NATIONAL INDIAN GAMING COMMISSION 

NOTICE OF VIOLATION 

NOV-16-01 

To: Leonard M. Harjo, Principal Chief 

Seminole Nation of Oklahoma 

P.O. Box 1498 

Wewoka, OK 74884 

Terry Hale, Interim Chief Gaming Regulator and Agent for Service 

Seminole Nation Gaming Agency · 

2015 W. Wrangler Blvd. 

Seminole, OK 74868 

A. Notification of Violation 

The Chairman of the National Indian Gaming Commission (NIGC or 

Commission) hereby gives notice that the Seminole Nation of Oklahoma 

(Respondent or Nation), located in Wewoka, OK, has violated NIGC regulations 

and the Nation's gaming ordinance by failing to ensure that Tribal Internal 

Control Standards (TICS) are established and implemented that provide a level of 

control equal to or exceeding the applicable standards set forth in NIGC 

regulations. 

B. Authority 

Under the Indian Gaming Regulatory Act and NIGC regulations, the Chairman 

may issue a Notice of Violation to any person for violation of any provision of the 

IGRA, NIGC regulations, or any provision of a tribal gaming ordinance or 

resolution approved by the Chairman. 25 U.S.C. § 2713; 25 C.F.R. § 573.3. 

C. Applicable Federal Laws and Tribal Ordinance Provisions 

1. Two general purposes of the IGRA are: 

a. to provide a statutory basis for the regulation of gaming by an 

Indian tribe adequate to ensure that the Indian tribe is the primary 

beneficiary of the gaming operation, and to assure that gaming is 

conducted fairly and honestly by both the operation and players; 

and 

b. to declare that the establishment of federal standards for gaming 

are necessary to meet Congressional concerns regarding gaming 
and to protect such gaming as a means of generating tribal revenue. 

25 U.S.C. §§ 2702(2) and (3). 

2. In September 2012 1 the NIGC promulgated Minimum Internal Control 

Standards (MICS) for Class II gaming. 25 C.F.R. Part 543. Internal 

controls are the primary procedures used to protect the integrity of casino 

funds and games and are a vitally important part of properly regulated 

gaming. Inherent in gaming operations are concerns related to customer 

and employee access to cash, questions of fairness of games, and the threat 

of collusion to circumvent controls. The MICS promote IGRA's purposes 

by ensuring that a tribe is the primary beneficiary of the gaming operation 

and protecting gaming as a means of tribal revenu.e. 

3. The MICS require that the Seminole Nation Gaming Agency (SNGA), the 

Nation's gaming regulatory body, ensure that TICS are both established 

and implemented that provide a level of control that equals or exceeds 

those set forth in the NIGC MICS. 25 C.F.R. § 543.3(b). 

4. In addition, the Seminole Tribal Gaming Ordinance requires the Nation's 

Chief Tribal Regulator to issue regulations to implement TICS. Seminole 

Nation of Oklahoma Tribal Ordinance No. T0-2011-11, Sections 

105(a)(4) and 107(b)(5). 

5. NIGC regulations also require that the Nation's gaming operations 

develop a System of Internal Control Standards (SICS) to implement the 

TICS, as approved by the SNGA. 25 C.F.R. § 543.3(c). Thus, both the 

SNGA and the operations have an obligation to ensure the implementation 

of the TICS. 

6. SICS is defined as "[a]n overall operational framework for a gaming 

operation that incorporates principles of independence and segregation of 

function, and is comprised of written policies, procedures, and standard 

practices based on overarching regulatory standards specifically designed 

to create a system of checks and balances to safeguard the integrity of a 

gaming operation and protect its assets from unauthorized access, 

misappropriation, forgery, theft, or fraud." 25 C.F.R. § 543.2. 

7. While the MICS detail hundreds of standards for internal controls that 

cover many aspects of a gaming operation, the following specific 

standards are applicable here: 

a. accounting controls must be established and procedures 

implemented to safeguard assets and ensure that each operation 

prepares accurate, complete, legible, and permanent records of all 

1 The MICS were amended on Oct. 25, 2013. 78 FR 63874. 

2 
transactions pertaining to gaming revenue and activities for 

operational accountability. 25 C.F.R. § 543.23(b)(l); 

b. the Nation's TICS must require that documentation such as 

checklists, programs, and reports be prepared to evidence all 

internal audit work and that follow-up be performed regarding 

compliance with TICS, SICS, and MICS, including all instances of 

noncompliance. 25 C.F.R.§ 543.23(c)4; 

