Fred Thomas 

Chairman 

Kickapoo Tribe in Kansas 

P.O. Box 271 

Morton, KS 66439-0271 

Dear Mr. Thomas: 

 his letter responds to your request to review and approve 

the amendment to the Kickapoo Tribe in Kansas's tribal gaming 

ordinance submitted on May 20, 1996. The amendment was adopted 

by Resolution No. 96-39A on April 26, 1996. The ordinance was 

approved by the Chairman of the National Indian Gaming Commission 

(NIGC) on July 15, 1994 and amended on July 31, 1995. The 

amendment does not require approval by the NIGC because the 

amendment addresses issues not raised in the IGRA - or the NIGC's 

regulations. - 

Under the IGRA and the regulations of the NIGC, the Chairman 

is directed to review ordinances and amendments with respect to I 

the requirements of the IGRA and the implementing regulations. 

Thus, the scope of the Chairman's review and approval is limited 

to the requireme-nts of the IGRA and the NIGC regulations. 

Provisions other than those required under the IGRA or the NIGC 

regulations that may be included in a tribal ordinance are not 

subject to review and approval. 

Thank you for submitting the Kickapoo Tribe in Kansas's 

amendment for review. If you have questions or require further 

assistance, please contact Jessica Roff at (202) 632-7003. 

... -. incerely y\otg~ '=LYY3- 

- ~akold A. Monteau 

Chairman 

1441 L STREET. N.W. 9TH FLOOR WASHINGTON, D.C. 2000'; EL.: 202-632-7003 FAX: 202-632-7066 
Resolution No.%-39A 

RESOLUTION 

WHEREAS, the Kickapoo Tribe of Indians of the Kickapoo ReSe~ation inKansas is organized in accordance 

with the provisions of the Indian Reorganization Act of June 18, 1937, (Stat. 984), and 

WHEREAS, the Kickapoo Tribe of Indians of the Kickapoo Reservation in Kansas is empowered by the 

Kickapoo Constitution and By-laws approved by the Seaetary of Interior on February 26, 1937, 

and 

WHEREAS, the Indian Gaming Regulatory Act, Pub. L 100-497, U.S.C. Section 2701 et seq. needs a gaming 

commission, and 

WHEREAS, the Kickapoo tribe has the responsibility to protect the public interest and the integrity of the 

gaming commission, and 

WHEREAS, the Kickapoo Tribal Council adopted the Kidcapo Tribal Gaming Commission Ordinance July 

10, 1995, and 

WHEREAS, Tribal Ordinance (the Tribal Gaming Commission Ordinance No.95-01) authorized the Tribal 

Gaming Commission to license persons engaged in gaming activities on the resewation , and 

employ and license gaming commission staEf and employees; and 

WHEREAS, the Tribal Gaming Commission has recommended amendments to Section 5 (e) and 7 (b) of the 

Ordinance No. 95-01, and 

WHEREAS, the Tribal Council has reviewed and considered the recommendations of the Garmng 

Commission, and believe that the amendments will enable the Gaming Commission to better 

perform its duties and responsibilities. 

NOW THEREFORE BE IT ORDAINED, that the attached Amended Kickapoo Nation Tribal Gaming 

Commission Ordinance is hereby approved. 

AND BE IT FURTHER ORDAINED, that amendments Sec. 5 (e) and 7 (b) of the Tribal Gaming 

Commission Ordinance is hereby approved and effective on this 26th date of April 19%. 
CERTIFICATION 

The foregoing Ordinance was adopted by the Kickapoo Tribal Council in a special session on this &th day of 

April 1996, at which la members of the Tribal Council were present, constituting the required quorum, with 3 

voting for, against, _g abstaining with the Chairman not voting. 

c 0 ~TvW a! 

Fred 'I'hoth, Chainnan 

Kickapoo Tribe in Kansas 

Bobbi Darnell, Secretary 

Kickapoo Tribe in Kansas 
AMENDED 

Y 

KICKAPOO NATION TRIBAL GAMING COMMISSION ORDINANCE 

SECTION 1. STATEMENT OF POLICY. It is the purpose of this 

ordinance to provide for the sound regulation of all gaming activities on lands within 

the jurisdiction of the Kickapoo Nation in Kansas, in order to protect the public 

interest in the integrity of such gaming activities, to prevent improper or un1awfi.d 

conduct in the course of such gaming activities, to strengthen tribal self-government 

and to promote economic self-suf5ciency of the Kickapoo Nation. 

