, - ..Chairman Alfred R. Pemberton ; . . Leech Lake Band of Chippewa Indians . . Route 3, Box 100 

Cass Lake, Minnesota 56633 

Dear Chairman Pemberton: 

This letter responds to your request to review and approve the 

tribal gaming ordinance submitted on September 13, 1993, and 

amended on November 30, 1993, for the Leech Lake Band of Chippewa 

Indians (the '@Bandn). 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. 1 

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 Band's gaming ordinance, the 

Band is now required to conduct background investigations on its 

key employees and primary 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 Leech Lake Band of 

Chippewa Indians of Minnesota for review and approval. The NIGC 

staff and I look forward to working with you and the Band in 

implementing the IGRA. 

sincerely yours, ' 

cc: Charles Brown, Galning ~irectbr 

1850 M STREET. N W.. SUITE 250 WASHINGTON. O.C. 20036 TEL: 202-632-7003 FAX: 202-632-7066 
LEECH LAKE BAND OF CHIPPEWA INDIANS 

AUTHORIZATION FOR SUBMISSIONS TO NIGC 

RESOLUTION NO. 94-1 

WHEREAS, the Indian Gaming Regulatory Act of !988 ant: the 

requlations of :he Natio~ai. Irlaiar? .al C~rrnissii:)n 

(NIGC) require that certain sui>ml i,:.ns kbe l~ade to rhe 

NIGC when the Leech Lake Ba!?d c=,f Chippewa Indi?ns submits 

i ts :C:l.ass I1 and 1: Gami.ng C1rdlnar:se fc:.: NIGC approval ; 

azc 

WHEREAS, the Leech Lake Tribal Ccunci l nas rev;ewed the 

s:~bmiss;-sas. id the ebesl.;ljnation .=if agents fa:>r 

service of NIGC doc~rments , the pol isies and proce~?:',ures of 

cb gamir:q operat ions, and a sr.smorar-,du~ ;~^ff m. u;~~ersti regardinq the ci: ~se~:..I:.iat I (T?!; ~f sriminal 

historv record infor~at il.?~ by ?he ???it ions: Indian Garr~lng 

Cornmlssioc; and 

WHEREAS, the Lee55 Lake Band cbf Chlp!:.ewz. Indians wishes 79 rake 

ali. .2.pg+og.riate s.afirnlselons t..> t:he r9TC;il; 

NOW THEREFORE BE IT RESOLVED t3at the Ohairmayi ~f the Lb?erh Lake 

Tri~ai Comcci A , Ai £red R. Fembertan, i s hereby authorized 

tr: de~ii-gate ?,;lGC agent,s for servics, td-, certify 

,tribal c;an?ing p.~lii.~ies ar26 prr,tcei.::~res : the N'IGC, tc: 

sign on behalf of the Leech I,ake Eanc:. a menoran;",?,i:t1 c.f 

un6erstank.rrifi.g regarding the ,,ii.: ssern:nacicr, isif crir?ll:Ial 

hi~tory rec:orb fnfo~ma.rlon by tY:s ?:atic\?~il l:n,f!iai? c:::arni::;g 

Co~mission, and to sign or certify c~tner related 

doc?!mei:t s rt: yI(;C. 

WE DO HEREBY CERTIFY, th3.t the fl?regoi:~~; res~>-,!~.it:!=lr, wzs drrly 

pr3eented to accT adc!pte?. by ,I vcte :3f s.. f.31~. and .-.-_- Q -,,,-- against, 

at a Gaming Commission . . :?enri;-ii; of rhe lli3ech ?:e~~?rva:::.r3:: 

m' ' . . irikai Clriur::::, . aj sf? ~ct lrgas the Leech Lake Gami:;~ ::cm.ission, a 
LEECH LAKE BAND. OF CHIPPEWA- INDIANS 

CLASS 1-1 AND 11.1 GAMING ORDINANCE 

RESOLUTION NO. 94-2 

WHEREAS, the Leech Lake Band of Chippewa Zndiens owns, operates, 

ant licenses gaming facrlities cn the Leech Lake Znciian - x,eservat :on as ?art of i ts sovereigi-; qavernmenta; power ; 

WHEREAS, such ganin~ facili'ies provi,de an essential source 9f 

eagloy~.ent tc Band memSers and their fmiiles as we:: as 

to menbers of the nno-Indian com.uni. ty :n an? arciind the 

Leech Lake 2ese::va; ion ; acd 

WHEREAS, such qam!r,q fact l irles prcnride the Bz.nd w: tk ye-jel?ce tp.2: 

is TJ~ tai :o arograrns o,-~erated by the Salil': f~r. 'he ge:.:,eral 

weifare of :ts memS*rsr aimid 

WHEREAS, :he Leech Ls.k;e Reser-va t i c.n Tr i ha i Ctaunc : i I. s t hs 

~~\7e~~~.~;~ 5,3fi!i ;;.f t!l2 Le;.i--' -L,;-l ;~KE - ' sanz :;:f ,:".n i 2pewa Ln~; ans 

anii !??as r he a:it h~ri .ty ?1!1i1 L'~GPC'!:S ib: i i ?.v V.2 reg::ii~te 

gsr;::iq ctc : ile Leacl; L~~ke Ressrvat i ,211 ar!;:: a ,... c 2 F ,, G thk 

9 ,zi I-; c] ' 5 !."j 3 ;F j 12 ,.-J <: (1 fi~;yt :L 5 j, ,:> '2 ; 3 ~ 

WHEREAS, :he ieeci? Lake Keservatlcil Trlcal :':oyAnci l tile ' . .- I., ;., .?j ," , 

, ~yid .'.-e$-~.r-~q~~b:iit~: A. .. ,b -. i . ex~rcise federaiiy 

, * reccgc: zed :i.ri'i-ieren!: powers #of sel f ,-goverr::>~.:d w; : 3; :: t ....... i~e 

ieec:; Lake Reservarl'ion, and pursuant t: r k!e Xinu;ssot s, 

C1hi~get.i~ 'Tr.ibe ::on~t.it:~.:tj.sr: j- ,, to 

prr;:nulqat@ c3r,;i,inar?.c?s T ;:\ prom.:>t~ cene::al we: f are :-$. 

WHEREAS, pi.lrs;ia;!- t il) i t CiCsri? powers of s9.L f--g~;~e~:~r:!.~~~t an.,j cr,~der 

!ii-.e t,~a,rr+s .,I,? +' F. ..., . - ,.r.e z;=:aera, Ix31.a;2 !,jami:-:,; gegu~atc~yy Act of 

1988, 2nd r;:.lt~~~ the te2rpn.s of Tribai/State C:;:2mpacts w:I~.P~ 

tile bar,ij 'has e:rec!..ited with the State of :?ln2eso:ar it is 

wisz all:?: nscesszry 2: Inpiec':e~.t certal~ regciatisfis 

re;:.rarb.ing garr!in,~ w? thi:? the Leec:-. Lake Re:::pr?,.:at;:rlr,; ,;:? 

