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July 22, 2021 

VIA E-MAIL

Dennis Ramirez, Chairman 

Mechoopda Indian Tribe of Chico Rancheria 

125 Mission Ranch Blvd 

Chico, CA 95926 

Re: Mechoopda Tribe of Chico Rancheria Gaming Ordinance

Dear Chairman Ramirez: 

This letter is to inform you that the Mechoopda Tribe of Chico Rancheria’s Gaming Ordinance, 

enacted by Resolution #21-19 on March 6, 2021, is approved by operation of law. 

Pursuant to the Indian Gaming Regulatory Act and NIGC regulations, the Chairman has ninety 

days from the date of submission to either approve or disapprove a gaming ordinance.1

Any ordinance not acted upon at the end of the ninety-day period is considered approved by the 

Chairman, but only to the extent that it is consistent with IGRA and NIGC regulations.2 The NIGC 

received the Gaming Ordinance on April 22, 2021. The 90-day deadline to approve or disapprove the 

ordinance is July 21, 2021. Because the Chairman took no action within the ninety-day period, the 

Nation’s gaming ordinance is approved to the extent it is consistent with IGRA and NIGC regulations. 

It is the Office of General Counsel’s opinion that although the Tribe’s Gaming Ordinance is 

substantially compliant with IGRA, the Tribe did not submit copies of all tribal gaming regulations. 

Please submit a copy of the Tribe’s gaming regulations upon enactment. 

Thank you for submitting the Gaming Ordinance. If you have any questions, please contact Staff 

Attorney Barbara Marvin at 202-302-0815. 

Sincerely,

Michael Hoenig

General Counsel

cc: Wyatt Rosette, Rosette, LLP. (via e-mail)

1

 25 U.S.C. § 2710(e); 25 C.F.R. § 522.9. 2 Id.
Page 1 of 14

MECHOOPDA INDIAN TRIBE OF CHICO RANCHERIA

GAMING CODE

A law to authorize and regulate the conduct of Class II and Class III gaming within the jurisdiction 

of the Mechoopda Indian Tribe of Chico Rancheria.

TABLE OF CONTENTS

Part 1 – General Provisions................................................................................2

Section 1 – Authorized Conduct.............................................................................2

Section 2 – Authority..........................................................................................2

Section 3 – Purpose............................................................................................2

Section 4 – Ownership of Gaming...........................................................................2

Section 5 – Policy...............................................................................................2

Section 6 – Repeal..............................................................................................3

Section 7 – Severability........................................................................................3

Section 8 – Definitions.........................................................................................3

Part 2 – Tribal Gaming Commission......................................................................4

Section 1 – Establishment....................................................................................4

Section 2 – Tribal Gaming Commission Powers...........................................................5

Section 3 – Tribal Gaming Commission Duties............................................................6

Section 4 – Executive Director Duties.....................................................................12

Part 3 – Gaming Facility...................................................................................12

Section 1 – Gaming Facility License.......................................................................12

Section 2 – Gaming Facility Duties........................................................................13

Section 3 – Patron Dispute Resolutions....................................................................13

Part 4 – Primary Management Official and Key Employee........................................13

Section 1 – Primary Management Official and Key Employee License..............................13

Section 2 – Primary Management Official and Key Employee Duties.................................14
Page 2 of 14

PART 1

GENERAL PROVISIONS

Section # 1 – Authorized Conduct:

Subject to this Mechoopda Indian Tribe of Chico Rancheria Gaming Code (“Code”), Class II and 

Class III gaming conduct is authorized. 

Section # 2 – Authority:

Enacted by the Tribal Council of the Mechoopda Indian Tribe of Chico Rancheria (“Tribal 

Council”) on March 16th, 2021 by Resolution No. 21-19. 

Section # 3 – Purpose: 

The Tribal Council, as the governing body of the Mechoopda Indian Tribe of Chico Rancheria 

(the “Tribe”), hereby enacts this Code to govern and regulate Class II and Class III gaming 

conduct on the Tribe’s Indian Lands. 

Section # 4 – Ownership of Gaming:

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

gaming operation authorized by this Code, except as expressly provided in this Code. 

