MAR -8 ZXE 

Rick GrelIner, Esq. 

Attorney for the Apache Tribe 

of Oklahoma 

439 N.W. 18' Street 

Oklahoma City, Oklahoma 73 103 

Fax: (405) 602-0991 

Dear Mr. Grelhec 

This letter is in response to your request for the National Tndian Gaming Commission (NI(3-C) to 

review and approve the revised Gaming Ordinance for the Apache Tribe of Oklahoma enacted 

pursuant to Resolution Number ABC-19-06-Gaming-04, onJanuary 19,2006, and subsequently 

amended, pursuant to Resolution Nmber ABC-02-03-06-Gamitlg-I, onFebruary 3,2006. This 

letter constitutes such approval under the Indian Gaming Regulatory Act (IGRA) subject to the 

provisions below. 

The Apache Gaming Ordinance, as amended February 3,2006, is approved only to the extent that 

it complies with the provisions of IGRA and MGC Regulations. Specifically, 4 102(k) contains a 

definition for "Indian Lands" and attempts to adopt the language found in the Model Ordinance. 

However, the deftnition incorporated into the Apache Tribe's Gaming Ord'ice omits several 

words contained in the Model. As we believe this to be a typographical error, the approval of this . ordinance incorporates the definition of "Indian Lands" as defined in MGC Regulations. 25 

C.F.R. 5 502.12. It is important to further note that the gaming ordinance is approved for gaming 

as defined in the IRA, over which the Tribe has jurisdiction. 

the ordinance for review and approval. The NGC staff and I look 

and the Apache Tribe of Oklahoma on future gaming issues. 

cc via fax only: Nathan Tselee, Chairman 

(405) 247-2686 

WTIOW H- 1441 L St. NW. Suite 9100, Washington, DC 2W5 Tel: 202.632.7003 Fax: 202.632.7066 WW.MIGC.GW 

RECIOHRL OFFICES hltland, OR: Sacramento. CA: Phoenix. AZ; St. Paul, MN;Tuba. OK 
APACHE BUSINESS COMMITEE 

Nathan Tselee-Interim chain& 

Donnie Cabaniss-Interim SecreWyTTreasurez 

Telephone: 405/247-9493 

Apache Tribe o£ OkLhoma L 

51 1 Eaa Gdondo 

Post m~ Box 122CI 

ANADARKO, OKLAHOhdA 73005 

APACHE BUSINESS COMMITTEE 

Phillip Wetselline-Committee Member 

(INTERIM)-Tribal Administrator 

Fax: 4051247-2686 

RQC- \CI-ac? -h9-0~ 

RESOLUTION NO.- 

A RESOLUTION BY THE APACHE TRIBE OF OKLAHOMA RATIFYING, - 1;; 

ADOPTING, APPROVING TRIBAL GAMING ORDINANCE PURSUANT TO THE IND~N :';? 

. // GAMING REGULATORY ACT AND REVOKING OF ALL PREVIOUS GAMING =; -i 

ORDINANCES rv -;;a,% r fzgz I I !<f- - 

WHEREAS, the Apache Tribe of Oklahoma is sovereign, self-governing a ----z X Lixm 

Indian tribe formally recognized by the United States (;7sc 

Government; and - 5 2, 

c-3 -- 

43 2" 

WHEREAS, Article 111 of the Apache Tribe of Oklahoma Constitution states, the supreme 

governing body of the Apache Tribe of Oklahoma shall be the tribal council; and 

WHEREAS, Article IV of the Apache Tribe of Oklahoma Constitution states, the officers of the 

tribe shall be Chairman, Vice-Chairman and Secretary-Treasurer; and 

WHEREAS, Article V of the Apache Tribe of Oklahoma Constitution states, this committee 

shall have such powers as may be delegated to it by appropriate resolutions of the 

tribal council, and, within such delegated authority, may transact business an 

otherwise speak or act on behalf of the tribe in all matters on which the tribe is 

empowered to act on or in the future. 'The business committee may as it deems 

necessary appoint subordinate commitlees and representatives; and 

BE IT RESOLVED, that the Business CoIl.lmittee of the Apache Tribe of Oklahoma 

has reviewed the terms and provisions of past gaming ordinances with the Tribal Attorney, 

and in the exercise of its sound business judgment, has determined that the terns and provisions 

do not meet the current needs of the Tribe; and, 

BE IT FURTHER RESOLVED, that the Business C:ornrnittee of the Apache Tribe of 

Oklahoma will revoke past gaming ordinances with the: intention to improve the economic condition 

of the Tribe and its members, increase tribal revenues, enhance the Tribe's economic self 

sufficiency, and enable the Tribe to better serve the social, economic, educational and health 

needs of the Tribe's members; and 

BE IT FINNALLY RESOLVED, that the Business Committee of the Apache Tribe of 

Oklahoma hereby approves and adopts the attached model gaming ordinance and submits to the 

National Indian Gaming Commission for expedited review and approval. 
NOW THEREFORE BE IT RESOLVED, that the Tribe does hereby authorize, the Business 

Committee of the Apache Tribe of Oklahoma to revoke past gaming ordinances and rati@, adopt 

and approve the attached gaming ordinance that better suits the needs of the Tribe. 

p~c- -&&hi4 

Resolution No A~~~ VJq 

CERTIFICATION 

herebya&nhtan afficial mee~lgofthe ApacheTribeofOklahoma Wlsiness chnmhe, held 

2006, at which a quorum was pesmt, the above resolution was preoaded and 

approved 

bavoted or, 0 -and 0 ~brtan. 

