DEC 1 8 2006 

VIA FACSIMILE AND U.S. MAIL 

Mr. Juan Garza, Jr., Chairman 

Kickapoo Traditional Tribe of Texas 

794 Lucky Eagle Drive 

Eagle Pass, Texas 78853 

Fax: (830) 758-8008 

RE: Approval of Class I1 Tribal Gaming Ordinance 

Dear Mr. Garza, 

This letter is in response to your request for the National Indian Gaming Commission 

(NIGC) to review and approve the revised Gaming Ordinance for the Kickapoo 

Traditional Tribe of Texas, enacted on December 4, 2006, and received by the NIGC on 

December 5, 2006. This letter constitutes such approval under the Indian Gaming 

Regulatory Act (IGRA). It is important to note that the Gaming Ordinance is approved 

for gaming only on Indian Lands, as defined in the IGRA, over which the Tribe has 

jurisdiction. 

dinance for review and approval. The NIGC staff and I 

u and the Kickapoo Traditional Tribe of Texas on future 

Chairman 

cc: Gloria Hernandez, Esq. 

NATIONAL HEADQUARTERS 1441 L St. NW, Suite 9100. Washington. DC 20005 Tel: 202.632.7003 Fax: 202.632.7066 WWW.NlGC.GOV 

REGIONAL OFFICES Portland. OR; Sacramento. CA; Phoenix, AZ; St. Paul. MN; Tulsa, OK 
KICKAPOO TRADITIONAL TRIBE OF TEXAS 

Section 

101 

102 

103 

104 

105 

106 

107 

108 

109 

110 

11 1 

112 

113 

114 

115 

116 

117 

118 

119 

201 

GAMING ORDINANCE .z 

I 

F: 

SEP 1 2 2&l6 

Table of Contents 6 

Title shJ I zcb 

Findings 

Declaration of Purpose 

Definitions 

Gaming Authorized 

Ownership of Gaming 

Use of Gaming Revenue 

Per Capita Payments 

Gaming Commission 

Ethics 

Complimentary Items 

Audit 

Environment and Public Health and Safety 

Patron Dispute Resolution 

Tribal Internal Control Standards 

Facility Licenses 

Agent for Sewice of Press 

Compliance with Federal Law 

Repeal 

Tribal Access to Financial Information 

Licenses for Key Employees and Primary Management 

Officials 

License Application Forms 

License Fees 

Fingerprints 

Background Investigations 

Procedures for Conducting a Background Check on 

Applicants 

Eligibility Determination 

Procedures for Forwarding Applications and Reports for 

Key Employees and Primary Management Officials to 

the National Indian 1 Gaming Commission 

Report to the National Indian Gaming Commission 

Granting a Gaming License 

License Suspension 

Board of Review for Disputes 

Licenses for Vendors 

Submission of a Vendor License Application 

Contents of the Vendor License Application 

Page 

3 

3-4 

4-8 

8 

8 

8 

8-9 

10-15 

15-16 

16 

16-17 

17 

17 

17 

18 

18 

18 

19 

19 

19 

304 Vendor Background I vestigation 30 

Enacted by Tribal Council action on 

Page 1 of 33 

July 28,2006 
KICKAPOO TRADITIONAL TRIBE OF TEXAS 

GAMING ORDINANCE 

Section Title 

305 Vendor License Fee 

306 Vendor Background Investigation Report 

307 Exemption for Vendors Licensed by Recognized 

Regulatory Authorities 

308 Licenses for Non-Gaming Vendors 

Enacted by Tribal Council action on 

July 28,2006 

Page 

31 

3 1 

3 1 

Page 2 of 33 
KICKAPOO TRADITIONAL TRIBE OF TEXAS 

GAMING ORDINANCE 

10 Findings ' 12 (ldU 

The Kickapoo Traditional Tribe of Texas finds that: 

(a) Gaming on Tribal Lands is a valuable means of generating revenues needed by 

the Kickapoo Traditional Tribe of Texas to enhance economic development 

and self-sufficiency, promote and strengthen self-governance, increase Tribal 

member employment, and to fund Tribal social programs and services; and 

(b) Tribal Regulation and control of gaming on Tribal Lands is necessary in order 

to ensure the welfare and best interests of the Tribe, its members and patrons of 

the Tribe's gaming enterprises, prevent any proliferation of organized crime 

and other corrupting influences on Tribal Lands, protect the fairness of gaming 

conducted on Tribal Lands and preserve the political integrity of the Tribe. 

5 102 Declaration of Purpose 

The express purpose of this Ordinance is: 

(a) To provide a statutory basis for the regulation of gaming on Tribal Lands to 

ensure that gaming is shielded from organized crime and other corrupting 

influences, to ensure that the Tribe is the primary beneficiary of the gaming 

operation, and to assure that gaming is conducted fairly and honestly by both 

the operator and the player; 

(b) To regulate and control gaming on Tribal Lands for the protection of gaming 

as a means of promoting economic development, self-sufficiency, and strong 

tribal government. 

(c) To foster a spirit of cooperation with federal officials in the regulation of 

gaming; 

(d) To ensure that gaming on Tribal Lands is conducted in conformity with 

Tribal law, the Indian Gaming Regulatory Act (IGRA), 25 U.S.C. section 

2701 et seq. and regulations promulgated pursuant thereto. 

Enacted by Tribal Council action on 

July 28,2006 

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KICKAPOO TRADITIONAL TRIBE OF TEXAS 

GAMING ORDINANCE 

(e) To ensure that the construction and maintenance of gaming facilities and the 

operation of all gaming conducted at such facilities is conducted in a manner 

which adequately protects the environment, public health, and safety; and 

(f) To establish and independent regulatory authority charged with oversight and 

enforcement of gaming regulatory matters under Tribal Law, with the goal of 

becoming self-regulating under IGRA and regulations promulgated thereto. 