Section # 5 – Policy:

The authorization and regulation of Class II and Class III gaming conduct is necessary to 

encourage economic development to improve the Tribe’s economic situation to provide basic 

governmental function for its members. The Tribe is committed to furthering self-determination 

and by doing so, net revenues from Class II and Class III gaming conduct may be utilized solely 

for:

(a) funding the Tribal government operations or programs;

(b) providing for the general welfare of the Tribe and its members;

(c) promoting Tribal economic development;

(d) donating to charitable organizations; or 

(e) providing financial assistance to help fund operations of local government agencies.
Page 3 of 14

Section # 6 – Repeal.

All prior laws enacted by the Tribal Council governing Class II and/or Class III gaming conduct 

are hereby repealed. 

Section # 7 – Severability.

If any provision or application of this Code is determined by review to be invalid, such 

determination may not be held to render such provision inapplicable to other persons or 

circumstances, nor shall such determination render invalid any other provision of this Code.

Section # 8 – Definitions.

“Compact” means the Tribal-State Compact between the State of California and the Mechoopda 

Indian Tribe of Chico Rancheria. 

“Gaming Facility” means any building licensed by the Mechoopda Indian Tribe of Chico 

Rancheria Gaming Commission to conduct Class II and/or Class III gaming. 

“IGRA” means the Indian Gaming Regulatory Act (25 U.S.C. §§ 2701 et seq.). 

“Indian Lands” means land: (1) within the limits of an Indian reservation; or (2) over which an 

Indian tribe exercises governmental power and that is either held: (a) in trust by the United States 

for the benefit of any Indian tribe or individual; or (b) by an Indian tribe or individual subject to 

restriction by the United States against alienation. 

“Key Employee” means: (1) any person who is employed by a Gaming Facility whose annual 

salary exceeds $50,000 per year; (2) any person who performs one or more of the following 

functions: (a) bingo caller; (b) counting room supervisor; (c) chief of security; custodian of gaming 

supplies or cash; (d) floor manager; (e) pit boss; (f) dealer; croupier; (g) approver of credit; (h) 

custodian of gambling devices including persons with access to cash and accounting records within 

such devices; and (3) any person designated by the Tribe. 

“Management Contract” means any agreement with a contractor providing for the management 

of all or part of the Gaming Facility. 

“Primary Management Official” means: (1) the person(s) having management responsibility for 

a Management Contract; (2) any person who has authority: (a) to hire and fire employees of a 

Gaming Facility; (b) to oversee the day-to-day operations of a Gaming Facility; or (c) over 

financial management; and (3) any other person designated by the Tribe. 
Page 4 of 14

PART 2

TRIBAL GAMING COMMISSION

Section # 1 – Establishment:

1.1 Governmental Subdivision. The Tribal Council hereby establishes the Mechoopda Indian 

Tribe of Chico Rancheria Gaming Commission (“Tribal Gaming Commission”) as a 

governmental subdivision of the Tribe, charged with implementation of this Code and 

regulation over Class II and Class III gaming conduct and enforcement of federal laws, the 

Compact, and Tribal laws. 

1.2 Place of Business. The Tribal Gaming Commission shall maintain its headquarters and 

principal place of business within Tribal offices. The Tribal Gaming Commission may 

establish other places of business if determined by the Tribal Gaming Commission to be in 

the best interest of the Tribe. 

1.3 Duration. The Tribal Gaming Commission shall have perpetual existence in its own name, 

unless dissolved by the Tribal Council. 

1.4 Arm of the Tribe. The Tribal Gaming Commission is a function of the Tribe’s government. 

Notwithstanding any authority delegated to the Tribal Gaming Commission under this 

Code, the Tribe reserves to itself the right to bring suit against any person or entity in its 

own right, on behalf of the Tribe or on behalf of the Tribal Gaming Commission, whenever 

the Tribe deems it necessary to protect the sovereignty, rights and interests of the Tribe or 

the Tribal Gaming Commission. 

1.5 Sovereign Immunity of the Tribal Gaming Commission. As a governmental subdivision 

of the Tribe, all inherent sovereign rights of the Tribe are hereby expressly extended and 

reserved to the Tribal Gaming Commission, including sovereign immunity from suit in any 

state, federal or tribal court. 