SECTION 2. -. For purposes of this Ordinance: 

(a) "Act" means the Indian Gaming Regulatory Act, Pub.. 100-497, 25 

U.S.C. 2701 et seq. 

@) "Chairman" means the Chairman of the Kickapoo Tribal Gaming 

Commission established by this Ordinance. 

(c) "Class I1 gaming" means Class 11 gaming as defined in accordance 

with the Act, 25 U.S.C. 2703 (7) (A). 

(d) Class III gaming" means Class 111 gaming as defined in accordance 

with the Act, 25 U.S.C. 2703 (8). 

(e) "Commission" means the Kickapoo Tribal Gaming Commission 

established by this Ordinance. 

(f) "Compact" means the Kickapoo Nation in Kansas - State of Kansas 

Gaming Compact. 

(g) "Enterprise" means the Kickapoo Gaming Enterprise established by the 

Tribe to conduct all gaming operations of the Tribe on the Reservation. 
(h) "Executive Director" means the Executive Director of the Kickapoo > 

Tribal Gaming Commission established pursuant to this ordinance. 

(I) "Gaming employee" means a gaming employee as defined in the 

' Compact, and includes primary management officials and key employees of the 

gaming operation. 

Cj) "Gaming facilities" means any room or rooms in which Class I1 gaming 

or Class 111 gaming is conducted on the Reservation. 

(k) "National Indian Gaming Commission" means the National Gaming 

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

(1) ''Net revenues" means gross revenues of a Class 111 gaming activity 

less amounts paid out as, or paid for, prizes and total operating expenses including 

debt service but excluding management fees paid to a management contractor within 

the meaning of 25 U.S.C. 2711 (c). 

(m) c'Ordinance" means this kckapoo Nation Tribal Gaming Ordinance. 

(n) "State" means the State of Kansas. 

(0) "State gaming agency" means the Kansas Lottery or a division thereof 

or such other agency of the State as may fi-om time to time be designated by written 

notice to the Tribe as the single state agency responsible for oversight of Class I11 

gaming as authorized by the Compact. 

(p) "Tribe" means the Kickapoo Nation in Kansas. 

SECTION 3. ADOPTION OF COMPACT. The Compact is hereby 

incorporated within and enacted as an integral part of this Ordinance with respect to 

all forms of Class 111 gaming, and the Compact including the Appendices thereto is 

appended to and made a part of this Ordinance as if set forth in hll herein; 

provided, however, that nothmg in the adoption of the Compact herein shall be 

deemed to affect the operation by the Tribe of any Class I1 gaming, whether 

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conducted with or without the gaming facilities, or to confer upon the State any 

jurisdi'ction over such Class I1 gaming conducted by the Tribe on its Reservation. 

SECTION 4. ACTIVITIES, 

(a) of Class III -I (1. The Tribe may conduct or 

operate all forms of Class III gaming authorized under the Compact. 

(b) I1 gaming. In addltion to the forms of Class III 

gaming authorized pursuant to section 4 (a) hereof, the Tribe shall be authorized to 

conduct all fonns of Class I1 gaming. 

SECTION 5. ACT. This Orhance shall 

be construed in a manner which conforms to the Act in all respects, and if 

inconsistent with the Act in any manner the provisions of the Act shall govern. 

(a) son .. . In compliance with 25 U.S.C. 2710 

(b) (2) (A), the Tribe shall have the sole proprietary interest and responsibility for 

the conduct of any gaming activity on the Reservation; provided, however, that 

nothing herein shall (I) preclude the Tribe fiom entering into a Management 

Contract as authorized under 25 U.S.C. 271 1; or (ii) interfere with the exercise by 

any secured party of its rights under any duly approved collateral lease, leasehold 

mortgage or other iinancing agreement with the Tribe to enforce its security interests 

in the premises on which such gaming activities may be conducted, or to enforce its 

rights against gross revenues of the Tribe fiom its gaming activities for the purpose 

of repayment of the debt obligations of the Tribe to such secured party in 

accordance with the provisions of such agreements. 

