan of organization or any proposed changes 

(or any part thereof) are inconsistent with minimum internal control standards, the Gaming 

Office shall issue a letter of disapproval, which shall set forth the inconsistencies in detail.

4) The minimum internal control standards may be modified by the Gaming Office in the 

manner set forth in Section 404, or in the manner set forth below. The Gaming Office shall 

inform ADOG in writing of any changes to the Tribe’s minimum internal control standards.
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a. The Gaming Office may propose modifications to the minimum internal control 

standards by providing written notice of the proposed changes to the Gaming Facility 

Operator and the date the Gaming Office proposes to have the changes be effective. 

The Gaming Facility Operator shall submit any comments on the proposed changes to 

the minimum internal control standards to the Gaming Office within 30-days after 

receiving notice of the proposed changes from the Gaming Office. The Gaming Office 

shall not issue a final regulation modifying the minimum internal control standards until 

it has reviewed and considered the Gaming Facility Operator’s comments. The Gaming 

Office’s decision to modify any minimum internal control standards shall constitute 

final action of the Gaming Office.

b. The Gaming Facility Operator may propose changes to the minimum internal control 

standards by providing written notice of the proposed changes to the Gaming Office 

and the date the Gaming Facility Operator proposes to have the changes be effective. 

The Gaming Office shall review the proposed changes within 30 days after receiving 

them from the Gaming Facility Operator and shall notify the Gaming Facility Operator 

in writing whether it approves or does not approve of the proposed changes. If the 

Gaming Office approves the proposed changes, its notice of approval shall set forth the 

date on which the proposed changes will become effective. The Gaming Office’s 

decision to approve or disapprove any proposed changes shall constitute final action of 

the Gaming Office.

5) The Gaming Facility Operator shall provide written notice to the Gaming Office identifying 

all bank accounts maintained by the Gaming Facility Operator by bank and account number 

and identifying by name all individuals with authority to sign on each account. The Gaming 

Facility Operator shall provide written notice to the Gaming Office of any changes to this 

information within 5 business days of any changes.

SECTION 1306 NOTIFICATION

The Gaming Facility Operator shall promptly notify the Gaming Office of any non-compliance 

with the minimum internal control standards, the Ordinance, the Compact or the Act or any other 

matters adversely affecting the integrity of Gaming Activities or the integrity of the Gaming 

Facility Operator. The Gaming Facility Operator shall promptly notify the Gaming Office of any 

employee termination and the reason for the termination.
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SECTION 1307 ANNUAL INDEPENDENT AUDIT

1) The Gaming Facility Operator shall prepare financial statements for its operations in 

accordance with generally accepted accounting principles on a regular basis and shall 

provide the Gaming Office with copies of those financial statements.

2) Within 120 days after the end of each fiscal year, the Gaming Facility Operator shall 

provide the Gaming Office with an audit of its financial statements for the prior year, along 

with any reports or management letter(s) the accountant has prepared. The audit shall be 

conducted by an independent certified public accountant in accordance with generally 

accepted auditing standards. Either the firm or all independent certified public accountants 

engaged to do audits pursuant to this Section shall be licensed by the Arizona State Board 

of Accountancy. The audit shall be prepared at the Gaming Facility Operator’s expense. 

The auditor shall prepare an audit report expressing an unqualified or qualified opinion on 

the financial statements or, if appropriate, disclaim an opinion on the financial statements 

taken as a whole. The examination and audit shall disclose whether the accounts, records, 

internal controls, and accounting procedures of the Gaming Facility Operator are in 

compliance with the Act. The audit shall comply with the requirements of Section 12(g) of 

the Compact; it shall audit and report the Tribe’s Class III Net Win. It shall also include or 

be supplemented with an attestation by the auditor that Class III Net Win is accurately 

reported consistent with the terms of Compact Appendix I.