. . 1 - WHEREAS, It :s jc rne besc jn+eres[s cf tfie Leecn Lakc Ban& to .. . re\.lise i2 i?, :zol:;,pyeI~pnsiv(3 :.(!a~z~?y 21, :t~ rjy~-,,7jous fazing 

requ ..ax 1csns and to ! nc~r.y;~3rfite t'>lem l: (1) -. GR8 

z,~im~yey;ey_ 1 yle 72::-,~ ng i1,9'-~7 -, i, rs ,Ld - 'P-. .-. & , a;.ifi ;he diaar'- Lake -. _.- i_' , r i ha i &L L.rr 

-. 1, acring .3:3 tl.:e Band G~:?I:IC <;C:-J!~~;;C :;3,s :he 

ssverpit;;~ ayrthor 1 t.:r to adopt a!nen& j, c s ga~i11c. 

pr:zira:;~e~ ; 
K,,.:)W TEE~EFOHE 5E IT RESOI,VED x:',~a t, the I,eezh jiake Reservat i4.33 yyi bal 

'::?uncl ,'i , i12 i t r? ewn ,:apaci t y 3:-:d as t !-lo, .;ee;sn Band Gc?,mi 3~ 

c::o~:nission. a:id :n ~xercfse of its a:::ht;s--i,?/ ar,d its 

respo~sibilities under- zipplicable federal i.3~ and Trl ic(;;j.,: /stat,% 

gamin$ ccmpa::t s , hereby repeals a1 l previous gamr nq i21-41 rlances 

regciat ic:.r.s ar,d adopts the f o! lowi~g camp-eher,s i.ve ::I ass 11 anitGaming Ordinance. 
LEECH LAKE RESERVATION TRIBAL COUNCIL 

AKA 

LEECH LAKE RESERVATION BUSINESS COMMITTEE 

RESOLUTION NO. 94-3 

WHEREAS, it is in the best interest of the Leech Lake Band to 

settle certain obligations under the Equipment Lease Agreement of 

May 25, 1990 with Creative Games Technology by amending such 

Agreement. 

THEREFORE, BE IT RESOLVED that the Leech Lake Reservation Tribal 

Council hereby: 

1. Ratifies the attached I1Amendment to May 25, 1990 Equipment 

Lease Agreementw between the Leech Lake Band of Chippewa Indians, 

and Creative Games Technology, Inc., a Delaware corporation, and 

2. Authorizes Alfred R. Pemberton, the Chairman of the Tribal 

Council, and James D. Michaud, the Secretary/Treasurer of the 

Tribal Council to execute the attached "Amendment to May 25, 1990 

Equipment Lease Agreementw and all related documents on behalf of 

the Leech Lake Reservation Tribal Council. 

WE DO HEREBY CERTIFY that the foregoing resolution was duly 

presented and adopted by a vote of for and against at a - 

Gaming Meeting of the Leech Lake Tribal Council, a quorum being 

present, held on August 28th , 1993, at Cass Lake, 

Minnesota and remains in full force and effect, and has not been 

amended, modified, or revoked. 

Dated : August 28th ,1993 

~lfrd R. Pemberton, Chairman 

~eech Lake ~eservation Tribal Council 

f J es D. Michaud, 

gecretaryl~reasurer 

Leech Lake Reservation Tribal Council 
LEECH LAKE I AND 

- CHIPPEWA INDIANS 

CLASS I"1 & I11 

GAMING ORDINANC 
TABLE OF CONTENTS 

. 

Item Paqe No . 

Letter of Submission of Leech Lake Band Gaming Ordinance ....... 1 

Gmina Ordinance 

Purpose ........................................................ 2 

Gaming Authorized .............................................. 2 

Ownership of Gaming ............................................ 2 

Use of Gaming Revenue .......................................... 3 

Audit ......................................................... 3 

Protection of the Environment and Public Health and 

Safety ......................................................... 4 

License for Key Employees and Primary Management 

Officials ...................................................... 4 

A . Definitions ............................................... 4 

B . Application Forms ......................................... 5 

C . Background Investigations ................................. 6 

D . Eligibility Determination ............................... 8 

E . Procedures for Forwarding Applications and Reports 

to the National Indian Gaming Commission .................. 8 

F . Report to the National Indian Gaming Commission ........... 9 

G . Granting a Gaming License ................................. 10 

H . License Suspension ........................................ 10 

License Locations .............................................. 11 

Repeal ........................................................ 11 

Compliance With Tribal-State Compacts .......................... 11 

Conduct of Class I1 and Class I11 Games ........................ 11 

Leech Lake Band of Chippewa Indians Gamins Control Code 

Rules and Restrictions for Gaming Activities ................... 12 

Rules and Restrictions Governing Bingo Games ................... 12 

1 . Conduct of Games .......................................... 13 

2 . Bingo Records ........................................e.... 14 

3 . Checkers Required ......................................... 14 

4 . Gross Receipts compared and discrepancies reported ........ 14 

Rules and Restrictions Governing "Blackjack" Games ............. 14 

1 . Object of Game ............................................ 14 

2 . Cards and Value ........................................... 14 

3 . Wagers ................................................... 15 

a . Original Wager ...................................... 15 

b . Split Wager ........................................ . 15 

c . Double-Down Wager ............................ ....... 15 

d . Insurance Wager ..................................... 15 

e . Tip-Bet Wager ....................................... 15 

f . Disposition of Tip-Bet Wagers Received .............. 
. 

Item Paae No . 

4 . Staffing ...............*.........,....................... 16 

a . Necessary staff on duty ............................. 16 

b . Training of Dealers ................................. 16 

c . Training of Pit Bosses .............................. 16 

5 . Equipment ................................................ 16 

a . Blackjack Playing Table - Physical Characteristics .. 16 

b . Drop Boxes - Physical characteristics ............... 17 

c . Blackjack Cards - Physical Characteristics .......... 17 

d . Blackjack Dealing Shoe .............................. 18 

e . Blackjack Chips - Physical Characteristics .......... 18 

6 . Distribution of Chips to Playing Tables - 

Use of Fill Slips ....................................... . 18 

a . Fill Slips - Characteristics ........................ 18 

b . Fill Slips - Use .................................... 18 

c . Fill Slips - Accounting ............................. 19 

7 . Removal of Chips from Playing Tables - Use of Credit 

Slips .................................................... 19 

a . Credit Slips - Characteristics ...................... 19 

b . Credit Slips - Use .................................. 19 

c . Credit Slips - Accounting ........................... 20 

8 . Blackjack Chip Bank Services ............................. 20 

a . Sale of Blackjack Chips ............................. 20 

b . Procedure for Accepting Cash. ....................... 20 

c . Exchange of Chips - Placement of Currency 

in Drop BOX.........................................^^ 

d . Disposition of Currency - Access to Drop BOX........^^ 

e . Redemption of Chips ................................. 21 

D . Video Games of Chance ....................................... 21 

1 . Licensing of Manufacturers ............................... 21 

2 . Licensing of Distributors ................................ 21 

3 . Suspension. Revocation. or Non-Renewal of 

Manufacturer or Distributor License. ..................... 21 

4 . Qualifications of Lessors of Video Games of Chance ....... 21 

5 . Technical Standards: Testing and Approval of 

Video Games of Chance .................................... 22 

6 . Technical Standards: Application for Approval of 

Prototype Video Game of Chance ........................... 22 

7 . Technical Standards: Testing of Video Games of Chance .... 22 

8 . Technical Standards: Report of Test Results .............. 23 

9 . Technical Standards: Modifications of Approved Video 

Games of Chance .......................................... 23 

10 . Technical Standards: Conformity to Technical Standards 

of Compact on Video Games of Chance ...................... 23 

11 . Technical Standards: Information to be Provided .......... 24 

12 . Technical Standards: Hardware and Software 

Requirements for Video Games of Chance ................... 24 

Ordinance duly adopted by the Leech Lake Reservation 

Tribal Council ................................................. 25 
Paae No . 