(b> of net revenues. In compliance with 25 U.S.C. 27 10 (b) 

(2) and(3), net revenues fiom any gaming activity are not to be used for purposes 

other than: 
conducted withm or without the gaming facilities, or to confer upon the State any \ 

jurisdiction over such Class I1 gaming conducted by the Tribe on its Reservation. 

SECTION 4. ON FOR GAMING ACTNUEL 

(a) -. The Tribe may conduct or 

operate all forms of Class III gaming authorized under the Compact. 

(b) Class I1 gaming. In addtion to the forms of Class 111 

gaming authorized pursuant to section 4 (a) hereof, the Tribe shall be authorized to 

conduct all forms of Class II gaming. 

SECTION 5. ACT. This Ordinance shall 

be construed in a manner which conforms to the Act in all respects, and if 

inconsistent with the Act in any manner the provisions of the Act shall govern. 

.. . (a) q. In compliance with 25 U.S.C. 271 0 

(b) (2) (A), the Tribe shall have the sole proprietary interest and responsibility for 

the conduct of any gaming activity on the Reservation; provided, however, that 

nothing herein shall (I) preclude the Tribe from entering into a Management 

Contract as authorized under 25 U.S.C. 271 1; or (ii) interfere with the exercise by 

any secured party of its rights under any duly approved collateral lease, leasehold 

mortgage or other financing agreement with the Tribe to enforce its security interests 

in the premises on which such gaming activities may be conducted, or to enforce its 

rights against gross revenues of the Tribe fiom its gaming activities for the purpose 

of repayment of the debt obligations of the Tribe to such secured party in 

accordance with the provisions of such agreements. 

(b) s. . . In compliance with 25 U.S.C. 27 10 (b) 

(2) and(3), net revenues from any gaming activity are not to be used for purposes 

other than: 

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(I) to fund tribal government operations or programs; 9 

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

(iii) to promote tribal economic development; 

(iv) to donate to charitable organizations; 

(v) to help find operations of local government agencies, or 

(vi) any other purposes permitted under the Act. 

(c) Annula&. In compliance with 25 U.S.C. 2710 (b) (2) (C) and 

(D), all gaming activities shall be subject to an audit by independent certified public 

accountants, not less than annually, and copies of the annual audit shall be provided 

to the National Indian Gaming Commission. All contracts for supplies, services, or 

concessions for a contract amount in excess of $25,000 annually (except contracts 

for professional legal or accounting services) relating to Class I1 or Class 111 gaming 

shall be subject to such audits. 

(dl ty standards. In compliance with 25 U.S.C. 2710 (b) (2) 

(E), the construction and maintenance of any gaming facilities, and the operation of 

gaming activities, shall be conducted in a manner which adequately protects the 

environment and the public health and safety and for that purpose shall comply with 

the requirements of the Compact and all other applicable health, safety and 

environmental standards enacted by the Tribe. 

(e) . . mvestgahm and hcensing. In compliance with 25 

U.S.C. 2710 (B) (2) (F): 

(i) all gaming employees, including all primary management 

officials and key employees of any gaming enterprise, shall be 

subject to the background investigation and licensing 

requirements of IGRA, this Ordinance and the Compact which 

include requirements for initial background investigations and 

ongoing review for all gaming employees. The Tribe shall 

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notifjr the National Inhan Gaming Commission of the 

results of the licensing process for its primary management 

officials and key employees in accordance with such regulations 

or procedures as the National Indian Gaming Commission may 

establish. 

(ii) before issuing a license to a gaming employee, the 

Commission shall forward the results of the appropriate 

background investigation to the National Indian Gaming 

Commission in such fonn as shall be required by the National 

Indian Gaming Commission. 

(iii) if the Commission determines, on the basis of the 

background investigation conducted under subsection (i) and 

such other information as it may obtain, that the applicant is 

qualified for a gaming employee license, the commission may, 

but shall not be required to issue such license. The Commission, 

at its sole discretion, may impose any qualifications to such 

license it deems appropriate, or may refuse to issue such license 

despite an applicant's qualifications. 

(iv) All persons who are not gaming employees but work at 

any facility where authorized gaming occurs or is supervised or 

administered, must obtain a non-gaming work permit. Such 

work permits shall be issued upon determining that the employee 

is not a threat to the effective regulation of gaming and creates 

no risk or enhances no danger of unfair or illegal practices, 
methods or activities in the conduct of gaming on the 

reservation. All applicants for work permits shall provide the 

dormation required in the Compact. 

