AUG 2 5 I995 

Michael B. Jandreau, Chairman 

Lower Brule Sioux Tribe 

Lower Brule, SD 57548 

Dear Chairman Jandreau: 

This letter responds to your request to review and approve 

the tribal gaming ordinance, Ordinance No. LB-95-E, adopted on 

June 14, 1995, by the Lower Brule Sioux Tribe (Tribe). This 

letter constitutes such approval under the Indian Gaming 

Regulatory Act (IGRA). 

Under the IGRA and the regulations of the National Indian 

Gaming Commission (NIGC), the Chairman is directed to review 

ordinances with respect to the requirements of the IGRA and the 

implementing regulations. Thus, the scope of the Chairman's 

review and approval is limited to the requirements 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. Also, 

such approval does not constitute approval of specific games. It 

is important to note that the gaming ordinance is approved for 

gaming only on Indian lands as defined in the IGRA. 

With the Chairman's approval of the Tribe's gaming 

ordinance, the Tribe is now required to conduct background 

investigations on its key employees and pr-imary management 

officials. The NIGC expects to receive a completed application 

for each key employee and primary management official pursuant to 

25 C.F.R. S 556.5(a) and an investigative report on each 

background investigation before issuing a license to a key 

employee or primary management official pursuant to 25 C.F.R. 

S 556.5(b). 

Thank you for submitting the ordinance of the Lower Brule 

Sioux Tribe for review and approval. The NIGC staff and I look 

forward to working with you and the Tribe in implementing the 

IGRA. 

Sincerely yours, 

/7 

cc: Julian Brown, Esq. 

General Legal Counsel 

Lower Brule Sioux ~ribe 

P.O. Box 340 

Pierre, South Dakota 57501 . -".. ". . . ... 

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ORDINANCE NO. LB-95-E 

LOWER BRULE SIOUX TRIBAL C0V;NCIL 7 

REVISED TRIBAL OMNIBUS CLASS I1 AND CLASS I11 GAMING ORDINANCE 

The Lower Brule Sioux Tribal Council does hereby ordain: 

CHAPTER OF TEE LOWER BRULE SIOUX TRIBAL LAW AND ORDER CODE 

Section 1. Purpose. 

The Lower Brule Sioux Tribal Council (hereinafter "Tribal Co~ncil'~ or 

"Council") of the Lower Brule Sioux Tribe (hereinafter "Tribe") , empowered by the 

Tribe's Constitution to enact ordinances, hereby enacts this ordinance in order to 

set the terms for class I1 gaming and class I11 gaming operations on Tribal lands. 

Section 2. GAMING AUTHORIZED. 

Class I1 gaming and class I11 gaming as defined in the Indian Gaming 

Regulatory Act ("IGRA"), Pub. L. 100-497, 25 U.S.C. sec, 2703 (7) and sec. 2703 (8) 

(as amended, if applicable), and in the regulations promulgated by the National 

Indian Gaming Commission, 25 C.F.R. Sec. 502.3 and sec. 502.4 (as amended, if 

applicable), is hereby authorized. 

SECTION 3. OWNERSHIP OF GAMING. 

The Tribe shall have the sole propriety interest in and responsibility for the 

conduct of any gaming operation authorized by this ordinance. 

SECTION 4. DESIGNATED AGENT FOR SERVICE OF PROCESS. 

The Tribe herewith provides written notification to the National Indian Gaming 

Commission, pursuant to applicable lawe and regulations, including but not limited 

to 25 C.F.R. sec. 519.1 and sec. 522.2 (g) (as amended, if applicable), that the 

Tribe designates as its agent, with address, for service of any official 

determination, order, notice of violation, or other document or item: 

Tribal Chairperson 

Lower Brule Sioux Tribal Office 

Lower Brule Sioux Tribe 

P.O. Box 187 

Lower Brule, South Dakota 57548-0187 

Section 5. DISPUTE RESOLUTION BETWEEN THE GAMING PUBLIC AND THE TRIBE OR THE 

MANAGEMENT CONTRACTOR (IF ANY). 