c. the SNGA's internal audit department must document the 

performance of the revenue audit procedures, the exceptions noted, 

and the follow-up of all audit exceptions. 25 C.F.R. § 543.24(c); 

d. internal controls must include adequate backup and data recovery 

procedures. 25 C.F.R. § 543.200)(1)-(2). In addition, recovery 

procedures must be tested at specific intervals at least annually and 

results documented. Backup data files and recovery components 

must be managed with at least the same level of security and 

access controls as the system for which they are designed to 

support. 25 C.F.R.§ 543.200)(3)-(4); 

e. at least monthly for computerized player tracking systems, the 

gaming operations must perform the following procedures: review 

authorization documentation for all manual point 

additions/deletions for propriety; review exception reports, 

including transfers between accounts; and review documentation 

related to access to inactive and closed accounts. 25 C.F.R. 

§ 543.24( d)( 4)(ii)(A)-(C); 

f. the Nation must establish and implement policies and procedures 

for the verification of the receipt, issuance, and use of controlled 

inventory, including but not limited to keys and pre-numbered 

and/or multi-part forms, on at least a monthly basis. 25 C.F.R. 

§ 543 .24( d)(lO)(i); 

g. at least monthly, the gaming operations must review variances 

related to bingo accounting data which must include, at a 

minimum, variances noted by the Class II system for cashless 

transactions in and out, external bonus payouts, vouchers out, and 

coupon promotions out. The uperalions musl investigate and 

document any variance noted. 25 C.F.R. § 543.24(d)(l)(iii); 

h. the operations must ensure the monthly footing of a randomly 

selected sample of redeemed bingo vouchers and the tracing of the 

totals to the totals recorded in the voucher systems and to the 

3 
amount recorded in the applicable cashier's accountability 

document. 25 C.F.R. § 543.24(d)(l)(v); 

L at least monthly, the gaming operations must review promotional 

payments, drawings, and giveaway programs to verify payout 

accuracy and proper accounting treatment in accordance with the 

rules provided to patrons 25 C.F.R. § 543.24(d)(4)(i); 

J. the SNGA must perform an internal audit relative to Title 31. TICS 

at Section 129(A)(l); 

k. the gaming operations must implement procedures to safeguard the 

integrity of technological aids to the play of bingo during 

installations, operations; modifications; removal, and retirements 

that include maintaining initial meter readings related to installed 

game servers and player interfaces. 25 C.F.R. § 543.8(g)(3)(i)(I); 

l. the operations must maintain sufficient installation testing 

documentation that includes testing of: communication with the 

Class II gaming system, the accounting system, and the player 

tracking system; currency and vouchers to bill acceptors; voucher 

printing, meter incrementation, and pay tables for verification; 

player interface denominations; all buttons to ensure they are 

operational and properly programmed; system components; and 

locks. 25 C.F.R. § 543.8(g)(5)(i)(A)-(K); 

m. controls must be established and procedures implemented to verify 

that patrons are paid the appropriate amount after a voucher is 

verified. 25 C.F.R. § 543.8(i)(l)(ii); 

n. the gaming operations must comply with a minimum bankroll 

formula to ensure they maintain cash or cash equivalents in an 

amount sufficient to satisfy obligations to patrons as they are 

incurred. 25 C.F.R. § 543.18(c)(4); 

o. the cage and vault inventories must be counted independently by at 

least two agents who must make individual counts to compare for 

accuracy and to maintain individual accountability. 25 C.F.R. 

§ 543 .18(c)(3); 

p. outside agents may be granted remote access for system support, 

provided that each access session is documented and maintained at 

the place of authorization. 25 C.F .R. § 543 .20(h)(l )(i)-(vii) and (2); 

q. the surveillance system must monitor and record a general overview 

of activities occurring in each cage and vault area with sufficient 

4 
clarity to identify individuals within the cage and patrons and staff 

members at counter areas and to confirm the amount of each cash 

transaction. 25 C.F.R. § 543.21(c)(4)(i); 

r. the surveillance system must monitor with sufficient clarity a 

general overview of all areas where cash or cash equivalents may be 

stored or counted. 25 C.F.R. § 543.21(c)(5)(i); 

s. gaming operations must prepare accounting records on a doubleentry system of accounting, maintaining detailed subsidiary 