(g) The Kickapoo Traditional Council of the Kickapoo Traditional Tribe of 

Texas, empowered by the Kickapoo Traditional Tribe of Texas Constitution 

to enact ordinances, hereby enacts this ordinance in order to govern Class I1 

[and Class I11 when applicable] gaming operations on the Tribe's Indian 

lands. 

5 103 Definitions 

Unless a different meaning is clearly indicated in this Ordinance, the terms used 

herein shall have the same meaning as defined in the Indian Gaming Regulatory 

Act (IGRA), 25 U.S.C. 5 2701 et seq., and its regulations, 25 C.F.R. 5 500 et seq. 

Specifically: 

(a) "Authority" means the Kickapoo Traditional Tribe of Texas Gaming 

Regulatory Authority established by this Ordinance. 

(b) "Authority Data" means all information, files, reports, records, 

correspondence and other data collected, created, received, maintained or 

disseminated by the Authority regardless of its physical form, storage 

method, or conditions of use. 

(c) "Applicant" means an individual or entity that applies for a Tribe gaming 

license or certification. 

(d) "Background Investigation" has the meaning given in 25 C.F.R. Part 556.4. 

(f) "Class I gaming" means social games solely for prizes of minimal value or 

traditional forms of Indian gaming engaged in by individuals as a part of, 01- 

in connection with, tribal ceremonies or celebrations. 

Enacted by Tribal Council action on 

July 28,2006 

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KICKAPOO TRADITIONAL TRIBE OF TEXAS 

GAMING ORDINANCE 

(g) "Class I1 gaming" means: 

(1) the game of chance commonly known as bingo (whether or not 

electronic, computer, or other technologic aids are used in connection 

therewith) : 

i. whch is played for prizes, including monetary prizes, with cards 

bearing numbers or other designations, 

ii. in which the holder of the card covers such numbers or designations, 

when objects, similarly numbered or designated, are drawn or 

electronically determined, and 

iii. in which the game is won by the first person covering a previously 

designated arrangement of numbers or designations on such cards, 

including (if played in the same location) pull-tabs, lotto, punch 

boards, tip jars, instant bingo and other games similar to bingo, and 

(2) Card games that are explicitly authorized by the laws of the State, or are 

not explicitly prohibited by the laws of the State and are played at any 

location in the State, but only is such card games are played in 

conformity with those laws and regulations (if any) of the State 

regarding hours or periods of operation of such card games or 

limitations on wagers or pot sizes in such card games. 

(3) The term "class I1 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. 

(h) "Class I11 gaming" means all forms of gaming that are not class I gaming or 

class I1 gaming. 

(i) "Commission" means the Tribal Gaming Commission established to perform 

regulatory oversight and to monitor compliance with Tribal, Federal, and 

applicable State regulations. 

(j) "Commissioner" means a Tribal Gaming Commissioner. 

Enacted by Tribal Council action on 

July 28,2006 

Page 5 of 33 
KJCKAPOO TRADITIONAL TRIBE OF TEXAS 

GAMING ORDINANCE 

(k) "Compact" means a Tribal-State Compact concerning class I11 gaming 

approved by the Secretary of the Interior and published in the Federal 

Register pursuant to 25 U.S.C. @ 2710 (d). 

(1) "Compliance" means that any gaming and gaming related activity regulated 

by this Tribal Ordinance is conducted in accordance with applicable laws. 

(m) "Conditional Licenses" means the issuance of a Conditional License to an 

applicant is based on approved criteria set forth by the K.T.T.T. Gaming 

Commission. 

(n) "Confidential Data" means Authority Data on a Person that by Tribal 

Ordinance, regulation or order, or by applicable federal law, is not made 

available to the public. The term includes Confidential Limited Availability 

Data and Confidential Restricted Availability Data. 

(0) "Complimentary" shall have the meaning as set forth in 25 C.F.R. $542.2(a). 

(p) "Directly related to" means a spouse, child, parent, grandparent, grandchld 

or sibling. 

(q) "Gaming Facility or Facilities" means The Kickapoo Lucky Eagle Casino. 

(r) "Indian lands" for purposes of this ordinance means: 

(1) all lands within the limits of the Tribe's reservation: 

(2) any lands title to which is either held in trust by the United States for the 

benefit of the Tribe or individual or held by the Tribe or individual 

subject to restriction by the United States against alienation and over 

which the Indian Tribe exercises governmental power; and 

(3) for all lands acquired into trust for the benefit of an Indian tribe after 

October 17, 1988, the lands meet the requirements set forth in 25 U.S.C. 

$2719. 

(s) "Indian Tribe" means the Kickapoo Traditional Tribe of Texas. 

Enacted by Tribal Council action on 

July 28,2006 

Page 6 of 33 
KICKAPOO TRADITIONAL TRIBE OF TEXAS 

GAMING ORDINANCE 

(t) "Key Employee" means 

(1) a person who performs one or more of the following hnctions: 

Bingo caller; 

Counting room supervisor; 

Director of security; 

Custodian of gaming supplies or cash; 

Floor manager; 

Pit boss; 

Dealer; 

Croupier; 

Approver of credit; or 

Custodian of gambling devices including persons with access to 

cash and accounting records withn 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. 

(u) "Net Revenues" means gross gaming revenues of an Indian gaming operation 

less: 

(1) Amounts paid out as, or paid for, prizes; and 

(2) Total gaming-related operating expenses, excluding management fees. 

(v) "Primary Management Official" means 

(I) The person(s) having management responsibility for a management 

contract; 

(2) Any person who has authority: 

Enacted by Tribal Council action on 

July 28,2006 

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KICKAPOO TRADITIONAL TRIBE OF TEXAS 

GAMING ORDINANCE 

(A) To hire and fire employees; or 

(B) To set up working policy for the gaming operation; or 

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

management responsibility. 

5 104 Gaming Authorized 

Class I1 gaming is hereby authorized. 

5 105 Ownership of Gaming 

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

conduct of any gaming operation authorized by thls ordinance. 