5.1. Policy to Attempt to Satisfy Customer. 

As a matter of policy of the Lower Brule Sioux Tribe, if any dispute arises 

between a customer in the gaming public and the Tribe, or if any dispute arises 

between a customer in the gaming public and the casino's management contractor (if 

any), each person related to the dispute who is associated with the Tribe or the 

casino shall use his or her best efforts to amicably and immediately resolve the 

dispute to the satisfaction of the customer, within the legal and commercial 
constraints imposed upon each Tribal or casino person related to the dispute and 

within the legal and commercial constraints imposed upon thp: Tribal gaming 

enterprise. 

5.2, Simplified Final Dispute Resolution. 

If the dispute cannot be amicably and immediately resolved to the satisfaction 

of the customer, the Tribal or casino person most directly related to the dispute 

(a) shall refer the dispute to his or her immediate supervisor and (b) shall 

assure that the. customer is politely, conveniently, and professionally directed to 

that immediate supervisor for resolution of the dispute. After consultation with 

the customer and with any other person deemed appropriate by that immediate 

supervisor, the decision of that immediate supervisor shall be final in resolving 

the dispute. 

5.3. Unusual Chain of Command. 

If the dispute does not lend itself to resolution by the immediate supervisor 

of the Tribal or casino person most directly related to the dispute, or if the 

General Manager of the casino is a party to the dispute, then the final decision 

shall be rendered by the General Manager of the casino. 

5.4, Tribal Gaming Commission by Its Rule-Making Authority May Amend This 

Dispute Resolution Procedure, If Such Amendment Is Displayed at the Casino. 

This ordinance by its terms expressly authorizes the Tribal Gaming Commission 

to amend this procedure by rule or regulation to resolve a dispute arising between 

a customer in the gaming public and the Tribe, and to resolve a dispute arising 

between a customer in the gaming public and the casino's management contractor (if 

any), but only if that amendment by rule or regulation is displayed to the public 

at the casino, pursuant to the Tribal Gaming Commission's rule-making authority 

(including but not limited to that rule-making authority conferred by Regulation 

1.3 (Powers of the Gaming Commission) and Chapter 6 (Promulgation of Rules) of the 

Lower Brule Sioux Tribe Gaming Regulations (as amended, if applicable)). Nothing 

contained herein shall in any way be construed as a legislative intent of the Lower 

Brule Sioux Tribal Council to detract from or otherwise influence any other 

rule-making authority of the Tribal Gaming Commission or of the Tribal Council. 

SECTION 6. USE OF GAMING EIEVENUE. 

6.1. PURPOSES. 

Net revenues from Class I1 gaming and class I11 gaming shall be used only for 

the for the following purposes: to fund Tribal government operations and 

programs; to provide for the general welfare of the Tribe and its members; to 

promote Tribal economic development; to donate to ,charitable organizations; and 

to help fund operations of local government agencies. 

6.2. PER CAPITA PAYMENTS PLAN. 

If the Tribe elects to make per capita payments to Tribal members, it shall 

authorize such payments only upon approval of a plan submitted to the Secretary of 

the Interior under 25 U.S.C. sec. 2710 (b) (3) (as amended, if applicable). 
SECTION 7. AUDIT, 

r" 

7-10 ANNUAL AUDIT. 

The Tribe shall cause to be conducted annually an independent audit of gaming 

operation and shall submit the resulting audit reports to ,the National Indian 

Gaming om mission. 

7.2. SCOPE OF AUDIT. 

.. . , . , .. . 

All gaming related contacts 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 7.1 above. 

SECTION 8r PROTECTION OF THE ENVIRONMENT AND PUBLIC HEALTH AND SAFETY. 

Class I1 gaming and class I11 gaming facilities shall be constructed, 

maintained, and operated in a manner that adequately protects the environment and 

public health and safety. 

SECTION 9. LICENSES FOR KEY EMPLOYEES AND PRIMARY MANAGEMENT OFFICIALS. 