Tribal-State Compact for Control of Class I11 Blackjack 

On the Leech Lake Reservation In Minnesota 

Section 1 . Findings and Declaration of Policy ............. -26 

Section 2 . Duration. ene ego ti at ion and Effect on Right 

to Request Compacts under the IGRA for Class I11 Gaming ... 27 

Section 3 . Allocation of Jurisdiction ......................... 29 

Section 4 . Regulatory Standards For lackj jack ..........*...... 29 

Section 5 . Background Investigations and Licensing of 

Employees and Managers ............................. 37 

Section 6 . Accounting and Audit Procedures .................... 39 

Section 7 . Amendments to Regulatory and Technical 

Standards for Blackjack .................................... 39 

Section 8 . Definitions ........................................ 39 

Section 9 . Effectiveness Contingent Upon Federal 

Court Judgement ........................................... 40 

Section 10 . Effect of Breach ................................... 40 

Section 11 . Retention of Legal Arguments ....................... 41 

Tribal-State Compact For Control of Class I11 Video Games 

of Chance on the Leech Lake Reservation in Minnesota 

Section 1 . Findings and Declaration of Policy ................. 43 

Section 2 . Duration and Renegotiation. ........................ 44 

Section 3 . Allocation of Jurisdiction ......................... 45 

Section 4 . Regulatory Standards for Video Games of Chance ..... 45 

Section 5 . Background Investigations and Licensing of 

Employees and Managers .................................... 48 

Section 6 . ~echnical Standards for Video Games of Chance ...... 49 

Section 7 . Reservation of Rights Under the IGRA ............... 58 

Section 8 . Severability ....................................... 59 

Draft Letter ~esignating Tribal Agent for Service 

of NIGC Documents . Gaming Director ............................ 60 

Draft Letter ~esignating Tribal Agent for Service 

of. NIGC Documents - Chairman of the Tribal Council .............61 

Draft Letter ~esignating Agent for Gaming Operations 

for Service of NIGC Documents . Gaming Director ................ 62 

Draft Letter ~esignating Agent for Gaming Operations for 

Service of NIGC Documents . Chairman of the Tribal Council ..... 63 

Policies and Procedures of the Leech Lake Band of Chippewa 

Indians for Backqround Investiqations of Key Employees and 

Primarv Manaqement Officials 

Band Responsibility ............................................ 64 

Applications and State and Federal Background Checks ........... 64 
. 

Item Paqe No . 

Dated and Certified by Chairman of the Tribal Council .......... 66 

Issuance of Licenses. Identification Cards. and 

Badqe Policv - 

General Policy ................................................. 67 

Identification Card Specifications ............................. 67 

a . Color Code ....................... .,...................... 68 

b . License Number ............................................ 68 

c . Expiration Date ........................................... 68 

d . Job Code .......................................... ....... 68 

e Photograph . ............................................*. -68 

f . Nae .........................*..........*......*......... 69 

Personnel ~esponsible for the Issuance of 

Identification Cards ........................................... 69 

a . Policies for Issuance of Identification Cards .......... 69 

1 . Initial Hiring ...................................... 69 

2 . Transfers ........................................... 69 

3 . Temporary Identification Cards ...................... 70 

4 . Visitors Identification Cards ....................... 70 

5 . Tribal Council Members .............................. 70 

Equipment of the Employee Identification Cards ................. 71 

Dated and Certified by Chairman of the Tribal Council .......... 72 

Leech Lake Reservation Tribal Council Gaming Division 

License Agreement .......................................... 73 

Procedures for Resolving Disputes Between the Gaming Public 

and Leech Lake Band Gaming Operations ...................... 74 

Completion Instructions for Personal History Statement for 

Key Employees and Primary Management Officials ............. 75 

Procedures for Processing Fingerprint Cards .................... 83 

Memorandum of Understanding ~egarding the Dissemination of 

Criminal History Record Information by the National Indian 

Gaming Commission .............................................. 86 
The Leech Lake Band of Chippewa Indians (hereinafter "Band"), 

empowered by the Constitution of the Minnesota Chippewa Tribe to 

enact ordinances, hereby enacts this ordinance in order to set the 

terms for Class I1 and I11 gaming operations on Band lands. 

11. Gamins authorized 

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

Regulatory Act, P.L. 100-447, 25 U.S.C. Section 2703 (7) (A) and 25 

U.S.C. Section 2703 (8) (hereinafter "IGRA") and by the regulations 

promulgated by the National Indian Gaming Commission at 25 C.F.R. 

Section 502.3 and 25 C.F.R. Section 502.4 (as published in the 

Federal Register at 57 FR 12382-12393, April 9, 1992) are hereby 

authorized. 

111. Ownership of Gaminq 

The Band shall have 

responsibility for the 

by this ordinance. 

the 

condu 

sole 

.ct of 

proprietary interest in and 

any gaming operation authorized 
IV. Use of Gamins Revenue 

A. Net revenues from Class I1 and Class I11 gaming shall be used 

only for the following purposes: to fund Band government 

operations and programs; provide for the general welfare of 

the Band and its members; promote Band economic development; 

donate to charitable organizations; or help fund operations of 

local government agencies. 

B. If the Band elects to make per capita payments to Band 

members, it shall authorize such payments only upon approval 

of a plan submitted to the Secretary of the Interior under 25 

U.S.C. Section 2710 (b) (3). 

V. Audit 

A. The Band shall cause to be conducted annually an independent 

audit of gaming operations and shall submit the resulting audit 

reports to the National Indian Gaming Commission. 
B. All gaming related contracts 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 A. above. 

VI. Protection of the Environment and Public Health and Safety 

Class I1 and Class I11 gaming facilities shall be constructed, 

maintained and operated in a manner that adequately protects the 

environment and the public health and safety. 

VII. Licenses for Kev Employees and Primarv Manaqement Officials 

The Band shall ensure that the policies and procedures set out in 

this section are implemented with respect to key employees and 

primary management officials employed at any Class I1 or Class 111 

gaming enterprise operated on Indian lands. All key employees and 

primary management officials shall have duly approved Band licenses 

issued in accordance with this section. 

A. Definitions 

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

1. Kev Employee means: 

(a) A person who performs on or more of the following 

functions: (1) Bingo caller 

(2) Counting room supervisor 

(3) Chief of security 

(4) Custodian of gaming supplies or cash 

(5) Floor manager 

(6) Pit boss 

(7) Dealer 

(8) Croupier 

(9) Approver of credit 

(10) Custodian of gambling devices 

including persons with access to 

cash and accounting records within 

such devices, or 

(b) If not otherwise, included, any other person whose 

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

year; or 

(c) If not otherwise included, the four most highly 

compensated persons in the gaming operation. 
2. Primarv Manasement Official means: 

(a) The person having management responsibility for a 

management contract; 

(b) Any person who has authority: 

(1) To hire and fire employees; or 

(2) To set up working policy for the gaming 

operation; or 

(c) The chief financial officer or other person who has 

financial management responsibility. 