1.6 Tribal Gaming Commission Membership. The Tribal Gaming Commission is comprised 

of one (1) Chairman and up to two (2) Commissioners. The Chairman and Commissioners 

are collectively referred to as (“Tribal Gaming Commissioners”).

1.7 Quorum. All questions requiring action of the Tribal Gaming Commission must be 

determined by a majority vote of the Tribal Gaming Commissioners at a meeting where a 

quorum of at least two (2) Tribal Gaming Commissioners are present. 

1.8 Appointment. The Tribal Gaming Commissioners must be appointed by the Tribal Council 

and confirmed at any Tribal Council meeting.

1.9 Background Check. The Tribal Council must require each Tribal Gaming Commissioner 

to submit to a criminal background check. Based on the results of the background check,
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the Tribal Council shall make an appropriate eligibility determination and keep the Tribal 

Gaming Commissioner criminal background check results on file. 

1.10 Term. The Tribal Council may appoint any Tribal Gaming Commissioner to serve for up 

to three (3) years. 

1.11 Compensation. Tribal Gaming Commissioners will be compensated at a rate set by the 

Tribal Council. In order to ensure the Commission is not improperly influenced, a Tribal 

Gaming Commissioner’s compensation may not be based on a percentage of gaming 

revenue.

1.12 Eligibility. The following persons are not eligible to serve as Tribal Gaming 

Commissioners: Tribal Council members, while serving as such; current employees of the 

Gaming Facility; 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.

Section # 2 – Tribal Gaming Commission Powers:

2.1 Regulations. The Tribal Gaming Commission may promulgate regulations:

(a) to establish procedures designed to detect irregularities or fraud;

(b) to design a regulatory system to oversee Class II and Class III gaming;

(c) to establish procedures governing the conduct hearings and enforcement actions; or

(d) any other regulations to ensure compliance with this Code. 

2.2 Inspections. The Tribal Gaming Commission may:

(a) request assistance of federal or local law enforcement;

(b) during normal business hours, reasonably enter upon premises to examine accounts, 

books, papers and documents;

(c) inspect, examine, photocopy and audit all papers, books and records; or

(d) conduct any investigation to determine compliance with this Ordinance.

2.3 Contracting. The Tribal Gaming Commission may enter contracts on behalf of the Tribal 

Gaming Commission without Tribal Council approval. The Tribal Gaming Commission 

shall acquire Tribal Council approval for any contract that provides a waiver of sovereign 

immunity, unless all of the following are met: (i) any dispute against Tribal Gaming 

Commission shall be brought solely by other party and no other party or entity; (ii) any 
Page 6 of 14

such dispute shall be limited to causes of action to interpret or enforce the agreement; (iii) 

suit may be brought solely in federal court; (iv) any such award or damages resulting from 

dispute shall be enforceable against the assets Tribal Gaming Commission exclusively and 

no other assets of the Tribal Gaming Commission’s parents, affiliates, subsidiaries or the 

Tribe; and (v) the limited waiver is non-assignable. 

2.4 Investigations. The Tribal Gaming Commission may investigate any suspicion of 

wrongdoing or violations to determine compliance with federal law, tribal law or the 

Compact in connection with any gaming activities and require correction of violations as 

the Tribal Gaming Commission deems necessary. 

Section # 3 – Tribal Gaming Commission Duties:

3.1 Annual Budget. The Tribal Gaming Commission shall prepare an annual operating budget 

and present it to the Tribal Council no less than thirty (30) days prior to the commencement 

of each operating year.

3.2 Gaming Facility Licensing. The Tribal Gaming Commission shall:

(a) issue a separate Gaming Facility license to each place, facility or location on Indian 

lands where Class II and/or Class III gaming is conducted;

(b) establish Gaming Facility license applications, which at a minimum shall include:

i. a legal description of the lands upon which the facility is located;

ii. certification that the site constitutes Indian lands; and

iii. signed by a management official of the Gaming Facility for each gaming place, 

facility or location. 

