Saint Regis Mohawk Tribe 

Ohiarihk6:wa/July 1, 2017 

National Indian Gaming Commission 

Department of the Interior 

1849 C Street NW 

Mail Stop #1621 

Washington, D.C. 20240 

Chief Eric Thompson 

Chief Beverly Cook 

Chief Michael Conners 

Sub-Chief Cheryl Jacobs 

Sub-Chief Shelley Jacobs 

Sub-Chief Agnes Jacobs 

Via e-mail to: Vannice Doulou@nigc.gov 

Oi"iginal to follow 

Tekwanonhwera:ton 1 Greetings Chairman Chaudhuri, Vice Chair Isom-Clause and Associate Commissioner 

Simermeyer, 

As the elected officials of the Saint Regis Mohawk Tribe, please accept t is as ou.r official written comment : on 

the following National Indian Gaming Commission consultation t opics: 

1. Draft Guidance in accordance with Tribal comments received for voluntary non-binding Ch'.SS Ill 

minimum internal control standards (MICS) and regulatory changes as a result of the 2015-16 

consultation; 

2. Rural Outreach; 

3. Developing a Strong Tribal Workforce through Training; 

4. Management Contract Regulations and Procedures; 

5. Technical Standards for Mobile Gaming Devices; and 

6. Fees. 

Class III MICS 

We support the issuance of Class III MICS for tribes who wish to utilize· hem and the ICC proposal to suspend 

25 C.F.R. Part 542 with the clarify statement that the regulation is no- enforcea le. The St Regis Mohawk Tn1bal 

Gaming Commission has reviewed the draft and made comments on the following: 

Section 3(e)(4) amend to read "A card and dice control log". 

Section 3(1) The following standards must apply if foreign currency is exchai'lged in the pit. 

The Akwesasne Mohawk Casino Resort offers dual currency, US and Canadian, at specific table games 

and the foreign currency is not exchanges as we have Cana ian denominated chips. The pro}osed 

regulations should be applicable if foreign currency is exchanged for US dollars in the · able game pit. 

Rural Outreach 

We believe the NIGC can best deliver technical assistance and training to smaller rural operations by having a 

greater presence at such small rural locations. By splitting the St. Paul regina! office into two distinct regions is 

a start. We also believe the best teacher is audits. Our philosophy is by learning from audit findings. We use 

these findings as a tool to measure our operational and regulatory effectiveness. When there are findings, it is 

a learning opportunity to correct the issue and either improve training, education, or procedures, or maybe an 

three, to ensure the issue does not occur on subsequent audits. We encourage the NIGC to start with a fuU audit 

Page 1 of 2 

Helping Build A Bener Tomorrow 

lakhiienawa:se· Senha Aioianerenhake ne Eniohrhen·ne 

412 State Route 37 

Akwesasne, New York 13655 

www.srmt-nsn.gov 

Phone: 518-358-2272 
of the operations in question, then provide assistance to the tribe in how to effect meaningful change to correct 

the issue. Often, simply understanding the finding and the importance of correcting it wiU enable a tribe to move 

forward towards better compliance. We believe the delivery of audit findings and meaningful education of the 

findings will assist the NIGC in improving these tribal operations. The key is ·· o view such audits as not being 

punitive but educational. 

Training 

The St. Regis Mohawk Tribal Gaming Commission is constantly challenged loy technology, and the advancement 

of technology in gaming. Understanding the technological advancements in gaming, and how to properly 

regulate them are a prime focus of our Gaming Commission. Therefore, we encourage the NIGC to provide more 

advanced, in depth training focused on current technology and also keep tribes apprised of what technology is 

coming in the future. 

Management Contracts 

We do not utilize a management contract, and have not since 2000. We do not have any comments on this 

subject. 

Mobile Gaming Devices 

We support the issuance of regulations focusing on mobile gaming devices and this is one of the areas where 

our Tribal Gaming Commission is focusing their efforts on. The St. Regis Mohawk Tribal Gaming Commiss:ion 

does not have any suggestions or changes to your proposed section S47.18. 

Fees 

The Saint Regis Mohawk Tribe supports the NIGC's proposed changes in fees regulations "ound at 25 C.F.R. Part 

514. 

The Tribal Council of the Saint Regis Mohawk Tribe appreciates the opportunity to make written comments on 

the consultation topics of the National Indian Gaming Commission. 

Sken:nen 1 In peace, 

THE SAINT REGIS MOHAWK TRIBAL COUNCIL 

~ Tribal Chief 

Page 2 of 2 

/fL, / s Tribal Chief