5 106 Use of Gaming Revenue 

Net revenues from tribal gaming shall be used only for the following purposes: 

(1) to fund tribal government operations and programs; 

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

(3) To promote tribal economic development; 

(4) To donate to charitable organizations; or 

(5) To help fund operations of local government agencies. 

5 107 Per Capita Payments 

(a) "Per Capita Payment" means the distribution of money or other thing of value 

to all members of the Tribe, or to identified groups of members, which is 

paid directly from the net revenues of any tribal gaming activity. 

Enacted by Tribal Council action on 

July 28,2006 

Page 8 of 33 
KICKAPOO TRADITIONAL TRIBE OF TEXAS 

GAMING ORDINANCE 

(b) If the Tribe elects to make per capita payments to tribal members from 

revenues derived from its gaming operations, it shall ensure that the 

following requirements of 25 C.F.R. Part 290 are met: 

1. The Tribe shall authorize and issue such payments only in 

accordance with a revenue allocation plan submitted to and approved 

by the Secretary of the Interior under 25 U.S.C. 4 27 10(b)(3). 

2. The Tribe shall ensure that the interests of minors and other legally 

incompetent persons who are entitled to receive any per capita 

payments under a Tribal per capita payment plan are protected and 

preserved, and that the per capita payments are disbursed to the 

parents or legal guardian of such minors or legal incompetents in 

such amounts as may be necessary for the health, education, or 

welfare or the minor or other legally incompetent person, under a 

plan approved by the Tribal Council and the Secretary of the 

Interior. The Tribe must also establish criteria and a process for 

withdrawal of funds by the parent or legal guardian. 

3. The Tribal Council shall designate or create a Tribal court system, 

forum, or admnistrative process for resolution of disputes 

concerning the allocation of net gaming revenues and the 

distribution of per capita payments and will explain how it will 

correct deficiencies. 

4. The Tribal Council shall ensure that the Tribal revenue allocation 

plan reserves an adequate portion of net gaming revenues from the 

tribal gaming activity to do one or more of the following purposes: 

fund Tribal Government operations or programs; provide for the 

general welfare of the tribe or its members; promote tribal economic 

development; donate to charitable organizations; or to help fund 

operations of local governments. 

5. The Tribal Council shall ensure that distributions of per capita 

payments are made according to specific eligibility requirements. 

6. The Tribal Council shall ensure that Tribal members are notified of 

the tax liability for per capita payments and how taxes will be 

withheld. 

Enacted by Tribal Council action on 

July 28,2006 
KICKAPOO TRADITIONAL TRIBE OF TEXAS 

GAMING ORDINANCE 

5 108 Gaming Commission 

(a) The Tribe hereby establishes a Tribal Gaming Commission whose duty it is 

to regulate tribal gaming operations. The Tribal Gaming Commission shall 

consist of 3 members. There shall be among them a Chairperson, ViceChairperson, and at least one additional Commissioner. 

(b) The purpose of the Tribal Gaming Commission is regulatory, not 

managerial. The Commission will conduct oversight to ensure compliance 

with Tribal, Federal, and, if applicable, State laws and regulations. The 

Commission will serve as the licensing authority for individuals employed in 

the gaming operation and will administer background investigations as part 

of the licensing process. The Commission will also have a role in monitoring 

compliance with the internal controls for the gaming operation and in 

tracking revenues. In order to carry out its regulatory duties, the Commission 

shall have unrestricted access to all areas of the gaming operation and to all 

records. The Commission shall have authority to take enforcement actions, 

including suspension or revocation of an individual gaming license when 

appropriate. 

(c) The Tribe recognizes the importance of an independent Tribal Gaming 

Commission in maintaining a well-regulated gaming operation. The 

Commission shall be and act independently and autonomously from the 

Tribal Council in all matters withn its purview. No prior or subsequent 

review by the Tribal Council of any actions of the Commission shall be 

required or permitted except as otherwise explicitly provided in this 

Ordinance. To avoid potential conflicts of interest between the operation and 

regulation of the gaming facility, the Tribe hereby finds that, at a minimum: 

(1) No member of the Tribal Council may serve on the Gaming 

Commission; 

(2) No member directly related to or living with any Tribal Council member 

may serve on the Gaming Commission; 

(3) Members of the Gaming Commission are prohibited from gambling in 

the facility; and 

Enacted by Tribal Council action on 

July 28,2006 

Page 10 of 33 
KICKAPOO TRADITIONAL TRIBE OF TEXAS 

GAMING ORDINANCE 

(4) Members of the Gaming Commission are prohibited from accepting 

complimentary items from the gaming operation, excepting food and 

beverages valued at fewer than five dollars. 

(d) Tribal Gaming Commissioner positions shall be filled in the following 

manner: 

Through appointment by the Tribal Council. 

(e) Nominees for positions of Tribal Gaming Commissioner must satisfy the 

suitability standards set forth for key employees and primary management 

officials, found in Section 103 (t) of this Ordinance. Such background 

investigations shall be performed under the direction of the National Indian 

Gaming Commission. 

(f) The Tribal Gaming Commission shall: 

1) Conduct or cause background investigations to be conducted on, at a 

minimum, primary management officials and key employees; 

2) Review and approve all investigative work conducted; 

3) Report results of background investigations to the NIGC; 

4) Obtain and process fingerprints, or designate a law enforcement agency to 

obtain and process fingerprints; 

5) Make licensing suitability determinations, which shall be signed by the 

Chairman of the Gaming Commission; 

6) Issue gaming licenses to management officials and employees of the 

operation, consistent with the suitability determination; 

7) Establish standards for licensing Tribal gaming operations; 

81) Issue facility gaming licenses to Tribal gaming operations; 

Enacted by Tribal Council action on 

July 28,2006 

Page 11 of 33 
KICKAPOO TRADITIONAL TRIBE OF TEXAS 

GAMING ORDINANCE 

9) Inspect, examine and monitor all gaming activities, and have immediate 

access to review, inspect, examine, photocopy and audit all records of the 

gaming establishment; 