The Tribe shall have ensure that the policies and procedures set out in 

this section are implemented with respect t'o key employees and primary management 

officials employed at any class I1 gaming and class I11 gaming enterprise operated 

on Indian Lands: 

9.1. DEFINITIONS. 

For the purposes of this section, the following definitions apply: 

9.1.1. "Key employee" means 

9.1.1.1. A person who performs one or more of the 

following functions: 

9.1.1.1.1. Bingo caller; 

9.1.1.1.2. Counting room supervisor; 

9.1.1.1.3. Chief of security; 

9.1.1.1.4. Custodian of gaming supplies or cash; 

9.1.1.1.5. Floor manager; 

9.1,1.1.6. Pit boss; 

9.1.1.1.7. Dealer; 

9.1.1.1.8. Croupier; 

9.1.1.1.9. Approver of credit; or 
9.1.1.1.10. Custodian of gambling devices including persons 

with access to cash and accounting records within such devices; r '- 

9.1.1.2. If not otherwise included, anp other person whose 

total cash compensation is in excess of $50,000 per year; or 

9.1.1.3. If not otherwise included, the four most highly 

compensated persons in the gaming operation. 

9.1.2. "Primary management official" means 

9.1.2.1. The person having management responsibility for a 

management contract; 

9.1.2.2. Any person who has authority: 

9.1.2.2.1. To hire and fire employees; or 

9.1.2.2.2. To set up working policy for the gaming 

operation; or 

9.1.2.3. The chief financial officer or other person who has 

financial management responsibility. 

9.1.3. "Tribal Gaming Commission" means the Lower Brule Sioux Tribal 

Gaming Commission, also sometimes described as the Lower Brule Sioux Tribe 

Commission on Gaming. 

9.1.4. "State Gaming Commission" means the South Dakota Gaming 

Commission, also sometimes described as the South Dakota Comrnission on Gaming. 

9.1.5. "Tribal Gaming Comrnission or its designee" means the Lower 

Brule Sioux Tribal Gaming Commission or the entity designated to act for and on 

behalf of said Tribal Gaming Commission in the Gaming Compact between the Lower 

Brule Sioux Tribe and the State of South Dakota (as amended, if applicable). The 

Tribal Gaming Commission's "designee" includes, but is not limited to, the State 

Gaming Commission, particularly as contemplated in said Gaming Compact. 

9.1.5.1. The State Gaming Commission's description of procedures 

for conducting background investigations is set forth in detail in the statutes and 

regulations of the State of South Dakota, including but not limited to Chapter 

42-7B (Limited Card Games and Slot Machines--Gaming Commission) of the South 

Dakota Codified Laws (SDCL Ch. 47-7B) and Chapters 20:18:06 (Applications and 

Fees), 20:18:07 (Application Approval), 20:18:08 (Enforcement), 20:18:09 (Grounds 

for Disciplinary Action), 20:18:10 (Disciplinary Proceedings), 20: 18: 11 

(Contested Cases), 20:18;12 (Summary Suspension Procedure), 20:18:21 (Operation 

of Gaming Establishments), 20:18:22 (Accounting Regulations), 20:18:23 

(Suitability and Unsuitability Procedure), 20:18:24 (Exclusion List) , and 

20:18:27 (Gaming Compact with Recognized Indian Tribes) of the Administrative 

Rules of South Dakota (ARSD Chs. 20:18:06, 20:18;07, 20:18:08, 20:18:09, 20:18:10, 

20:18:11, 20:18:12, 20:18:21, 20:18:22, 20:18:23, 20:18:24, and 20:18:27). 
9.1.5.2. By this definition in this Gaming Ordinance, the Federal 

regulatory requirements of ,.; 

"{a) description of procedures to conduct or 

cause to be conducted background 

investigations on key employees and 

primary management officials" 

(25 C.F.R. sec. 522.2 (b) (as amended, if applicable)) and 

"{i) dentification of a law enforcement agency that will 

take fingerprints and a description of procedures for conducting 

a criminal history check by a law enforcement agency. Such 

a criminal history check shall include a check of criminal 

history records information maintained by the Federal Bureau 

of Investigationll 

(25 C.F.R. sec. 522.2(h) (as amended, if applicable)) expressly shall be included 

within the background investigations conducted for the Tribal Gaming Commission by 

the State Gaming Commission under the within Gaming Compact. As a matter of 

on-going practice and procedure under said Gaming Compact, the Lower Brule Sioux 

Tribe and its Tribal Gaming Commission expressly confirm that' the within "criminal 

history check" has included and shall continue to "include a check of criminal 

history records information maintained by the Federal Bureau of Investigation" 

(id. ). 