Nathan W. Tdee, lntenm Chairman Date 

Date 

Date 
APACHE BUSINESS COMMITTEE 

Nathan Tselee-Interim Chairman 

. Domie Cabanias-Interim SecmtaryITrcasurer 

Telephone: 4011247-9493 

APACHE BUSINESS COMMITTEE 

Phillip Wetselline-Committee Member 

(INTERIM)-Tribal Administrator 

Fa: 4051247-2686 

Apache Tribe o£ Okshoma 

5 1 1 East Colorado 

Post ofice Bor 1220 

ANADARKO, OKLAHOMA 73005 

32-a3-06-&n*n - / 

RESOLUTION NO. ABC-2006- - 

B 

A RESOLUTION BY THE APA F OIUAHOMA AMENDING 

THE RECENTLY SUBMITTED NATIONAL INDIAN GAMING COMMISSION MODEL 

TRIBAL GAMING ORDINANCE 

WHEREAS, the Apache Tribe of Oklahoma is sovereign, self-governing 

Indian tribe formally recognized by the United States 

Government; and 

WHEREAS, Article III of the Apache Tribe of Oklahoma Constitution states, the supreme 

governing body of the Apache Tribe of Oklahoma shall be the tribal council; and 

WHEREAS, Article IV of the Apache Tribe of Oklahoma Constitution states, the officers of the 

tribe shall be Chairman, Vice-Chairman and Secretary-Treasurer; and 

WHEREAS, Article V of the Apache Tribe of Oklahoma Constitution states, this committee 

shall have such powers as may be delegated to it by appropriate resolutions of the 

tribal council, and, within such delegated authority, may transact business an 

otherwise speak or act on behalf of the tribe in all matters on which the tribe is 

empowered to act on or in the future. The business committee may as it deems 

necessary appoint subordinate committees and representatives; and 

WHEREAS, the Apde Business Committee ("Al3C") of the Apache Tribe of Oklahoma 

has recently submitted a model tribal gaming ordinance for review and 

expedited approval of the National Indian Gaming Commission and has 

since been advised by the NIGC that such ordinance needs to be amended 

because of errors which exist in the model ordinance, and 

WHEREAS, The ABC hereby submits the following amendments to the subject Ordinance: 

1. Section 102 (c) 1 (C) is hereby amended to state: 

"in which the game is won by the first person covering a previously 

designated arrangement of numbers or designations on such cards, 

including (if played at the same location) pulltabs, lotto, punchboards, tip 

jars, instant bmgo, and other games similar to bingo, and 

'!' C] 33.JSfj 2 Section 103 is hereby amendeb \o: !dt@ 

-, r t ".C i -1% J ' -.I - :. i ,J 

"Class I1 and Class I11 ga&garq he;ebpiap@-ynzed." 

17- 
3. Section 108 (e) is hereby amended to state: 

"Nominees for positions of Tribal Garmng Commissioner must satisfy the 

Suitability standards set forth for key employees and primary management 

officials, found in Section 207 of this Ordinance. Such Background 

investigations shall be performed under the direction of the Gaming 

Commission by either a designated employee or an outside independent 

investigative firm." 

4. Section 108 (f) (4) is amended to state: 

"obtain and process fingerprints" 

5. Section 205 (b) (8) is amended to state: 

"for each felony for which there was an ongoing prosecution or a 

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

date of disposition if any;" 

6. Section 208 (a) is amended to state: 

'When a key employee or primary management official is employed to 

work at a gaming operation authorized by this ordinance, the Commission 

shall forward to the National Indian Gaming Commission a completed 

application for employment and conduct the background investigation and 

make the determination referred to in subsection 207 of this section." 

BE IT FURTHER RESOLVED, That the ABC will submit for expedited review the 

aforementioned amendments to the previously submitted gaming ordinance with the intention to 

improve the economic condition of the Tribe and its members, increase tribal revenues, enhance 

the Tribe's economic self sufficiency, and enable the Tribe to better serve the social, 

economic, educational and health needs of the Tribe's members; and 

NOW THEREFORE BE IT RESOLVED, that the Apache Tribe of Oklahoma does hereby amend the 

previously submitted gaming ordinances as herein described and requests the National Indian Gaming 

Commission to expedite the review and approval of such amendments. A@-oz~ 36 6 .- (#fl(flG 

Resolution No. ABC-2006- - 

CERTIFICATION 

We, the hereby &that an afficial medmg ofthe Apache Tribe ofOklahoma Wlsiness Comrmttee, held 

onthe ZrO day of,~2006,atwhi&aqu0~mwasp~theabove~mwaspresentedand 

approved 

by avde of 3 For, Q Agamst, and 0 Abstajn. 

philliP w&#lm, Apache Business Committee Member 

Y--~-OL 

Date 

/3/0 6 

Date 

Apache Tribe of Oklahoma Gaming Ordinance 

Purpose 

Definitions 

Gaming Authorized 

Ownership of Gaming 

Use of Gaming Revenue 

Per.Capita Payments 

Board of Directors 

Gaming Commission 

Ethics 

Complimentary Items 

Audit 

Environment and Public Health and Safety 

Dispute Resolution 

Tribal lnternal Control Standards 

Facility Licenses 

Agent for Service of Process 

Compliance with Federal Law 

Repeal 

Tribal Access to Financial Information 

Licenses for Key Employees and Primary 

Management Ofiicials 

License Application Forms 

License Fees 

Fingerprints 

Background Investigations 

Procedures for Conducting a Background Check on 

Applicants 

Eligibility Determination 

Procedures for Forwarding Applications and Reports 

for Key Employers and Primary Management Oflicials 

to the NlGC 

Report to the NlGC 

Granting a Gaming License 

license Suspension 

Board of Review for Disputes 

Licenses for Vendors 

Submission of a Vendor License Application 
W WWWWW 0 00000 

= 9?':n.+u 
Section 101. Purpose 

T h e A p a c h e Tribe of Oklahoma (Tribe), empowered by the &to enact ordinances, hereby enacts this ordinance in order to govern Class II gaming 

operations on the Tribe's Indian lands. 

Section 102. Definitions 

Unless a different meaning is clearly indicated in this Ordinance, the terms used herein shall have the same meaning as defined in the lndian Gaming Regulatory Act (IGRA), 25 

U.S.C. 5 2701 et seq., and its regulations, 25 C.F.R. § 500 et seq. Specifically: 

(a) Board of Directors means the Tribal Gaming Board of Directors, who shall serve as primary management officials in overseeing the General Manager and the day-to-day 

non-regulatory aspects of the gaming operation. 

(b) Class I gaming means social games solely for prizes of minimal value or traditional forms of Indian gaming engaged in by individuals as a part of, or in connection with, 

tribal ceremonies or celebrations. 

