Chief Bill John Baker 

Cherokee Nation 

P.O. Box 948 

Tahlequah, OK 74465 

October 27, 2014 

Re: Cherokee Nation Tribal Gaming Act, Legislative Act 17-14. 

Dear Chief Baker, 

This letter responds to your July 25, 2014, request on behalf of the 

Cherokee Nation to the National Indian Gaming Commission to review and 

approve the Nation's amendments to its gaming act. The amendments to the 

gaming act are contained in Legislative Act 17-14 and Legislative Act 07-14 of 

the Council of the Cherokee Nation. 

Legislative Act 17-14 and Legislative Act 07-14 revise the Tribe's current 

gaming act to conform with NIGC regulations, to differentiate between gaming 

activities and non-gaming activities that may or may not be under the jurisdiction 

of the Tribal gaming commission, to provide Tribal Council representation on the 

Tribal gaming commission, and most notable, to require that the Tribal regulations 

and controls not exceed or conflict with the NIGC's Minimum Internal Control 

Standards (MICS). The provisions most significantly amended cover definitions, 

membership of the Tribal gaming commission, powers and duties of the Tribal 

gaming commission, authorization of gaming, oversight of fiscal affairs, 

employment applications procedures, licensing procedures, and background 

investigation processes. 

Thank you for bringing the amended gaming act to our attention. The 

gaming act is approved to the extent it is consistent with the requirements of the 

Indian Gaming Regulatory Act and NIGC regulation. 

NATIONAL HEADQUARTERS 90 K St. NE, Suite 200, W ashington, DC 20002 Tel: 202.632.7003 fox: 202.632.7066 WWW.NIGC.GOV 

REGIONAL OFFICES Portland, OR; Sacramento, CA; Phoenix, AZ; St. Poul, MN; Tulsa OK 
Chief Baker 

October 27, 2014 

Page 2of2 

However, I am compelled to note my misgivings over some aspects of the 

gaming act. In particular, the provision of the gaming act that requires tribal 

regulations and controls not exceed the federal controls undermines the spirit of 

the NIGC regulations, especially the MICS - which are designed to be the ground 

floor of regulations μpon which a tribe could build up from to address its specific 

requirements. Here, the Cherokee Nation has changed its Tribal law to limit the 

ability of its Tribal gaming commission to create controls it finds uniquely and 

perhaps better suited to its needs. 

The NIGC sought to bolster tribal sovereignty and self-determination when 

it adopted the new Class II MICS by providing tribes with appropriate flexibility 

and discretion in developing tribal-specific regulations. Specifically, certain 

internal controls were left for tribes to develop and articulate in a manner that 

reflected their unique experience and specific regulatory concerns. With this 

gaming act, the Cherokee Nation has declined to authorize the development of 

such tribal-specific controls and instead defers to standards set forth by federal 

regulations and state compact terms. Further, implementing this provision of the 

gaming act may be difficult because Tribal regulators may struggle with 

determining what would "exceed" the NIGC MICS. Because of the potential 

implementation difficulties that may result from the gaming act's lack of 

specificity, the NIGC will likely need to review the Tribe's gaming operations 

with greater scrutiny. 

If you have any questions, please contact Staff Attorney Heather Corson at 

(202) 632-7003. 

Sincerely, 

nodev Chaudhuri 

hairman (Acting) 

cc: Elizabeth Homer, Homer Law 
Committee: Rules 

Date:6-5-14 Committee Date: 6-17-14 

Legislative Act 17-14 

Author: Hembree/Hill 

Sponsor: Victoria Vazguez 

An Act 

A LEGISLATIVE ACT AMENDING LA #10-11 MAKING TECHNICAL 

AMENDMENTS TO THE CHEROKEE NATION GAMING ACT 

BE IT ENACTED BY THE CHEROKEE NATION: 

§ 1. Title and Codification 

This enactment shall be known as the "Cherokee Nation Technical Gaming Amendment Act" 

and shall be codified at Title 4, Sections 1 to 69 of the Cherokee Nation Code Annotated. 

§ 2. Purpose 

The purpose o:fthis Act is: 

A. To amend Legislative Act #l 0-11 to make technical amendments to conform 

Cherokee Nation's gaming ordinance to the regulations of the National Indian 

Gaming Commission. 

§ 3. Legislative History 

A. IGRA was enacted on October 17, 1988, establishing the NIGC. Under the 

IGRA, the NIGC is charged with regulating Class II gaming and certain 

aspects of Class III gaming. 

B. The NIGC adopted certain regulations in Chapter III of Title 25, Code of 

Federal Regulations (Parts 500-599), to provide purpose and scope, procedures 

for service of NIGC determinations, requirements for submitting new and 

existing gaming ordinances to the Chairman for approval, requirements for 

background investigations on Primary Management Officials and Key 

Employees, and requirements for licensing employees of Indian gaming 

operations. 

C. Cherokee Nation enacted Legislative Act 30-89, on April 8, 1989, known as 

the "Cherokee Nation Tribal Gaming Act," to regulate the conduct of gaming 

owned and operated by the Cherokee Nation. 

D. On October 22, 1990, the Cherokee Nation amended the Gaming Act with 

Legislative Act 9-90, to comply with P.L. 100-497, October 17, 1988, 102 

Stat. 2467, and to establish the Cherokee Nation Gaming Commission. 
E. On April 11, 1994, the Cherokee Nation amended the Gaming Act with LA 1-

94. 

F. On October 16, 1995, the Cherokee Nation adopted Resolution 126-95 to 

authorize Class III gaming on Indian lands under its jurisdiction in the State of 

Kansas and other states where such gaming is permitted. 

G. On October 2, 2003, the Cherokee Nation amended the Act with LA 29-03 to 

authorize and provide for the regulation of Class III gaming which had been 

compacted for with the State of Oklahoma and/or authorized by legislative 

action. 

H. On November 10, 2003, the Cherokee Nation amended the Gaming Act with 

LA 37-03 to clarify the activities that fall under the jurisdiction of the 

Cherokee Nation Gaming Commission. 

I. On November 15, 2004, the Cherokee Nation amended the Gaming Act with 

LA 44-04 to provide technical amendments to the Gaming Act and provide for 

the regulation of Class III gaming that had been compacted for with the State 

of Oklahoma and/or authorized by legislative acts. 

J. On August 21, 2006, the Cherokee Nation amended the Gaming Act with LA 

20-06 relating to gaming on lands within the jurisdiction of the Cherokee 

Nation. 

K. On March 12, 2007, the Cherokee Nation amended the Gaming Act with LA 

15-07 to clarify that the Cherokee Nation Gaming Commission shall issue a 

separate license to each place, facility, or location in which Class II or Class III 

gaming is conducted. 

L. On September 13, 2010, the Cherokee Nation repealed and replaced Title 4-

Amusements and Sports and the above gaming acts with the passage of 

Legislative Act #26-10. 

M. On May 19, 2011, the Cherokee Nation enacted LA #10-11, which repealed 

and replaced LA #30-89, LA #9-90, LA #1-94, R #126-95, LA #29-03, LA 

#37-03, LA #44-04, LA #20-06, LA #15-07 and amended LA #26-10. 

N. On April 24, 2014, the Cherokee Nation enacted LA #07-14 which amended 

LA #10-11. 

§ 4. Definitions 

For the purposes of this Title, and unless a different code meaning is clearly indicated, the 

terms used in this Title shall have the same meaning as defined in the "Indian Gaming 

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Regulatory Act," Public Law 100-497, codified at 25 U.S.C. §§ 2701 et. seq., as amended: 

A. "Advisory Member" means a member of the Tribal Council, appointed 

by the Tribal Council, to attend and participate in meetings of the Cherokee 

Nation Gaming Commission and shall serve in an advisory, non-voting 

capacity. 

B. "Agent" and "Officially Licensed Agent" means any entity I corporation, 

wholly or majority owned by the Nation, its parent, subsidiary, and/or affiliate 

companies that conducts or has responsibility for gaming activities. 

C. "Class I Gaming" means social games solely for prized of minimal value 

or traditional forms of Indian gaming engaged in by individuals as a part of, or 

in connection with, tribal ceremonies or celebrations. 

D. "Class II Gaming" means: 

1. Bingo or lotto (whether or not electronic, computer, or other 

technological aids are used) when players: 

a. Play for prizes with cards bearing numbers or other 

designations; 

b. Cover numbers or designations when object, similarly 

numbered or designated, are drawn or electronically 

determined; and 

c. Win the game by being the first person to cover a designated 

pattern on such cards. 

2. If played in the same location as bingo or lotto, Class II gaming 

includes: 

a. Pull-tabs, punch boards, tip jars, instant bingo, and other games 

similar to bingo; and 

b. Non-banking games that: 

I. State law explicitly authorizes, or does not explicitly 

prohibit, and are played legally anywhere in the state; and 

ii. Play in conformity with state laws and regulations 

concerning hours, periods of operation, and limitations on 

wagers and pot sizes. 

3. Class II Gaming does not include any banking card games, including 

baccarat, chemin de fer, or blackjack (21), or electronic or 

electromechanical facsimiles of any game of chance or slot machines of 

any kind. 

E. "Class III Gaming" includes all those forms of gaming that are not Class 

I or Class II gaming. 

F. "Compact" means any agreement entered into between the Cherokee 

Nation and the State of Oklahoma, as approved by the Secretary of the Interior, 

for the purposes of conducting Class III gaming. Any such agreement shall 

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only affect the scope of Class III gaming activities. 