records, compare recorded accountability for assets to actual assets 

at periodic intervals, and take appropriate action with respect to any 

variances. 25 C.F.R. § 543.23(b)(2)(ix); 

t. procedures must be implemented to, at least monthly, review 

variances related to bingo accounting data in accordance with an 

established threshold, which must include, at a minimum, 

variance( s) noted by the Class II gaming system for cashless 

transactions in and out, external bonus payouts, vouchers out and 

coupon promotions out and to investigate and document any 

variance noted. 25 C.F.R. § 543.24(d)(l)(iii); 

u. at least monthly, the gaming operations must review statistical 

reports for any deviations from the mathematical expectations 

exceeding a threshold established by the TGRA for bingo and 

investigate and document any deviations compared to the 

mathematical expectations required by 25 C.F.R. § 547.4. 

25 C.F.R. § 543.24(d)(l)(iv); 

v. at least annually, all computerized player tracking systems must be 

reviewed by agent(s) independent of the individuals that set up or 

make changes to the system parameters. The review must be 

performed to determine that the configuration parameters are 

accurate and have not been altered without appropriate management 

authorization, and test results must be documented and maintained. 

25 C.F.R. § 543.24(d)(4)(iii); and 

w. at least quarterly, unannounced currency counter and currency 

counter interface (if applicable) tests must be performed, and the 

test results documented and maintained. All denominations of 

currency and all types of cash out tickets counted by the currency 

counter must be tested. 25 C.F.R. § 543.24(d)(8)(i). 

5 
D. Circumstances of the Violation 

1. The Nation is a federally recognized Indian Tribe with tribal headquarters 

in Wewoka, Oklahoma. 

2. The Nation operates three facilities at which it offers both Class II and 

Class III gaming: the Seminole Nation Casino in Seminole, OK; the River 

Mist Casino in Konowa, OK; and the Wewoka Trading Post Casino in 

Wewoka, OK. 

3. Between 1999 and 2002, the Nation: operated Class III gaming without a 

compact;2 continued play of the games despite the issuance of 3 warning 

notices, a notice of violation, a proposed civil fine assessment, and a 

temporary closure order to stop the play of Class III games; and further 

expanded the illegal gaming, leading to another notice of violation, 

proposed civil fine assessment, and a temporary closure order of all of the 

Nation's facilities. 

4. The Nation appealed the notices of violation, proposed civil fine 

assessments, and the temporary closure orders to the Commission. In May 

2002, the Commission affirmed the notices of violation and closure orders, 

which the Nation appealed to federal court. In June 2003, the Commission 

assessed a combined civil fine in the amount of $11,276,000.00. 

5. In December 2003, the Nation and the Commission reached a settlement 

in the federal suit. As part of that agreement, the Nation agreed to pay the 

civil fine. The Nation makes quarterly civil fine payments of 10% of its 

net gaming revenue toward the satisfaction of the fine. 

6. On January 20, 2012, the Nation re~uested that the Commission waive the 

balance remaining on the civil fine. 

7. By letter dated November 14, 2012, the Commission declined to waive the 

fine, indicating that "the AUP reports from the past several years show a 

pattern of high risk practices that are noncompliant with NIGC 

regulations." 

8. The Commission indicated, however, that it would waive the remaining 

fine balance provided the Nation demonstrated, for a period of three years 

that it had: corrected the significant findings noted in the AUP reports for 

fiscal years 2011 and 2012; and demonstrated a level of internal control 

oversight that ensures compliance with NIGC regulations. 

2 The Nation now has a tribal-state compact for the lawful operation of Class III gaming. 3 This was the fifth time the Nation petitioned the Commission for waiver or reduction of the civil fine. The 

details of the prior requests are not relevant here. 

6 
9. Less than a year later, on June 13, 2013, the Nation requested a reduction 

or waiver of the remaining balance, arguing that the balance would be 

fully paid within the three year time frame. 

10. The Commission agreed to stay payment of the civil fine and review 

whether the Nation corrected the significant findings from the 2011 and 

2012 AUP reports and whether it could otherwise demonstrate compliance 

with NIGC regulations. 

11. Toward that end, between mid-2013 and early 2015, NIGC staff reviewed 

the Nation's internal audit function for the fiscal years ending September 

30, 2012, September 30, 2013, and September 30, 20144

, the consolidated 

audited financial statements and the AUP reports for the three gaming 

operations for those years, management responses to the AUP reports, 

internal audit plans of action, and 6-month review follow up reports. 