(c) receive and submit notice to the National Indian Gaming Commission that issuance of 

a Gaming Facility License is under consideration by the Tribal Gaming Commission at 

least one hundred twenty (120) days before the opening of any new place, facility or 

location on Indian lands where Class II and Class III gaming will occur;

(d) submit a copy of each newly issued or renewed facility license to National Indian 

Gaming Commission within thirty (30) days of issuance, along with any other required 

documentation; and 

(e) notify the National Indian Gaming Commission within thirty (30) days if a Gaming 

Facility is terminated or expires, or if a gaming place, facility, or location closes or 

reopens. 
Page 7 of 14

3.3 Primary Management Officials and Key Employee Licensing. The Tribal Gaming 

Commission shall:

(a) establish applications for Primary Management Official and Key Employee licenses, 

which at a minimum shall include:

i. full name, other names used (oral or written), social security number, birth date, 

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

ii. currently, and for the previous five (5) years; business and employment 

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

addresses, and driver’s license numbers;

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

one (1) personal reference who was acquainted with the applicant during each 

period of residence listed under paragraph (a)(ii) of this Section;

iv. current business and residential telephone numbers, and all cell phone numbers;

v. a description of any existing and previous business relationships with other 

tribes, including any ownership interest in those businesses;

vi. a description of any existing and previous business relationships with the 

gaming generally, including ownership interests in those businesses;

vii. 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;

viii. 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 of disposition, 

if any;

ix. for each misdemeanor conviction or ongoing misdemeanor prosecution 

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

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

disposition, if any;

x. 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 paragraphs (a)viii-ix of this 

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

the date of disposition, if any;
Page 8 of 14

xi. the name and address of any licensing or regulatory authority with which the 

person has filed an application for an occupational license or permit, whether 

or not such license or permit was granted;

xii. a photograph;

xiii. a signed statement confirming receipt of disclosures required under Part 2 

Section 3.3(b);

xiv. any other information Tribe or Tribal Gaming Commission deems relevant; and

xv. request for fingerprints to be completed by the Tribal Gaming Commission, 

which is the law enforcement agency designated to take fingerprints. 

(b) provide Primary Management Officials and Key Employee applicants with the 

following disclosures prior to being filled out by an applicant:

i. Privacy Act Notice. 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 granted a gaming 

license. The information will be used by the Tribal gaming regulatory 

authorities and by the National Indian Gaming Commission members and staff 

who have need for the information in the performance of their official duties. 

The information may be disclosed by the Tribe or the NIGC to appropriate 

Federal, Tribal, State, local or foreign law enforcement and regulatory 

agencies when relevant to civil, criminal, or regulatory investigations or 

prosecutions or when pursuant to a requirement by a tribe or the NIGC in 

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

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

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

being unable to license you for 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.

ii. Notice Regarding False Statements. A false statement on any part of your 

license application may be grounds for denying a license or the suspension or 

revocation of a license. Also, you may be punished by fine or imprisonment 

(U.S. Code, title 18, section 1001).

(c) conduct background investigations for each Primary Management Official and Key 

Employee applicant to sufficiently allow the Tribal Gaming Commission to make an 

eligibility determination under Part 2 Section 3.3(e), which at a minimum shall include 

a check of:
Page 9 of 14

i. criminal history records information maintained by the Federal Bureau of 

Investigations;

ii. civil history; and

iii. personal credit check. 

(d) create and maintain an investigative report for each background investigation of a 

Primary Management Official or Key Employee which shall include:

i. steps taken in conducting the investigations;

ii. results obtained;

iii. conclusions reached; and

iv. the basis for those conclusions.

(e) make determination of suitability on whether to issue a license. Tribal Gaming 

Commission may not issue a license if the licensing of applicant poses a threat to the 

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

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

conduct of gaming. Tribal Gaming Commission shall consider the applicant’s;

i. prior activities;

ii. criminal record; and

iii. reputation, habits, and associations. 

(f) prior to issuing a license to a Primary Management Official or Key Employee, the 

Tribal Gaming Commission shall prepare a notice of results of the applicant’s 

background investigation and submit it to the National Indian Gaming Commission no 

later than sixty (60) days after the applicant begins working, which at a minimum shall 

include:

i. a copy of the eligibility determination made under Part 2 Section 3.3(e);

ii. the applicant’s name, date of birth and social security number;

iii. the date on which the applicant began, or will begin, working as a Primary 

Management Official or Key Employee; and

iv. a summary of the information presented in the investigative report, including:

1. licenses that have been previously denied;
Page 10 of 14

2. gaming licenses that have been revoked, even if substantially reinstated;

3. every known criminal charge brought against the applicant within the last 

ten (10) years of the date of the application; and

4. every felony offense of which the applicant has been convicted or any 

ongoing prosecution.