G. "Facility License" means a separate license issued by the Gaming 

Commission to each place, facility or location on Indian lands and any other 

lands owned by the Cherokee Nation where Class II or Class III gaming may 

be conducted. 

H. "Gaming Commission" means the Cherokee Nation Gaming 

Commission. 

I. "Gaming Commissioner" means any member of the Gaming 

Commission duly appointed by the Principal Chief and confirmed by the Tribal 

Council. 

J. "Gaming Equipment" means all electronic, electro-mechanical, 

mechanical, or other physical components utilized in the play of Class II and 

Class III games. 

K. "Gaming Facility" means any premises, buildings, facilities, 

improvements, and/or equipment used or maintained in connection with the 

conduct of gaming, including but not limited to the storage of gaming 

equipment and/or materials and directly tied to the gaming operation/facility. 

This definition shall not include non-gaming operations, even if such 

operations are within the same building as gaming operations. 

L. "Gaming Facility Employee" means any employee of a gaming facility 

engaged in gaming or gaming related activity. 

M. "Gaming Public" or "Patron" means any natural person that is on the 

premises of a gaming facility acting or serving in the capacity as a customer or 

guest for the purpose of gaming. 

N. "Gaming System" means all components, whether or not technologic aids 

in electronic, computer, mechanical, or other technologic form, that function 

together to aid the play of one or more Class II games or any Class III games, 

inclusive of any and all support systems, player tracking and gaming 

accounting functions. 

0. "Gaming Vendor" means any person or entity who provides, through the 

sale, lease, rental or otherwise, any games, parts, maintenance or service in 

connection therewith to the Officially Licensed Agent in any amount. 

P. "IGRA" means the Indian Gaming Regulatory Act of 1988, Public Law 

100-497, as codified at 25 U.S.C. §2701 et. seq., as amended. 

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Q. "Indian Lands" means land over which Cherokee Nation exercises 

governmental power and that is either: 

1. Held in trust by the United States for the benefit of Cherokee Nation or 

any member of Cherokee Nation; or 

2. Held by Cherokee Nation or any member of Cherokee Nation which is 

subject to restriction by the United States against alienation. 

R. "Jurisdiction" means all lands owned by the Nation or over which the 

Nation exercises commercial and/or governmental authority or control. 

S. "Key Employee" means: 

1. A person who perfonns one or more of the following functions: 

a. Bingo Caller; 

b. Counting room supervisor; 

c. Security and Surveillance; 

d. Custodian of gaming supplies or cash; 

e. Floor manager; 

f. Pit boss; 

g. Dealer; 

h. Croupier; 

i. Approver of credit; 

j. Infonnation technology employee with access to gaming related 

systems and equipment; or 

k. Custodian of gambling devices including persons with access to 

cash and accounting records within such devices; 

2. If not otherwise included, any other person whose total cash 

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

3. If not otherwise included, the four most highly compensated persons in 

the gaming operation. 

4. Any other person designated by the Nation as a Key Employee. 

T. "License" means: 

1. In connection with a gaming facility, a license issued by the Cherokee 

Nation Gaming Commission authorizing the operation of a gaming 

facility at a particular location owned and operated by the Nation; 

2. In connection with an individual person, a license or pennit issued by 

the Cherokee Nation Gaming Commission authorizing the person to be 

engaged as a non-gaming employee, Key Employee, or Primary 

Management Official of a licensed gaming facility; and 

3. In connection with certain vendors, a license or permit issued by the 

Cherokee Nation Gaming Commission authorizing an individual or 

entity to conduct business and/or engage in activities that impact the 

operation of a gaming facility. 

U. "Nation" or "Tribe" means the Cherokee Nation. 

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V. "NIGC" means the National Indian Gaming Commission. 

W. "Non-Gaming Employee" means any employee of the gaming operation 

who is not a Key Employee or Primary Management Official. If applicable, 

any Non-gaming employees licensed by the Gaming Commission shall be 

licensed in accordance with any limitations, restrictions, or regulatory 

requirements included in Section 22 of this Act. 

X. "Non-Gaming Vendor" means any person or entity who, directly or 

indirectly, provides or is likely to provide at least twenty-five thousand dollars 

($25,000.00) in goods or services to an Officially Licensed Agent within the 

gaming facility's fiscal year. PROVIDED, that attorneys or certified public 

accountants and their firms shall be exempt from this definition to the extent 

that they are providing services covered by their respective professional 

licenses. 

Y. "Person" means any natural individual, company, partnership, firm, joint 

venture, association, Limited Liability Company (LLC), corporation, estate, 

political entity of the Cherokee Nation, or other identifiable entity to which this 

title can be applied. 

Z. "Primary Management Official" means: 

1. The person having management responsibility for a management 

contract; 

2. Any person who has authority: 

a. To hire and fire employees; 

b. To set up working policy for the gaming operation; or 

3. The chief financial officer or other person who has financial 

management responsibility. 

4. Any other person designated by the Nation as a Primary Management 

Official. 

AA. "Working Days" means Monday through Friday, except for holidays 

recognized by the Cherokee Nation and/or the federal government. 

§ 5. Protection of the Environment, Public Health and Safety 

A. All gaming facilities licensed by the Gaming Commission shall be constructed, 

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

environment and the health and safety of the public. 

B. The Gaming Commission shall utilize and/or rely on the Nation's established 

regulatory systems or certifications by appropriately licensed professionals for 

the purposes of enforcing applicable codes or regulations at each gaming 

facility. Laws, codes, regulations, policies, standards or procedures shall 

cover, at a minimum: 

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1. Emergency preparedness, including but not limited to fire suppression, 

law enforcement, security, and ambulatory services; 

2. Food and potable water; 

3. Construction and maintenance; 

4. Hazardous materials; 

5. Sanitation (both solid waste and wastewater); and 

6. Other environmental or public health and safety standards adopted by 

the tribe in light of climate, geography, and other local conditions as 

may be applicable to the individually licensed gaming facilities. 

7. Other city, county, and/or state standards the Nation may elect to abide 

by. 

The Gaming Commission shall recommend to the Principal Chief and the 

Council of the Cherokee Nation any revisions or additions to laws, regulations, 

policies, standards or procedures necessary to comply with IGRA. 

C. Each facility shall be required to follow all applicable federal, tribal, and/or 

state codes or regulations provided in the Cherokee Nation Code Annotated, 

and any modifications or amendments made thereto, and/or that may be 

recognized, adopted, or followed by an appropriate Nation Commission or 

Department. The Gaming Commission shall rely on and not duplicate the 

regulation of such Commissions and Departments to ensure compliance with 

all applicable codes or regulations. 

§ 6. Words and Terms 

In constructing th.e provisions of this Code, save when otherwise plainly declared or clearly 

apparent from the context: 

A. Words in the present tense shall include the future tense; 

B. Words in masculine, feminine and neutral genders shall include all genders, 

and; 

C. Words in the singular shall include the plural, and in the plural shall include 

the singular. 

§ 7. Provisions as Cumulative 

The provisions of this Act shall be cumulative to existing Law. 

§ 8. Severability 

The provisions of this Act are severable and if any part of provision hereof shall be held void, 

the decision of the Court so holding shall not affect or impair any of the remaining parts or 

provisions of this Act. 

7 
§ 9. Self-Help Contributions 

To the extent that this Act involves programs or services to citizens of the Nation or others, 

self-help contributions shall be required, unless specifically prohibited by the funding agency, 

or a waiver is granted due to physical or mental incapacity of the participant to contribute. 

§ 10. Sovereign immunity 

Notwithstanding any provisions herein, this Act shall not limit or restrict the inherent 

sovereignty of Cherokee Nation, and neither the Act nor any of its provisions shall operate to 

waive, in whole or in part, the sovereign immunity of Cherokee Nation. 

§ 11. Emergency declared 

It being immediately necessary for the welfare of the Cherokee Nation, the Council hereby 

declares that an emergency exists, by reason whereof this Act shall take effect and be in full 

force after its passage and approval. 

§§12. -19. Reserved/or Future Use 

§ 20. Establishment of Cherokee Nation Gaming Commission 

The Cherokee Nation Gaming Commission is hereby established as a part of the Executive 

Branch of the government of the Nation in order to carry out the Nation's responsibilities 

under the IGRA (as amended) and the NIGC's regulations at 25 C.F.R. § 501 et. seq. (as 

amended) and to implement the provisions of this Act. Provided, however, all actions and 

regulations of the Gaming Commission shall be consistent with the provisions of this Act, all 

other laws and resolutions of the Cherokee Nation Tribal Council, and the Constitution of the 

Cherokee Nation and any applicable laws and/or regulations or regulating agencies 

established by the State of Oklahoma either: 1) pursuant to a compact on lands other than the 

lands defined in Section 4 (P) and (Z) of this Title; or 2) applicable to facilities operating: a) 

under the jurisdiction of the Oklahoma Horse Racing Act, Okla. Stat. tit. 3A, § 200 et. seq.; or 

b) in connection with a horse racing facility under a license granted under the authority of 

Okla. Stat. tit. 3A §262. 

§ 21. Membership 

A. The Gaming Commission shall consist of no less than five (5) members of the 

Cherokee Nation to be appointed by the Principal Chief of the Cherokee 

Nation and approved by the Tribal Council of the Cherokee Nation. In addition 

to the Gaming Commission, three (3) Tribal Council members shall be 

appointed to participate in Gaming Commission meetings in an advisory, nonvoting capacity. These Advisory Members shall be appointed to serve by the 

Tribal Council. The term of an advisory member shall be three (3) years. 