(v) Any person or entity proposing to sell or lease Electronic 

Games of Chance or other Gaming Services to the Tribe shall be 

licensed to do so. The procedures for such license and the 

standards therefore are the same as those applicable to gaming 

employees herein, except that if applicant is a corporation, trust 

or partnership, applications must be made by any person or 

entity holding 10% or more of any beneficial or legal interest 

therein. 

(vi) The Tribe may employ, and the Gaming Commission may 

license an applicant for a position as a key employee, 

gaming employee, manufacturer-distributor, 

pnmary management official, standard gaming employee, 

state gaming agency employee, and management 

contractor, in accordance with the following procedure: 

(aa) The applicant must sign a privacy notice release as 

set forth in the Indian Gaming Regulation Act, and 

provide other information which permits the Gaming 

Commission to conduct an investigation of 

the applicant's criminal history, credit hstory, and drivers 

license history; (bb) If the applicant's criminal hstory, 

credit history, and drivers license history meet the 

standards of IGRA and Section 2 1 of the Compact, then 
the applicant may be issued a gaming license pending 

completion of the investigation by the Garmng Commission and 

State Gaming Agency in accordance with Mer requirements of 

the Compact. (cc) The applicant must represent by affidavit 

that he or she meets the licensing standards of Section 21 of the 

Compact, and any applicant who so represents and who is 

subsequently found to be in violation of any of such licensing 

standards during the term of his or her employment shall be 

dismissed. Any applicant employed under this subsection shall 

not acquire any rights of permanent employment. The Gaming 

Commission shall not be required to reveal the sources of 

information obtained in the course of any such investigation. 

SECTION 6. I?IwuES. Any individual who violates any 

provision of this Ordinance, including the provisions of the Compact incorporated 

herein, shall be subject to civil penalties including exclusion fiom employment by 

any Tribal gaming enterprise, exclusion fiom attendance at any Tribal gaming 

facility, exclusion fiom the Reservation if a non-member of the Tribe, or, with 

respect to any person subject to the jurisdiction of the Tribe to impose such fines, a 

fine of not more than $500.00 for each such violation. The Commission established 

pursuant to this Ordinance shall have the jurisdiction to impose any such penalties 

on any person within the jurisdiction of the Tribe to impose such penalties on any 

person within the jurisdiction of the Tribe to impose such penalties. 

SECTION 7. CO-. 

(a) . . of Comrmsslon. There shall be established a Kickapoo 

Tribal Gaming Commission consisting of a chainnan and two other members who 

shall be appointed by the Tribal Chairman with the advice and consent of the Tribal 

Council, at least two of whom shall be members of the Tribe, but none of whom 

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shall be employees of the Enterprise, and who shall each serve for a term of three 

* 

years commencing on the date of their appointment; provided, that one of the initial 

members appointed shall be designated to serve for an initial term of one year and 

', one of the initial members appointed shall be designated to serve for an initial term 

of two years. The members of the Commission shall serve on a part time basis and 

the compensation of members of the Commission shall be established by the Tribal 

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

Members of the Commission may be removed for cause by a three-fourths (314) 

vote of the members of the Tribal Council. Vacancies in the Commission may be 

filled by appointment by the Tribal Chairman with the advice and consent of the 

Tribal Council. No member or employee of the Cornmission shall participate as a 

player in any gaming activity conducted by the Tribe. 

0) Powers and of Comrmsslon . . . The Commission shall have the 

following powers and duties: 

(i)(A) The Commission shall have primary responsibility for oversight 

of tribal gaming operations to assure the integrity of such 

operations and shall, for that purpose, employ non-uniformed 

inspectors, who may be present in all gaming facilities during all 

hours of operation and who shall be under the sole supervision 

of the commission and not under the supervision of any 

management employees of the Tribal gaming operations. Such 

inspectors shall have unfettered access to all areas of the gaming 

facilities at all times, and personnel employed by the Enterprise 

shall for such purposes provide such inspectors access to locked 

and secure areas of the gaming facilities in accordance with the 

standards of operation and management promulgated pursuant to 

the Compact. Such inspectors shall report to the Commission 
regarding any failure by the Enterprise to comply with any of the 

provisions of the Compact or this Ordinance and any other 

applicable laws and ordinances. Inspectors assigned by the 

Commission may also receive consumer complaints within the 

gaming facilities and shall assist in seeking voluntary resolution 

of such complaints. Inspectors appointed by the Commission 

shall be licensed as gaming employees in accordance with the 

Compact. 