(g) require all Primary Management Officials and Key Employees to have a gaming 

license;

(h) upon submission of the notice of results of the applicant’s background investigation to

the National Indian Gaming Commission under Part 2 Section 3.3(c), the Tribal 

Gaming Commission may issue a license to a Primary Management Official or Key 

Employee; 

(i) notify the National Indian Gaming Commission of the issuance of a license to a Primary 

Management Official or Key Employee within thirty (30) days of issuance;

(j) reconsider license applications and take into account National Indian Gaming 

Commission objections mentioned in an objection statement to the issuance of a license 

received by the National Indian Gaming Commission; 

(k) notify the National Indian Gaming Commission if the Tribal Gaming Commission does 

not issue a license to an applicant for Primary Management Official or Key Employee 

and forward copies of the eligibility determination and notice of results of the 

applicant’s background investigation to the National Indian Gaming Commission; 

(l) if, after a license is issued to a Primary Management Official or Key Employee, the 

Tribe receives notice from the National Indian Gaming Commission that the Key 

Employee or Primary Management Official is not eligible for employment, the Tribal 

Gaming Commission shall:

i. immediately suspend the license;

iii. provide the licensee, the Gaming Facility and the Tribal Council with written 

notice of the suspension and proposed revocation; and

iii. provide the licensee with notice of a time and a place for a hearing on the 

proposed revocation of a license. All rights to notice and hearing shall be 

governed by Tribal Law.

(m)after a revocation hearing, the Tribe shall decide whether to revoke or to reinstate the 

license at issue. The Tribe shall notify the National Indian Gaming Commission of its 

decision to revoke or reinstate a license within 45-days of receiving notification from 
Page 11 of 14

the National Indian Gaming Commission that a Primary Management Official or Key 

Employee is not eligible for employment; and

(n) the Tribal Gaming Commission, and its investigators, shall keep confidential the 

identity of each person interviewed in the course of conducting a background 

investigation.

3.4 Meetings. The Tribal Gaming Commission shall:

(a) meet at least once per week to conduct formal business; and

(b) keep meeting minutes. 

3.5 Records Retention. The Tribal Gaming Commission shall retain:

(a) for at least three (3) years from the date a Primary Management Official or Key 

Employee is terminated from employment with a Gaming Facility:

i. information contained in the application for licensing received under Part 2 

Section 3.3(a); 

ii. investigative reports created pursuant to Part 2 Section 3.3(d); and

iii. eligibility determinations made pursuant to Part 2 Section 3.3(e).

(b) for at least two (2) years from the date the audit is sent to the NIGC pursuant to Part 

 2 Section 3.10. 

3.6 Minimum Internal Control Standards. The Tribal Gaming Commission shall comply with 

25 CFR Part 542 (as in effect on October 19, 2006, or as it may be amended) by formally 

adopting and making applicable to the Tribe’s gaming activities, internal control standards 

that: 

(a) provide a level of controls that equals or exceeds those set forth in 25 CFR Part 542, as 

published or as revised by mutual agreement between the Nation Indian Gaming 

Commission and the Tribe;

(b) contain standards for currency transaction reporting in compliance with 31 CFR Part 

103. 

3.7 Executive Director. The Tribal Gaming Commission shall hire an Executive Director to 

serve as an at-will employee of the Tribal Gaming Commission to oversee day-to-day 

operations of the Tribal Gaming Commission. 

3.8 Executive Director Background Check. The Tribal Gaming Commission must require the 

Executive Director to submit to a criminal background check. Based on the results of the 
Page 12 of 14

background check, the Tribal Gaming Commission shall make an appropriate eligibility 

determination and keep the Executive Director criminal background check results on file. 

3.9 Appeals. The Tribal Gaming Commission shall oversee any proceeding where an action 

taken by the Tribal Gaming Commission or the Executive Director are being challenged. 