Advisory Members shall be provided the same information as the Gaming 

Commissioners and tt1e Gaming Commission shall inform the Advisory 

8 
Members of all meetings so Advisory Members shall be able to attend all 

meetings of the Gaming Commission. 

B. To be eligible to serve as a commissioner, a person must: 

1. Be at least 25 years of age; 

2. Have a bachelor's degree from a college or university or equivalent 

experience; 

3. Be of high moral character or integrity; 

4. Be physically able to carry out the duties of office; and, 

5. Be able to pass a background investigation equivalent to that of a 

Primary Management Official to obtain and maintain a gaming license. 

C. The Principal Chief shall, at the time of making the initial appointments and 

also at the time of making each appointment to fill a vacancy on the 

Commission as provided herein, designate one member to serve as Chairman, 

one member to serve as Vice Chairman and one member to serve as Secretary. 

D. The terms of office of the Gaming Commission shall be three (3) years. 

Provided, however, the amendments set forth in this Legislative Act shall not 

affect the terms of office of the persons who are members of the Gaming 

Commission as of the effective date of this Act. 

E. At the expiration of their term, a Gaming Commissioner shall continue to serve 

until they are reappointed or replaced pursuant to sub-section (G) of this 

section. 

F. Gaming Commission members shall serve their terms of office free from 

political influence from any department of the government of the Nation and 

may be removed only for cause, after a hearing by the Cherokee Nation 

District Court under such tules and procedures as prescribed by the Tribal 

Council. A petition for removal for cause may be brought by a vote of the 

majority of Tribal Council Members or the Principal Chief. Except as 

authorized under the Constitution of the Cherokee Nation, no member of the 

Gaming Commission shall, directly or indirectly, solicit, receive or in any 

manner be concerned in soliciting or receiving any assessment, subscription or 

contribution for any tribal political organization, candidacy or other tribal 

political purpose. No member of the Gaming Commission shall be a member 

of a committee of a partisan tribal political club, or a candidate for nomination 

or election to any paid tribal office, or take part in the management or affairs of 

any tribal political party or in any tribal political campaign, except to exercise 

his or her right as a private citizen privately to express his or her opinion and to 

cast his or her vote. 

G. In the event of the expiration of a Gaming Commissioner's term or a vacancy 

in the membership of the Gaming Commission, the Principal Chief shall, 

within one hundred-eighty (180) days of the occun-ence of the vacancy, fill 

9 
.such vacancy for the unexpired term, subject to confirmation by a majority 

vote of the Tribal Council. In the case of filling a vacancy, such appointment 

shall only be for the unexpired term. 

§ 22. Powers and Duties of the Gaming Commission 

A. The Gaming Commission shall have the power to regulate and generally 

oversee conduct of all gaming operations in order to ensure compliance with 

this Act and any regulations adopted and orders issued by the Gaming 

Commission. The Gaming Commissioners shall each execute a conflict of 

interest provision disclosing potential unethical situations. 

B. The Gaming Commission shall be charged with the sole responsibilities of 

administering and enforcing the gaming provisions of this Act and any TribalState Compact to which the Nation may be a party. 

C. It shall be the responsibility of the Commission to promulgate regulations 

necessary to administer the relevant provisions of this Act, provided that rules 

and regulations promulgated or created by the Cherokee Nation Gaming 

Commission shall not exceed or conflict with the regulations issued by the 

Nation Indian Gaming Commission, including but not limited to the Nation 

Indain Gaming Commission Minimum Internal Control Standards or the 

provisions of the Indian Gaming Regultory Act, as applicalbe, unless 

specifically outlined by law; nor shall the regulations promulgated exceed or 

conflict what is required under any Cherokee Nation-State of Oklahoma 

Gaming Compact. 

D. The powers and duties of the Gaming Commission shall include, but not be 

limited to, the following: 

1. Making available application forms for all licenses and/or permits. 

2. Supervising the collection of all fees prescribed by this Act, Gaming 

Commission regulation, federal statutes or regulations, and any TribalState Compact to which the Nation may be a party. 

3. Processing all license applications and tax returns, which will be 

submitted under oath. 

4. Determining applicable fees. 

5. Auditing and/or reviewing financial records directly related to gaming 

activities only to ensure proper accountability. 

6. Reviewing all records, documents and anything else necessary and 

pertinent to the financial accountability of licensees or enforcement of 

any provision of this ordinance. 

7. Assessing sanctions, fines, or other penalties as needed against all 

vendors and/or facilities under the jurisdiction of and as deemed proper 

by the Gaming Commission for any violation of applicable laws, rules, 

and/or regulations applicable to gaming activities. 

8. Establishing procedures for conducting background investigations on 

10 
and licensing of Key Employees, Primary Management Officials, other 

gaming facility employees, and vendors. 

9. Establishing procedures for issuing licenses and permits to such 

employees, officials, and vendors. 

10. Obtain and process fingerprints, or designate a law enforcement agency 

to obtain and process fingerprints. 

11. Review and approve all investigative work conducted and report any 

possible or suspected criminal violation to the Cherokee Nation 

Marshal Service. 

12. Make license and/or permit suitability determinations. 

13. Report background investigation results to the National Indian Gaming 

Commission, as required. 

14. Inspect, examine, and monitor all gaming facility activities on a 

continuing basis. 

15. Have immediate, unfettered access to all areas of a gaming facility to 

review, inspect, examine, photocopy and/or audit all records of the 

gaming facility. 

16. Conduct civil I regulatory investigations of any suspected or reported 

violations of this Act, Gaming Commission regulation, tribal and/or 

federal statutes or regulations, or any Tribal-State Compact provision 

pertaining to gaming activities. 

17. Establish procedures for resolving disputes between the gaming public 

and a licensed gaming facility. 

18. Hold hearings on patron complaints, in compliance with procedures 

established by the Gaming Commission and/or any Tribal-State 

Compact provision. 

19. Comply with any and all reporting requirements under the IGRA, any 

Tribal-State Compact to which the Nation may be a party, and any 

other applicable law. 

20. Promulgate, issue, and enforce regulations necessary to comply with 

the minimum internal control standards issued by the Gaming 

Commission or the National Indian Gaming Commission, as amended. 

Provided that, all regulations shall be drafted in accordance with 

Section 22(C) as set further herein. 

21. Promulgate, issue, and enforce regulations on levying of fines and/or 

denial, suspension, restriction, or revocation of a gaming license or 

permit for violations of this Act, any Gaming Commission regulation, 

or any other applicable Tribal, Federal, or State law or regulation. 

Fines may not be assessed on employees. 

22. Ensure compliance with National Indian Gaming Commission 

regulations requiring payment of annual fees to, and filing reports with, 

the National Indian Gaming Commission. 

23. Ensure that all gaming facilities are in compliance with the federal 

Privacy Act procedures as required by NIGC regulations. 

24. The Gaming Commission or any member thereof, in the performance 

of its duties as defined by law, shall have the power to, in 

11 
administrative proceedings administer oaths and conduct administrative 

hearings for the purpose of the enforcement of this Act and/or any rules 

and regulations adopted by the Gaming Commission, assessment or 

collection of any fine, costs or other fees. The gaming facility shall 

provide the attendance of witnesses and the production of the books, 

records and papers of any person, firm, association or corporation 

under the jurisdiction of the Nation as necessary to show cause why 

action should not be taken by the Commission. Provided that the 

Cherokee Nation Marshal Service and Office of Attorney General have 

primary jurisdiction to enforce all criminal laws concerning gaming. 

E. Dispute Resolution 

1. The Gaming Commission shall promulgate regulations for resolving 

disputes between the gaming public and a gaming facility. 

a. Separate regulations shall be provided for Class II and Class III 

gaming activities. 

b. For Class III disputes, the Gaming Commission shall follow the 

parameters set forth in any Tribal-State Compact to which the 

Nation may be a party. 

2. In resolving such disputes, the Gaming Commission may receive 

written statements, affidavits, or other materials from the parties of said 

dispute or their witnesses and, in its discretion, may order one or more 

hearings to take oral statements or testimony. 

3. Any decision of the Gaming Commission in resolving such disputes 

shall be in writing and may be appealed by the parties to the Cherokee 

Nation District Court by filing an appeal, which shall contain a 

statement of the grounds for the appeal, within thirty (30) days of the 

date of receipt of the Gaming Commission's decision, in accordance 

with 4 CNCA § 67. 

4. All decisions of the Gaming Commission for which a timely appeal has 

not been filed shall be final. 

5. The dispute resolution procedures shall not apply to disputes governed 

by the regulations of the Oklahoma Horse Racing Commission. 

§ 23. Restrictions on Commissioners 

A. To avoid potential conflicts of interest between the management and regulation 

of a gaming operation, the Nation hereby declares that: 

1. No person, while actively serving in any of the following capacities 

may serve on the Gaming Commission: Principal Chief or Deputy 

Principal Chief, member of the Tribal Council, Justice or Judge of the 

Nation's courts, Nation employee, employee of the Gaming 

Commission, any employee of a gaming facility owned and operated by 

the Nation or its authorized agent or any appointed member thereof, or 

any vendor actively conducting business with a gaming facility. 

However, nothing herein shall prevent a Tribal Council member from 

12 
serving as a non-voting Advisory Member to the Gaming Commission. 

2. No person who is ineligible to be a Key Employee or Primary 

Management Official or any person convicted of a felony, 

embezzlement, theft or any other :financially-related crime or honestyrelated crime, such as fraud, may serve on the Gaming Commission. 