(B) The Commission shall have primary responsibility for, and 

supervision over, the Surveillance Department and shall 

have the authority to employ and license surveillance staff 

and personnel in accordance with the procedure outlined 

in subsection 5 (e) (vi) (aa), (bb) and (cc). 

(ii) The Commission may on its own initiative investigate any aspect 

of the operations of the Enterprise in order to protect the public 

interest in the integrity of such gaming activities and to prevent 

improper or un1awfi.d conduct in the course of such gaming 

activities, and shall investigate any report of a failure of the 

Enterprise to comply with the provisions of the Compact or this 

Ordinance and may require the Enterprise to take any corrective 

action deemed necessary by the Commission upon such terms 

and conditions as the Commission may compel any person 

employed by or doing business with the Enterprise to appear 

before it and to provide such information, documents or other 

materials as may be in their possession to assist in any such 

investigation. 
(iii) The commission shall carry out each of the responsibilities and % 

duties set forth for the Tribal Garmng Agency in the Compact, 

including the Standards of Operation and Management appended 

thereto. 

(iv) The Commission shall prepare a plan for the protection of public 

safety and the physical security of patrons in each of its gaming 

facilities, setting forth the respective responsibilities of the 

Commission, the security department of the Enterprise, any 

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

agency. 

(v) The Commission shall review and approve floor plans and 

surveillance systems for each gaming facllity and may confer 

with the State Gaming Agency regarding the adequacy of such 

plans and systems. 

(vi) The Commission shall promulgate, review and revise (as 

necessary) Standards of Operation and Management for Class 11. 

gaming activities in accordance with the Compact. In the event 

the Commission proposes revisions to those Standards, the 

Commission shall provide the Tribal Council with a copy of its 

proposed revisions at the same time the proposed revisions are 

provided to-the State Gaming Agency. If revisions to the 

Standards are adopted, the Commission shall provide the Tribal 

Council with written notice of the approved revisions with five 

(5) days. 
* 

(vii) The Commission may issue and revoke licenses for gaming 

employees in accordance with Section 4 (e) (i) of hs 

Ordinance. 

(viii) The Commission shall establish a list of persons barred from the 

gaming facilities because their criminal history or association 

with career offenders or career offender organizations poses a 

threat to the integrity of the gaming activities of the Tribe. 

(ix) The Commission shall promulgate, review and revise ( as 

necessary) the rules of each game of chance operated by the 

Tribe pursuant to the Compact and shall in accordance with the 

provisions of the Compact noti@ the State Gaming Agency of 

such rules and of any changes in such rules. In the event the 

Commission proposes changes to these rules, the Commission 

shall provide the Tribal Council with a copy of the proposed 

changes at the same time the proposed changes are provided to 

the State Gaming Agency. If changes to the rules are adopted, 

the Commission shall provide the Tribal Council with notice of 

the approved changes within five (5) days. 

(x) The Commission shall enforce the health and safety standards 

applicable to the gaming facilities of the Enterprise in 

accordance with section 5 (d) of this Ordinance. Prior to the 

opening of any facility for gaming the Enterprise shall obtain a 

certificate of compliance from the Commission relating to the 
gaming facilities. The Commission shall issue a certificate of 

compliance to the Enterprise upon a determination that the 

gaming facilities of the Enterprise comply with such standards. 

(xi) The Commission may impose penalties for violations of this 

Ordinance, the Compact or the Standards of Operation and 

Management in accordance with section 5 of this Ordinance. 

(xii) The Commission may in the name of the Tribe bring any civil 

action or criminal complaint in the courts of the Tribe, State or 

the United States to enforce the provisions of this Ordinance or 

to enjoin or otherwise prevent any violation of this Ordinance, 

the Act or the Compact, occurring on the Reservation. 