3.10 Annual Independent Audit. The Tribal Gaming Commission shall submit the annual 

independent audit to the National Indian Gaming Commission performed by the Gaming 

Facility under Part 3 Section 2.2 within sixty (60) days of receiving the annual independent 

audit from the Gaming Facility. A copy of the annual independent audit will be made 

available for review, upon request, to the Tribal Council.

Section # 4 – Executive Director Duties:

4.1 Operations. The Executive Director shall, subject to the supervision of the Tribal Gaming 

Commission, perform all duties, exercise all powers, and assume and discharge all 

responsibilities imposed by this Code or delegated by the Tribal Gaming Commission, 

which shall include:

(a)serving as the supervisor of Tribal Gaming Commission employees; and

(b)providing the Tribal Gaming Commissioners with assistance to properly implement this 

Code.

4.2 Agent for Service of Process. The Executive Director shall serve as the agent for service 

of any official determination, order, or notice of violation and may accept service at:

ATTN: Executive Director

Mechoopda Indian Tribal Gaming Commission

125 Mission Ranch Blvd

Chico, CA 95926

PART 3

GAMING FACILITY

Section # 1 – Gaming Facility License:

1.1 License Required. No person or entity may conduct Class II and/or Class III gaming 

without having first applied for and obtained a Gaming Facility license. Each place, 

facility, or location on Indian lands where Class II and/or Class III gaming is conducted is 

required to obtain a license from the Tribal Gaming Commission. 

1.2 Term. The Gaming Facility license is valid for a term of two (2) years. 
Page 13 of 14

Section # 2 – Gaming Facility Duties:

2.1 Environment and Public Health and Safety. Gaming Facilities shall construct, maintain, 

and operate in a manner that adequately protects the environment, and the healthy and 

safety of the public. 

2.2 Audit. Gaming Facilities shall cause independent audits to be conducted:

(a) annually;

(b) inclusive of all gaming-related contracts that result in the purchase of supplies, services,

or non-gaming concessions for more than $25,000 in any year (except contracts for 

professional legal and accounting services); and 

(c) in conformance with generally accepted accounting standards. 

2.3 Inspections. Gaming Facilities shall provide the Tribal Gaming Commission with 

unrestricted access to any area of the gaming operation for inspections conducted pursuant 

to Part 2 Sections 2.2 and 2.4. 

2.4 Reporting. The Gaming Facility shall submit the results of the independent audit 

conducted pursuant to Part 3 Section 2.2 to the Tribal Gaming Commission within one (1) 

week from receiving the findings from the independent auditor. 

Section # 3 – Patron Dispute Resolutions:

Patrons with gaming complaints against a Gaming Facility as their sole remedy may file a claim 

in accordance with the Tribe’s gaming dispute resolution procedures established and maintained 

by the Tribe, and as applicable, in accordance with the Compact. Patron gaming dispute resolution 

may include informal resolution between the claimant and the Gaming Facility, formal review by 

the Tribal Gaming Commission if requested by the claimant, and thereafter, appeal of the Tribal

Gaming Commission decision by the claimant to the Tribal Council. All claims must meet the 

requirements of the Tribe’s gaming dispute resolution procedures. The Tribe’s gaming dispute 

resolution procedures are the sole remedy for any gaming dispute and gaming dispute claims are 

not subject to any review or appeal outside of the Tribe’s gaming dispute resolution procedures.

PART 4

PRIMARY MANAGEMENT OFFICIAL AND KEY EMPLOYEE

Section # 1 – Primary Management Official and Key Employee License:

1.1 License Required. No person may be employed at a Gaming Facility as a Primary 

Management Official or Key Employee without receiving a valid license issued by the 

Tribal Gaming Commission within the first ninety (90) days of employment. 
Page 14 of 14

1.2 Term. A Primary Management Official or Key Employee license is valid for seven (7) 

years. 

Section # 2 – Primary Management Official and Key Employee Duties:

2.1 Compliance with Laws. Primary Management Official’s and Key Employees shall ensure

all employees of the Gaming Facility, and gaming patrons comply with the federal laws, 

Tribal laws and the Compact. Violations of these requirements may be grounds for 

termination of employment and expulsion from the Gaming Facility.

2.2 Material Changes. Primary Management Official’s and Key Employees shall update the 

Tribal Gaming Commission of any material change that would be reflected on a license 

application.