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ST. CROIX CHIPPEWA INDIANS OF WISCONSIN

TITLE 6

CHAPTER 2

GAMING ORDINANCE

Resolution No. 07-19-2021-02

Legislative History:

Established on March 23, 1995 via Resolution No. 01-09-95-01

Amended on October 27, 2006 via Resolution No. 10-25-06-01
STCCIW Title 6, Chapter 2

St. Croix Gaming Ordinance

1

ST. CROIX GAMING ORDINANCE

TABLE OF CONTENTS

ARTICLE I – GENERAL PROVISIONS.......................................................................5

6 S.C.T.C. § 02.01(1) Title ..........................................................................................5

6 S.C.T.C. § 02.01(2) Authority ..................................................................................5

6 S.C.T.C. § 02.01(3) Interpretation ............................................................................5

6 S.C.T.C. § 02.01(4) Gaming Enterprises Owner .......................................................5

6 S.C.T.C. § 02.01(5) Tribal Gaming Policy................................................................5

6 S.C.T.C. § 02.01(6) Purpose .....................................................................................6

6 S.C.T.C. § 02.01(7) Agent of Service .......................................................................6

6 S.C.T.C. § 02.01(8) Severability and Non-Liability ..................................................7

6 S.C.T.C. § 02.01(9) Tribal Court ..............................................................................7

ARTICLE II – DEFINITIONS ......................................................................................7

6 S.C.T.C. § 02.02(1) Definitions................................................................................7

ARTICLE III – GAMING REVENUE......................................................................... 11

6 S.C.T.C. § 02.03(1) License Required .................................................................... 11

6 S.C.T.C. § 02.03(2) Use of Gaming Revenue ......................................................... 11

6 S.C.T.C. § 02.03(3) Per Capita Payments............................................................... 12

6 S.C.T.C. § 02.03(4) Gaming Revenue Accounts..................................................... 12

6 S.C.T.C. § 02.03(5) Cash Prizes............................................................................. 12

6 S.C.T.C. § 02.03(6) Tribal-State Gaming Compact Taxes....................................... 12

6 S.C.T.C. § 02.03(7) Title 31 Compliance................................................................ 12

ARTICLE IV – TRIBAL COUNCIL............................................................................ 12

6 S.C.T.C. § 02.04(1) Tribal Council Delegation Authority ....................................... 12

6 S.C.T.C. § 02.04(2) Tribal Council Retained Authority .......................................... 13

6 S.C.T.C. § 02.04(3) Use of Gaming Revenues........................................................ 13

6 S.C.T.C. § 02.04(4) Dismissal of Gaming Commissioners...................................... 13

6 S.C.T.C. § 02.04(5) Financial Reports.................................................................... 13

6 S.C.T.C. § 02.04(6) Structural Changes.................................................................. 14
STCCIW Title 6, Chapter 2

St. Croix Gaming Ordinance

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6 S.C.T.C. § 02.04(7) Policies and Regulations ......................................................... 14