Class II gaming means: 

computer, or other technologic aids are used in connection therewith): 

(A) which is played for prizes, including monetary prizes, with cards 

bearing numbers or other designations, 

(B) in which the holder of the card covers such numbers or designations 

when objects, sinlilarly numbered or designated, are drawn or electronically determined, and 

(c) in which the game is won by the first person covering a previously 

designated arrangement of nunlbers or designations on such cards, including (if played in the same location, lotto, punch boards, tip jars, instant bingo, and other games similar to bingo, 

and 

(2) card games that: 

(A) are explicitly authorized by the laws of the State, or 

(B) are not explicitly prohibited by the laws ofthe State and are played 

at any location in the State, but only is such card games are played inconformity with those laws and regulations (if any) of the State regarding hours or periods of operation of such card 

games or limitations on wagers or pot sizes in such card games. 

(3) The term "class 11 gaming" does not include: 

(A) any banking card games, including baccarat, chemin de fer, or 

Blackjack (21). or 

(B) electronic or electron~echanical facsimiles of any game of chance or 

slot n~achines of any kind. 

[25 U.S. C. 5 2703(7); 25 C.F. R. 5 502.31 
(d) Class Ill gaming means all forms of gaming that are not class I gaming or class II gaming 

125 U.S.C. 5 2703(8); 25 C.F.R. 5 502.41 

(e) Commission means the Tribal Gaming Commission established to perform regulatory oversight and to monitor compliance with Tribal, Federal, and applicable State 

regulations. 

(f) Commissioner means a Tribal Gaming Commissioner 

(g) Compact means a Tribal-State Compact concerning class Ill gaming approved by the Secretary of the Interior and published in the Federal Register pursuant to 25 U.S.C. 9 

2710(d). 

(h) Complimentary shall have the meaning as set forth in 25 C.F.R. §542.2(a). 

(i) Directly related to means a spouse, child, parent, grandparent, grandchild, aunt, uncle, or first cousin 

(j) Director means a Member of the Tribal Gaming Board of Directors 

(k) Indian lands means: 

(1) all lands within the limits of the Tribe's reservation; 

(2) any lands title to which is either held in trust by the United States for the 

benefit of the Tribe or individual or held by the Tribe or individual subject to United States against alienation and over which the Indian Tribe exercises governmental 

power; and 

(3) for all lands acquired into trust for tl~e benetit of an Indian tribe afler October 

17, 1988, the lands meet tlle requirements set forth in 25 U.S.C. 8 2719. 

125 U.S.C. 5 2703(4); 25 U.S.C. 5 2719; 25 C.F. R. 5 502.121 

(I) Indian Tribe means the Apache Tribe of Oklahoma. 

(m) Key Employee[ll means: 

(1) A person who performs one or more of the following functions: 

(A) Bingo caller; 

(B) Counting room supervisor 

(C) Chief of security, 

(D) Custodian of gaming supplies or cash; 

(El Floor manager; 

(F) Pit boss; 

Section 104. Ownership of Gaming 

The Tribe shall have the sole proprietary interest in and responsibility for the conduct of any 

gaming operation authorized by tli~s ordinance. 

[25 U.S.C. 9 2710(b)(2)(A); 25 C. F, R. 9 522.4(b)(1)] 

Section 105. Use of Gaming Revenue' 

(a) Net revenues from tribal gaming shall be used only for the following purposes: 

(1) to fund tribal government operations and programs; 

(2) to provide for the general welfare of the Tribe and its members; 

(3) to promote tribal ecouon~ic development; 

(4) tn rlnnntp tn rhnrltphlr nrga!?lze!inns; nr 

(5) to help fund operations of local government agencies 

[25 U.S.C. 9 2710(b)(2)(B); 25 C.F.R. 5 522.4(b)(2)] 

Section 106. Per Capita Payments 

(a) "Per Capita Payn~ent" means the distribution of money or other thing of value to all 

Members of the Tribe, or to identified groups of members, which is paid d~rectly from the net revenues of any tribal gaming activity. 

[25 C.F. R. 9 290.21 

(b) If the Tribe elects to make per capita payments to tr~bal members from revenues 

derived from its gaming operations, it shall ensure that the following requirements of 25 C.F.R. Part 290 are met: 

(1) The Tribe shall authorize and issue such payments only in accordance with a 

Revenue allocation plan subn~itted to and approved by the Secretary of the Interior under 25 U.S.C 8 2710(b)(3). 

[25 U.S.C. 9 2710(b)(3); 25 C.F.R. 9 522.4(b)(2)(ii)] 

(2) The Tr~be shall ensure that the interests of minors and other legally incompetent 
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Two of the following: 

Degree in Business Administration, Accounting, Marketing, or an 

equivalent field; 

Minimum five (5) years experience in business management; 

Min~mum two (2) years experience in casino management; or 

Demonstrated knowledge of federal Indian law, the Indian Gaming 

Regulatory Act, and related statutes and regulations 

And 

A basic knowledge of gaming management, business, finance, or law. 

(c) The Board of Directors shall perform the following duties: 

(1) Monitor and oversee the day-to-day operations of the gaming facility, 

whether managed by a tribal employee or by an approved management contractor; 

(2) Inspect and examine on a periodic basis all books, records, and papers of the 

gaming facility; 

(3) Set hours of operation for the gaming facility; 

(4) Set wager limits. 

(5) Develop marketing plans; 

(6) Oversee the interview, selection, and training of employees of the gaming operation; 

(7) Establish e~~~ployee policies, rates of pay, and hours of work; 

(8) Adopt an annual operating budget, subject to Tribal Council approval; 

(9) Enter into contracts on behalf of the gaming facility, subject to Tribal Council 

approval and NIGC review, 

(10) Hold hearings on employee complaints, in compliance with procedures 

established in the gaming ordinance and other Tribal gaming regulations or 

psrsonriel policies,[yand 
(1 1) Any other dut~es necessary to monitor and oversee the gaming operation 

(d) Board of Director positions shall be filled in the following manner: 

Through election by the Apache Business Committee 

(e) At least one member of the Board of Directors shall be a local business owner with no ties to or financial interest in the gaming 0perati0n.l~~ 

(f) The Tribe recognizes the importance of an independent Tribal Gaming Board of Directors in maintaining a well-managed gaming operation. To avoid potential conflicts of 

interest between the operation and regulation of the gaming facility, the Tribe hereby finds that, at a minimum: 

(1) No member of the Tribal Council or Tribal Gaming Commission may serve 

on the Board of Directors; 

(2) No person directly related to or living with any Tribal Council member 

or Tribal Gaming Commissioner may serve on the Board of Directors; 

(3) Members of the Board of Directors are prohibited from gambling in the 

Fitiiiiiy, a11ci 

(4) Members of the Board of Directors are prohibited from accepting 

complimentary items from the gaming operation. 