3. Gaming Commissioners are prohibited from: 

a. Gambling in any gaming facility owned and operated by the 

Nation or its authorized agents; 

b. Providing contractual services of any kind to any gaming 

facility; 

c. Providing any management services to any gaming facility 

pursuant to a management contract; 

d. Accepting complimentary items from a gaming facility; 

e. Accepting gratuities or any other thing of value that could be 

considered a bribe from any licensee or applicant for a license 

or permit; and, 

f. Engaging in outside employment or activities, including seeking 

or negotiating for future employment, that conflicts with their 

official duties and responsibilities. 

B. For purposes of this section, subparagraphs (A)(3)(d) and (A)(3)(e), 

complimentary items and/or gratuities, shall not include ceremonial gifts or 

other items of nominal value, or meals provided at the expense of a gaming 

facility, provided that such items do not each exceed one-hundred dollars 

($100.00) in value and are not offered as an inducement or for any action taken 

by the Gaming Commission. 

§ 24. No Financial Interest 

No Gaming Commissioner shall have any direct or indirect financial interest in any gaming 

facility or gaming vendor licensee. For purposes of this section, indirect financial interest 

shall not include ownership of any mutual funds or other non-self-directed investment fund 

which holds stock in a publicly traded company but shall include direct ownership of such 

stock. 

§ 25. Limitations-Recommendations 

The Gaming Commission shall exercise only that authority granted herein, but may make 

additional recommendations to the Principal Chief at any time it deems proper. 

§ 26. Budget and Compensation 

A. Commission Funding and Budget 

1. Fees; General 

a. The Gaming Commission shall be subject to the annual 

budgeting process as prescribed by the Principal Chief. 

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b. Each licensee under the jurisdiction of the Gaming Commission 

shall pay to the Nation fees as established and scheduled by the 

Gaming Commission. 

c. The Gaming Commission, by a vote of not less than a majority 

of its members, shall adopt the rate of the fees imposed on any 

gaming vendor, employee, facility, and any other licensing fee 

schedule on a bi~annual basis. 

d. The projected expenditures of the Gaming Commission shall be 

in an amount not to exceed the amount of funds projected to be 

derived from fee assessments made under this section. 

e. Any increases to the Gaming Commission budget shall follow 

the established tribal budgetary process. 

f. Any unexpended fees shall be considered gaming revenues and 

shall be used in accordance with Section 3 8 of this Act. 

2. Operational Fees 

a. The Treasurer shall adopt preliminary rates for gaming 

operations fees prior to the beginning of each fiscal year based 

upon the approved budget for the Commission and, if deemed 

necessary, shall modify those rates at any time during the fiscal 

year. 

b. The Gaming Commission shall establish a schedule of fees to 

be paid to the Nation by each operation regulated under this 

Act. Fees shall be paid to the Nation on a monthly basis. 

3. Penalties 

a. Failure by any vendor or facility to pay the fees imposed under 

the schedules established by the Gaming Commission shall, 

subject to the regulations of the Gaming Commission, be 

grounds for denial or revocation of the approval of any permit 

or license issued the licensee. 

b. The Gaming Commission may assess a fine on any vendor or 

facility for failure to pay any prescribed license fee. 

i. Any assessed fines shall be collected by the Nation to be 

used in accordance with Section 3 8 of this Act and shall 

not be considered a part of the Gaming Commission 

budget. 

B. Gaming Commissioner Compensation 

1. The annual compensation, payable monthly, of the Gaming 

Commissioners shall be dete1mined as a part of the annual budget 

appropriation. 

2. In no event shall compensation be based on a percentage of net profits 

from gaming operations of the Nation. 

3. Members are eligible to be reimbursed for actual expenses incurred for 

Gaming Commission business, including necessary travel expenses, in 

addition to their monthly compensation. 

14 
§ 27. Authorization of Gaming 

A. Prohibition of Unauthorized Gaming 

No person licensed by the Gaming Commission shall engage, conduct or 

condone any game in a facility under the jurisdiction of the Gaming 

Commission unless such game is approved by the Gaming Commission and 

regulations for rules governing such game have been duly promulgated and 

approved by the Gaming Commission. 

B. Authorization of Gaming 

The Gaming Commission may authorize the playing of any game not 

prohibited by the IGRA, any game not prohibited by a Tribal-State Compact, 

and/or not specifically prohibited by the laws of the State of Oklahoma. The 

Gaming Commission shall promulgate regulations for rules governing all 

authorized games, including regulations governing the equipment, whether 

electronic or manual (e.g. chips, cards, machines, computer systems, etc.) used 

in such game. Any provision in a Tribal-State Compact with the State of 

Oklahoma providing for testing, notice to, and comment from the State shall be 

complied with before any game is authorized by the Gaming Commission. 

C. Approval of Gaming Equipment 

The Gaming Commission shall have the discretion to review and approve all 

gaming systems and other equipment used in the gaming facility as to quality, 

design, integrity, fairness, honesty, and suitability. 

1. The Gaming Commission may require a prototype or sample of any 

model of gaming system or other equipment used in the gaming facility 

to be placed in the custody of the Gaming Commission and retained as 

a control for comparison purposes. 

2. The Gaming Commission may rely on an independent outside testing 

laboratory or other professional expertise it deems necessary or 

appropriate to ensure the integrity of gaming systems, equipment, 

supplies, etc. 

D. Rules and Regulations of Games 

1. It shall be the responsibility of the Gaming Commission to promulgate 

regulations establishing the particular rules of all classes of gaming for 

each authorized game in order that said gaming will be conducted with 

fairness and uniformity. 

2. The rules of each authorized game offered at facilities licensed by the 

Gaming Commission shall be posted, and shall be clearly legible, in a 

15 
conspicuous location and/or made available to patrons in pamphlet 

form. Such rules, and any modifications or amendments thereto, must 

be approved by the Gaming Commission prior to publication and 

implementation. 

E. Gaming Related Activity ofthe'Nation 

The Gaming Commission shall have full jurisdiction for regulatory compliance 

and enforcement of any other gaming related activity that the Nation may elect 

to conduct. The Gaming Commission shall promulgate such regulations as it 

deems necessary to ensure the integrity of such activity and to ensure 

compliance with all applicable laws and regulations but the scope of such 

regulations shall be in accordance with Section 22(C) of this Act. Gaming 

Commission approval with regard to compliance with applicable gaming laws 

and regulations shall be required for any contracts related to any such gaming 

related activities. For the purposes of this section, such gaming related 

activities shall include, but are not limited to the following: 

1. Manufacture, development, assembly, sales, or distribution of any 

gaming machines, devices, equipment, software, or components 

thereof; 

2. Joint ventures with other Tribes, entities, persons, etc. related to 

gaming activity; 

3. Pre-licensure of any entity or individual providing loans, grants or 

similar financial arrangements related to gaming activity in excess of 

$50,000 in any twelve-month period, subject to the exceptions set forth 

in the Compact between the Cherokee Nation and State of Oklahoma. 

§ 28. Prohibited Acts 

A. In addition to other civil and criminal acts that may be regulated or prohibited 

by this Act, any Tribal-State Compact to which the Nation may be a party, 

other Tribal law or applicable federal law, the following shall constitute 

prohibited activities and unauthorized gaming under this Act and shall subject 

any perpetrator to Gaming Commission action including, but not limited to, the 

imposition of civil penalties, referral to appropriate law enforcement 

authorities for criminal proceedings, and license suspension or revocation. It is 

prohibited for any person: 

1. To alter or misrepresent the outcome of a game or other event on which 

wagers have been made after the outcome is determined but before it is 

revealed to the players; 

2. 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 knowledge of any event that affects the outcome of the 

game or knowledge that is the subject of the bet or wager; 

3. To aid anyone in acquiring such knowledge as set forth in paragraph 

(2) above for the purpose of increasing or decreasing a bet or wager, or 

16 
for the purpose of determining the course of play contingent upon that 

event or outcome; 

4. To claim, collect, or take or attempt to claim, collect or take, money or 

anything of value in or from a gambling game with intent to defraud, 

without having made a wager contingent thereon, or to claim, collect or 

take an amount greater than the amount won; 

5. To knowingly entice or induce another to go to any place where a 

gambling game is being conducted or operated in violation of the 

provisions of this Act, with the intent that the other person play or 

participate in that gambling game; 

6. To place or increase a bet or wager after acquiring knowledge of the 

outcome of the game or event which is the subject of the bet or wager, 

including past-posting and pressing bets; 

7. To reduce the amount wagered or cancel the bet after acquiring 

knowledge of the outcome of the game or other event which is the 

subject of the bet or wager, including pinching bets; 

8. To manipulate with intent to cheat, any component of a gaming device 

in a manner contrary to the designed and normal operational purpose of 

the components, with knowledge or hope that the manipulation affects 

the outcome of the game or prize or with knowledge of any event that 

affects the outcome of the game or prize; 

9. To solicit funds or anything of value from any patron or employee for 

personal gain, such as panhandling, vagrancy, or prostitution. 