10) Ensure compliance with all Tribal, State, and Federal laws, rules, and 

regulations regarding Indian gaming; 

11) Investigate any suspicion of wrongdoing associated with any gaming 

activities; 

12) Hold hearings on patron complaints, in compliance with procedures 

established in the gaming ordinance and other Tribal gaming regulations; 

13) Comply with any and all reporting requirements under the IGRA, TribalState compact to whlch the Tribe is a party, and any other applicable law; 

14) Promulgate and issue regulations necessary to comply with applicable 

internal control standards; 

15) Promulgate and issue regulations on the levying of fees and/or taxes 

associated with gaming license applications; 

16) Promulgate and issue regulations on the levying of fines and/or 

suspension or revocation of gaming licenses for violations of the gaming 

ordinance, or any other Tribal, Federal, or State, if applicable, gaming 

regulations; 

17) Establish a list of persons not allowed to game in Tribal gaming facilities 

in order to maintain the integrity of the gaming; 

18) Establish a list of persons who have voluntarily asked to be excluded 

from Tribal gaming facility and create regulations for enforcing this 

exclusion; 

19) Provide referrals and information to the appropriate law enforcement 

officials when such information indicates a violation of Tribal, Federal, or 

State statutes, ordinances, or resolutions; 

Enacted by Tribal Council action on 

July 28,2006 

Page 12 of 33 
KICKAPOO TRADITIONAL TRIBE OF TEXAS 

GAMING ORDINANCE 

20) Create a list of regulatory authorities that conduct vendor background 

investigations and licensing which the Commission recognizes as 

trustworthy; 

21) Draft regulations exempting vendors from the licensing and/or 

background investigation requirements if they have received a license 

from a recognized regulatory authority; 

22) Perform such other duties the Commission deems appropriate for the 

proper regulation of the Tribal gaming operation; and 

23) Promulgate such regulations and guidelines as it deems appropriate to 

implement the provisions of this Ordinance. 

(g) The Gaming Commission shall ensure that all records and information 

obtained as a result of an employee background investigation shall remain 

confidential and shall not be disclosed to persons who are not directly 

involved in the licensing and employment processes. Information obtained 

during the course of an employee background investigation shall be disclosed 

to members of management, human resource personnel or others employed 

by the tribal gaming operation on a need-to-know basis for actions taken in 

their official capacities. This Section 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 

Commission and staff in the performance of their official duties. 

(h) Terms of Office for Tribal Gaming Commissioners shall be as follows: the 

Chair shall serve an initial term of one year, with subsequent Chairs serving 

three-year terms. The Vice-Chair and Cornmissioner(s) shall serve an initial 

term of two years, with subsequent Vice-Chairs and Commissioners serving 

three- year terms. 

(i) The following persons are not eligible to serve as Tribal Gaming 

Commissioners: 

Tribal Council members, while serving as such; employees of the gaming 

operation, while serving as such; gaming contractors (including any 

principal of a management or other contracting company); persons directly 

related to or sharing a residence with any of the above; persons ineligible to 

Enacted by Tribal Council action on 

July 28,2006 

Page 13 of 33 
KICKAPOO TRADITIONAL TRIBE OF TEXAS 

GAMING ORDINANCE 

be key employees or primary management officials; Non-tribal members 

previously convicted of a felony, of embezzlement, of theft, or of any other 

money-related crime or honesty-related crime (such as fraud) cannot serve 

as Tribal Gaming Commissioners. 

Tribal members previously convicted of a felony, of embezzlement, of 

theft, or of any other money-related crime or honesty-related crime (such as 

fraud) will only be allowed to serve as Tribal Gaming Commissioners if the 

Tribal Council specifically finds a significant amount of time has passed 

and that the person is now of trustworthy character. The Tribal Council 

shall require a criminal history check with appropriate law enforcement 

agencies and shall review this criminal history report and make an 

appropriate suitability determination before appointing an individual to a 

position as a Tribal Gaming Commissioner. 

(i) The independence of the Tribal Gaming Commission is essential to a wellregulated gaming operation. For that reason, Commissioners may only be 

removed from office by the Tribal Council prior to the expiration of their 

respective terms for neglect of duty, misconduct, malfeasance, or other acts 

that would render a commissioner unqualified for hisher position. Any 

allegations of neglect of duty, misconduct, malfeasance, or other acts that 

would render him or her unqualified for hisher position must be 

substantiated by a preponderance of the evidence. Commissioners will be 

given an opportunity to provide evidence rebutting the grounds for their 

proposed removal before the removal is considered. A vote of the Tribal 

Council on the validity of the removal shall be final and not subject to further 

appeal. A wrongful removal shall entitle the affected Commissioner to 

compensation for expenses incurred in an appeal and any pay withheld only. 

(k) A majority of the Commission shall constitute a quorum. The concurrence of 

a majority of the members appointed to the Commission shall be required for 

any final determination by the Commission. The Commission may act in its 

official capacity even if there are vacancies on the Commission. 

(I) Tribal Gaming Cornmissioners shall be compensated at a level determined by 

the Tribal Council. Commissioner compensation shall not be based on a 

percentage of gaming revenue to ensure the Commission is not improperly 

influenced. 

Enacted by Tribal Council action on 

July 28,2006 

Page 14 of 33 
KICKAPOO TRADITIONAL TRIBE OF TEXAS 

GAMING ORDINANCE 

(m) The Commission shall keep a written record of all its meetings. 

5 109 Ethics 

(a) The Tribe recognizes that the duties of the Tribal Gaming Commission 

include malung important decisions on highly sensitive issues. As such, the 

Tribe has determined that the Gaming Commission shall be held to extremely 

high ehcal standards. Prior to talung their positions on the Commission 

(Members), the Members shall agree to be bound by the following principles: 

1) Members shall not hold financial interests that conflict with the 

conscientious performance of their duties as managers and regulators. 