B. Application Forms 

1. 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: 

In compliance with the Privacy Act 

of 1974, the following information 

is provided: Solicitation of the 

information 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 

employed in a gaming operations. 

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 investigations or 

prosecutions or when pursuant to a 

requirement by a tribe or the 

National Indian Gaming Commission in 

connection with the hiring or firing 

of an employee, the issuance 

or revocation of a gaming license, 

or investigations of activities 

while associated with a tribe or 

gaming operation. Failure to 

consent to the disclosures indicated 

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. 

2. Existing key employees and primary management officials 

shall be notified in writing that they shall either: 

a. Complete a new application form that contains a 

Privacy Act notice; or 

b. Sign a statement that contains the Privacy Act notice 

and consent to the routine uses described in that 

notice. 

3. The following notice shall be placed on the application 

form for a key employee or a primary official before that 

form is filled out by an applicant. 

A false statement on any part of your application may 

be grounds for not hiring you, or for firing you after 

you begin work. Also, you may be punished by fine or 

imprisonment. (u.S. Code, title 18, section 1001.) 

4. The Band shall notify in writing existing key employees 

and primary management officials that they shall either: 

a. Complete a new application form that contains a notice 

regarding false statements; or 

b. Sign a statement that contains the notice regarding 

false statements. 

Backqround Investisations 

1. The Band shall request from each primary management 

official and from each key employee all of the following 

information: 

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

security number (s), birth date, place of birth, 

citizenship, gender, all languages (spoken or 

written) ; 

b. Currently and for the previous 5 years: business and 

employment positions held, ownership interests in 

those businesses, business and residence addresses, 

and drivers license numbers; 
c. The names and current addresses of at least three 

personal references, including one personal reference 

who was acquainted with the applicant during each 

period of residence listed under paragraph (l)(b) of 

this section; 

d. Current business and residence telephone numbers; 

e. A description of any existinu and previous business 

relationships wich Indian txibes, incluciing ownership interests in those businesses; 

f. A description of any existing an previous business 

relationships with the gaming industry generaily, 

including ownership interests in those businesses; 

g. 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; 

h. For each felony for which there is an ongoing 

prosecution or a conviction, the charge, the name and 

address of the court involved, and the date and 

disposition if any; 

i . For each mi sdernea~or convict ion or ongoing misdemeanor 

prosecution (e~cluding minor traffic violationsj 

within iO years of the date of the application, the 

name and address of the court involved and the date 

and disposition; 

j. For each crlmi~al charge (excluding minor traffic 

charges), whether or not there is a conviction, if 

such criminal charge is within 10 years of the date of 

the application and is not otherwise listed pursuant 

to paragraph (l)(h) or (llli) of this section, the 

criminal charge, the name and address of the court 

involved and the date and disposition; 

k. The name and address of any 1 icensing 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; 

1. A current photograph; 

in. Any other information the Sand deems relevant; and 

n. Fingerprints taken on behalf of the Band by officials 

from the Leech Lake Division of Resource Management. 
2. The Band shall conduct an investigation sufficient to make 

a determination under subsection D. below. In conducting 

a background investigation, the Band or its agent shall 

promise to keep confidential the identity of each person 

interviewed in the course of the investigation. 

Fingerprints taken on behalf of the Band shall be 

submitted through the National Indian Gaming Commission to 

the Federal Bureau of Investigation for a fingerprint 

check. In addition, for Class I11 gaming, pursuant to 

~ribal/State Compacts, the Band shall submit information 

to the State of Minnesota in order to allow the State 

Commissioner of Public Safety to perform a background 

check. 

D. Eliqibilitv Determination 

The Band, through Leech Lake Gaming shall review a person's 

prior activities, criminal record, if any, and reputation, 

habits and associations to make a finding concerning the 

eligibility of a key employee or primary management official 

for employment and licensing in a gaming operation. If Leech 

Lake Gaming determines that employment of the person 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, the gaming operation shall not employ or license 

that person in a key employee or primary management official 

position. 

E. Procedures for Forwardins Applications and Reports for Key 

Employees and Primarv Manaqement Officials to the National 

Indian Gamins Commission 

1. When a key employee or primary management official 

begins work at a gaming operation authorized by this 

ordinance, the Band through Leech Lake Gaming shall forward 

to the National Indian Gaming Commission a completed 

application for employment and conduct the background 

investigation and make the determination referred to in 

subsection D of this section. 

2. The Band through Leech Lake Gaming shall forward the 

report referred to in subsection F of this section to the 

National Indian Gaming Commission within 60 days after an 

employee begins work or within 60 days of the approval of 

this ordinance by the Chairman of the National Indian 

Gaming Commission. 

3. The gaming operation shall not employ as a key 

employee or primary management official a person who 

does not have a Band license after 90 days. 
. With respect to key employees and primary management 

officials, the Band through Leech Lake Gaming 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 (3) years fromthe date of 

termination of employment. 

F. Report to the National Indian Gaminq Commission 

1. Pursuant to the procedures set out in subsection E of this 

section, the Band through Leech Lake Gaming 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: 

a. Steps taken in conducting a background investigation; 

b. Results obtained; 

c. Conclusions reached; and 

d. The bases for those conclusions. 

2. The Band through Leech Lake Gaming shall submit, with the 

report, a copy of the eligibility determination made under 

subsection D of this section. 

3. If a license is not issued to an applicant, the Band 

through Leech Lake Gaming: 

a. Shall notify the ~ational Indian Gaming Commission; and 

b. May forward copies of its eligibility determination and 

investigative report (if any) to the National Indian 

Gaming Commission for inclusion in the Indian Gaming 

Individuals Records System. 

4. With respect to key employees and primary management 

officials, the Band through Leech Lake Gaming shall retain 

applications for employment and reports (if any) of 

background investigations for inspection by the Chairman of 

the National ~ndian Gaming Commission or his or her 

designee for no leass than three (3) years from the date of 

termination of employment. 
G. Grantinq a Gaminq License 

If, within a thirty (30) day period after the National 

Indian Gaming Commission receives a report, the National 

Indian Gaming Commission notifies the Band that it has no 

objection to the issuance of a license pursuant to a 

license application filed by a key employee or a primary 

management official for whom the Band has provided an 

application and investigative report to the National 

Indian Gaming Commission, the Band through Leech Lake 

Gaming may issue a license to such applicant. 

2. The Band through Leech Lake Gaming shall respond to a 

request for additional information from the Chairman of 

the National Indian Gaming Commission concerning a key 

employee or a primary management official who is the 

subject of a report. Such a request shall suspend the 30- 

day period under paragraph G.1. of this section until the 

Chairman of the National Indian Gaming Commission receives 

the additional information. 

3. If, within the thirty (30) day period described above, the 

National Indian Gaming Commission provides the Band with 

a statement itemizing objections to the issuance of a 

license to a key employee or to a primary management 

official for whom the Band has provided an application and 

investigative report to the National ~ndian Gaming 

Commission, the Band shall reconsider the application, 

taking into account the objections itemized by the 

~ational 1ndian Gaming Commission. The Band through 

Leech Lake Gaming shall make the final decision whether to 

issue a license to such applicant. 

H. License Suspension 

1. If, after the issuance of a gaming license, the Band 

receives from the National Indian Gaming Commission 

reliable information indicating that a key employee or a 

primary management official is not eligible for employment 

under subsection D. above, the Band through Leech Lake 

Gaming shall suspend such license and shall notify in 

writing the licensee of the suspension and the proposed 

revocation. 

