Lasted Updated 2019

Human Trafficking Questions &Answers

1. What authority does the NIGC have in regard to Human Trafficking (e.g., labor or sex 

trafficking)?

IGRA and NIGC regulations require Tribes to operate gaming facilities in a manner that 

adequately protects public health and safety. In addition, Tribes must include this mandate 

in their gaming ordinances. If conditions exist that threaten public health or safety - by 

posing a real and immediate threat that may result in serious harm, the NIGC may 

immediately order the gaming operation to close as well as issue a notice of violation 

against the Tribe and the operation’s management contractor. By closing the gaming 

operation, the NIGC addresses the real and immediate threat that Human Trafficking poses to 

human health and well-being. Subsequently, the NIGC may issue civil fines against the 

Tribe and management contractor too. 

2. What may NIGC do in regard to individuals involved in Human Trafficking?

If a gaming operation’s management contractor is an individual, the individual may be 

subject to a notice of violation and civil fine. If a gaming operation’s primary 

management officials or key employees are involved in Human Trafficking, the NIGC will 

notify the Tribe that it must suspend these employees’ gaming licenses. And if these 

individuals seek employment at other Tribes’ gaming operations, the NIGC will object to 

the issuance of their gaming licenses. In sum, an individual’s involvement in Human 

Trafficking serves as immediate and future grounds for revoking and denying their gaming 

license. 

3. How does the NIGC monitor public health and safety at gaming operations?

NIGC Compliance Officers visit gaming operations, conducting compliance reviews; 

receive information from tribal gaming commissioners, officials, employees, and witnesses; 

and request documents or other evidence. IGRA and NIGC regulations allow the NIGC to 

request public health and safety information at any time given IGRA’s Environment, 

Public Health and Safety (EPHS) mandate but also specifically when reviewing gaming 

ordinances for approval and as part of facility license submissions for new or reopened 

gaming facilities. 

4. How does NIGC coordinate addressing Human Trafficking violations with other federal, 

state, and tribal law enforcement agencies?

IGRA directs the NIGC to refer violations of federal, state, and tribal law to the 
Lasted Updated 2019

appropriate law enforcement officials. So, if evidence exists of Human Trafficking 

violations, NIGC will refer the matter to: the F.B.I. and Department of Justice, given the 

federal human trafficking laws that may be implicated; to state law enforcement, if the 

potential violation occurs in a state having criminal jurisdiction over the Indian lands or 

reservation (Public Law 280); and to tribal law enforcement, if tribal laws are implicated. 

5. What is the NIGC doing in regard to Human Trafficking?

NIGC is working diligently to raise awareness regarding Human Trafficking and 

encourage Tribal gaming operators and officials to take proactive prevention measures. The 

NIGC is in regular contact with other federal and non-federal agencies and groups to help 

raise awareness of Human Trafficking and share resources with Tribes. Historically, NIGC 

offered Human Trafficking training as part of its annual regional training courses 

throughout the country. In 2020, NIGC transitioned to providing that training online through 

webinars. In short, the goal is to equip the tribal gaming industry with resources to deter Human 

Trafficking.