ARTICLE V – ST. CROIX GAMING COMMISSION................................................. 14

6 S.C.T.C. § 02.05(1) Creation of the St. Croix Gaming Commission........................ 14

6 S.C.T.C. § 02.05(2) Headquarters........................................................................... 14

6 S.C.T.C. § 02.05(3) St. Croix Gaming Commission Powers ................................... 14

6 S.C.T.C. § 02.05(4) St. Croix Gaming Commission Membership ........................... 15

6 S.C.T.C. § 02.05(5) St. Croix Gaming Commission Meetings ................................ 16

6 S.C.T.C. § 02.05(6) Removal and Vacancies of Gaming Commissioners................ 16

6 S.C.T.C. § 02.05(7) Duties of the St. Croix Gaming Commission........................... 17

6 S.C.T.C. § 02.05(8) St. Croix Gaming Commission Confidentiality........................ 20

6 S.C.T.C. § 02.05(9) St. Croix Gaming Commission Right of Entry......................... 21

6 S.C.T.C. § 02.05(10) St. Croix Gaming Commission Audits................................... 21

6 S.C.T.C. § 02.05(11) Investigations........................................................................ 21

6 S.C.T.C. § 02.05(12) St. Croix Gaming Commission Travel................................... 21

ARTICLE VI – ST. CROIX GENERAL MANAGERS ................................................ 22

6 S.C.T.C. § 02.06(1) St. Croix Gaming Management Powers................................... 22

6 S.C.T.C. § 02.06(2) Hiring of Gaming Management............................................... 22

6 S.C.T.C. § 02.06(3) Duties of Gaming Management............................................... 22

6 S.C.T.C. § 02.06(4) Reporting Requirements for Gaming Management.................. 24

6 S.C.T.C. § 02.06(5) Gaming Management Travel................................................... 24

6 S.C.T.C. § 02.06(6) Gaming Management Confidentiality...................................... 24

ARTICLE VII – CHIEF EXECUTIVE OFFICER...................................................... 24

6 S.C.T.C. § 02.07(1) St. Croix Chief Executive Officer............................................ 24

6 S.C.T.C. § 02.07(2) Hiring of Chief Executive Officer ........................................... 24

6 S.C.T.C. § 02.07(3) Duties of Gaming Management............................................... 25

6 S.C.T.C. § 02.07(4) Reporting Requirements for CEO............................................ 26

6 S.C.T.C. § 02.07(5) Chief Executive Officer Travel ............................................... 27

6 S.C.T.C. § 02.07(6) Gaming Management Confidentiality...................................... 27

6 S.C.T.C. § 02.07(7) Chief Executive Officer Disestablishment ............................... 27
STCCIW Title 6, Chapter 2

St. Croix Gaming Ordinance

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ARTICLE VIII – AUDIT ............................................................................................. 27

6 S.C.T.C. § 02.08(1) Annual Audit Engagement ...................................................... 27

6 S.C.T.C. § 02.08(2) Submitting Audit Reports........................................................ 28

6 S.C.T.C. § 02.08(3) Audit of Gaming Related Contracts......................................... 28

ARTICLE IX – PUBLIC HEALTH AND SAFETY..................................................... 28

6 S.C.T.C. § 02.09(1) Gaming Facilities.................................................................... 28

6 S.C.T.C. § 02.09(2) State Certified Inspector.......................................................... 28

ARTICLE X – EMPLOYEE LICENSING................................................................... 28

6 S.C.T.C. § 02.10(1) St. Croix Gaming Commission Authority................................ 28

6 S.C.T.C. § 02.10(2) Agent for Service of Process................................................... 29

6 S.C.T.C. § 02.10(3) Separate Licenses.................................................................... 29

6 S.C.T.C. § 02.10(4) Employee Gaming License Requirements............................... 29

6 S.C.T.C. § 02.10(5) Licensee Requirements ........................................................... 29

6 S.C.T.C. § 02.10(6) Licensee Acceptance............................................................... 30

6 S.C.T.C. § 02.10(7) Employee Gaming License Notices......................................... 31

6 S.C.T.C. § 02.10(8) Failure to Provide Notice ........................................................ 31

6 S.C.T.C. § 02.10(9) Employee Gaming License Restrictions.................................. 31

6 S.C.T.C. § 02.10(10) Employment License Requirement........................................ 32

6 S.C.T.C. § 02.10(11) Application for Employee Gaming License ........................... 32

6 S.C.T.C. § 02.10(12) Fingerprint Procedure............................................................ 33

6 S.C.T.C. § 02.10(13) Confidentiality of Identity..................................................... 34

6 S.C.T.C. § 02.10(14) Application Review Procedure .............................................. 34

6 S.C.T.C. § 02.10(15) Forwarding Applications to the NIGC................................... 35

6 S.C.T.C. § 02.10(16) Forwarding Investigative Reports to the NIGC...................... 35

6 S.C.T.C. § 02.10(17) Granting Employee Gaming Licenses.................................... 36

6 S.C.T.C. § 02.10(18) Denying Employee Gaming Licenses.................................... 37

6 S.C.T.C. § 02.10(19) Suspension of Employee Gaming Licenses............................ 38

6 S.C.T.C. § 02.10(20) Revocation of Employee Gaming Licenses............................ 38

6 S.C.T.C. § 02.10(21) NIGC Notice of Ineligibility for Employment ....................... 39

6 S.C.T.C. § 02.10(22) Appeal Process...................................................................... 39
STCCIW Title 6, Chapter 2