(g) Members of the Board of Directors may be removed from Office by the Tribal Council prior to the expiration of their respective terms only for neglect of duty, misconduct, 

malfeasance, or other acts that would render the Director unqualified for hislher position. When the Tribal Council believes that a removal is appropriate, it shall so notify the 

Director(s) and hold a hearing on the matter. The Tribal Council may opt to preliminarily remove the Director pending the hearing. At the hearing the Director may provide evidence 

rebutting the grounds for hislher removal. A vote of the Tribal Council on the validity of the preliminary removal shall be final and not subject to further appeal. A finding by the Tribal 

Council that the preliminary removal was wrongful shall entitle the affected Director to compensation for expenses incurred in appealing the wrongful removal, and shall entitle the 

Director to any pay withheld. 

(h) Members of the Tribal Gaming Board of Directors shall be compensated at a level determined by the Apache Business Committee prior to their appointment. 

Section 108. Gaming Commissionm 

(a) The Tribe hereby establishes a Tribal Gaming Commission whose duty it is to regulate tribal gaming operations. The Tribal Gaming Commission shall consist of three 

members. There shall be among them a Chairperson, Vice-Chairperson, and one additional Commissioner. 

(b) The purpose of the Tribal Gaming Commission is regulatory, not managerial. The Commission will conduct oversight to ensure compliance with Tribal, Federal, and, if 

applicable. State laws and regulations. The Commission will serve as the licensing authority for individuals employed in the gaming operation and will administer background 

investigations as part of the licensing process. The Commission will also have a role in monitoring compliance with the internal controls for the gaming operation and in tracking 

revenues In order to carry out its regulatory duties, the Commission shall have unrestricted access to all areas of the gaming operation and to all records. The Commission shall 

have authority to take enforcement actions, including suspension or revocation of an individual gaming license when appropriate. 

(c) The Tribe recognizes the importance of an independent Tribal Gaming Commission in maintaining a well-regulated gaming operation. The Commission shall be and act 

independently and autonomously from the Tribal Council in all matters within its purview. No prior or subsequent review by the Tribal Council of any actions of the Commission shall 
be required or permitted except as otherwise explicitly provided in this Ordinance. To avoid potential conflicts of interest between the operation and regulation of the gaming facility, 

the Tribe hereby finds that, at a minimum: 

(1) No member of the Tribal Council or Tribal Gaming Board of Directors may 

serve on the Gaming Commission, 

(2) No member directly related to or living with any Tribal Council member or 

Tribal Gaming Board of Directors member may serve on tlie Gaming Commission; 

(3) Members of the Gaming Commission are prohibited from gambling in the 

facility; and 

(4) Members of tlie Gaming Commission are prohibited froni accepting 

complimentary itenis from the gaming operation, excepting food and beverages 

valued at under five dollars. 

(d) Tribal Gaming Commissioner positions shall be filled in the following manner: 

Through appointment by the Apache Business Committee pursuant to an election. 

(e) Nominees for positions of Tribal Gaming Commissioner must satisfy the suitability standards set forth for key employees and primary management officials, found in 

Section Xlll of this Ordinance. Such background investigations shall be performed under the direction of the Gaming Commission by either a designated employee of the gaming 

commission or an outside independent investigative firm. 

(f) The Tribal Gaming Commission shall: 

(1) Conduct or cause background investigations to be conducted on, at a 

minimum, primary management officials and key employees; 

(2) Review and approve all investigative work conducted; 

(3) Report results of background investigations to the NIGC; 

(4) Obtain and process fingerprints, or designate a law enforcement agency to 

obtain and process fingerprints; 

(5) Make licensing suitability determinations, which shall be signed by 

tlie Chairman of tlie Gaming Commission: 

(6) Issue gaming licenses to management officials and employees of the 

operation, consistent with the suitability determination; 

(20) Create a list of regulatory authorities that conduct vendor background 

investigations and licensing wliich the Cotnmission recognizes as trustworthy; 

(21) DraR regulations exempting vendors from the licensing and/or background 

investigation requirements if they have received a license from a recognized regulatory authority; 

(22) Perform such other duties the Commission deems appropriate for the proper 

regulation of the Tribal gaming operation 

(23) Promulgate such regulations and guidelines as it deems appropriate to 

implement the provisions of this Ordinance. 

(g) The Gaming Commission shall ensure that all records and information obtained as a result of an employee background investigation shall remain confidential and shall 

not be disclosed to persons who are not directly involved in the licensing and employment processes. Information obtained during the course of an employee background investigation 

shall be disclosed to members of management, human resource personnel or others employed by the tribal gaming operation on a need-to-know basis for actions taken in their official 

capacities. 

This Section does not apply to requests for such information or records from any Tribal, Federal or State law enforcement or regulatory agency, or for the use of such information -------A- ,...'LA c---:--:-- --A -.-":- A,.- --A -t.L-:- -=:-:-a A,.':-- ul ICLUIUJ vy ~IIC ~UIIISIIIJJIUII annu atall III ~IIC ~CIIUIIII~I(LC UI LSIC~I UIIILI~I UVLICJ. 

(h) Terms of Office for Tribal Gaming Commissioners shall be as follows: the Chair shall serve an initial term of one year, with subsequent Chairs serving three-year terms. 

The Vice-Chair and Commissioner(s) shall serve an initial term of two years, with subsequent Vice-Chairs and Commissioners serving three-year terms. 

(i) The following persons are not eligible to serve as Tribal Gaming Commissioners: Tribal Council members, while serving as such; employees of the gaming operation, 

while sewing as such; gaming contractors (including any princ~pal of a management or other contracting company); persons directly related to or sharing a residence with any of the 

above; persons ineligible to be key employees or primary management officials. Non-tribal members previously convicted of a felony, of embezzlement, of theft, or of any other moneyrelated crime or honesty-related crime (such as fraud) cannot serve as Tribal Gaming Commissioners. Tribal members previously convicted of a felony, of embezzlement, of theft, or of 

any other money-related crime or honesty-related crime (such as fraud) will only be allowed to serve as Tribal Gaming Commissioners if the Apache Business Committee specifically 

finds a significant amount of time has passed and that the person is now of trustworthy character. The Tribal Council shall require a criminal history check with appropriate law 

enforcement agencies and shall review this criminal history report and make an appropriate suitability determination before appointing an individual to a position as a Tribal 

Gaming Commissioner. 