2. The Band through Leech Lake Gaming shall notify the 

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

proposed revocation of a license. 
3. After a revocation hearing, the Band through Leech Lake 

Gaming shall decide to revoke or to reinstate a gaming 

license. The Band through Leech Lake Gaming shall notify 

the National Indian Gaming Commission of its decision. 

VIII. License Locations 

The Band through Leech Lake Gaming shall issue a separate license 

to each place, facility, or location on Indian lands where Class I1 

or Class I11 gaming is conducted under this ordinance. 

IX. Repeal 

All prior gaming ordinances are hereby repealed. 

X. Compliance With Tribal-State Compacts 

The Band shall adopt regulations and take all actions necessary to 

ensure that Class I11 gaming conducted on the lands of the Band 

complies in all respects with the Tribal-State Compacts between the 

Band and the State of Minnesota for Class I11 Video Games of Chance 

and Class 111 Blackjack Gaming. 

XI. Conduct of Class I1 and Class I11 Games 

All Class I1 and Class I11 games operated under this ordinance 

shall be conducted in accordance with this section. 

[Put in here the substantive requirements of the 1991 Gaming Code] 
LEECH LAKE BAND OF CHIPPEWA INDIANS 

GAMING CONTROL CODE 

A. Rules and Restrictions for Gaminq Activities. Each license 

operating a Gaming Enterprise under a license issued by the 

Band pursuant to Section 2 of these regulations must at all 

times observe the following rules and restrictions on gaming 

activities: 

No Credit Extended. All gaming shall be conducted on a 

cash basis. Except as herein provided, no person shall be 

extended credit for gaming by any Gaming ~nterprise. This 

restriction shall not apply to credits won by players who 

activate play on video games of chance after inserting 

coins or currency into the game, and shall not restrict the 

right of a Gaming ~nterprise to offer check cashing or to 

install or accept bank card or credit card transactions in 

the same manner as would be normally permitted at any 

retail business within the State of Minnesota. 

Minimum Ase for Players. No person below the age of 

eighteen (18) years on the date of gaming shall be 

permitted to participate in the gaming in any Gaming 

Enterprise. If any person below the age of eighteen (18) 

years plays and otherwise qualifies to win any prize, the 

prize shall not be paid, and the estimated amount wagered 

during the course of the game shall be returned to the 

player. 

3. Procedure Manuals. Each Gaming Enterprise shall publish 

and maintain a manual governing personnel policies and 

procedures, including standards of conduct and job 

descriptions for each employee, and describing the 

procedures that the Enterprise will follow, and the rights 

available, to each employee subject to the manual. 

B. Rules and Restrictions Governinq Binqo Games. The conduct of 

bingo games within a Gaming Enterprise must take place within 

the following rules and restrictions: 

1. Binqo ~quipment to be Used. The conduct of bingo must 

employ a machine or other device from which bingo balls, or 

appropriate substitute equipment, are withdrawn, ensuring 

that such drawing is on a random basis. The balls or 

appropriate substitute drawing equipment must be available 

for inspection by the players before a bingo session begins 

to determine that all are present and in operating 

condition. Each numbered ball or marker must be 

essentially equal as to size, weight, shape and balance and 
as to all other characteristics that may control their 

selection and all must be free from any defects and be 

present in the receptacle before each game is begun. Each 

bingo card must have printed on its face both its 

individual card or sheet number and the series number 

assigned by the manufacturer to that set of bingo cards. 

2. Conduct of Games. Bingo games shall be conducted in the 

following manner: 

Each ~aming Enterprise conducting Bingo games shall 

post a notice or notices on its premises which are 

plainly visible to the public, and which shall contain 

the rules governing the conduct of bingo. 

All sales of bingo cards must take place upon the site 

immediately preceding or during the session for which 

the bingo cards are being sold. 

No bingo card shall be reserved for use by players, 

except braille cards or other cards for use by legally 

blind or disabled players. 

The particular arrangement of numbers required to be 

covered in order to win each game must be clearly 

described and announced to the players immediately 

before. 

Immediately following the drawing of each ball in a 

bingo game, the caller shall display the letter and 

number on the ball to the players and corresponding 

letter or number on the Gaming Enterprise's flashboard 

must be lit for player viewing. 

A winner shall be determined when a specified pattern 

of called numbers appear on a card; and every winning 

card shall be verified by an employee of the Gaming 

Enterprise. 

Upon a bingo player declaring a winning bingo, the next 

ball or object randomly selected must be removed and 

must be the next ball or object to be called in the 

event the declared winning bingo is not valid. 

No person shall engage in any act, practice, or course 

of operation that would affect the integrity or 

adversely affect the outcome of any bingo game. 

No person who works at a Gaming Enterprise during a 

bingo session shall be permitted to play in a bingo 

game during that bingo session. 

No person who works at a Gaming Enterprise may have 

direct contact with a member of his or her immediate 

family, including the employee's spouse, child, parent, 

brother, or sister, on any matter involving the play of 

bingo, during a bingo session. 
3. Binso Records. For each bingo session, the following 

records must be kept: 

a. the number of players in attendance; 

b. the total amount wagered; 

c. the total prizes, cash and non-cash awarded; 

d. a copy of the schedule of gems and their prizes; and 

e. the number and price of cards sold, by type. 

4. Checkers required. One or more checkers must be engaged 

for each bingo session. The checker or checkers must 

record on a form prescribed by the Tribal Council the 

number of cards played in each game, the registration or 

card number of each winning card, and the prizes awarded to 

the recorded cards. Each checker must certify that the 

figures are correct to the best of the checkers knowledge. 

5. Gross receipts compared and discrepancies reported. The 

gross receipts of each bingo occasion must be compared to 

the checkers' records by an employee of the Gaming 

Enterprise who did not sell cards for the session. The 

comparison must be on a form prescribed by the Tribal 

Council. If a discrepancy of more than $20 is found 

between the gross receipts as reported by the checkers and 

the gross receipts determined by totalling the cash 

receipts, a copy of the comparison must be provided to the 

Tribal Council within five days of the bingo session. 

Rules and Restrictions Governinq "Blackjackw Games. The 

conduct of games of "Blackjack" in a Gaming Enterprise must 

take place in accordance with the following rules and 

restrictions. 

1. Object of Game. Blackjack shall be a Table Game played by 

a maximum of seven players, with one Dealer per Table. The 

object of the game shall be for a player to obtain a higher 

total point count than the Dealer, but not to exceed 

twenty-one points, and subject to the provisions of this 

Code, the rules of play shall be those generally applicable 

to the game known as "Blackjack" or "Twenty-one", as that 

game is played in the United States of America. 

2. Cards and Values. The game shall be played with decks of 

m lack jack Cards, which shall have the characteristics 

specified in section 5.e.3. of this Gaming Control Code, 

and shall comply with the terms of the Compact. For 

purposes of Blackjack, the blackjack Cards shall have the 

following values: 

a. Aces shall count either one point or eleven points, 

at the option of the player; 

b. Numbered Blackjack Cards shall count the same number 

of points as the number on the Card (for example, a 

"9" Card shall count 9, and a "10" Card shall count 

10. 

c. Blackjack Cards bearing a King, Queen, or Jack shall 

count 10. 