9.2. PRIVACY NOTICE 

9.2.1. The following notice regarding privacy shall be placed on the 

application form for a key employee or a primary management official before that 

form is filled out by an applicant: 

"In compliance with the Privacy Act of 1974 (as amended, 

if applicable), the following information is provided: 

Solicitation of the information on this form is authorized by 25 

U.S.C. sec. 2701 et seq. (as amended, if applicable). The 

purpose of the requested information is to determine the 

eligibility of individuals to be employed in a gaming 

operation. The information will be used by National Indian Gaming 

Commission members and staff who have need for the information 

in the performance of their official duties. The information 

may be disclosed to appropriate Federal, Tribal, State, local, 

or foreign law enforcement and regulatory agencies when relevant 

to civil, criminal, or regulatory investigations or 

prosecutions or when pursuant to a requirement by a Tribe or 

the Natipnal Indian gaming Commission in connection with the 

hiring or firing of an employee, the issuance or revocation 

revocation of a gaming license, or investigations of 

investigations of activities while associated with a 

a Tribe or a gaming operation. Failure to consent to the 

disclosures indicted in this notice will result in a 

Tribe's being unable to hire you in a primary 

management official or key employee position. 
"The disclosure of your Social Security Number (SSN) 

is voluntary. However, failure to supply a SSN may..result in 

errors in processing your application." I 

9.2.2. Existing key employees and primary management officials shall be 

notified in writing that they shall either: 

9.2.2.1. Complete a new application form that contains a Privacy Act 

notice; or . . . .. 

9.2.2.2. Sign a statement that contains the Privacy Act notice and 

consent to the routine uses described in that notice. 

9.3, Notice regarding Any False Statement. 

9.3.1. The following notice regarding any false statement shall be 

placed on the application form for a key employee or a primary management official 

before that form is filled out, by an applicant: 

" 'A false statement on any part of your 

applicationmay be grounds for not hiring 

you, or for firing you after you begin work. 

Also, you may be punished by fine or 

imprisonment.' (Title 18 U.S. Code sec. 1001 

(as amended, if applicable) . ) 

9.3.2. The Tribe shall notify in writing existing key employees and 

primary management officials that they shall either: 

9.3.2.1. Complete a new application form that contains a notice 

regarding false statements; or 

9.3.2.2. Sign a statement that contains the notice regarding false 

statements. 

9.4 Background Investigations. 

The Tribe, through the Tribal Gaming omm mission or its designee, shall 

perform a background investigation for each primary management official and for 

each key employee of any Tribal gaming operation. 

9.4.1. The Tribe shall request from each primary management official 

and from each key employee all of the following information: 

9.4.1.1. Full name, other names used (oral or written), social 

security number (s), birQh date, place of birth, citizenship, gender, all languages 

(spoken or written); 

9.4.1.2. Currently and for the previous five years: business and 

employment positions held, ownership interests in those businesses, business and 

residence addresses, and driver's license numbers; 
9.4.1.3. The names and current addresses of at least three 

personal references, including one personal reference who was ac9ainted with the 

applicant during each period of residence listed under the immediately preceding 

subsubsubsection 9.4.1.2.; 

9.4.1.4. Current business and residence telephone numbers; 

9.4.1.5. A description of any existing and previous business 

relationships with Indian Tribes, including ownership interests in those businesses; 

9.4.1.6. A description of any existing and previous business 

relationships with the gaming industry generally, including ownership interests in 

those businesses; 

9.4.1.7. 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; 

9.4.1.8. For each felony for which there is an ongoing prosection 

or a conviction, the criminal charge, the name and address of the court involved, 

and the' date and disposition (if any); 

9.4.1.9. For each misdemeanor conviction or ongoing misdemeanor 

prosecution (excluding minor traffic violations), within ten years of date of the 

application, the criminal charge, the name and address of the court involved, and 

the date and disposition (if any); 

9.4.1.10. For each criminal charge ('excluding minor traffic 

charges), whether or not there is a conviction, if such criminal charge is within 

ten years of the date of the application and is not otherwise listed pursuant to 

the immediately preceding two subsubsubsections 9.4.1.8. and 9.4.1.9., the criminal 

charge, the name and address of the court involved, and the date and disposition 

(if any); 