2) Members shall not engage in financial transactions using nonpublic 

information or allow the improper use of such information by others on 

their behalf to further any private interest. 

3) Members shall not solicit or accept any gift or other item of monetary 

value, including complimentary items or services (see Section 110, 

below), from any person or entity seelung official action or inaction 

from, doing business with, or conducting activities regulated by the 

member's organization, or whose interests may be substantially affected 

by the performance or nonperformance of the Members' duties. 

4) Members shall make no unauthorized commitments or promises of any 

kind purporting to bind the Tribe. 

5) Members shall not use their positions for private gain. 

6) Members shall act impartially, in accordance with all relevant Tribal, 

Federal, and State laws (where applicable), and shall not give 

preferential treatment to any private organization or individual, 

including to any persons related to Members. 

7) Members shall ensure that Tribal property and gaming assets shall be 

properly segregated and safeguarded, and that such property and assets 

shall not be used for unauthorized activities. 

Enacted by Tribal Council action on 

July 28,2006 

Page 15 of 33 
KICKAPOO TRADITIONAL TRIBE OF TEXAS 

GAMING ORDINANCE 

8) Members shall not engage in outside employment or activities, 

including seeking or negotiating for future employment, which conflict 

with their official duties and responsibilities. 

9) Members shall disclose waste, fraud, abuse, and corruption to 

appropriate authorities. 

10) Members shall endeavor to avoid any actions creating the appearance 

that they are violating the law or the ethical standards listed herein. 

11) Members shall disclose any real or apparent financial or personal 

conflicts. If there is a real conflict or the appearance of one, the member 

shall not take part in any decision related to the conflict. 

5 110 Complimentary Items 

(a) The use of complimentary items shall be governed by regulations established 

by the Tribal Gaming Commission. 

(b) No Key Employee, Primary Management Official, Tribal Council member, 

or Tribal Gaming Commission member, or any person directly related to or 

sharing a residence with the persons, shall be authorized to receive 

complimentary items other than food and beverages valued at under five 

dollars, or, if at a public event held at the gaming facility, the free food and 

beverages offered to the general public. 

(c) Complimentary Items shall be included in the annual budget for the gaming 

operation, with maximum limits specified, and shall be subject to approval by 

the Tribal Council. 

5 111 Audit 

(a) The Tribe shall cause an annual outside independent audit of gaming 

operations to be conducted, and shall submit the resulting audit reports to the 

National Indian Gaming Commission. 

Enacted by Tribal Council action on 

July 28,2006 

Page 16 of 33 
KICKAPOO TRADITIONAL TRIBE OF TEXAS 

GAMING ORDINANCE 

(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. 

8 112 Environment and Public Health and Safety 

(a) Gaming facilities shall be constructed, maintained and operated in a manner 

that adequately protects the environment and the public health and safety. 

(b) KTTT Tribal Council shall adopt standards that assure adequate protection of 

the environment and the public health and safety. 

5 113 Patron Dispute Resolution 

Patrons who have complaints against the gaming establishment shall have as their 

sole remedy the right to file a petition for relief with the Tribal Gaming 

Commission. Complaints shall be submitted in writing, and at the discretion of the 

Commission, the petitioner may be allowed to present evidence. The Gaming 

Commission shall hold a hearing within 30 days of receipt of petitioner's 

complaint. Petitioner may have counsel present at such hearing. The Commission 

shall render a decision in a timely fashion and all such decisions will be final when 

issued. Any patron complaint must be submitted to the Commission wihn thirty 

(30) days of the incident giving rise to the complaint. All claims by patrons shall 

be limited to a maximum recovery of actual proven damages, except disputes 

relating to a patron's entitlement to a game prize, which shall be limited to the 

amount of such prize. The Commission's decision shall constitute the 

complainant's final remedy. 

5 114 Tribal Internal Control Standards 

The Tribe shall adopt and implement Internal Control Standards (ICS) for the 

operation of its Tribal gaming operation in accordance with applicable law. The 

Tribe's ICS shall be set out in separate regulations to be reviewed and approved by 

the Tribal Council. 

Enacted by Tribal Council action on 

Page 17 of 33 

July 28,2006 
KICKAPOO TRADITIONAL TRIBE OF TEXAS 

GAMING ORDINANCE 

5 1 15 Facility Licenses 

(a) The Tribal Gaming Co~nmission shall issue a separate license to each place, 

facility, or location on Indian lands where class I1 [andlor Class 1111 gaming 

is conducted under this ordinance. 

(b) The Tribal Gaming Commission shall issue a separate license to each place, 

facility, or location on Indian lands where Class I1 [andlor Class 1111 gaming 

is conducted under this ordinance once every two years. The Tribal Gaming 

Commission shall specify the form, conditions and content for the application 

for such licenses, which shall be submitted by the general manager 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 

constitute "Indian lands" as specified in the Indian Gaming Regulatory Act, 

and shall identify the environmental, health, and public safety standards with 

which the facility 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 Tribal Gaming 

Commission shall only issue such licenses if the applications therefore 

include the required information and certifications and such Wer 

conditions as the Tribal Gaming Commission shall have specified. 

5 116 Agent for Service of Process 

The Tribe hereby designates the Tribal Council Chairman agent for service of 

process, who may be contacted at: 794 Lucky Eagle Dr. Eagle Pass, Texas 78852 

Attn. Legal Department. 

5 117 Compliance with Federal Law 

The Tribe will comply with all applicable federal law, including the Bank Secrecy 

Act, 3 1 U.S.C. 8 53 1 1 et seq. 

Enacted by Tribal Council action on 

July 28,2006 

Page 18 of 33 
KICKAPOO TRADITIONAL TRIBE OF TEXAS 

GAMING ORDINANCE 

5 118 Repeal 

All prior gaming ordinances are hereby repealed, voided and superceded by this 

Gaming Ordinance. 