12. The purpose of our review was to the determine ifthe Nation corrected the 

significant findings noted in the AUP reports for the fiscal years ended 

September 30, 2011, and September 30, 2012, and to assess the overall 

effectiveness of the Nation's internal audit process to determine the level 

of compliance by the gaming operations with the adopted TICS. As part of 

this review we assessed the Nation's internal audit function for fiscal years 

2012, 2013, and 2014. 

13. The most significant and troubling finding, with respect to all three 

gaming operations, was that NIGC staff was unable to determine 

whether appropriate follow-up was conducted, and whether necessary 

measures were taken to correct the significant AUP findings from 

2011 and 2012, because basic documentation required by 25 C.F.R. § 

543.23(c)(4) to be maintained was not kept and follow-up regulatory 

requirements were not implemented, as discussed below. 

14. In particular, NIGC staff found that the Nation's internal audit department 

failed to adequately produce documentation to evidence the work it 

performed or the conclusions it reached including the documents 

examined, testing procedures performed, or the persons interviewed for 

the completion of routine audit checklists. See 25 C.F.R. § 543.23(c)(4). 

15. The internal audit function was not able to provide sufficient audit 

evidence to determine whether the gaming operations were in substantial 

compliance with the TICS. NIGC provided on-site training to the 

Nation's internal audit staff the week of May 27, 2014, covering topics 

for achieving an effective internal audit function including: adequate 

4 The internal audit process represents a vital element in the protection of tribal assets, the preservation of 

operational integrity, and the evaluation and improvement of effective risk management, control, and 

governance practices. 

7 
documentation; testing procedures; audit checklist completion; report 

writing; audit file maintenance; internal audit requirements; and follow-up 

audit procedures. In August 2014, NIGC staff conducted on-site training 

for the Nation on the minimum bankroll formula calculation. 

16. NIGC staff returned the week of January 12, 2015, to review the internal 

audit function for fiscal year 2014 and discovered that despite the training 

provided, the Nation still did not maintain sufficient audit evidence to 

determine whether the gaming operations were in substantial compliance 

with the TICS. . 

17. On July 24, 2015, I wrote to Willis Deatherage, SNGA Chairman and 

expressed grave concerns about the Nation's ability to adequately protect 

its gaming operations. 

18. Between September 8 and 25, 2015, NIGC audit staff conducted an on'-site 

Internal Control Assessment and an internal audit review of the Nation's 

three gaming operations. 

19. The ICA was a study and evaluation of the system of internal controls 

specific to the conduct and recognition of gaming related transactions 

governing cash handling, documentation, game integrity, and auditing of 

the three gaming operations. The objective was to observe and test to 

measure compliance with NIG.C MICS. The examination was made for the 

time period beginning February 1, 2015, through July 31, 2015, (the 

testing period). The results continued to show significant areas of noncompliance. 

20. A review of the internal audit function continued to show that the Nation 

was unable to produce sufficient audit evidence to determine whether the 

three gaming operations were in substantial compliance with the TICS. 

Moreover, at least some of the significant findings discovered by NIGC 

staff should also have been identified by the Nation's internal audit staff; 

yet none were. In addition, the internal audit work papers and audit files 

were still not adequately prepared to evidence the internal audit work 

performed, including all instances of noncompliance. The internal audit 

department neither properly documented the conclusions reached, nor the 

resolution of all exceptions. 

21. During the testing period, the SNGA had neither established TICS 

regarding, nor had the three operations implemented SICS for a data 

recovery policy as required by 25 C.F.R. § 543.200). As a result, data 

recovery procedures are not tested on an annual basis, with documentation 

of results. 

8 
22. During the testing period, the SNGA had not established TICS, nor had 

the three operations implemented SICS for computerized player tracking 

systems to ensure the review of authorization documentation for all 

manual point additions/deletions for propriety; exception reports, 

including transfers between accounts; and documentation related to access 

to inactive and closed accounts, in violation of25 C.F.R. § 

543.24( d)( 4)(ii)(A)-(C). 

23. During the testing period, the SNGA had not established TICS, nor had 

the three operations implemented SICS for the verification of the receipt, 

issuance, and use of controlled inventory, including but not limited to 

keys, and pre-numbered and/or multi-part forms, on at least a monthly 

basis. 25 C.F.R. § 543.24(d)(10)(i). 