9.4.1.11. 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; 

9.4.1.12. A current photograph; 

9.4.1.13. Any other information the Tribe deems relevant; and 

9.4.1.14. Fingerprints consistent with procedures adopted by the 

Tribe according to 25 C.F.R. sec. 522.2 (h) (as amended, in applicable). As 

described in the definition in subsubparagraph 9.1.5. defining that the "Tribal 

Gaming Commission or its designee" performs the within background investigations, 

the Federal regulatory requirements of 25 C.F.R. sec. 522.2 (b) and (h) (as 

amended, if applicable) expressly shall be included within the background 

investigations conducted for the Tribal Gaming Commission by the State Gaming 

Commission under the within Gaming Compact (as amended, if applicable). As a 

matter of on-going practice and procedure under said Gaming Compact, the Lower 

Brule Sioux Tribe and its Tribal Gaming Commission expressly confirm that the 

within "criminal history check" has included and shall continue to "include a 

check of criminal history records information maintained by the Federal Bureau of 

Investigationn (id.). 
9.4.2. The Tribe, through the Tribal Gaming Commission,.~r its designee, 

shall conduct or cause to be conducted an investigation sufficient to make an 

eligibility and suitability determination under subsection 9.5 below. In 

conducting a background investigation, the Tribe, through the Lower Brule Sioux 

Tribal Gaming Commission or its designee, shall promise to keep confidential the 

identity of each person interviewed in the course of the investigation. 

9.5. Eliqibility and Suitability Determination. 

The Tribe, through the Tribal Gaming Commission itself, shall review a 

person's prior activities, criminal record (if any), and reputation, habits, and 

associations to make a finding concerning the eligibility and suitability of a key 

employee or a primary management official for employment in a gaming operation. If 

the Tribal Gaming Commission, in applying the standards adopted in this ar any 

other Tribal ordinance, determines that employment of the person poses a threat to 

the public interest of to the effective regulation of gaming, or creates or 

' enhances the dangers of unsuitable, unfair, or illegal practices or methods or 

activities in the conduct of gaming, the Tribal gaming operation, and the Tribal 

gaming operation's management contractor (if any), shall not employ that person in 

a key employee or primary management official position. 

9.6. Report to the National Indian Gaming Commission. 

9.6.1. When the Tribe employs a primary management official or key 

employee, the Tribe, through the Tribal Gaming Commission or its designee, shall 

forward to the National Indian Gaming Commission a completed application containing 

the information listed in the preceding subsection 9.4 on ~ack~round Investigations. 

9.6.2. Before issuing a license to a primary management official 

or to a key employee, the Tribe, through the Tribal Gaming Commission or its 

designee, shall prepare and forward to the National Indian Gaming Commission an 

investigative report on each background investigation. An investigative report 

shall include all of the following: 

9.6.2.1. Steps taken in conducting the background' 

investigation; 

9.6.2.2. Results obtained; 

9.6.2.3. Conclusions reached; and 

9.6.2.4. The bases for those conclusions. 

9.6.3. When the Tribe forwards its report to the National Indian 

Gaming Commission, the Tribe shall include a copy of the eligibility and 

euitability determination-made under the preceding subsection 9.5. 

9.6,4. If the Tribe does not license an applicant -- 

9.6.4.1. The Tribe, through the Tribal Gaming Commission or its 

designee, shall notify the National Indian Gaming Commission; and 
9.6.4.2. The Tribe, through the Tribal Gaming Commission or its 

designee, may forward copies of its eligibility and suitability +termination and 

investigative report (if any) to the National Indian Gaming Commission for 

inclusion in the Indian Gaming Individuals Records System. 

9.6.5. With respect to key employees and primary management officials, 

the Tribe shall retain applications for employment and reports (if any) of 

background investigations for inspection by the Chairman of the National Indian 

Gaming Commission or his or her designee for no less than three years from the date 

of termination .of employment. . -. 

9.7. Procedures for Forwarding Applications and Reports for Key Employees and 

Primary Management Officials to the National Indian Gaming Commission. 