5 11 9 Tribal Access to Financial Information 

A copy of the Tribal gaming operation annual audit will be made available for 

review, upon request, to: 

K.T.T.T. Tribal Council 

andlor 

Tribal Members 

5 201 Licenses for Key Employees and Primary Management Officials 

The Tribe 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 gaming enterprise operated on Indian lands. The Tribe will issue 

licenses and perform background investigations according to requirements at least 

as stringent as 25 C.F.R. Parts 556 and 558. 

5 202 License Application Forms 

(a) The following notice shall be placed on the application form for a 

key employee or a primary management official: 

In compliance with the Privacy Act of 1974, the following 

information is provided: 

Solicitation of the information on this form is authorized 

by 25 US. C. 2701 et seq. The purpose of the requested 

information is to determine the eligibility of individuals to be 

employed in a gaming operation. The information will be used 

by the Tribe and the National Indian Gaming Commission 

members and stag who have need for the information in the 

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performance of their oficial duties. The information may be 

disclosed to appropriate Federal, Tribal, State, local, or foreign 

law enforcement and regulatory agencies when relevant to civil, 

criminal or regulatory investigations or prosecutions or when 

necessary pursuant to a requirement by a Tribe or the National 

Indian Gaming Commission in connection with the hiring or 

Jiring of an employee, the issuance or revocation of a gaming 

license, or investigation 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 being 

unable to hire you in a primary management oficial or key 

employee position. The disclosure of your Social Security 

Number (SSN) is voluntay. However, failure to supply a SSN 

may result in errors in processing your application. 

(b) The following additional notice shall be placed on the application form for a 

key employee or a primary official: 

A false statement on any part ofyouv 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. Ordinance, 

Title 18, section 1001) 

(c) The Commission shall notify in writing existing key employees and primary 

management officials who have not completed an application containing the 

notices set forth above that they shall either: 

(I) Complete a new application form that contains both the Privacy Act 

and false statement notices; or 

(2) Sign a statement that contains the Privacy Act and false statement 

notices and consent to the routine uses described in that notice. 

§ 203 License Fees 

The Tribe may charge a license fee, to be set by the Tribal Gaming Commission, 

to cover its expenses in investigating and licensing Key Employees and Primary 

Management Officials of the gaming operation. 

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5 204 Fingerprints 

Each applicant for a Key Employee or Primary Management Official shall be 

required to have fingerprints taken as part of the license application procedure. 

Fingerprints shall be taken by K.T.T.T. Tribal Gaming Commission Licensing 

Staff. Fingerprints will then be forwarded to the NIGC for processing through the 

FBI and NCIC to determine the applicant's criminal history, if any. 

tj 205 Background Investigations 

a) The Tribal Gaming Commission is responsible for conducting background 

investigations and suitability determinations. 

b) The Tribal Gaming Commission shall request from each primary 

management official and from each key employee all of the following 

information: 

(1) Full name, other names used (oral or written), social security number(s), 

blrth date, place of birth, citizenshp, gender, all languages (spoken or 

written); 

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

positions held, ownership interests in those businesses, business and 

residence addresses, and driver license numbers; 

(3) 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 (b)(2) of this 

section; 

(4) Current business and residence telephone numbers; 

(5) A description of any existing and previous business relationshps with 

Indian Tribes, including ownership interests in those businesses; 

(6) A description of any existing and previous business relationshps with 

the gaming industry generally, including ownership interests in those 

businesses; 

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(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 was an ongoing prosecution or a 

conviction, the charge, the name and address of the court involved, and 

the date and disposition if any; 

(9) For each misdemeanor conviction or ongoing misdemeanor prosecution 

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

application, the name and address of the court involved and the date and 

disposition; 

(10) For each criminal 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 b),(8) or b), (9) of this section, the criminal charge, the name 

and address of the court involved and the date and disposition; 

(1 1) 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; 

(1 2) A photograph taken within the last year; and 

(1 3) Any other information the Tribe deems relevant. [25 C.F.R. 5 556.41 

5 206 Procedures for Conducting a Background Check on Applicants 

(a) As part of its review procedure, the Commission or its agent shall employ or 

engage a private investigator to conduct a background investigation on each 

applicant sufficient to allow the Gaming Commission to make an eligibility 

determination under section 207 bellow. The investigator shall: 

1) Verify the applicant's identity through items such as a social security 

card, driver's license, birth certificate, or passport; 

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2) Contact each personal and business reference provided in the License 

Application, when possible; 

3) Obtain a personal credit check; 

4) Conduct a civil history check; 

5) Conduct a criminal hstory check via the submission of the applicant's 

fingerprints to the NIGC, and further obtain information from the 

appropriate court regarding past felony andlor misdemeanor 

convictions and criminal charges within the last ten years; 

6) Inquire into any previous or existing business relationshps with the 

gaming industry and Indian tribes by contacting the entities or tribes; 

7) Verify the applicant's history and status with any licensing agency by 

contacting the agency; and 

8) Take other appropriate steps to verify the accuracy of the information, 

focusing on problem areas noted. 

(b) The investigator shall create an investigative report noting the steps taken, 

information gained, potential problem areas, and disqualifying information. 

(c) The Gaming Commission and its investigator shall promise to keep 

confidential the identity of each person interviewed in the course of the 

investigation, other than disclosure as required under Federal, Tribal, or State 

law. 

5 207 Eligibility Determination 

The Tribal 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 a key employee or primary management official for 

employment in a gaming operation. If the Tribal Gaming Commission 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, a 

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management contractor and/or a tribal gaming operation shall not employ that 

person in a key employee or primary management official position. 

5 208 Procedures for Forwarding Applications and Reports for Key 

Employees and Primary Management Officials to the National Indian 

Gaming Commission 

(a) When a key employee or primary management official is employed to work 

at a gaming operation authorized by thls ordinance, the Commission 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 Section 207 of this Ordinance. 