10. To unlawfully take or attempt to take any chips, currency, machine 

redemption tickets, or anything of value from any patron or employee 

on the gaming facility premises; 

11. To refuse to leave the gaming facility when appropriately advised to do 

so by a member of management, security, and/or the Gaming 

Commission; 

12. To damage or attempt to damage, either intentionally or negligently, 

any property, gaming device or equipment, or any article belonging to 

the Tribe, patron, or employee; 

13. Under the age of eighteen (18) to make any wager either directly or 

indirectly in any gaming facility; 

14. To either intentionally or knowingly cause injury or harm to any 

patron, or employee or threaten to do so; 

15. To possess any chips, cards, devices, paraphernalia, etc., that could 

reasonably be concluded as useful in cheating, defrauding, 

manipulating, or altering any game, gaming device, equipment, 

machine, computer, or supplies; 

16. For any employee to aid, conspire, collude or assist in any way any 

other employee or patron to win or have an unfair advantage to win or 

otherwise acquire anything of value unfairly; 

17. For any employee to knowingly provide false information or to 

misrepresent information contained in a gaming license application 

and/or during the course of a background investigation; 

17 
18. For any employee to knowingly make a false or misleading statement 

to the independent auditors or internal auditors, nor shall any employee 

conceal or intentionally fail to reveal any information necessary to 

make the statements to such auditors not false or misleading; 

19. For any employee to knowingly make a false or misleading statement 

in connection with any contract for services or property or in response 

to any official inquiry by the Gaming Commission or its agents; 

20. For any employee to knowingly make a false or misleading statement 

to any investigator or other representative of the Gaming Commission 

in the course of an investigation of a complaint or violation of this Act, 

the Gaming Commission rules and regulations, or of any provision of a 

Tribal-State compact to which the Nation may be a party; 

21. For any employee to knowingly alter and/or destroy gaming records 

(e.g. Surveillance footage, gaming paperwork, accounting/financial 

reports) without proper authorization and/or that is outside of 

prescribed policies and procedures for such records; 

22. For any person to offer or attempt to offer anything of value to a 

licensee in an attempt to induce the licensee to act or refrain from 

acting in a manner contrary to the official duties of the licensee 

contained in this Act, the Gaming Commission rules and regulations, 

any Tribal-State compact to which the Nation may be a party, or any 

applicable law; 

23. For any licensee to accept anything of value with the expectation that 

receipt of such thing of value is intended, or that may be perceived as 

intended, to induce the licensee to act or refrain from acting in a 

manner contrary to the official duties of the licensee contained in this 

Act, the Gaming Commission rules and regulations, any Tribal-State 

Compact to which the Nation may be a party, or any applicable federal 

law; 

24. For any person to take any action which interferes with or prevents the 

Gaming Commission or its agents from fulfilling its duties and 

responsibilities under this Act; 

25. Any person possessing knowledge and/or any evidence that any gaming 

system or other equipment used in the gaming facility has been 

tampered with or altered in any way that would affect the integrity, 

fairness, honesty, or suitability of the system or equipment shall be 

immediately reported to the Gaming Commission; 

26. Any action the Gaming Commission may take on the an individual for 

engaging in any of the foregoing does not preclude the Cherokee 

Nation Marshal Service and/or the Office of the Attorney General from 

taking any action they may deem necessary. 

B. Unauthorized Gaming 

Any person who commits any act of unauthorized gaming on any premises 

licensed by the Gaming Commission and/or owned and operated by the Tribe 

18 
shall be in violation of this Act and the Gaming Commission shall seek 

prosecution in the appropriate court of competent jurisdiction. Prosecution for 

such violations in other than a Federal Court is not meant to be exclusive; a 

finding of guilt or innocence shall not deprive the Federal government from 

jurisdiction. 

C. Prohibition Against Electronic Aids 

Except as specifically permitted by the Gaming Commission, it is a crime for 

any person to possess with the intent to use, or actually use, at any table game, 

either alone or in concert with others, any calculator, computer, or other 

electronic, electrical, or electromechanical device to assist in projecting an 

outcome at any table game, to keep track of or analyze the cards having been 

dealt, to change the probabilities of any table game or the playing strategies to 

be utilized. Violations are subject to Gaming Commission action and/or 

prosecution by the Nation and/or federal government under applicable laws. 

D. Violations & Sanctions 

1. Any patron, employee, vendor, or vendor agent who violates any part 

of this Act or any applicable law or regulation either referenced or 

contained herein, shall be deemed to have committed a crime. All 

matters and occmTences which indicate that a criminal act under the 

Tribal Code, any Tribal-State Compact to which the Nation may be a 

party, and/or federal law may have occurred in or around any gaming 

facility shall be immediately reported to the appropriate law 

enforcement agency and the Gaming Commission. 

2. Violations which are not covered under a criminal code shall be 

deemed a civil violation. The Gaming Commission is authorized to 

establish a civil violations list of penalties and fines which shall be 

imposed by the Gaming Commission for all such civil violations of a 

vendor or facility with the violator afforded the rights to a hearing as 

provided in Chapter Six of this Act. 

3. If the Gaming Commission should have reasonable cause to believe 

any such violation was committed, it may impose licensing sanctions, 

vendor or facility fines, seek prosecution and/or exclusion. 

§ 29. Reserved/or Future Use 

§ 30. License Required for Gaming Facilities 

A. Any agent of the Cherokee Nation conducting gaming operations for the 

benefit of the Cherokee Nation on property of the Cherokee Nation, including 

lands under the jurisdiction of the Cherokee Nation other than the lands 

defined in Section 4 (P) of this Title, shall be required to have and display 

prominently an appropriate, valid and current license issued pursuant to 

provisions of this Act. 

19 
B. The Gaming Commission shall issue a separate license to each place, facility, 

or location where Class II and/or Class III gaming is conducted under the 

jurisdiction of the Cherokee Nation pursuant to this Title. Said license shall be 

renewed annually as set out herein. 

C. The Gaming Commission shall specify the form, conditions and content for the 

application for such licenses, which shall be submitted by the chief 

management official of the facility, and the initial application shall include a 

legal description of the lands whereon the facility is located, and a certification 

that said premises are lands under the jurisdiction of the Cherokee Nation as 

defined by this Title and shall identify the environmental, health, and public 

safety standards with which the place, facility, or location must comply, and a 

certification that the facility is in compliance therewith. Each subsequent 

application for the renewal of such facility license shall identify any changes or 

additions to said legal description and applicable environmental, health and 

safety standards, and include current certifications of compliance therewith. 

The Gaming Commission shall only issue such licenses if the applications 

therefore include the required information, certifications, and such further 

conditions as the Gaming Commission shall have specified. 

D. Conducting gaming operations without the lawful written approval and 

licensure of the Gaming Commission is a crime, and is punishable under 21 

CNCA § 10. The Cherokee Nation Marshal Service and Office of the Attorney 

General have primary authority to enforce tribal criminal laws concerning 

gaming. 

§ 31. Classes and Fees 

There shall be four (4) different classes of gaming, each characterized by its separate 

requirements and fees. These classes are created in compliance with the Indian Gaming 

Regulatory Act, Public Law 100"497, October 17, 1988, 25 U.S.C. 2501 et. seq., and the rules 

and regulations adopted pursuant to said Act. 

§ 32. Charitable Gaming 

Charitable gaming operations are not required to be licensed by the Gaming Commission 

provided that: 

1. All proceeds are for the benefit of a charitable organization. 

2. The Gaming Commission determines the charitable organization to be exempt 

from this Act. 

3. The charitable gaming operation is operated wholly by the charitable 

organization's employees and/or volunteers. 

20 
4. The Gaming Commission, at its sole discretion, may require the charitable 

organization to adopt procedures that protect the integrity of the gaming 

offered and that safeguard the assets used in connection with the gaming 

operation. 

§ 33. Class I Gaming License 

No license requirement. 

§ 34. Class II Gaming License 

Only a tribal enterprise wholly owned by the Cherokee Nation or its designated and approved 

agent or employee may apply for and receive a Class II Gaming license. Gaming operations 

must be conducted in facilities of the Cherokee Nation. A separate license must be issued by 

the Gaming Commission for each place, facility or location in which Class II gaming is 

conducted. 

§ 35. Class III Gaming License 

Only a tribal enterprise wholly owned by the Cherokee Nation or its designated and approved 

agent or employee may apply for and receive a Class III Gaming license. Gaming operations 

must be conducted in facilities of the Cherokee Nation. A separate license must be issued by 

the Gaming Commission for each place, facility or location on which Class III gaming is 

conducted. 

§ 36. Facility License 

The Gaming Commission may issue a facility license, pursuant to regulations adopted by the 

Gaming Commission, to a gaming facility ifthe gaming facility: 

A. Is adequate in all respects to accommodate the gaming intended to be carried 

on within the structure. 

B. Is equipped with security and surveillance equipment meeting or exceeding 

provisions set forth in regulations established by the Gaming Commission. 

C. Meets environmental, public health and safety standards of the Nation pursuant 

to §5 of this Code. 

D. Meets all requirements of applicable Tribal, Federal, and/or State law. 

E. Has paid all applicable license fees and other costs. 

21 
§ 37. Vendor Licensing 

A. All gaming and non-gaming vendors as defined in Section 4 are required to 

apply for and obtain a vendor license from the Gaming Commission prior to 

conducting business with any gaming facility, unless exempted under subsection B of this section. 

B. The requirement in sub-section A above does not apply to the following 

vendor categories: 

1. Tribal, local, State, or Federal govenunents and associated agencies; 

2. Cherokee Nation owned and/or chartered companies; 

3. Attorneys and Certified Public Accountants and their firms, to the 

extent that they provide services covered by their respective 

professional licenses; 

4. Sponsorships or charitable organizations; 

5. Public utilities; 

6. Entertainment; 

7. Insurance companies; 

8. Travel companies; 

9. Fleet service providers; 

10. Any person that qualifies for an exemption under the terms of any 

Tribal-State compact to which the Nation may be a party; or 

11. Any person otherwise specifically excluded by the Gaming 

Commission based on circumstances unique to that vendor or vendor 

category as determined by the Gaming Commission. 