9.7.1. When key employee or a primary management official begins work 

at a gaming operation authorized by this ordinance, the Tribe, through the Tribal 

Gaming Commission or its designee, shall : 

9.7.1.1. Forward to the National Indian Gaming Commission 

the completed application for employment that contains the notices and information 

listed in subsection 9.2 (Privacy Notice), 9.3 (Notice regarding Any False 

Statement.), and 9.4 (Background Investigations); and 

9.7.1.2. Conduct the background investigation under 

subsection 9.4 to determine the eligibility of the key employee or the primary 

management official for continued employment in the gaming operation. 

9.7.2. Upon completion of a background investigation and a 

determination of eligibility for employment in a ~ribal gaming operation, the 

Tribe, through the Tribal Gaming Commission to its designee, shall forward the 

investigative report referred to in the preceding subsubsection 9.6.2. to the 

National Indian Gaming Commission within sixty days after an employee begins work 

or within sixty days of the approval of this ordinance by the Chairman of the 

National Indian Gaming Commission under 25 C.F.R. Part 523 (as amended, if 

applicable). The counting of the sixty days shall begin after the latter of the two 

dates that both the employee begins work - and the ordinance is approved by the 

Chairman of the National Indian Gaming Commission. 

9.7.3. The gaming operation shall not employ as a key employee or as a 

primary management official a person who does not have a license within ninety days 

after the Tribe forwards to the National Indian Gaming Commission the investigative 

report referred to in the preceding subsubsection 9.6.2. 

9.7.4. During the thirty-day period beginning when the National Indian 

Gaming Commission receives a report submitted under the preceding subsubsection 

9.7.2., the Tribe acknowledges the Chairman of the National Indian Gaming 

Commission may request additional in£ ormat ion from the Tribe concerning a key 

employee or a primary management official who is the subject of a report. Such a 

request shall suspend the thirty-day period until .the Chairman receives the 

additional information. 
Granting a Gaming License. 

9.8.1. If, within the thirty-day period after the National Indian 

Gaming omm mission receives the report described in tbe iarmediately preceding 

subsubsection 9-7.4., the National Indian ~amin9 Comis~ion notifies the Tribe that 

it has no objection to the insurance 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 Indian Gaming 

Commission, the .Tribe may issue a license to such applica&. 

9.8.2. If, within the thirty-day period described in the preceding subsubsection 9.7.4., the National Indian Gaming ~onunissi& provides the Tribe with 

a statement itemizing objections to the issuance of a license to a by employee or 

to a primary management official for whom the Tribe has &Tided an application and 

investigative report to the National Indian Gaming co&ssion, the Tribe shall 

reconsider the application, taking into account the objections itemized by the - 

Commission. The Tribe shall make the final decision whethr to issue a license to 

such applicant. 

9.9 License Suspension. 

9.9.1. 1f, after the %issuance of a gang license, the Tribe 

receives from the ~ational Indian ~aming' Commission reliable inf omat ion indicating 

that a key employee or a primary management official is notf eligible for employment 

under subsection 9.5 above, the Tribe shall suspend such license and shall notify 

in writing the licensee of the susp&nsion and the proposed revocation. 

9.9.2. The ~ribe shall notify the licensee of a the and a place 

for a hearing on the proposed revocation of the license. 

9.9.3. After the revocation hearing, the Tribe shall to 

revoke or to reinstate the gaming license. The Tribe shall notify the National 

1ndian Gaming Commission of the Tribe's decision. 

SECTION 10. LICENSE LOCATIONS. 

The Tribe shall issue a separate license to each place, facility, or 

location on Indian lands where class 11' gaming and class I11 gaming is conducted 

under this ordinance. 

SECTION 11. REPEAL 

TO the extent that they are inconsistent with this ordinance, all prior 

gaming ordinances are hereby repealedCXR!l!IFICATIOBI 

The foregoing Ordinance was duly adopted by the LOWer BrUle Sioux Tribal Council, 

assembled in ~egular Session, with quo-, Present, on the 14th day of June, 1995, 

by affirmative vote of f fve members none 0EJposingt none absent, and none not 

voting . 
LoWsR BRULE AoUX TRIBAL COUNCIL