(j) The independence of the Tribal Gaming Commission is essential to a well-regulated gaming operation. For that reason, Commissioners may only be removed from office 

by the Apache Business Committee prior to the expiration of their respective terms for neglect of duty, misconduct, malfeasance, or other acts that would render a commissioner 

unqualified for hislher position. Any allegations of neglect of duty, misconduct, malfeasance, or other acts that would render him or her unqualified for hislher position must be 

substantiated by a preponderance of the evidence. Commissioners will be given an opportunity to provide evidence rebutting the grounds for their proposed removal before the 

removal is considered. A vote of the Apache Business Committee on the validity of the removal shall be final and not subject to further appeal. A wrongful removal shall entitle the 

affected Commissioner to compensation for expenses incurred in an appeal and any pay withheld. 

(k) A majority of the Commission shall constitute a quorum. The concurrence of a majority of the members appointed to the Commission shall be required for any final 

determination by the Commission. The Commission may act in its official capacity even if there are vacancies on the Commission. 

(I) Tribal Gaming Commissioners shall be compensated at a level determined by the Tribal Council. Commissioner compensation shall not be based on a percentage of 

gaming revenue to ensure the Commission is not improperly influenced. 

(m) The Commission shall keep a written record of all its meetings 

Section 109. ethic^^'^ 
(a) The Tribe recognizes that the duties of the Gaming Board of Directors and the Tribal Gaming Commission include making important decisions on highly sensitive issues. 

As such, the Tribe has determined that the Board of Directors and the Gaming Commission shall be held to extremely high ethical standards. Prior to taking their positions on the 

Board and the Commission (Members), the Members shall agree to be bound by the following principles: 

(1) Members shall not hold financial interests that conflict with the conscientious 

perfor~nance of their duties as managers and regulator^.^'"' 

(2) Members shall not engage in financial transactions using nonpublic 

Information or allow the improper use of such information by others on their behalf to krther any private interest 

(3) Members shall not solicit or accept any giR or other item of monetary value, 

including complimentary items or services (see Section 110, below), from any person or entity seeking official action or inaction from, doing business with, or 

conducting activities regulated by the member's organization, or whose interests may be substantially affected by the performance or nonperformance of the 

Members' duties. 

(4) Members shall make no unauthorized com~nitments or promises of any kind 

purporting to bind the Tribe. 

(5) Members shall not use their positions for private gain 

(6) Members shall act impartially, in accordance with all relevant Tribal, Federal, 

and State laws (where applicable), and shall not give preferential treatment to any private organization or individual, including to any persons related to 

Members. 

(7) Members shall ensure that Tribal property and gaming assets shall be 

properly segregated and safeguarded, and that such property and assets shall not be used for unauthorized activities. 

(8) Members shall not engage in outside elnployment or activities, including 

seeking or negotiating for future en~ployment, which conflict with their official duties and responsibilities 

(9) Members shall disclose waste, fraud, abuse, and corruptio~i to appropriate Authorities. 

(10) Members shall endeavor to avoid any acttons creating the appearance that 

they are violatir~g the law or the ethical standards listed herein. 

(I I) Members shall d~sclose any real or apparent financial or personal conflicts. If there is a conflict members shall not be tnvolved in a decision related 

there is a real conflict or the appearance of one, the member shall not take part in any decision related to the conflict 
Section 110. Complimentary 

(a) The use of complimentary items shall be governed by regulations established by the Tribal Gaming Commission 

(b) No Key Employee, Primary Management Official, Tribal Council member, member of the Gaming Board of Directors or Tribal Gaming Commission, or any person 

directly related to or sharing a residence with the persons, shall be authorized to receive complimentary items other than food and beverages valued at under five dollars, or, if at a 

public event held at the gaming facility, the free food and beverages offered to the general public. 

(c) Complimentary Items shall be included in the annual budget for the gaming operation, with maximum limits specified, and shall be subject to approval by the Tribal 

Council. 

Section 11 I. Audit 

(a) The Tribe shall cause an annual outside independent audit of gaming operations to be conducted, and shall submit the resulting audit reports to the National Indian 

Gaming Commission. 

[25 U.S.C. 5 2710(b)(2)(C); 25 C.F.R. 5 522.4(b)(3)] 

(b) All gaming related contracts that result in the purchase of supplies, services, or concessions in excess of $25,000.00 annually, except contracts for professional legal 

and accounting services, shall be specifically included within the scope of the audit that is described in subsection A. above. 

[25 U.S.C. 5 2710(b)(2)(D); 25 C.F.R. 5 522.4(b)(4)] 

Section 112. Environment and Public Health and Safety 

(a) Gaming facilities shall be constructed, maintained and operated in a manner that adequately protects the environment and the public health and safety. 

[25 U.S.C. $2710(b)(2)(E); 25 C.F.R. 5 522.4(b)(7)] 

(b) Apache Business Committee shall adopt standards that assure adequate protection of the environment and the public health and 

Section 113. Patron Dispute Resolutionu1 

Patrons who have complaints against the gaming establishment shall have as their sole remedy the right to file a petition for relief with the Tribal Gaming Commission. 

Complaints shall be submitted in writing, and at the discretion of the Commission, the petitioner may be allowed to present evidence. The Gaming Commission shall hold a hearing 

within 30 days of receipt of petitioner's complaint. Petitioner may have counsel present at such hearing. The Commission shall render a decision in a timely fashion and all such 

decisions will be final when issued. Any patron complaint must be submitted to the Commission within thirty (30) days of the incident giving rise to the complaint. All claims by patrons 

shall be limited to a maximum recovery of $10,000.00 per occurrence, and a cumulative limit of $50,000.00 per patron in any twelve (12) month period, except disputes relating to a 

patron's entitlement to a game prize, which shall be limited to the amount of such prize. The Commission's decision shall constitute the complainant's final remedy. 