14 
In the initial deal, when a player or the Dealer is dealt 

as Ace an any of the ten count Blackjack Cards, that 

combination shall constitute a natural Blackjack, which may 

be identified by the player or Dealer as "Blackjackw. 

Wasers. In the play of Blackjack, the following forms of 

wagers may be made by a player: 

a. Orisinal Waser. An Original Wager shall be made by 

placing a Chip or Chips representing an amount from 

two dollars and ten dollars, as designated by a sign 

plainly posted at each table, inside the betting 

space provided on the playing surface of the 

Blackjack Playing Table, before the first Card is 

dealt in a game. Once the first Card is dealt in a 

game, no Original Wage may be altered by any player. 

b. Split Waqer. If a player receives, in the initial 

deal of Cards, either a pair or any two ten-count 

Cards, the player may split the Cards, provided that 

no player may play more than four hands in one 

betting space. For each hand thus created, the 

player may wager an amount equal to the Original 

Wager. 

c. Double-Down Waser. After receiving two Cards, or two 

Cards for each hand in a split hand, a player may 

make a Double-Down Wager by wagering an additional 

amount equal to the Original Wager; and a player 

playing split hands may made a Double Down Wager by 

Wagering an amount equal to the Original Wager for 

one or more such hands, provided that no player may 

place a Double-Down Wager on split Aces. 

d. Insurance Waqer. If the first Card received by the 

dealer is an Ace, a player may make an insurance 

Wager in an amount equal to one-half of the amount of 

the Original Wager. 

e. ~ip-Bet Waqer. A Tip-Bet Wager, if made, shall be 

made before the first Card is dealt, and may be in 

any amount up to one-half of the original wager. It 

may not be increased or changed during play, and 

cannot be the subject of a Double-Down Wager or an 

Insurance Wager. If, following a ~ip-~et Wager, a 

player splits hands, the Tip-Bet Wager shall be 

assigned to the player's sight-hand set of Cards 

(the first Cards to be played). All Tip-Bet Wagers 

shall have a pay-off of one dollar for each dollar 

wagered, whether or not the player receives a 

natural Blackjack. When a Tip-Bet Wager is made, if 

a player's hand wins the ~ip-~et Wager shall be 
returned to the player and the amount won from the 

Enterprise becomes the property of the Dealer; if 

the Dealer's hand wins the Tip-Bet Wager becomes the 

property of the Enterprise; and if the player's hand 

ties the Dealer's hand, the player may either take 

back the Tip-Bet Wager or leave it on the playing 

surface for the next round of play. 

f. Disposition of Tip-Bet Waqers Received. All tip bets 

won by a Dealer shall be deposited in the locking 

Tip Box in the Dealer's pit area, shall be pooled 

with all other tips earned by Dealer, and shall be 

divided weekly between Dealers and Pit Bosses on a 

formula to be agreed upon by them, subject to the 

requirements of Federal and State income tax laws 

and regulations. 

4. Staffinq. At any Gaming Enterprise conducting lack jack 

games, the following staffing requirements shall apply: 

a. Necessary staff on duty. At all times during the 

conduct of Blackjack games at a Gaming Enterprise, the 

following staff must be on duty: 

(1) at least one cashier; 

(2) at least one pit boss for each pit area open, and 

not less than one pit boss for each four open 

tables; 

(3) one dealer per open table. 

b. Trainins of Dealers. All Dealers in Blackjack games 

must have completed at least thirty hours of training 

with the Gaming Enterprise. 

c. Trainins of Pit Bosses. All Pit Bosses must have 

completed at least six weeks of employment as a Dealer, 

and at least thirty hours of Pit Boss Training within 

the Gaming ~nterprise. 

5. ~quipment. The following requirements shall apply to all 

equipment used in the play of Blackjack: 

a. Blackjack Playins Table -- Physical Characteristics. 

Each Playing Table for the play of Blackjack shall have 

the following characteristics: 

(1) The Playing Table shall have either five or seven 

separate distinct betting spaces. 

(2) The playing surface of the Paying Table shall 

prominently display the following complete 

statements: "Blackjack PAYS 3 TO 2" and "CALLER 

MUST STAND ON 17 AND MUST DRAW TO 16". 
(3) Drop boxes, meeting the requirements of section 

5.c.2. of this Gaming Control Code, shall be 

securely locked to each Playing Table. 

(4) The playing surface shall include special betting 

places use of the placement of Tip Bet Wagers. 

(5) Unless only one Playing Table is used at a Gaming 

~nterprise, a Playing Table number must be either 

permanently imprinted, or adhesively backed and 

impressed thereon, or attached to the top of each 

Playing Table. 

(6) Each Playing Table or pit areas shall be equipped 

with a removable transparent lockable Tip Box. 

(7) A Card or plaque located on the top of each 

Playing Table must indicate the minimum and 

maximum wagers permitted under the provisions of 

this Gaming Control Code. 

b. Drop Boxes -- Phvsical Characteristics. Each Playing 

Table for the play of Blackjack shall have a removable 

metal container known as a "Drop Box" into which must 

be deposited all duplicate Fill Slips, original Credit 

slips, and currency received from players for the 

purchase of Chips. Each Drop Box shall have the 

following characteristics: 

(1) Unless only one Blackjack Playing Table is used at 

a Gaming Enterprise, each Drop Box shall have a 

number, either attached, permanently imprinted, or 

adhesively backed and impressed thereon, which 

corresponds to the number of the Playing Table to 

which it is attached. 

(2) Each Drop Box shall be securely locked to its 

Playing Table, and shall have an individually 

keyed lock. 

(3) ~uring play, each Drop Box shall have a money 

plunger, which shall remain in the Drop Box slot 

at all times except when currency and forms are 

inserted into the Drop Box. 

c. Blackjack Cards -- Physical Characteristics. All cards 

used in the play of Blackjack shall have the following 

characteristics: 

(1) The cards used in the play of Blackjack shall be 

four or more complete decks of Blackjack Cards, 

shuffled together and used as one deck. The 

cards must be dealt as a single packet from a 

Dealing Shoe, which shall have the 

characteristics described in section 5.e.4. of 

this Gaming Control Code. 

(2) The design and color of the backs of each card in 

the decks in a Dealing Shoe shall be identical. 
(3) No deck of lackj jack Cards may be used in any 

Blackjack game if any card therein is taped, 

defaced, bent, crimped, cut, shaved, or deformed 

in any other manner. 

d. Blackiack Dealins Shoe -- Physical Characteristics. 

Each dealing Shoe used in the play of Blackjack shall 

have the following characteristics: it shall have an 

opaque face plate, a white or transparent base plate, 

and transparent sides, or a cutout under the base plate 

of each side, and shall be designed to contain at least 

four complete decks of Blackjack Cards. 

e. ~lackiack Chips -- Physical Characteristics. Each Chip 

used in the play of Blackjack shall have the following 

characteristics: 

(1) Each Chip shall be a die-cut clay security chip, 

designed manufactured and constructed to prevent, 

to the maximum extent possible, its 

counterfeiting. 

(2) The playing value of each Chip, and the name of 

the Gaming Enterprise issuing the Chip, shall be 

clearly imprinted on the Chip. 