24. During the testing period, the three operations had not implemented SICS 

for the review of variances noted by the "Class II system that include 

cashless transactions in and out, external bonus payouts, vouchers out, and 

coupon promotions out." 25 C.F.R. § 543.24(d)(l)(iii). 

25. During the testing period, the three operations had not implemented SICS 

to ensure the monthly footing of a randomly selected sample of redeemed 

bingo vouchers and the tracing of the totals to the totals recorded in the 

voucher systems and to the amount recorded in the applicable cashier's 

accountability document. 25 C.F.R. § 543.24(d)(l)(v). 

26. During the testing period, the three operations were not performing 

monthly reviews of promotional payments in accordance with the rules 

provided to patrons. 25 C.F.R. § 543.24(d)(4)(i). 

27. During the testing period, the three gaming operations did not maintain 

records of the initial meter readings related to installed game servers and 

player interfaces. 25 C.F.R. § 543.8(g)(3)(i)(I). 

28. During the testing period, the three gaming operations did not maintain 

sufficient installation testing documentation that included testing of 

communication with the Class II gaming system, the accounting system, 

and the player tracking system; currency and vouchers to bill acceptors; 

voucher printing, meter incrementation, pay tables for verification; player 

interface denominations; all buttons to ensure they are operational and 

properly programmed; system components; and locks. 25 C.F .R. § 

543 .8(g)(5)(i)(A)-(K). 

29. During the testing period, the Seminole Nation Casino and Wewoka 

Trading Post s5 policy of tickets expiring in 24 hours is contrary to the 

5 The Report of Audit Exceptions for each gaming operation incorrectly states that this violation was noted 

at all casinos. It was not noted at River' Mist. 

9 
redemption policy stated on the tickets and in the ticket validation system. 

It was discovered that "expired" cash-out tickets totaled more than 

$75,000 between the two operations for fiscal year 2015. As a result, the 

operations are not honoring valid vouchers and not ensuring patrons are 

paid the appropriate amount, a business practice that calls into question 

game integrity. 25 C.F.R. § 543.8(i)(l)(ii). 

30. During the testing period, for all three operations the minimum bankroll 

calculation dated June 30, 2015, was inaccurate. Currency maintained in 

gaming areas other than the cage were not included and recorded. In 

addition, the Seminole Nation Casino had a deficiency for its next 

business day cash requirement. 25 C.F.R. § 543.18(c)(4). 

31. During the testing period, the River Mist and Wewoka Trading Post 

operations' vault inventories were not counted independently by at least 

two agents. It was observed that vault personnel counted their funds but no 

other employee performed a second count. The manager on duty signed 

the vault inventory control documentation but did not perform an actual 

independent count. 25 C.F.R. § 543.18(c)(3). 

32. During the testing period, it was determined that documentation for each 

remote access system support session is not maintained at the place of 

authorization. The Information Technology Department lacks oversight 

and system access control over gaming machine vendor remote access 

sessions. Consequently, vendors retain direct connectivity into their 

respective gaming servers. Furthermore, Information Technology has no 

insight into reporting or monitoring of gaming system performance and 

receives no report generations from each vendor. 25 C.F.R. 

§ 543.20(h)(l)(i)-(vii) and (2). 

33. During the testing period, the surveillance system at River Mist6 did not 

monitor and record a general overview of activities occurring in each cage 

and vault area with sufficient clarity to confirm the amount of each cash 

transaction. 25 C.F.R. § 543.21(c)(4)(i). 

34. During the testing period, the surveillance system at River Mist7 did not 

monitor and record a general overview of all areas where cash or cash 

equivalents may be stored or counted. 25 C.F.R. § 543.21(c)(4)(i). 

3 5. During the testing period, a comparison of the recorded accountability of 

assets to actual assets at periodic intervals was not completed as required 

at the three operations. 25 C.F.R. § 543.23(b)(2)(ix). 

6 The surveillance function was not tested at Seminole Nation Casino or Wewoka Trading Post. 7 The surveillance function was not tested at Seminole Nation Casino or Wewoka Trading Post. 

10 
36. During the testing period, the review of statistical reports for any 

deviations from the mathematical expectations exceeding a threshold was 

not completed on a monthly basis as required. 25 C.F.R. 

§ 543.24(d)(l)(iv); 

36. During the testing period, an annual review of the computerized player 

tracking system parameters to ensure they are accurate and have not been 

altered was not completed by agent(s) independent of the individuals that 

set up or make changes to the system parameters. 25 C.F .R. § 

543.24( d)( 4)(iii). 