Section 114. Tribal Internal Control Standards 

The Tribe shall adopt and implement Internal Control Standards (ICS) for the operation of its Tribal gaming operation in accordance with applicable law. The Tribe's ICS shall 

be set out in separate regulations to be reviewed and approved by the Tribal Council. 

Section 115. Facility LicensesllJ1 

(a) The Tr~bal Gamlng Commlss~on shall Issue a separate l~cense to each place, faclllty, or locat~on on lnd~an lands where class II @m%mJ gamlng IS conducted under 

thls ordinance 
[25 U.S.C. 5 2710(b)(l)(B); 25 C.F.R. 5 522.4(b)(6)] 

(b) The Tribal Gaming Commission shall issue a separate license to each place, facility, or location on lndian lands where Class II and Class Ill gaming is conducted under 

this ordinance once every three.u The Tribal Gaming Commission shall specify the form, conditions and content for the application for such licenses, which shall be submitted by the 

chief management official of the facility, and the initial application shall include a legal description of the lands whereon the facility is located, and a certification that said premises 

constitute "lndian lands" as specified in the lndian Gaming Regulatoty Act, and shall identify the environmental, health, and public safety standards with which the facility must comply, 

and a certification that the facility is in compliance therewith Each subsequent application for the renewal of such facility license shall identify any changes or additions to said 

legal description and applicable environmental, health and safety standards, and include current certifications of compliance therewith. The Tribal Gaming Commission shall only issue 

such licenses if the applications therefore include the required information and certifications and such further conditions as the Tribal Gaming Commission shall have specified. 

Section 116. Agent for Service of Process 

The Tribe hereby designates the Chairman of the Business Committee as agent for service of process, who may be contacted at: 

511 East Colorado, Anadarko, Oklahoma 73005 

[25 C.F. R. 5 519.11 

Section 117. Compliance with Federal LawL'" 

The Tribe will comply with all applicable federal law, including the Bank Secrecy Act, 31 U.S.C. § 531 1 et seq 

Section I1 8. Repeal1!I1 

To the extent that they are inconsistent with this ordinance, all prior gaming ordinances are hereby repealed 

Section 119. Tribal Access to Financial Informationu 

A copy of the Tribal gaming operation annual audit will be made available for review, upon request, to: 

Apache Business Committee 

Section 201. Licenses for Key Employees and Primary Management Officials 

The Tribe shall ensure that the policies and procedures set out in this section are implemented with respect to key employees and primary management officials employed at 

any gaming enterprise operated on lndian lands. The Tribe will issue licenses and perform background investigations according to requirements at least as stringent as 25 C.F.R. Parts 

556 and 558. 

[25 U.S.C. 5 2710(b)(2)(F); 25 C.F.R. 5 558.3; 25 U.S.C. 5 522.4(b)(5)] 

Section 202. License Application Forms 

(a) The following notice shall be placed on the application form for a key employee or a primary management official: 

In con~pliarice with the Privacy Act of 1974, the following information is provided: Solicitation of the information on this form is authorized by 25 IJ.S C. 

2701 et seq The purpose of the requested information is to determine the eligibility of ~ndividuals to be employed in a gaming operation. The information will 

be used by the Tr~he and the National Indian Gaming Commission members and staff who have need for the information in the performance of their official 

Alltir~ The infnrrnntinn mnv hr dicrlncprl tn nnnrnnrtnt~ F~rtrrnl Trihnl Stntr lnrnl nr fnrpion Inw rnfnrrrmrnt 2nd rrol~lntnn, nopncipc wh~n rrlrvnnt tn rivil 

(2) Currently and for the previous 5 years: business and employment positions held, ownership interests in those businesses, business and 

residence addresses, and drivers license numbers; 

(3) The names and current addresses of at least three personal references, including one personal reference who was acquainted with the 

applicant during each period of residence listed under paragraph (b)(2) of this section; 

(4) Current business and residence telephone numbers; 

(5) A description of any existing and previous business relationships with Indian Tribes, including ownership interests in those businesses; 

(6) A description of any existing and previous business relationships with the gaming industry generally, including ownership interests in those 

businesses; 

(7) The name and address of any licensing or regulatory agency with which the person has filed an application for a license or permit related 

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

(8) For each felony for which there was an ongoing prosecution or a conviction, within 10 years of the date of the application, the charge, the 

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

(9) For each misdemeanor conviction or ongoing misdemeanor prosecution (excluding minor traffic violations), within 10 years of the date of 

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

(10) For each criminal charge (excluding minor traffic charges), whether or not there is a conviction, if such criminal charge is within 10 years of 

the date of the application and is not otherwise listed pursuant to paragraph (b)(8) or (b)(9) of this section, the criminal charge, the name and address of the court involved and the date 

and disposition; 

(1 1) The name and address of any 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; 

(12) A photograph taken within the last year; and 

(13) Any other information the Tribe deems relevant. 

[25 C.F.R. 5 556.41 

Section 206. Procedures for Conducting a Background Check on Applicantsuq 

(a) As part of it's review procedure, the Commission or its agent shall employ or engage a private investigator to conduct a background investigation on each applicant 

sufficient to allow the Gaming Commission to make an eligibility determination under subsection G below. The investigator shall: 

(1) Verify the applicant's identity through items such as a social security card, drivers license, birth certificate, or passport; 

(2) Contact each personal and business reference provided in the License Application, when possible; 

(3) Obtain a personal credit check. 

(4) Conduct a civil history check; 
(5) Conduct a criminal history check via the submission of'the applicant's fingerprints to the NIGC, and further obtain information from the 

appropriate court regarding past felony and/or misdemeanor convictions and criminal charges within the last ten years; 

(6) Inquire into any previous or existing business relationships with the gaming industry and lndian tribes by contacting the entities or tribes; 

(7) Verify the applicant's history and status with any licensing agency by contacting the agency; and 

(8) Take other appropriate steps to verify the accuracy of the information, focusing on problem areas noted. 

(b) The investigator shall create an investigative report noting the steps taken, information gained, potential problem areas, and disqualifying information 

(c) The Gaming Commission and its investigator shall promise to keep confidential the identity of each person interviewed in the course of the investigation, other than 

disclosure as required under Federal, Tribal, or State law. 