3) All gaming related contracts that result in purchases of supplies, services, or concessions in 

an amount exceeding $25,000 in any year (except contracts for professional legal or 

accounting services) shall be specifically included within the scope of the audit conducted 

under this section.

4) To facilitate the completion of such audits, the Gaming Facility Operator shall make and 

maintain complete, accurate, and legible records of all transactions pertaining to any 

Gaming Activities and any other revenue producing activities conducted by the Gaming 

Facility Operator at or in conjunction with any Gaming Facility. The Gaming Facility 

Operator shall maintain its financial records in accordance with generally accepted 

accounting principles and shall keep those records in a form suitable for audit under the 

standards of the American Institute of Certified Public Accountants. The Gaming Facility 

Operator shall maintain the records, as well as all original entry transaction records, until 

the later of five years from the date on which they are made or the term of record retention 

required by the Compact. The records shall be maintained at a Gaming Facility or in other 

locations approved by the Gaming Office.
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5) The Gaming Facility Operator shall maintain:

a. Accurate, complete, legible and permanent records of all transactions pertaining to the 

Gaming Operation in a manner suitable for audit under the standards of the American 

Institute of Certified Public Accountants;

b. General accounting records using a double entry system of accounting with transactions 

recorded on a basis consistent with Generally Accepted Accounting Principles;

c. Detailed supporting and subsidiary records;

d. Detailed records identifying revenues, expenses, assets, liabilities and fund balances 

equity for the Gaming Operation;

e. All records required by the internal control system including, but not limited to, those 

relating to any Gaming Activity authorized by this Ordinance;

f. Journal entries for the Gaming Operation;

g. Detailed records sufficient to accurately reflect gross income and expenses relating to 

its operations on a monthly and year-to-date basis;

h. Detailed records of any reviews or audits, whether internal or otherwise, performed in 

addition to the annual audit required in this Section, including, but not limited to, 

management advisory letters, agreed upon procedure reviews, notices of noncompliance and reports on the internal control system; and

i. Records of any proposed or adjusting entries made by an independent certified public 

accountant.

6) The Gaming Facility Operator shall use a uniform chart of accounts and accounting 

classifications to assure consistent and effective disclosure of financial information and 

shall submit to the Gaming Office a copy of any changes to its chart of accounts.

7) The Gaming Office, when it deems necessary, may request additional information 

regarding the Gaming Facility Operator’s financial statements, its audits, or both from the 

Gaming Facility Operator. The Gaming Office also may require the Gaming Facility 

Operator to have its independent accountant provide such information to the Gaming 

Office. If the Gaming Facility Operator receives any written communications from its 

independent accountant regarding internal control matters, the Gaming Facility Operator 

shall provide copies of those communications to the Gaming Office within thirty days after 

receiving the communications.
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8) The Gaming Office shall provide copies of the Gaming Facility Operator’s annual reports 

and management letters setting forth the results of the annual audit to the NIGC within 120 

days after the end of each fiscal year for the Gaming Facility Operator and to the State in 

accordance with the requirements of the Compact. The Gaming Office shall cooperate with 

the NIGC and the State with respect to any additional information the NIGC or the State 

may request.

SECTION 1308 PUBLIC DISCLOSURE OF PAYOFFS

The Gaming Facility Operator shall display at all times in each Gaming Facility a schedule of 

payoff information for all Gaming Activities conducted in the Gaming Facility. The Gaming 

Facility Operator shall post the information in a location accessible to patrons and in a manner 

clearly visible to patrons. The Gaming Facility Operator shall regularly update the posted 

information to reflect any changes in Gaming Activities or in payoffs.