6. Distribution of Chips to Playins Tables -- Use of Fill 

Slips. The following procedures shall govern the 

distribution of Chips to the playing Tables, and the use of 

Fill Slips, for the play of Blackjack: 

a. Fill Slips -- Characteristics. The Fill Slips required 

by this section of this Gaming Control Code shall be 

serially prenumbered forms, which shall be used in 

sequential order. Fill Slips shall be so designed as 

to permit the recording thereon of the following 

information: the date ad time of the use of the Fill 

Slip, the quantity and denomination of the Chips being 

distributed, the total dollar value of each 

denomination of Chips being distributed, the total 

dollar value of all of the Chips being distributed, the 

number of the Playing Table to which the distribution 

is being made, and the name of the Cashier making the 

distribution. 

b. Fill Slips -- Use. A Fill Slip shall be prepared by a 

Cashier prior to any distribution of Chips to any 

playing Table. On the original and duplicate Fill 

Slip, all of the information described in section 5.d. 1 

of this Gaming Control Code shall be recorded by the 

cashier distributing the Chips. The Pit Boss, or an 

employee designated by the Pit Boss, then shall examine 

the Chips being distributed and the Fill Slip, and if 

the Fill Slip correctly records all information, the 
Pit Boss or the designated employee shall sign the Fill 

Slip. The original copy of the Fill slip shall be 

retained by the Cashier, and the Pit Boss or the 

designated employee shall transfer the duplicate copy 

of the Fill Slip, together with the Chips being 

distributed, to the playing Table. The Dealer at the 

Playing Table shall then examine the Chips being 

distributed, and if the duplicate copy of the Fill slip 

correctly records all information, the Dealer shall 

sign or initial the duplicate Fill Slip, and shall then 

immediately deposit it in the Drop Box attached to the 

Playing Table. Any Fill Slips which are voided must be 

marked "voidw on both the original and duplicate copy, 

shall be signed by the person thus marking the Slips, 

and shall be recorded and retained in the same manner 

as valid Fill Slips. 

c. Fill Slips -- Accountina. Records of the serial number 

of all Fill Slips, and of name of the cashier to whom 

each Fill slip is distributed, together with the 

original and duplicate copy of each Fill Slip, 

including each void Fill Slip, shall be maintained by 

an employee of the Gaming Enterprise who is not a 

Cashier, Dealer, or Pit Boss. 

7. Removal of Chips from Plavinq Tables -- Use of Credit 

Slips. The following procedures shall govern the removal 

of Chips from the Playing Tables, and the use of Credit 

Slips, for the play of Blackjack: 

a. Credit Slips -- Characteristics. The Credit Slips 

required by this Section of this Gaming Control Code 

shall be serially prenumbered forms, which shall be 

used in sequential order. Credit Slips shall be so 

designed as to permit the recording thereon of the 

following information: the date and time of the use of 

the Credit Slip, the quantity and denomination of the 

Chips being removed, the total dollar value of each 

denomination of Chips being removed, the total dollar 

value of all of the Chips being removed, the number of 

the Playing Table from which the removal is being made, 

and the name of Dealer assigned to the Playing Table 

from which the Chips are being removed. 

b. Credit Slips -- Use. A Credit Slip shall be prepared 

prior to the removal of any Chips from any Playing 

Table. On the original and duplicate Credit Slip, all 

of the information described in section 5.e.l. of this 

Gaming Control Code shall be recorded by the Dealer 

from whose playing Table the Chips are being removed. 

The Pit Boss then shall examine the Chips being removed 

and the Credit Slip, and if the Credit Slip correctly 

records all information, the Pit Boss shall sign the 

Credit Slip. The original copy of the Credit Slip 
shall be retained by the Dealer, and shall immediately 

be deposited in the Drop Box attached to the Playing 

Table, and the Pit Boss shall transfer the duplicate 

copy of the Credit Slip, together with the Chips being 

removed, to the cashier. The cashier shall then 

examine the Chips being removed, and if the duplicate 

copy of the Credit Slip correctly records all 

information, the cashier shall sign or initial the 

duplicate Credit Slip and shall retain it. Any Credit 

Slips which are voided must be marked "Void" on both 

the original and duplicate copy, and shall be signed by 

the person thus marking the Slips. All Credit Slips 

marked "Voidw shall be recorded and retained in the 

same manner as valid Credit Slips. 

c. Credit Slips -- ~ccountinq. Records of the serial 

numbers of all Credit Slips, and of the name of the 

Dealer to whom each Credit Slip is distributed, 

together with the original and duplicate copy of each 

Credit Slip, including each void Credit Slip, shall be 

maintained by an employee of the Gaming Enterprise who 

is not a Cashier, Dealer, or Pit Boss. 

8. ~lackiack Chip Bank Services. Blackjack Chip Bank services 

shall occur in accordance with the following rules and restrictions: 

a. Sale of Blackiack Chips. Chips shall be sold only at 

Playing Tables, and shall be sold only for United 

States currency. No checks may be accepted for the 

purchase of Chips. The value at which Chips are sold 

and redeemed must be conspicuously posted by the Gaming 

Enterprise, and shall be visible to each person at the 

time Slips are purchased. 

b. Procedure for Acceptins Cash. Each Dealer accepting 

currency for Chips at a Playing Table shall spread such 

currency on the surface of the Playing Table, in full 

view both of the player who presented it and of the Pit 

Boss assigned to the Playing Table. The Dealer shall 

then announce the amount of such currency, in a tone of 

voice loud enough to be heard by the player who 

presented the currency and the Pit Boss assigned to the 

Playing Table. 

c. Exchanqe of Chips -- Placement of Currency in Drop Box. 

Immediately after performing the procedures described 

in this Section, the Dealer accepting currency shall 

give to the player who presented it an equivalent 

amount of Chips, and shall remove the currency received 

from the surface of the Playing Table and place it into 

the Drop Box attached thereto. 
d. Disposition of Currency -- Access to Drop Box. All 

currency received for chips at Playing Tables must be 

kept completely separate and apart from all other 

monies received by a Gaming Enterprise until such 

currency has been counted in accordance with the 

provisions of this Gaming Control Code. No person, 

other than the Count Team described in this Gaming 

Control Code, shall have access to the contents of any 

Drop Box. 

e. Redemption of Chips. Each Gaming Enterprise shall 

redeem Blackjack Chips for cash at the value for which 

they were sold, provided that such Chips were obtained 

lawfully and in accordance with the provisions of this 

Gaming Control Code. The cash bank from which funds 

are obtained to redeem Chips shall be completely 

separate and apart from all other monies held by the 

Gaming Enterprise. 

D. Video Games of Chance. The following requirements shall apply 

to the management and conduct of all Video Games of Chance 

within any Gaming ~nterprise: 

1. Licensins of Manufacturers. No Gaming Enterprise may own, 

lease, or operate video Games of Chance that have been 

manufactured by a manufacturer that has not received a 

license from the Tribal Council. The Tribal Council shall 

issue licenses only to manufacturers of video Games of 

Chance holding a valid license from the State of Minnesota, 

or the State of New Jersey, or the State of Nevada, or the 

State of South Dakota. 

2. Licensins of Distributors. No Gaming Enterprise may own, 

lease, or operate Video Games of Chance that have been 

distributed by a distributor that has not received a 

license from the Tribal Council. The Tribal Council shall 

issue license only to distributors of Video Games of Chance 

holding a valid license from the State of Minnesota, or the 

State of New Jersey, or the State of Nevada, or the State 

of South Dakota. 