Section 207. Eligibility Determination 

The Tribal Gaming Conlmission shall renew a person's prior activities, criminal record, if any, and reputation, habits and associations to make a finding 

concerning the eligibility of a key employee or primary managentent oficial for employn~ent in a gaming operation. If the Tribal Gaming Commission 

determines that employn~ent of the person poses a threat to the public interest or to the effective regulation of gaming, or creates or enhances dangers of 

unsuitable, unfair, or illegal practices and methods and activities in the conduct of gaming, a tribal gaming operation shall not employ that person in a key -.,.I A. ...;...".., .,."..",,a-.""+ -=-:..I .--:*:. -...p.U ," ,,. ,,..".Y.J I.. Y..Y6.,...CLI, "lll.,.Ul pUJILIVII. 

125 C.F.R. 5 558.21 

Section 208. Procedures for Forwarding Applications and Reports for Key Employees and Primary Management Officials to the National lndian Gaming Commission 

(a) When a key employee or primary management official is employed to work at a gaming operation authorized by this ordinance, the Commission shall forward to the 

National lndian Gaming Commission a completed application for employment and conduct the background investigation and make the determination referred to in subsection D of this 

section. 

(b) The gaming operation shall not employ as a key employee or primary management official a person who does not have a license afler 90 days. 

Section 209. Report to the National lndian Gaming Commission 

(a) The Tribal Gaming Commission shall prepare and forward a report on each background investigation to the National lndian Gaming Commission. An investigative 

report shall include all of the following: 

(I) Steps taken in conducting a background investigation, 

(2) Results obtained, 

(3) Conclusions reached; and 

(4) The hases for those conclusions. 
125 C.F. R. g 556.5(a), (b)] 

(b) The Commission shall forward the completed investigative report to the National lndian Gaming Commission within 60 days after an employee begins work or within 60 

days of the approval of this ordinance by the Chairman of the National lndian Gaming Commission. 

125 C. F.R. 5 558.3(b)] 

(c) The Commission shall submit, with the investigative report, a copy of the eligibility determination, unless the NlGC shall have advised the Tribe that the submission of 

the eligibility determination is not necessary. This determination shall include a Statement describing how the information submitted by the applicant was verified; a Statement of 

results following an inquiry into the applicant's prior activities, criminal record, if any, and reputation, habits and associations; a Statement showing the results of interviews of a 

sufficient number of knowledgeable people (such as former employers, personal references, and others referred to by the applicant) in order to provide a basis for the Tribal Gaming 

Commission to make a finding concerning the eligibility for licensing required for employment in a gaming operation; and a Statement documenting the disposition of all potential 

problem areas noted and disqualifying information 

(d) If a license is not issued to an applicant, the Tribal Gaming Commission: 

(1) Shall notify the NIGC; and 

(2) Shall forward copies of its eligibility determination and investigative report 

(il'at~yj IU lile KiGC ior inciusion in the lndlan tiamtng Ind~v~duals Records System. 

(e) With respect to all employee^,^ and in particular key employees and primary management officials, the Tribal Gaming Commission shall retain applications for 

employment and reports (if any) of background investigations for inspection by the Chairman of the NlGC or his or her designee for no less than three (3) years from the date of 

termination of employment. 

Section 210. Granting a Gaming License 

(a) If, within a thirty (30) day period after the National lndian Gaming Commission receives a report, the National lndian Gaming Commission notifies the Tribe that it has 

no objection to the issuance of a license pursuant to a license application filed by a key employee or a primary management official for whom the Tribe has provided an application and 

investigative report to the National lndian Gaming Commission, the Tribal Gaming Commission, acting for the Tribe, may issue a license to such applicant. 

125 C. F.R. 5 558.4(a)] 

(b) The Tribal Gaming Commission shall respond to a request for additional information from the Chairman of the National lndian Gaming Commission concerning a 

key employee or a primary management official who is the subject of a report. Such a request shall suspend the 30-day period under paragraph (a) of this section until the Chairman 

of the National lndian Gaming Commission receives the additional information. 

(c) If, within the thirty (30) day period described above, the National lndian Gaming Commission provides the Tribe with a Statement itemizing objections to the issuance of 

a license to a key employee or to a primary management official for whom the Tribal Gaming Commission has provided an application and investigative report to the National lndian 

Gaming Commission, the Tribe shall reconsider the application, taking into account the objections itemized by the National lndian Gaming Commission. The Tribe shall make the final 

decision whether to issue a license to such applicant. 
[25 C.F. R. 5 558.4(b)J 

Section 21 1. License Suspension 

(a) If, afler the issuance of a gaming license, the Tribal Gaming Commission receives from the National Indian Gaming Commission reliable information indicating that a key 

employee or a primary management official is not eligible for employment, the Tribal Gaming Commission shall suspend such license and shall notify in writing the licensee of the 

suspension and the proposed revocation. 

[25 C. F.R. 5 558.5(b)] 

(b) The Tribal Gaming Commission shall notify the licensee of a time and a place for a hearing on the proposed revocation of a license. 

(c) Afler a revocation hearing, the Tribal Gaming Commission shall decide to revoke or to reinstate a gaming license. The Commission shall notify the NlGC of its decision 

125 C.F.R. 5 558.5(d)] 

Section 212. Board of Review for 

The Tr~be has determined that, in order to adhere to this Ordinance and all gamlng regulations, there shall be established a Tribal Gaming Board of Review (Board of Review). The Board of Review shall 

serve as the final review body for employee disputes. Employee disputes shall include disputes with management, terminations, fines or other internal employee disputes, not to include actions taken by the 

Commission 

The Board of Review shall consist of five members. The membership shall be comprised of one member of the Tribal Gaming Commission, one member from the Tribal Council, one primary management 

official or key employee, one enrolled Tribal member not employed by the gaming operation, and one employee of the gaming ope ratio^^.^^ The members from the Tribal Gaming Comniission, Tribal 

Council, and gaming operation primary management official or employees sliall be elected from their representative groups and the enrolled Tribal member shall be appointed by the [insert Tribal authority]. 

Board of Review niembers sliall serve staggered terms. The two Tribal members shall serve three-year terms The primary management official or key employee shall serve a two-year term. The members 

from the Tribal Gaming Comn~ission and the Tribal Council shall serve one-year terms. The Board of Review members who are not en~ployed by the Tribe in some other capacity shall be compensated at a 

rate of $75.00 per meeting or hearing, and shall be reimbursed for actual costs incurred during the scope of his/her duties as a member of the Board of Review. Compensation shall never be tied to tribal 

gaming revenues. 