(xiii) The commission may receive any complaint fiom an employee 

of the Enterprise or any member of the public who is or claims 

to be adversely affected by an act or omission of the Enterprise 

or any employee thereof which is asserted to violate this 

Ordianance, the Compact, or the Standards of Management and 

Operation adopted pursuant to this Ordinance, and may impose 

such remedial action as it deems appropriate to bring the 

Enterprise into compliance with such provisions. The 

Commission may for this purpose, in its sole discretion, conduct 

a hearing and receive evidence with regard to such complaint if 

it deems an evidentiary proceeding useful in the resolution of 

such complaint. 

(xiv) The commission shall adopt an annual operating budget which 

shall be subject to the approval of the Tribal council and may in 

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accordance with said budget employ such staff fiom time to time 

as it deems necessary to fulfill its responsibilities under this 

Ordinance, and may retain legal counsel, consultants and other 

professional services including investigative services to assist the 

Commission with respect to any of the issues over which the 

Commission exercises jurisdiction. The expenses of the 

Commission in accordance with such budget shall be assessed 

against the Enterprise and the Enterprise shall pay such 

assessments to the Tribe. 

(c) -. The Chairman of the commission or any other member of 

the Commission acting in the absence of the Chairman may, whenever he deems it 

necessary to protect the public interest in the integrity of Tribal gaming operations, 

issue in the name of the Commission any order which the Commission has the 

power to issue, to the Enterprise or to any employee or contractor of the Enterprise 

or to any other person with the jurisdiction of the Tribe, to take any act or cease 

and desist from any action as may be required to protect the public interest; 

provided, that such order shall be subject to review by the Commission at its earliest 

opportunity, whereupon it may be confirmed or vacated by the Commission. 

(d) ve m. The Commission shall appoint an individual to 

serve as a Ml time Executive Director of the commission to administer its 

responsibilities on a day to day basis and to oversee inspectors appointed by the 

Commission as well as such other staff as the Commission may from time to time 

employ. The Executive Dvector shall be responsible for coordination the functions 

of the Commission with the State Gaming Agency and other state and local agencies 

as necessary. The Chairman may request the Executive Director to conduct a 

preliminary investigation and render a recommendation to the Commission with 

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

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investigation of any compliant, or any other action within the jurisdiction of the * 

Commission. The Executive Director shall have the power, in the name of the 

Commission, to conduct any hearing, investigation or inquiry, compel the production 

" of any infomation or documents, and otherwise exercise the investigator powers of 

the Commission, which the Commission may exercise under this Ordinance. 

(e) . . ocek of the Camrmsslan. 

(i) Regular meetings of the Commission may be self upon such 

notice, or without notice, and at such time and place as shall 

from time to time be fixed by the Commission. Unless otherwise 

specified by the Commission, no notice of such regular meetings 

shall be necessary. 

(ii) Special meetings of the Commission may be called by the 

Chairman or the Executive Director. the person or persons 

calling the special meeting shall £ix the time and place thereof. 

Neither the business to be transacted at, nor the purpose of, any 

regular or special meeting of the Commission need to be 

specified in the notice of the meeting. 

(iii) At any meeting of the Commission, a majority of the members 

then in office shall constitute a quorum for the transaction of 

business. The vote of a majority of the members present at a 

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

Commission. The chairman shall preside at all meetings of the 

Commission unless the Chairman designates another member to 

preside in his absence. 
(iv) Any action required or permitted to be taken at a meeting of the % 

commission may be taken without a meeting if all of the 

members sign written consents setting forth the action taken or 

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

date of such action. Such consents shall be filed with the 

minutes of the Commission, and shall have the same effect as a 

unanimous vote or resolution of the Commission at a legal 

meeting thereof. 

(v) Members of the Commission may participate in a meeting of the 

Commission by means of conference telephone or similar 

communications equipment by means of which all persons 

participating in the meeting can hear each other, and 

participation in a meeting in such matter by any member who 

does not object at the beginning of such meeting to the holding 

thereof in such manner shall constitute presence in person at 

such meeting. 