(b) The gaming operation shall not employ as a key employee or primary 

management official a person who does not have a license after 90 days. 

fj 209 Report to the National Indian Gaming Commission 

(a) The Tribal Gaming Commission shall prepare and forward a report on each 

background investigation to the National Indian Gaming Commission. An 

investigative report shall include all of the following: 

1) Steps taken in conducting a background investigation; 

2) Results obtained; 

3) Conclusions reached; and 

4) The bases for those conclusions. 

(b) The Commission shall forward the completed investigative report 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. 

(c) The Commission shall submit, with the investigative report, a copy of 

the eligibility determination, unless the NIGC shall have advised the Tribe 

that the submission of the eligibility determination is not necessary. This 

determination shall include a Statement describing how the information 

submitted by the applicant was verified; a Statement of results following an 

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inquiry into the applicant's prior activities, criminal record, if any, and 

reputation, habits and associations; a Statement showing the results of 

interviews of a sufficient number of knowledgeable people (such as former 

employers, personal references, and others referred to by the applicant) in 

order to provide a basis for the Tribal Gaming Commission to make a finding 

concerning the eligibility for licensing required for employment in a gaming 

operation; and a Statement documenting the disposition of all potential 

problem areas noted and disqualifying information obtained. 

(d) If a license is not issued to an applicant, the Tribal Gaming Commission: 

(1) Shall notify the NIGC; and 

(2) Shall forward copies of its eligibility determination and investigative 

report (if any) to the NIGC for inclusion in the Indian Gaming 

Individuals Records System. 

(e) With respect to all employees, and in particular key employees and 

primary management officials, the Tribal Gaming Commission shall retain 

applications for employment and reports (if any) of background 

investigations for inspection by the Chairman of the NIGC or his or her 

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

employment. 

5 210 Granting a Gaming License 

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

Commission receives a report, the National Indian Gaming Commission 

notifies the Tribe 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 Tribe has provided an application and investigative 

report to the National Indian Gaming Commission, the Tribal Gaming 

Commission, acting for the Tribe, may issue a license to such applicant. 

(b) The Tribal Gaming Commission 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 

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paragraph (a) of this section until the Chairman of the National Indian 

Gaming Commission receives the additional information. 

(c) If, within the thirty (30) day period described above, the National Indian 

Gaming Commission provides the Tribe with a Statement itemizing 

objections to the issuance of a license to a key employee or to a primary 

management official for whom the Tribal Gaming Commission has provided 

an application and investigative report to the National Indian Gaming 

Commission, the Tribe shall reconsider the application, talung into account 

the objections itemized by the National Indian Gaming Commission. The 

Tribe shall make the final decision whether to issue a license to such 

applicant. 

(d) Conditional Licenses are licenses that are issues to applicants who meet the 

criteria set forth by the Commission who otherwise do not qualify for a 

license. Conditional licenses may be issued by the Commission to applicants 

only after a through investigation, and conditions set by the Commission 

must be met by applicant. 

5 211 License Suspension 

(a) If, after the issuance of a gaming license, the Tribal Gaming Commission 

receives from the National Indian Gaming Commission reliable information 

indicating that a key employee or a primary management official is not 

eligible for employment, the Tribal Gaming Commission shall suspend such 

license and shall notify in writing the licensee of the suspension and the 

proposed revocation. 

(b) The Tribal Gaming Commission shall notify the licensee of a time and a 

place for a hearing on the proposed revocation of a license. 

(c) After a revocation hearing, the Tribal Gaming Commission shall decide to 

revoke or to reinstate a gaming license. The Commission shall notify the 

NIGC of its decision. 

Enacted by Tribal Council action on 

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§ 212 Board of Review for Disputes 

The Tribe has determined that, in order to adhere to this Ordinance and all gaming 

regulations, there shall be established a Tribal Gaming Board of Review (Board of 

Review). The Board of Review shall serve as the final review body for employee 

disputes. Employee disputes shall include disputes with management, 

terminations, fines or other internal employee disputes, not to include actions 

taken by the Commission. 

The Board of Review shall consist of five members. The membership shall be 

comprised of one member of the Tribal Gaming Commission, one member from 

the Tribal Council, one primary management official or key employee, one 

enrolled Tribal member not employed by the gaming operation, and one employee 

of the gaming operation. The members from the Tribal Gaming Commission, 

Tribal Council, and gaming operation primary management official or employees 

shall be elected from their representative groups and the enrolled Tribal member 

shall be appointed by the K.T.T.T. Tribal Council. Board of Review members 

shall serve staggered terms. The two Tribal members shall serve three-year 

terms. The primary management official or key employee shall serve a two-year 

term. The members from the Tribal Gaming Commission and the Tribal Council 

shall serve one-year terms. The Board of Review members who are not employed 

by the Tribe in some other capacity shall be compensated at a rate decided by 

Council Resolution as needed. Compensation shall never be tied to tribal gaming 

revenues. 

The Board of Review members shall elect a Chairperson from among them, 

whose duty it shall be to preside over all meetings and hearings. In addition, the 

members shall elect a Vice-Chair who shall be the custodian of any evidence 

submitted, and who shall preside in the Chairperson's absence. The Board of 

Review shall meet at on an as needed basis, shall keep official records of the 

meetings. No later than three working days following a hearing on employee 

disputes, the Board of Review shall issue its findings. Findings of the Board shall 

be final when issued, and its decision shall be the final administrative decision. 

No Board of Review member shall be removed prior to the end of hislher term 

without cause. Removal shall be effectuated by a majority vote of the entire 

Board of Review, and shall be a final decision. A Board of Review member shall 

not review any decisions affecting hirnlher, or any person directly related to him or 

her. 

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5 301 Licenses for Vendors 

(a) Vendors of gaming services or supplies with a value of $25,000 or more 

annually must have a vendor license from the Tribal Gaming Commission in 

order to transact business with the Tribal gaming operation. Contracts for 

professional legal and accounting services are excluded from this section. 

(b) Gaming vendors are vendors who provide gaming supplies and services, 

including cash-related services. 