The Board of Review members shall elect a Chairperson from among them, whose duty it shall be to preside over all meetings and hearings. In addition, the members shall elect a Vice-Chair who shall be 

the custodian of any evidence submitted, and who shall preside in the Chairperson's absence. The Board of Review shall meet as needed but no later than ten days of a dispute being received, sliall keep 

official records of the meetings. No later than three working days following a hearing on employee disputes, the Board of Review sliall issue its findings. Findings of the Board shall be final when issued. 

No Board of Rev~ew member sliall be removed prior to the end of hisher tern1 without cause. Removal shall be effectuated by a majority vote of the entlre Board of Review, and shall be a final decision. A 

Board of Review member shall not review any decisions affecting himselWherself, or any person directly related to him or her. 

Section 301. Licenses for Vendorsu3) 

(a) Vendors of gaming services or supplies with a value of $25,000L'y10r more annually must have a vendor license from the Tribal Gaming Commission in order to transact 

business with the Tribal gaming operation. Contracts for professional legal and accounting services are excluded from this section. 

(b) Gaming vendors are vendors who provide gaming supplies and services, including cash-related services 

(c) Non-gaming vendors provide services that do not have the ability to impact the integrity of the Tribal gaming operations, such as media advertising, facility maintenance 

workers, linen and laundry services, and food and beverage suppliers. The Tribal Gaming Commission shall create a regulation detailing which vendors fall into this category and shall 
maintain a register of the non-gaming vendors that it licenses. The regulation may exempt from licensing requirements non-gaming vendors who: 1) are a Tribal, Local, State, or 

Federal government agencies; 2) are regulated by the State of Oklahoma or the Tribe; or 3) will provide goods of insubstantial or insignificant amounts or quantities if the Tribal 

Gaming Commission determines that licensing of the vendor is not necessary to protect the public interest. 

Section 302. Submission of a Vendor License Applicationm 

In order to obtain a gaming vendor license, the business must complete a vendor application and submit to background checks of itself and its principals. Principals of a business include its officers: 

directors, management, owners. partners, non-institutional stockholders that either own 10% or more of the stock or are the 10 largest stockholders, and the on-site supervisor or manager under the 

agreement with the Tribe, if applicable. 

Section 303. Contents of the Vendor License ApplicationL3" 

(a) Applications for gaming vendor licenses must include the following: 

(1) Name of business, business address, business phone, federal tax ID number (or SSN if a sole proprietorship), main office address if different from business 

address, any other names the applicant has done business under, type of service applicant will provide; 

(2) Whether the applicant is a partnership, corporation, limited liability company, sole proprietorship, or other entity; 

(3) If the applicant is a corporation, the state of incorporation, and the qualification to do business in the State of Oklahoma if the gaming o~eration is in a different 

S:s:e :ban the Staie of iiicu~pu~aiiu~~. 

(4) Trade name, other names ever used, names of any wholly owned subsidiaries or other businesses owned by the vendor or its principals; 

(5) General description of the business and its activities; 

(6) Whether the applicant will be investing in or loaning money to the gaming operation and, if so, how much; 

(7) A description of any existing and previous business relationships with the gaming industry generally, including ownership interests in those businesses; 

(8) A list of Indian tribes with which the vendor has an existing or previous business relationship, including ownership, financial, or management interests in nongaming activities;1321 

(9) Names, addresses, and phone numbers of three business references with whom the company had regularly done business for the last five years; 

(10) The name and address of any licensing or regulatory agency with which the business has filed an application for a license or permit related to gaming, whether 

or not such license or permit was granted; 

(1 1) If the business has ever had a license revoked for any reason, the circumstances involved; 

(12) A list of lawsuits to which the business has been a defendant, including the name and address of the court involved, and the date and disposition if any; 

(13) List the business' funding sources and any liabilities of $50,000 or 

(14) A list of the principals of the business, their social security numbers, addresses and telephone numbers, title, and percentage of ownership in the company; and 

(15) Any further information the Tribe deems relevant 
(b) The following notice shall be placed on the application form for a vendor and its principals: 

Inclusion of false or misleading information in the vendor application may be grounds for denial or revocation of the Tribe's vendor license. 

(c) A vendor may submit a copy of a recent license application to another jurisdiction if it contains the information listed above. The vendor will be required to submit in 

writing any changes in the information since the other license application was filed and any information requested by the Tribe not contained in the other application. 

Section 304. Vendor Background InvestigationLw 

The Tribal Gaming Commission shall employ or otherwise engage a private investigator complete an investigation of the gaming vendor. This 

investigation shall contain, at a minimum, the following steps: 

(a) Verify of the business' incorporation status and qualification to do business in the State where the gaming operation is located; 

(b) Obtain a business credit report, if available, and conduct a Better Business Bureau check on the vendor 

(c) Conduct a check of the business' credit history; 

(d) Call each of the references listed in the vendor application; and 

jej Conauci an invesiigaiion oi ine principais oi ihe business, inciudirig a crirriirlai ilisiory ci~eck, a c~eliii ~epu~i, iliiel-views with thc: ijersoiial iei~ieiices listed. 

Section 305. Vendor License FeeL''' 

The Tribe may charge a license fee, to be set by the Tribal Gaming Commission, to cover its expenses in investigating and licensing vendors of the gaming operation. 

Section 306. Vendor Background Investigation Reportw 

The private investigator shall complete an investigative report covering each of the steps taken in the background investigation of the gaming vendor and its principals and 

present it to the Tribal Gaming Commission. 

Section 307. Exemption for Vendors Licensed by Recognized Regulatory Authoritiesm 

The Tribal Gaming Commission may adopt regulations naming specific licensing authorities that it recognizes and may authorize exemptions to the vendor licensing process for 

vendors which have received a license from one of the named regulatory authorities. 

Section 308. Licenses for Non-Gaming vendorsw 

For non-gaming vendors, the Tribal Gaming Commission is authorized to create a less stringent vendor licensing process, including a due diligence check rather than a full 

aackground investigation as laid out in Section 304. The Gaming Commission may investigate such vendors when appropriate and may conduct audits in addition to monitoring Tribal 

ourchases.