C. The Gaming Commission shall: 

1. Promulgate regulations for the vendor licensing application, 

background investigation, and licensing process, which shall be in 

conformity with the terms of any Tribal-State Compact to which the 

Nation may be a party; 

2. Promulgate regulations that provide two tiers of licensure. The first tier 

shall cover non-gaming vendors, and the second tier shall cover gaming 

vendors; 

3. Promulgate regulations that provide for due process for all license 

actions taken against a vendor and/or for any sanctions or fines levied 

against a vendor for violations of the Cherokee Nation gaming 

ordinance, Gaming Commission rules and regulations, the IGRA, 

NIGC rules and regulations, or any provision of any Tribal-State 

Compact to which the Nation may be a party; 

4. Promulgate fee schedules applicable to gaming and non-gaming vendor 

licenses, provided the non-gaming vendors shall be assessed a fee not 

to exceed the cost of the required background check; 

5. Require vendor agreements and/or contracts over twenty-five thousand 

dollars ($25,000.00) to be included in the annual external audit. 

22 
§ 38. Use of Gaming Revenue 

The Cherokee Nation will have the sole proprietary interest in and responsibility for the 

conduct of any gaming activity performed under a Class II or Class III license and all net 

revenues from any said gaming are to be used for tribal purposes including: 

A. To fund tribal government operations or programs; 

B. To provide for the general welfare of the Cherokee Nation and its tribal 

members; 

C. To promote tribal economic development; 

D. To donate to charitable organizations; or 

E. To help fund operations oflocal government agencies. 

§ 39. Reserved/or Future Use 

§ 40. Records, Returns and Audits 

A. It shall be the responsibility of the Gaming Commission to promulgate 

regulations and ensure the gaming operation establishes proper gaming 

accounting procedures and methods of operations for all licensees of Class II 

or Class III gaming activities so that all monies or things of value received and 

paid out may be properly monitored and accounted. All gaming facilities under 

the jurisdiction of the Gaming Commission shall be required to keep an 

approved gaming accounting system that shall comply with, but not be limited 

to, all applicable provisions of this Act and/or regulations of the Gaming 

Commission. Said accounting system shall reflect all business and financial 

transactions involved or c01mected in any manner with the gaming operation 

and conducting of gaming activities authorized by this Act. The Gaming 

Commission shall have the right to access such records or to secure a court 

order to seize records or property not surrendered. 

B. No applicant, licensee or employee thereof shall neglect or refuse to produce 

records or evidence or to give information upon proper and lawful demand by 

the Director of the Gaming Commission, or shall otherwise interfere, with any 

proper and lawful efforts by the Director of the Gaming Commission to 

produce such information. The Gaming Commission may conduct such 

hearings as deemed necessary to ensure compliance with the provisions of this 

Act and accountability for all monies received and spent. Failure to comply 

with the provisions of this Act or any rule or regulation promulgated by the 

Gaming Commission shall constitute grounds for denying, restricting, or 

revoking a gaming license or permit and/or levying sanctions or fines against 

gaming vendors and/or gaming facilities as determined by the Gaming 

23 
Commission. 

C. The Gaming Commission shall ensure annual independent audits of all gaming 

operations are conducted and shall submit the resulting annual audit report to 

the National Indian Gaming Commission in conformance with the NIGC's 

regulations, as applicable. The management and operation of any gaming 

facility shall be subject to all applicable provisions of the Indian Gaming 

Regulatory Act and any Tribal~State Compact to which the Nation may be a 

party. 

D. All gaming related contracts that result in the purchase of supplies, services, or 

concessions in excess of twenty~five thousand dollars ($25,000.00) annually, 

except contracts for professional legal and accounting services, shall be 

specifically included within the scope of the audit described in the preceding 

paragraph. 

§ 41. Certification of Gaming Systems and Equipment 

All gaming systems and/or equipment purchased, leased or otherwise acquired and utilized by 

a licensed gaming facility must meet all standards promulgated by the Gaming Commission. 

The Gaming Commission shall maintain records of all gaming equipment located at any 

gaming facility or storage facility approved by the Gaming Commission. 

§ 42. Age Limit for All Gaming 

No person who is under the age of eighteen (18) shall operate, engage, or participate in any 

manner in the operation of any class of gaming activity. It shall be the responsibility of the 

manager of all licensed gaming operations of the Cherokee Nation to ensure compliance with 

this age limit requirement. 

§ 43. Oversight of Fiscal Affairs 

The Gaming Commission shall promulgate regulations for internal controls and fiscal audits 

of all gaming activities operated by the Nation. At a minimum, those regulations shall: 

A. Require minimum procedures for safeguarding the gaming operation's gaming 

assets and revenues, including recording of cash and evidences of indebtedness 

and mandatory count procedures. Such procedures shall establish a control 

environment, gaming accounting system, and gaming control procedures that 

safeguard the assets of the organization, assures that operating transactions are 

properly recorded, and encourage adherence to prescribed policies; 

B. Require minimum reporting requirements to the Gaming Commission; 

C. Shall promulgate regulations for internal controls and fiscal audits of the 

gaming facilities. At a minimum, those regulations shall require external and 

24 
internal audits by Gaming Commission, Cherokee Nation Businesses Internal 

Audit or External Certified Public Accountants that meet federal requirements; 

D. Ensure that an adequate accounting system and uniform code of accounts and 

accounting classifications are in place to assure consistency, comparability, 

and effective disclosure of financial information; 

E. Require intervals at which such information shall be furnished; 

F. Provide for the maintenance of documentation to evidence all internal work 

performed as it relates to the requirements of this section, and; 

G. Provide that all financial statements and documentation referred to in section 

(F) be maintained for a minimum of five (5) years. 

§ 44. Prohibition Against Embezzlement 

Any delay, maneuver or action of any kind which is caused by any non-gaming employee, 

Key Employee, Primary Management Official, and/or vendor to unlawfully divert gaming or 

other proceeds properly belonging to the Nation shall constitute grounds for taking sanctions 

against that licensee. If the Gaming Commission finds an unlawful diversion was conducted 

or attempted, it shall sanction the licensee, report the matter to the appropriate law 

enforcement agency for further action and may take such other action as it deems necessary or 

appropriate. Sanctions may include the imposition of fines and/or the revocation, suspension, 

or limitation of, or refusal to renew, any license. 

§§ 45. - 49. Reserved/or Future Use 

§ 50. Gaming Permits and Licenses - General 

A. The Gaming Commission shall ensure that the following rules and regulations 

as prescribed by the IGRA, as amended, 25 CPR §556 and §558, as amended, 

and any Tribal-State Compact to which the Nation may be a party, are 

implemented with respect to Key Employees and Primary Management 

Officials employed at any gaming facility under the jurisdiction of the Gaming 

Commission. 

B. The Gaming Commission shall ensure that rules and regulations are developed 

and implemented for the licensure of all non-gaming employees of a gaming 

facility that are not Key Employees or Primary Management Officials. 

C. The Gaming Commissioners and Gaming Commission staff shall be subject to 

the licensing standards for Primary Management Officials. 

25 
§ 51. Standard for Licenses and Permits 

A. Licenses issued to Key Employees and Primary Management Officials 

hereunder shall comply with and incorporate all standards and requirements 

enumerated in 25 CFR and any amendments thereto, and also according to all 

standards and requirements enumerated in any Tribal-State Compact to which 

the Nation may be a party. 

§ 52. Application Forms 

A. The following notice shall be placed on the application form for Key 

Employees or a Primary Management Official before that form is filled out by 

an applicant: 

"In compliance with the Privacy Act of 1974, the following information is 

provided: Solicitation of the infonnation on this form is authorized by 25 

U.S.C. §§ 2701 et seq. The purpose of the requested information is to 

determine the eligibility of individuals to be granted a gaming license. The 

information will be used by the Tribal gaming regulatory authorities and by the 

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 by the Tribe or the NIGC 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 National Indian Gaming Commission in 

connection with the, the issuance, denial, or revocation of a gaming license, or 

investigations of activities while associated with a tribe or a gaming operation. 

Failure to consent to the disclosures indicated in this notice will result in a 

tribe's being unable to license you ffifor 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 on processing your application." 

B. The following notice 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 license application may be grounds for 

denying a license or the suspension or revocation of a license. Also, you may 

be punished by fine or imprisonment. (U.S. Code, Title 18, Section 1001.)" 

C. The Gaming Commission shall request the following information from each 

applicant for a Key Employee and Primary Management Official license: 

1. Full name, other nan1es used (oral or written), social security number(s), date 

26 
of birth, place of birth, citizenship, gender, all languages (spoken or written); 

2. Currently and for the previous five (5) years: business and employment 

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

addressed, and driver's license numbers(s); 

3. The names and current addresses of at least three (3) personal references, 

including one personal reference who was acquainted with the applicant during 

each period of residence listed under paragraph 2 of subsection A of this 

section; 

4. Current business and residence telephone numbers; 

5. A description of any existing and previous business relationships with Indian 

tribes, including ownership interests in those businesses; 

6. A description of any existing and previous business relationships with the 

gaming industry generally, including ownership interests in those businesses; 

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; 

8. For each felony for which there is an ongiong prosecution or a conviction, the 

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

if any; 

9. For each misdemeanor conviction or ongoing misdemeanor prosecution 

(excluding minor traffic violations), within ten (10) years of the date of the 

application, the name and address fo the Court involved, and the date and 

disposition, if any; 

10. For each criminal charge (excluding minor traffice charges), whether or not 

there is a conviction, if such criminal charge is within ten (10) years of the date 

of the application and is not otherwise listed pursuant to paragraphs 7 or 8 of 

this subsectio, the criminal charge, the name and address of the Court involved, 

and the date and disposition, if any; 

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; 

12. A current photograph; 

13. Any other information the Gaming Commission deems relevant; and, 

14. Fingerprints consistent with procedures adopted by the Gaming Commission in 

accordance with 25 C.F.R. § 522.2(h). 