3. Suspension, Revocation, or Non-Renewal of Manufacturer or 

Distributor License. In the event that the State of 

Minnesota, or the State of New Jersey, or the State of 

Nevada, or the State of South Dakota suspends, revokes, or 

refuses to renew a license of a manufacturer or distributor 

of Video Games of Chance similarly licensed by the Tribal 

Council, such actio shall be grounds for similar action by 

the Tribal Council and the Community shall suspend, revoke 

or refuse to renew the license issued by the Tribal Council 

to such manufacturer or distributor. 

4. Qualifications of Lessors of Video Games of.Chance. In 

accordance with the terms of the Compact on Video Games of 

Chance, prior to entering into any lease agreement for 
Video Games of Chance or related equipment each Gaming 

Enterprise shall obtain sufficient information and 

identification from the proposed lessor, and all persons 

holding any direct or indirect financial interest in the 

lessor or the proposed lease agreement, to permit the State 

of Minnesota to conduct a background check on those 

persons. The information shall be provided in writing, 

along with the standard fee, to the State Commissioner of 

Public Safety, who shall conduct the background check and 

provide a written report to the Tribal Council regarding 

each applicant within thirty (30) days of the receipt of 

such request. No Gaming Enterprise shall enter into a 

lease agreement for Video Games of Chance or related 

equipment with any person or entity if the State Department 

of public Safety determines that the lessor, or any manager 

or person holding a direct or indirect financial interest 

in the lessor or the proposed lease agreement has been 

convicted of a felony within the previous five years, or 

has been convicted of a felony or a gross misdemeanor 

involving fraud, misrepresentation or gambling. 

5. ~echnical Standards: ~estinq and Approval of Video Games 

of Chance. No video Game of Chance may be purchased, 

leased, or otherwise acquired by a Gaming Enterprise 

unless: (i) the Video Game of Chance is purchased, leased 

or acquired from a manufacturer or distributor licensedto 

sell, lease or distribute Video Games of Chance by the 

Tribal Council pursuant to this Code; and (ii) the Video 

Game of Chance, or a prototype thereof, has been tested, 

approved or certified by a Gaming Test Laboratory as 

meeting the requirements and standards of the Compact on 

Video Games of Chance. 

6. Technical Standards: Application for Approval of Prototvpe 

Video Game of Chance. Each Gaming Enterprise shall provide 

or require that a manufacturer of Video Games of Chance 

provide to a Gaming Test Laboratory two copies of Video 

Game of Chance illustrations, schematics, block diagrams, 

circuit analyses, technical and operation manuals, program 

object and secure codes and hexadecimal dumps (the compiled 

computer program represented in base 16 format) and any 

other information requested by the Gaming Test Laboratory. 

7. Technical Standards: Testinu of Video Games of Chance. 

If required by the Gaming Test Laboratory, the Gaming 

Enterprise shall require the manufacturer of a Video Game 

of Chance to transport not more than two working models of 

a Video Game of Chance and related equipment to a location 

designated by the laboratory for testing, examination and 

analysis. The testing, examination, and analysis may 

include the entire dismantling of the Video Game of Chance 

and related equipment and some tests may result in damage 

or destruction to one or more electronic components of the 

devices. If required by the laboratory, the Gaming 
Enterprise must require the manufacturer to provide 

specialized equipment or the services of an independent 

technical expert to assist with the testing, examination 

and analysis. 

8. Technical Standards: Rewort of Test Results: At the 

conclusion of each test of a Video Game of Chance, the 

Gaming Test Laboratory shall provide to the Minnesota State 

Commissioner of Public Safety and the ~ribal Council a 

report that contains findings, conclusions and a 

determination that the video Game of Chance and related 

equipment conforms or fails to conform to the technical 

requirements and standards set forth in the Compact on 

Video Games of Chance. If modifications can be made which 

would bring the Video Game of Chance or related equipment 

into compliance with the requirements and standards set 

forth in the Compact on Video Games of Chance, the report 

may contain recommendations for such modifications. 

9. ~echnical Standards: Modifications of Approved Video Games 

of Chance. The manufacturer or distributor of a Video Game 

of Chance shall assemble and install each Video Game of 

Chance and related equipment in a manner approved and 

licensed by the Tribal Council. No modification to the 

assembly or operational functions of any Video Game of 

Chance or related equipment may be made after testing and 

installation unless a Gaming Test Laboratory certifies to 

the Minnesota State Department of Public Safety and the 

Tribal Council that the modified Video Game of Chance 

conforms to the standards of the Compact on Video Games of 

Chance. All proposed modifications shall be described in 

a written request made to the Minnesota State commissioner 

of Public Safety, the Gaming Test Laboratory and the Tribal 

Council. The written request shall contain information 

describing the modification, the reason therefore and all 

documentation required by the Gaming Test Laboratory. In 

emergency situations where modifications are necessary to 

prevent cheating or malfunction, the Gaming Test Laboratory 

may grant temporary certification of the modifications for 

up to fifteen (15) days pending compliance with the terms 

of this Section of the Code. 

10. Technical Standards: Conformity to Technical Standards of 

Compact on Video Games of Chance. As a condition to 

maintaining a manufacturer's and/or distributor's license 

under this Code, each manufacturer and/or distributor of a 

Video Game of Chance shall certify to the Tribal Council 

and to the Minnesota State Commissioner of Public Safety 

that, upon installation, each Video Game of Chance placed 

in a Gaming Enterprise by such manufacturer or distributor 

(i) conforms precisely to the exact specifications of the 

Video Game of Chance prototype tested and approved by the 

Gaming Test Laboratory; and (ii) operates and plays in 
accordance with the technical standards set forth in 

sections 6.9 and 6.10 of the Compact on Video Games of 

Chance. 

11. Technical Standards: Information to be Provided. Prior to 

the installation of any Video Game of Chance acquired by a 

Gaming Enterprise after the effective date of the compact 

on Video Games of Chance, and as soon as possible but in no 

event later than October 30, 1990 for any Video Game of 

Chance operated by a Gaming Enterprise on or before the 

effective date of the Compact on Video Games of Chance, the 

Community shall require that the manufacturer or 

distributor of such Video Game of Chance provide to the 

Minnesota State Commissioner of Public Safety: (i) a list 

of all states in which the distributor or manufacturer from 

whom the Video Game of Chance was acquired or leased is 

licensed, the license numbers (if license numbers are 

issued) and operative dates of the license(s): and (ii) 

identification numbers or codes for each video Game of 

Chance placed in the Gaming Enterprise. 

12. Technical Standards: Hardware and Software Reauirements 

for Video Games of Chance. Each video Game of Chance 

operated by a Gaming Enterprise must be licensed by the 

Tribal Council, and, subject to the provisions of Section 

3e(ll) of this code, shall meet the specifications 

contained in Sections 6.9 and 6.10 of the Compact on Video 

Games of Chance, as those specifications may be amended 

from time to time. 
WE DO HEREBY CERTIFY that the foregoing ordinance was duly adopted 

Gaming 

by a vote of 5 for and 0 against at a hmmission meeting 

of the Leech Lake Reservation Tribal Council, also known as the 

~eech Lake Reservation Business Committee, a quorum being present, 

held on August, 28th .. , 1993, at Cass Lake, Minnesota. 

&/g.Lr7L- Alffid R. Pemberton, Chazrman