37. Four quarterly unannounced testing procedures were not performed on the 

drop and count function for the fiscal year ending September 30, 2015. 

25 C.F.R. § 543.24(d)(8)(i). . 

38. Between May 2013 and September 2015, NIGC staff provided over 1700 

hours of on-site training and technical assistance to the Nation. 

39. On February 25, 2016, I and other NIGC representatives addressed a 

meeting of the Seminole Nation Tribal Council in Seminole, OK. At that 

time I expressed that I had substantial concerns about the ongoing lack of 

compliance with internal control standards at the Nation's three gaming 

facilities, as well as concerns about the Nation's regulatory oversight of 

these facilities. Some of the specific violations set forth herein were 

discussed at that meeting and I was clear that this NOV was the probable 

next step. 

40. The above described violations indicate that the Nation has not met the 

objectives of providing reasonable assurances that: the gaming ope(ations 

are in compliance with all applicable tribal, state, and federal laws and 

regulations; the assets are adequately safeguarded; and the integrity of the 

gaming operations are preserved. 

E. Measures and Time Required to Correct the Violation 

As detailed above, the NIGC has expended a substantial amount of time and effort 

over the last several years to assist the Nation in correcting these violations. I am 

therefore not confident that additional time will result in substantial compliance. 

More importantly, the more time passes, the less confidence I have that controls 

are in place at the Nation's gaming operations adequate to ensure that the Nation 

is the primary beneficiary of the gaming operations and that gaming is conducted 

fairly and honestly by both the operations and players. 

NIGC regulations at 25 C.F.R. § 573.3(a)(4) require a reasonable amount of time 

be allowed to make corrections following an NOV. The Nation has been aware of 

the internal audit areas of non-compliance for several years. The NIGC advised 

11 
the Nation of the results of the ICA by letter dated January 28, 2016. Thus, thirty 

days from the date of service of this NOV is reasonable. The Nation has until 

June 19, 2016 to bring the three gaming operations and the SNGA into 

substantial compliance by establishing and implementing all MICS, TICS, and/or 

SICs discussed herein. Failure to do so could result in a temporary closure order. 

25 C.F.R. § 573.4 (a) (l)(i). 

F. Appeal 

Within thirty (30) days after service of this Notice of Violation, the Nation may 

appeal to the full Commission. The Nation may request a hearing under 25 C.F.R. 

Part 584, or may waive its right to an oral hearing and instead elect to have the 

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

under 25 C.F.R. Part 585. In either event, a notice of appeal shall be submitted to 

the National Indian Gaming Commission, c/o DOI, 1849 C Street, NW, MS# 

1621,Washington, DC 20240. Please also provide a copy via email to 

maria_getoff@nigc.gov. The Nation has a right to assistance of counsel in such an 

appeal. A notice of appeal must reference this NOV. 

If the Nation elects to have a hearing, within ten (10) days after filing a notice of 

appeal, it must file with the Commission a brief that states with particularity the 

relief desired and the grounds therefore and that includes, when available, 

supporting evidence in the form of affidavits. 25 C.F .R. § 5 83 (b )(2). If the 

Nation wishes to present oral testimony or witnesses at the hearing, it must 

include a request to do so with the brief. The request to present oral testimony or 

witnesses must specify the names of proposed witnesses and the general nature of 

their expected testimony, whether a closed hearing is requested and why. 25 

C.F.R. § 584.3(b). 

G. Fine-Submission oflnformation 

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

Respondent in an amount not to exceed $25,000 per violation per day. Under 25 

C.F.R. § 575.S(a), the Nation may submit written information about the violation 

to the Chairman within fifteen (15) days after service of this NOV (or such longer 

period as the Chairman may grant for good ca1:1se). The Chairman shall consider 

any information submitted in determining the facts surrounding the violation and 

the amount of the civil fine, if any. 

Dated this 2t1~ f May, 2016 

,. 

12 
Certificate of Service 

I certify that this Notice of Violation was sent by facsimile transmission and certified 

U.S. mrul, return receipt requested, on this 201

h day of May, 2016 to: 

Leonard M. Harjo, Principal Chief 

Seminole Nation of Oklahoma 

P;O. Box 1498 

Wewoka, OK 74884 

Terry Hale, Interim Chief Gaming Regulator and Agent for Service 

Seminole Nation Gaming Agency 

2015 W. Wrangler Blvd. 

Seminole, OK 74868 

13