D. The Gaming Commission shall determine the information required from and 

the content of a non-gaming employee license application. 

E. The Gaming Commission shall notify in writing existing vendors that they 

shall complete an application for licensure by the Gaming Commission. 

§ 53. Background Investigations 

A. The Gaming Commission shall conduct a background investigation of all 

applicants, including Key Employees and Primary Management Officials, 

27 
sufficient to make a dete1mination under 4 CNCA § 56 of the applicant's 

eligibility for continued employment in a gaming operation. In conducting a 

background investigation, the Gaming Commission and/or an agent acting on 

its behalf will keep confidential the identity of each person contacted in the 

course of the investigation. 

B. The Gaming Commission shall ensure that all records and information 

obtained as a result of a background investigation shall remain confidential and 

shall not be disclosed to persons who are not directly involved in the licensing 

process. Under no circumstances shall information obtained during the 

background investigation be disclosed to members of management, human 

resources personnel or others employed by the gaming facility without a signed 

and notarized release from the individual. 

C. Section B above does not apply to requests for such information or records 

from any Tribal, Federal or State law enforcement or regulatory agency, or for 

the use of such information or records by the Gaming Commission and staff in 

the performance of their official duties. 

§ 54. Continuing Duty to Provide Information 

All applicants and licensees shall have a continuing duty to provide any materials, assistance 

or other information required by the Gaming Commission, and to fully cooperate in any 

investigation conducted by or on behalf of the Gaming Commission. If any information 

provided on the application changes or becomes inaccurate in any way, the applicant or 

licensee shall promptly notify the Gaming Commission or the Director of the Gaming 

Commission of such changes or inaccuracies. 

§ 55. Terms and Parameters of Licenses and Permits 

A. Terms 

1. The terms for licenses issued to persons under this Act shall be 

provided for in regulations promulgated by the Gaming Commission. 

2. The terms for facility licenses shall be one year and shall expire on 

December 31st of each year. 

3. The terms for licenses issued to vendors under this Act shall be 

provided for in regulations promulgated by the Gaming Commission. 

4. Any license issued pursuant to the provisions of this chapter is valid 

only for the person, entity, or facility shown on the face thereof. It is 

not assignable or otherwise transferable to any other person, entity, or 

facility without the express written approval of the Gaming 

Commission. 

B. Violations of any provision of this Act or rules adopted by the Gaming 

Commission, any Tribal-State Compact, or relevant license provisions, by a 

licensee shall be deemed contrary to the public health, safety, morals, good 

28 
order and general welfare of the Nation and shall be deemed grounds for 

refusing to grant or renew a license, or restrict, suspend, or revoke a license. 

Acceptance of a license, or renewal thereof by a licensee, constitutes an 

agreement on the part of the of the licensee to be bound by the provisions of 

this Act and the rules of Gaming Commission, now and in the future, and to 

cooperate fully with the Gaming Commission. It is the responsibility of the 

licensee to remain informed of the contents of this chapter, the rnles and other 

applicable regulations, amendments, provisions, and condition, and ignorance 

thereof will not excuse violations. A license issued hereunder is a privilege 

and no right shall attach thereto. 

§ 56. Eligibility Determination 

A. The Gaming Commission shall review a person's prior activities, criminal 

record, if any, and reputation, habits, and associations to make a finding 

concerning the eligibility of an applicant for obtaining and maintaining a 

gaming license or permit. If the Gaming Commission determines that licensure 

or a business relationship with an individual poses a threat to the public interest 

or to the effective regulation of gaming, or creates or enhances dangers of 

tmsuitable, unfair, or illegal practices and methods and activities in the conduct 

of gaming, no gaming facility under the jurisdiction of the Gaming 

Commission shall employ that person in a position requiring a gaming license 

nor conduct any business with that vendor. 

B. The Gaming Commission shall review a vendor's business history, history of 

the vendor's principals, as applicable, reputation, and associations to make a 

finding concerning the vendor's eligibility to receive a vendor license. If the 

Gaming Commission determines that the vendor poses a threat to the public 

interest or to the effective regulation of gaming, or creates or enhances dangers 

of unsuitable, unfair, or illegal practices and methods and activities in the 

conduct of gaming, a tribal gaming operation shall not conduct business with 

that vendor. 

§ 57. Federal Review of Gaming Applicants 

a. Report to the National Indian Gaming Commission 

1. When a gaming facility employs a Key Employee or a Primary 

Management Official, the Gaming Commission shall fonvard to the 

National Indian Gaming Commissionmaintain a completed application 

containing the information listed in 4 CNCA § 52. 

2. Prior to issuing a license to a Key Employee or Primary Management 

Official, and pursuant to the procedures set out in 4 CNCA § 53, the 

Gaming Commission shall create and maintain an investigative report 

on each background investigation that includes all of the 

29 
followingpref*lre anEl forvvarEl to the National InElian Gaming • • • • • l t.. 1 ;J • t' t' 

~h 

Comm1ss10n an uwestlgat1ve report on eac11 uaclfgrounu mves iga 10n 

Key Employee anEl Primary Management Official. 

An hwestigative report shall incluEle all of the follmving: 

a. Steps taken in conducting a background investigation; 

b. Results obtained; 

c. Conclusions reached; and 

d. The basis for those conclusions. 

e. The Gaming Commission shall submit with the report a copy of 

the eligibility determination made under 4 CNCA § 56 . 

.1. No later than sixty (60) days after the applicant begins work, the 

Gaming Commission shall submit a notice of results of the applicant's 

background investigation to the NIGC, which shall contain: 

a. Applicant's name, date of bilth, and social security number; 

b. Date on which applicant began or will begin work as a Key 

Employee or Primary Management Official; 

c. A summary of the information presented in the investigative 

report, which shall at a minimum include a listing of licenses 

that have been previously denied; gaming licenses that have 

been revoked, even if subsequently reinstated; every known 

criminal charge brought against the applicant within the last 10 

years of the date of application; and every felony of which the 

applicant has been convicted or any ongoing prosecution; 

d. A copy of the eligibility determination made under 4 CNCA § 

56. 

4. All notices under this Section shall be provided to the NIGC through 

the appropriate Oklahoma regional NIGC office. 

5.* If a license is not issued to an applicant for a Key Employee or Primary 

Management Official position, the Nation or Gaming Commission: 

a. Shall notify the National Indian Gaming Commission; and 

b.MayShall forward copies of its eligibility determination and 

investigative report (if-aay-fnotice of results to the National Indian 

Gaming Commission for inclusion in the Indian Gaming Individuals 

Record System. 

6. &.-With respect to Key Employee2 and Primary Management Officials, 

the Gaming Commission shall retain applications for 

employmentlicensing, eligibility determination, and jnvestigativ~ 

reports (if any) of background investigations for inspection by the 

Chairman of the NIGC or his/her clesignee for no less than three (3) 

years from the date of termination of employment. 

30 
B. The gaming operation shall not employ as a Key Employee or Primacy 

Management Official a person who does not have a license after ninety (90) 

days. Procedures for fonvarding applications and reports for Key Employees 

and Primary Management Officials to the NIGG. 

1. When a Key Employee or Primm·y Mm1agement Official begins »:vork 

at a gaming operation authorized by this ordinm1ce, the Gm11ing 

Commission shall forwurd to the NIGG a completed applicatioa-fer 

employment and shall conduct the background investigation and mak-e 

the determination refel'fed to in 4 CNCA § 56. 

2. The Gaming Commission shall forwm·d the repmt referred to in 4 

CNCA § 57 (A) to the NIGG within sixty (60) days after an employee 

begins v101'k-or-\vithin sixty (60) days of the apprnval of this ordinm1ce 

by the Chairman of the NIGG. 

3. The gaming operation shall not employ as a Key Employee or Primary 

Mm1agement Official a persoH:-'who does not have a license after ninety 

(90) days. 

4 . The provisions outlined in sub section 1 above shall not apply to any 

background investigations conducted and reported to the NIGG under 

m1y agreement with the NIGG for reduced repo1ting of background 

investigation results. 

C. The process in section BA above does not apply to Non-Gaming Employees or 

Vendor principals/management officials as defined in this Title. The retention 

period for such records shall be defined by the Gaming Commission. 

§ 58. Granting a Gaming License or Permit 

A. If, vlithin a thi1ty (30) day period after the NIGG receives a repo1t, the NIGG 

notifies the Gaming Commission that it has no objection to the issuance of a 

license pursuant to a license application filed by a Key Employee or a Primm·y 

Mm1agement Official for whom the Gaming Commission has provided an 

investigative repo1t to the NIGG, the Gaming Commission may issue a license 

to such applicant;. Once the notice of results of an applicant's background 

investigation has been submitted to the NIGC, the Gaming Commission may 

issue the license to the applicant. 

B. The Gmning Commission shall respond to a request for additional information 

from the Chairmm1 of the NIGG conc-erH:iftg-a-Key Employee or a Primary 

Management Official ·.vho is the subject of a repo1t. Such a rnquest shall 

suspend the thhty (3 0) day period under paragraph A of this section until the 

Chairman of the NIGG receives the additional information. Upon issuance of 

the license, the Gaming Commission shall notify the NIGC of such issuance 

within thirty (30) days. 