(vi) No action of the Commission to impose a penalty pursuant to 

section 5 of this Ordinance, or to revoke a license for a gaming 

employee previously issued by the Commission, shall be vahd 

unless the person affected is given at least seven days' notice of 

the proposed action and the opportunity to appear and be heard 

before the Commission, either in person or through a 

representative or legal counsel, and to submit such evidence as 

the Commission deems relevant to the matter at issue; provided, 

that if the Commission deems it necessary to protect the public 
interest in the integrity of the gaming activities, the Commission 

may take such action with irnrnedate effect as it deems required, 

and shall thereupon provide notice and an opportunity to be 

heard to the affected person as soon as is reasonable practicable 

following such action. Any person who is denied an initial 

gaming employee license or who is barred from the gaming 

facilities by action of the commission may request a hearing 

before the Commission by written request submitted within 

thuty days following receipt of notice of the action of the 

Commission, and the Commission shall thereupon afford an 

opportunity to appear and be heard before the Commission, 

either in person or through a representative or legal counsel, and 

to submit such evidence as the Commission deems relevant to 

the matter at issue and thereafter the Commission shall either 

afErm or reconsider its decision. Any hearing conducted under 

this sub-section may at the direction of the Commission be 

conducted by the Executive Director or by one or more members 

of the Commission designated by the Commission for that 

PurPose. 

(vii) The Commission may adopt such additional procedures and 

rules as it deems necessary or convenient to govern its affairs 

and which are consistent with this Ordinance. 

SECTION 8. ON ANTI MANAGEMENT. 

The initial standards of operation and management for games of chance adopted in 

acordance with the Compact shall be those set forth as Appendix A of the Compact. 

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3 

SECTION 9. m. 

It shall be a violation of ths Ordtnance for any person to: 

-, (a) Conduct or participate in any Class III gaming operation on the 

Reservation other than at the gaming facilities. 

@) Receive, distribute, apply or Qvert any property, hds, proceeds or 

other assets of the Enterprise to the benefit of any inQvidual or any other person 

except as authorized by tbis Ordianance and the Resolution of the Tribe establishmg 

the Enterprise. 

(c) Tamper with any equipment used in the conduct of tribal gaming 

operations with the intent to cause any person to win or lose any wager other than in 

accord with the purblicly announced rules of such gaming operations. 

(d) Do any other act in connection with the conduct of the tribal gaming 

operations with the intent to affect the outcome of any wager other than in accord 

with the publicly announced rules of such gaming operations. 

(e) To alter or misrepresent the outcome or other event on which wagers 

have been made after the outcome is made sure but before it is revealed to the 

players. 

(f) To place, increase or decrease a bet or to determine the course of play 

after acquiring knowledge, not available to all players, of the outcome of the game 

or any event that affects the outcome of the game or which is the subject of the bet 

or to aid anyone in acquiring such knowledge for the purpose of placing, increasing 

or decreasing a bet or determining the course of play contingent upon that event or 

outcome. 

(g) To claim, collect or take, or attempt to claim, collect or take, money or 

anydung of value in or fiom a gambling game, with intent to defiaud, without having 
made a wager thereon, or to claim, collect or take an amount greater than the > 

amount won. 

@) To place or increase a bet after acquiring knowledge of the outcome of 

' the game or other event which is the subject of the bet, including past-posting and 

pressing bets. 

(I) To reduce the amount wagered or cancel the bet after acquiring 

knowledge of the outcome of the game or other event whlch is the subject of the bet, 

including pinching bets. 

(j) To manipulate, with the intent to cheat, any component of an electronic 

game of chance or gaming device in a manner contrary to the designed and normal 

operational purpose for the component. 

(k) Knowingly to use other than coins or tokens approved by the Tribal 

Gaming Agency or other lawful coin, legal tender of the United States of America, 

or to use coin not of the same denomination as the coin intended to be used in the 

gambling game. 

(1) To possess, with the intent to use, any device toassist in projecting the 

outcome of the game, in keeping track of the cards played, in analyzing the 

probability of the occurrence of an event relating to the game, or in analyzing the 

strategy for playing or betting to be used in the game. 

(m) To use any device or means to cheat, or to possess any such device 

while at the gaming facility. 
CERTIFICATION 

The foregoing Kickapoo Nation Tribal Gaming Ordinance was duly adopted 

at a special session of the Kickapoo Tribal Council held on tlus 26th day of April 

1996, at which 6 Tribal Council members were present mmting the required 

quorum, by a vote of 5 for, 0 against, 0 abstaining with the Chairman not voting. 

Chairman, 

Kickapoo Tribal Council 

Attest: I\ 

Secretary, 

Kickapoo Tribal Council