SECTION 1309 PATRON DISPUTES

1) Refusal to Pay Winnings. Whenever the Gaming Facility Operator refuses payment of 

alleged winnings to a patron or there is otherwise a dispute with a patron regarding that 

patron’s wins or losses from Gaming Activity, and the Gaming Facility Operator and the 

patron are unable to resolve the dispute to the satisfaction of the patron:

a. If the dispute involves five hundred dollars ($500) or more, the Gaming Facility 

Operator shall immediately notify the Gaming Office and shall inform the patron of his 

or her right to file a complaint with the Gaming Office requesting that it investigate.

b. If the dispute involves less than five hundred dollars ($500), the Gaming Facility 

Operator shall inform the patron of his or her right to file a complaint with the Gaming 

Office requesting that it investigate.

2) Complaint. All complaints shall be submitted in writing to the Tribal Gaming Office 

alleging that the Gaming Facility Operator has failed to pay winnings owed to the patron. 

The Gaming Office shall promptly provide a copy of the complaint to the Gaming Facility 

Operator. Within 15 days after notifying the Gaming Office of a patron dispute or within 15 

days after receiving from the Gaming Office a copy of a complaint filed by a patron, 

whichever is later, the Gaming Facility Operator shall file with the Gaming Office a written 

statement setting forth its position regarding the dispute. The Gaming Office shall cause a 

full investigation to be made of the patron’s allegations and the Gaming Facility Operator’s 

response, and shall determine whether the patron’s complaint is valid, whether the patron is 

entitled to any relief, and if so, the relief to which the patron is entitled.
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3) Notice to Patrons. The Gaming Office shall mail written notice by certified mail, return 

receipt requested, to the Gaming Facility Operator and the patron of its decision resolving 

the dispute within 30 days after the date that the Gaming Office is notified of a dispute by 

the Gaming Facility Operator or a request to conduct an investigation from the patron, 

whichever is later.

4) Effective Date of Decision. The decision of the Gaming Office is effective on the date it 

is received by the aggrieved party as reflected on the return receipt.

5) Review of Decision. Within 30 days after the date of receipt of the written decision, the 

aggrieved party may file a petition with the Gaming Office requesting a review of the 

decision. The Gaming Office may set a hearing on the matter or may make a decision based 

on the record previously developed and other documentation provided to it by the patron 

and the Gaming Facility Operator. The Gaming Office shall then issue a written decision 

within 60 days of the filing of the petition and mail it to the parties by certified mail, return 

receipt requested. This written decision of the Gaming Office shall be the final decision of 

the Gaming Office, subject to the provision for judicial review in Section 1204(2).

6) The patron may have counsel present at the hearing. The patron may be allowed to present 

evidence, at the discretion of the Commission.

SECTION 1310 PLAY BY EMPLOYEES

No Primary Management Official, Casino Floor Managers, Casino Department Director/Managers, 

Director/Assistant Director of Surveillance, Executive Director/Assistant Director of Gaming, or 

Tribal Gaming Inspectors shall play or place any wager, directly or indirectly, in any Gaming 

Activities. No employee under the age of twenty-one (21), shall play or place any wager, directly 

or indirectly, in any Gaming Activities. The Gaming Facility Operator shall prepare and submit to 

the Tribal Gaming Office a written Employee Play Policy that is consistent with Section 1310. The 

Gaming Facility Operator shall take reasonable steps to prevent such individuals from playing or 

placing wagers in Gaming Activities.

SECTION 1311 FINANCIAL SERVICES AT GAMING FACILITIES

The Gaming Facility Operator is prohibited from:

1) Locating an automatic teller machine (“ATM”) adjacent to, or in close proximity to, any 

Gaming Device;
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2) Locating in a Gaming Facility an ATM that accepts electronic benefit transfer cards issued 

pursuant to a state or federal program that is intended to provide for needy families or 

individuals;

3) Accepting checks or other non-cash items issued pursuant to a state or federal program that 

is intended to provide for needy families or individuals; and

4) Extending credit to any patron of a Gaming Facility for Gaming Activities.