(c) Non-gaming vendors provide services that do not have the ability to impact 

the integrity of the Tribal gaming operations, such as media advertising, 

facility maintenance workers, linen and laundry services, and food and 

beverage suppliers. The Tribal Gaming Commission shall create a regulation 

detailing which vendors fall into this category and shall maintain a register of 

the non-gaming vendors that it licenses. The regulation may exempt from 

licensing requirements non-gaming vendors who: 1) are a Tribal, Local, 

State, or Federal government agencies; 2) are regulated by the State of Texas 

or the Tribe; or 3) will provide goods of insubstantial or insignificant 

amounts or quantities if the Tribal Gaming Commission determines that 

licensing of the vendor is not necessary to protect the public interest. 

5 302 Submission of a Vendor License Application 

In order to obtain a gaming vendor license, the business must complete a vendor 

application and submit to background checks of itself and its principals. Principals 

of a business include its officers, directors, management, owners, partners, noninstitutional stockholders that either own 10% or more of the stock or are the 10 

largest stockholders, and the on-site supervisor or manager under the agreement 

with the Tribe, if applicable. 

5 303 Contents of the Vendor License Application 

(a) Applications for gaming vendor licenses must include the following: 

1) Name of business, business address, business phone, federal tax ID 

number (or SSN if a sole proprietorshp), main office address if different 

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from business address, any other names the applicant has done business 

under, type of service applicant will provide; 

2) Whether the applicant is a partnership, corporation, limited liability 

company, sole proprietorship, or other entity; 

3) If the applicant is a corporation, the state of incorporation and the 

qualification to do business in the State of Texas if the gaming operation 

is in a different State than the State of incorporation. 

4) Trade name, other names ever used, names of any wholly owned 

subsidiaries or other businesses owned by the vendor or its principals; 

5) General description of the business and its activities; 

6) Whether the applicant will be investing in or loaning money to the 

gaming operation and, if so, how much; 

7) A description of any existing and previous business relationships with the 

gaming industry generally, including ownershp interests in those 

businesses; 

8) A list of Indian tribes with whch the vendor has an existing or previous 

business relationship, including ownershp, financial, or management 

interests in non-gaming activities; 

9) Names, addresses, and phone numbers of three business references with 

whom the company had regularly done business for the last five years; 

10) The name and address of any licensing or regulatory agency with which 

the business has filed an application for a license or permit related to 

gaming, whether or not such license or permit was granted; 

11) If the business has ever had a license revoked for any reason, the 

circumstances involved; 

12) A list of lawsuits to which the business has been a party, including the 

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

any; 

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13) List the business' funding sources and any liabilities of $50,000 or more. 

14) A list of the principals of the business, their social security numbers, 

addresses and telephone numbers, title, and percentage of ownership in 

the company; and 

15) Any further information the Tribe deems relevant. 

(b) The following notice shall be placed on the application form for a vendor and 

its principals: 

Inclusion of false or misleading information in the vendor application may be 

grounds for denial or revocation of the Tribe's vendor license. 

(c) A vendor may submit a copy of a recent license application to another 

jurisdiction if it contains the information listed above. The vendor will be 

required to submit in writing any changes in the information since the other 

license application was filed and any information requested by the Tribe not 

contained in the other application. 

5 304 Vendor Background Investigation 

The Tribal Gaming Commission shall employ or otherwise engage a private 

investigator to complete an investigation of the gaming vendor. This investigation 

shall contain, at a minimum, the following steps: 

(a) Verify of the business' incorporation status and qualification to do business in 

the State where the gaming operation is located; 

(b) Obtain a business credit report, if available, and conduct a Better Business 

Bureau check on the vendor; 

(c) Conduct a check of the business' credit history; 

(d) Call each of the references listed in the vendor application; and 

(e) Conduct an investigation of the principals of the business, including a 

criminal hstory check, a credit report, and interviews with the personal 

references listed. 

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5 305 Vendor License Fee 

The Tribe may charge a license fee, to be set by the Tribal Gaming Commission, 

to cover its expenses in investigating and licensing vendors of the gaming 

operation. 

5 306 Vendor Background Investigation Report 

The private investigator shall complete an investigative report covering each of the 

steps taken in the background investigation of the gaming vendor and its principals 

and present it to the Tribal Gaming Commission. 

fj 307 Exemption for Vendors Licensed by Recognized Regulatory 

Authorities 

The Tribal Gaming Commission may adopt regulations naming specific licensing 

authorities that it recognizes and may authorize exemptions to the vendor licensing 

process for vendors which hold a license from one of the named regulatory 

authorities. 

5 308 Licenses for Non-Gaming Vendors 

For non-gaming vendors, the Tribal Gaming Commission is authorized to create a 

less stringent vendor licensing process, including a due diligence check rather than 

a full background investigation as laid out in Section 304. The Gaming 

Commission may investigate such vendors when appropriate and may conduct 

audits in addition to monitoring Tribal purchases. 

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READ, PASSED and APPROVED on the day of 

,2006. 

Certification 

I, Jesus Anico, Secretary, certify that the foregoing KTTT Gaming Ordinance was 

publicly read. On motion to approve this Ordinance the Traditional Council voted 

as follows: 

In Favor Against Abstain Absent 

Juan Garza, Jr. 

Jesus hco 

Rogelio Elizondo 

Jose "Pepe" Trevino 

David Gonzalez 

Jesus Anico, Secretary Date 

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KICKAPOO TRADITIONAL TRIBE OF TEXAS 

GAMING ORDINANCE 

THEREFORE, IT IS ORDAINED that the foregoing KTTT Gaming 

Ordinance is hereby passed as law effective immediately and becomes part of our 

governmental records as passed and as it may be amended in the future. 

Juan Garza, Jr., Council Chairman 

Jesus Anico, Council Secretary 

Date 

Date 

Rogelio Elizondo, Council Treasurer Date 

Jose "Pepe" Trevino, Council Member Date 

David J. Gonzalez, Council Member 

Enacted by Tribal Council action on 

July 28,2006 

Date 

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