C. u: v.'ithin the thirty (30) day period described above, the NIGG provides the 

Gmning Commissi0!-1--With a statement itemizing objections to the issuance of a 

31 
license to a Key Employee or to a Primary Management Official for 'vVhom the 

Gaming Commission has provided an application and investigative report to 

the NIGG, the Gmning Commission shall reconsider the application, taldng 

ffite-aeeount the objections itemized by the NIGG. The Gaming Commission 

shall make the final decision whether to issue a license to such appliemlt. The 

Gaming Commission shall respond to a request for additional information from 

the Chair of the NI GC concerning a Key Employee or Primary Management 

Official who is the subject of the report. 

D. If, within the thirty (30) day period described above in 4 CNCA § 58CB), the 

NIGC provides the Gaming Commission with a statement itemizing objections 

to the issuance of a license, the Gaming Commission shall reconsider the 

application, taking into account the objections itemized by the NIGC. The 

Gaming Commission shall make the final decision wlwther to issue a license to 

such applicant. 

§ 59. Preliminary Determination & License Suspension 

A. Whenever, upon preliminary factual finding, the Gaming Commission 

determines that any person has failed to comply with the provision of this Act 

or any regulations promulgated hereunder, the Gaming Commission shall 

make a certification of findings with a copy thereof to the subject or subjects of 

that determination. 

B. If, after the issuance of a gaming license--er--J?ermit to a gmning facility 

em:pl-eyee, the Gaming Commission receives from "'.he NIGG, for a Key 

Employee or Primary Management Official, or the Gaming Commission 

separately receives reliable information from the NIGC indicating that suehf!: 

licensee is not eligible for employment under 4 CNCA § 56, the Gaming 

Commission shall suspend such license and shall notify the licensee in writing 

of the suspension and proposed revocation. 

C. The Gaming Commission shall provide at least five (5) days notice to the 

licensee and the gaming facility of a time and place for a hearing on the 

proposed revocation of a license or permit, to be held within thirty (30) days of 

a preliminary determination. 

D. After a revocation hearing, the Gaming Commission shall decide to deny, 

revoke, reinstate, or set conditions for retention of a gaming license or permit. 

The Gaming Commission shall notify the NIGC of its decision concerning a 

Key Employee or Primary Management Official license within fo1ty-five (45) 

days of receiving notification from the NIGC pursuant to 4 CNCA § 59(B) 

abovefor a Key Employee or Primary Mm1agement Offieial. 

32 
§ 60. Scope 

This Chapter provides procedures for hearings and appeals to the Gaming Commission for: 

A. Violation(s) of Gaming Commission rules, regulations, policies . and/or 

procedures; 

B. Violation(s) of any Tribal-State Compact to which the Nation is a party; 

C. Violation(s) of any applicable Cherokee Nation law, rule, or regulations; 

D. Violation(s) of any applicable federal law, rule, or regulation; 

E. Patron disputes with a gaming facility; 

F. Citations and/or exclusions resulting from violations of federal and/or tribal 

statutes, and/or any provision of a Tribal-State Compact to which the Nation 

may be a party; or 

G. Any act that, in the view of the Gaming Commission, may affect an 

individual's ability to obtain or maintain a gaming license. 

§ 61. Opportunities for Hearing 

A. The Gaming Commission shall afford an applicant for a license an opportunity 

for hearing prior to any final action denying such application and shall afford a 

licensee or any other person subject to this ordinance the opportunity for a 

hearing prior to taking final action resulting in denying, tenninating, revoking, 

suspending, or limiting a license or any other adverse action the Gaming 

Commission deems appropriate; provided, the Director may temporarily 

suspend or extend suspension of licenses for up to sixty (60) days in those 

cases where such action is deemed appropriate by the Gaming Commission. 

B. In cases where a license is suspended prior to hearing, an opportunity for a 

hearing shall be provided promptly after suspension at the request of the 

licensee. 

C. The Gaming Commission is authorized to adopt rules and regulations, 

consistent with this Act, governing the conduct of any and all hearings before 

the Gaming Commission as well as the process of issuing, modifying, 

conditioning, suspending, or revoking any license. 

§ 62. Hearing 

At such hearing it shall be the obligation of the applicant or licensee to show cause why the 

preliminary detennination is incorrect, why the application in question should not be denied, 

33 
why the license or licenses in question shall not be revoked or suspended, why the period of 

suspension should not be extended, or to show cause why special conditions or limitations 

upon a license should not be imposed, to show cause why any other action regarding any 

other person or persons subject to any action should not be taken. 

§ 63. Appearance Through Counsel 

1. Parties to all hearings governed by this Act may appear personally or through 

an attorney, except that a party must personally attend any hearing on the 

merits unless his attendance has been waived, in writing, by the Gaming 

Commission. 

2. When a party has appeared through an attorney, service of all notices, motions, 

orders, decisions and other papers shall thereafter be made upon the attorney, 

unless the party requests otherwise in writing. 

3. When a party is represented by an attorney, the attorney shall sign all motions, 

notices, requests, and other papers on behalf of the party. 

4. Any attorney appearing before the Gaming Commission must be duly admitted 

and licensed by, and be a member of good standing before the Cherokee 

Nation Bar. 

§ 64. Hearing Procedures 

The Gaming Commission is vested with the authority to develop and implement such hearing 

procedures it deems necessary to carry out its responsibilities to hear any issue raised under 

this Act or under any term or condition of any Tribal-State Compact to which the Nation may 

be a party. 

§ 65. Determinations by the Commission 

A. The Gaming Commission shall make all determinations of issues before it by a 

majority vote of the Gaming Commissioners. 

B. All determinations made by the Gaming Commission involving the granting, 

denial, cancellation or revocation of a license; a finding of a violation of the 

gaming ordinance, the Gaming Commission rules and regulations, the IGRA, 

or any Tribal-State Compact to which the Nation may be a party; the 

conditions of any license issued by the Gaming Commission; any order by the 

Gaming Commission; or any other applicable laws, regulations or agreements, 

and the imposition of any sanctions or penalties shall be made by motion and 

on the record. 

C. A copy of any determination shall be served upon the licensee by registered or 

certified mail, or may be served personally. Refusal of service by the licensee 

34 
shall constitute service. 

§ 66. Request for Re-Hearing 

A. For permit or license determinations, the Gaming Commission may, in its 

discretion, grant a rehearing upon written request from a licensee, only upon a 

showing of substantial new evidence affecting the outcome of the decision, 

provided such request is made within fourteen (14) days of receipt of the initial 

decision rendered by the Gaming Commission. 

B. For disputes, the decision rendered by the Gaming Commission is not subject 

to a rehearing and shall follow the procedure outlined in §67 of this Act. 

§ 67. Appeals 

A. The Cherokee Nation District Court shall have exclusive jurisdiction to hear 

appeals from final decision of the Gaming Commission denying, modifying, 

conditioning, or revoking any license. 

B. Any affected party may appeal any final decision of the Gaming Commission 

within thirty (30) days after such decision by filing a notice of appeal with the 

District Court and serving a copy to the Gaming Commission. Thereafter the 

Gaming Commission shall promptly file the full record of the proceeding with 

the District Court. 

C. In all appeals, the District Court shall give proper deference to the 

administrative findings of the Gaming Commission. The District Court shall 

not set aside, modify or remand any determination by the Gaming Commission 

unless it finds that the determination is arbitrary and capricious, unsupported 

by substantial evidence or contrary to law. The District Court shall issue a 

written decision on all appeals. 

D. The District Court may, in its discretion, award costs and attorneys' fees to the 

Gaming Commission against any appellant whose appeal was frivolous, 

malicious, or in bad faith. Such fees shall be assessed and collected as a tax 

imposed under this Act. 

§ 68. Finality of Gaming Commission or Cherokee Nation District Court Action 

Any final finding or determination of the Gaming Commission which is not timely appealed, 

and any final determination of the Courts of the Cherokee Nation of an appeal of a decision 

rendered by the Gaming Commission in proceedings pursuant to 4 CNCA § 67 shall be final 

and binding in any other proceeding against or by the same person before the Gaming 

Commission or the Courts of the Cherokee Nation. 

§ 69. Reserved for Future Use 

35 
Enacted by the Council of the Cherokee Nation on the 14111 day of July, 2014. 

ATTEST: 

Jo 

Cot 

i 

ncil 

ishin~awk, of the Chero s~ me Nation 

Tina L~·~~~­ Glory Jordai , eaker 

Council of the CH rokee Nation 

Approved and signed by the Principal Chief this lttctay of -Su\ ':} , 2014. 

ATTEST: 

~9-1 ChUCLJoskin, Jr., Secretary of State 

f'U Cherokee Nation 

YEAS AND NAYS AS RECORDED: 

Tina Glory Jordm1 Yea 

David Walkingstick Yea 

Joe Byrd Yea 

Jodie Fishinghawk Yea 

Janelle Fullbright Yea 

David W. Thornton, Sr. Yea 

Don Garvin Yea 

Harley L. Buzzard Yea 

Curtis G. Snell Yea 

~~ Cherokee Nation 

Janees Taylor 

Dick Lay 

Cru·a Cowan Watts 

Buel Anglen 

Frankie Hargis 

Victoria Vazquez 

Julia Coates 

Jack D. Baker 

36 

Yea 

Nay 

Yea 

Yea 

Yea 

Yea 

Yea 

Yea