SECTION 1312 ADVERTISING GUIDELINES

In accordance with the requirements of Section 3(x)(3) of the Compact, the Gaming Facility 

Operator shall adopt and shall comply with guidelines for the advertising and marketing of Gaming 

Activities that are no less stringent than those contained in the American Gaming Association’s 

general advertising guidelines.

CHAPTER 14 VIOLATIONS AND REMEDIES

SECTION 1401 VIOLATIONS

It shall be a violation of this Ordinance for any Person to:

1) Conduct or operate any Gaming Activities within the Tribe except as provided in this 

Ordinance;

2) Receive, distribute, apply or direct any property, funds, proceeds or other asset of any 

Gaming Activities to the benefit of any individual or other Person except as authorized by 

this Ordinance or by any duly enacted Resolution of the Cocopah Tribal Council;

3) Tamper with any equipment used in the conduct of Gaming Activities with the intent to 

cause any Person to win or lose any wager other than in accordance with the publicly 

announced rules of such Gaming Activities;

4) Do any other act in connection with the conduct of any Gaming Activities with the intent to 

affect the outcome of any wager other than in accordance with the publicly announced rules 

of such Gaming Activities;

5) Participate as a player in any Gaming Activities if such individual is prohibited under 

Section 1303 or Section 1310 from participating in such Gaming Activities;
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6) Participate as a player in any Gaming Activities while such individual is listed as an 

individual banned from the Tribe’s Gaming Facilities as provided in Section 403(2)(i);

7) To conduct Gaming Activities within the Tribe without complying with the terms and 

conditions of the Ordinance, the Compact, or the Act;

8) To intentionally misrepresent a material fact to the Gaming Office or intentionally falsify 

any business records of the Gaming Facility Operator or report required by this Ordinance, 

the Compact or the Act; and

9) To fail to comply with any other provision of this Ordinance.

SECTION 1402 CIVIL PENALTIES

Any individual who violates any provision of this Ordinance, including the provisions of the 

Compact incorporated herein, shall be subject to civil penalties including exclusion from 

employment by any Tribal Gaming Operation, denial or revocation of a tribal gaming license, 

exclusion from attendance at any Tribal Gaming Facility, exclusion from the Reservation if a nonmember of the Tribe, or, with respect to any person subject to the jurisdiction of the Tribe to 

impose such fines, a fine of not more than $10,000 for each such violation. The Commission 

established pursuant to this Ordinance shall have the jurisdiction to impose any such penalties on 

any person within the jurisdiction of the Tribe to impose such penalties.

SECTION 1403 CIVIL REMEDIES

The Gaming Office may in the name of the Tribe bring any civil action in the courts of the Tribe to 

enforce the provisions of this Ordinance, the Compact, or the Act or to enjoin or otherwise prevent 

any violation of this Ordinance, the Compact, or the Act occurring within the territorial jurisdiction 

of the Tribe.

CHAPTER 15 TRANSITION PROVISIONS

SECTION 1501 EXISTING GAMES LAWFUL

Subject to the provisions of the Compact and notwithstanding any other provision of this 

Ordinance, any Gaming Facilities otherwise legally situated within the Tribe, the Gaming 

Activities carried on at such facilities as of the date on which this Ordinance becomes effective, 

shall be lawful until the day that is 120 days after the date on which applications for licenses of 

such facilities and personnel are due to be submitted to the Gaming Office established hereunder; 
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provided, that the Gaming Office may, upon application by the Gaming Facility Operator, extend 

such period to permit proper processing of any duly filed application.

SECTION 1502 REPEAL OF PRIOR ORDINANCES AND RESOLUTIONS

Upon enactment of this Ordinance, the Cocopah Tribal Gaming Ordinance enacted 30 July 1992, 

and all amendments thereto and any Resolution or other Ordinances of the Tribe or parts thereof 

which are inconsistent with Ordinance, are hereby repealed.

CHAPTER 16 AMENDMENTS

SECTION 1601 AMENDMENTS

This Ordinance may be amended by action of the Cocopah Tribal Council.