St. Croix Gaming Ordinance

4

6 S.C.T.C. § 02.10(23) License Retention.................................................................. 40

ARTICLE XI – VENDOR LICENSING ...................................................................... 40

6 S.C.T.C. § 02.11(1) Vendor Licensing Purpose ...................................................... 40

6 S.C.T.C. § 02.11(2) Vendor License Application.................................................... 41

6 S.C.T.C. § 02.11(3) Vendor Contracts Agreement .................................................. 41

6 S.C.T.C. § 02.11(4) Vendor Contracts Approval..................................................... 41

6 S.C.T.C. § 02.11(5) Duties Regarding Vendor Contracts........................................ 41

6 S.C.T.C. § 02.11(6) Approval of Vendor Contracts................................................. 42

6 S.C.T.C. § 02.11(7) Disclosure of Relationship ...................................................... 42

6 S.C.T.C. § 02.11(8) Vendor Responsibility............................................................. 42

6 S.C.T.C. § 02.11(9) Granted Vendor Licenses........................................................ 43

6 S.C.T.C. § 02.11(10) Disposition of Vendor Licensing Fees................................... 43

6 S.C.T.C. § 02.11(11) Vendor Document Storage .................................................... 43

6 S.C.T.C. § 02.11(12) Vendor Fee Exemption.......................................................... 43

ARTICLE XII – GENERAL PROVISIONS GOVERNING OPERATION ................. 44

6 S.C.T.C. § 02.12(1) Maintenance of Records.......................................................... 44

6 S.C.T.C. § 02.12(2) Management Contracts............................................................ 45

6 S.C.T.C. § 02.12(3) Tribal Council Approval of Management Contracts ................ 46

6 S.C.T.C. § 02.12(4) Liability Insurance .................................................................. 47

6 S.C.T.C. § 02.12(5) Conflicts of Interest................................................................. 47

6 S.C.T.C. § 02.12(6) Age Restriction for Game Play................................................ 47

6 S.C.T.C. § 02.12(7) Age Restriction for Employment............................................. 47

6 S.C.T.C. § 02.12(8) Intoxicated Individuals............................................................ 47

6 S.C.T.C. § 02.12(9) Restriction of Extended Credit for Gaming.............................. 47

6 S.C.T.C. § 02.12(10) Impartial Resolution of Player Dispute.................................. 48

6 S.C.T.C. § 02.12(11) Alcoholic Beverages ............................................................. 48

6 S.C.T.C. § 02.12(12) Employee Gambling.............................................................. 48

6 S.C.T.C. § 02.12(13) Patron Dispute Resolution..................................................... 48
STCCIW Title 6, Chapter 2

St. Croix Gaming Ordinance

5

ARTICLE I – GENERAL PROVISIONS

6 S.C.T.C. § 02.01(1) Title

This ordinance shall be known as the St. Croix Chippewa Indians of Wisconsin Gaming 

Ordinance (the “St. Croix Gaming Ordinance”). 

6 S.C.T.C. § 02.01(2) Authority

This Ordinance is enacted pursuant to the Constitution and By-Laws of the St. Croix 

Chippewa Indians of Wisconsin (the “Tribe”). Article IV of the Constitution and ByLaws provides that the St. Croix Tribal Council (the “Tribal Council”) is the governing 

body of the St. Croix Chippewa Indians of Wisconsin and Article V, Section 1(a) to 

negotiate with federal, state, and local governments on all matters affecting the welfare of 

the Tribe and Section 1(f) grants the Tribal Council to regulate its own procedure. 

6 S.C.T.C. § 02.01(3) Interpretation

This Ordinance shall be deemed a reasonable and proper exercise of police power of the 

Tribe for the protection of the public health, welfare, and safety of the people living on 

lands under the jurisdiction of the Tribe and all those who enter said lands for lawful 

purposes. The provisions of this Ordinance shall be liberally construed for 

accomplishment of this purpose. If this Ordinance are inconclusive the law of the Tribe 

shall be used as precedent and applied. If both are inconclusive on any matter, federal 

law, laws of other federally recognized Tribes, and the State of Wisconsin may be used as 

persuasive authority and enforced. 

6 S.C.T.C. § 02.01(4) Gaming Enterprises Owner

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

any gaming operation authorized by this Ordinance. The Tribe shall be the sole operator, 

conductor, manager, and owner of all gaming enterprises on tribal lands, except in those 

cases where the Tribe may deem it appropriate to enter into a management contract, it 

shall have the authority to do so, in a manner consistent with federal laws governing the 

terms and approval of such contracts, and provisions of this Ordinance that may apply.

6 S.C.T.C. § 02.01(5) Tribal Gaming Policy

The establishment, promotion and operation of gaming is necessary and desirable, 

provided that such gaming is regulated and controlled by the Tribe pursuant to tribal and 

federal law and any Tribal-State gaming Compact entered into pursuant to the Indian 

Gaming Regulatory Act, and that all proceeds of such gaming are used for the benefit of 

the Tribe as required by the Indian Gaming Regulatory Act and tribal law. When 

operated in accordance with the provisions of this Ordinance, such gaming will be 

conducive to the general welfare of all residents in the community where such gaming is 

conducted.
STCCIW Title 6, Chapter 2

St. Croix Gaming Ordinance

6

6 S.C.T.C. § 02.01(6) Purpose

The purpose of this Ordinance is to:

(a) Regulate, control, and license the operation of all gaming within the jurisdiction 

of the Tribe;

(b) Make clear and explicit that a tribal license to operate a gaming activity, to 

provide gaming related services or equipment, or to work as a gaming employee 

is a revocable privilege, not a right or a property interest;

(c) Make clear that a tribal license is required for each place, facility, or location on 

tribal lands where gaming occurs pursuant to 25 C.F.R. § 522.4(b)(6);

(d) Ensure that tribally regulated gaming is conducted fairly and honestly by both 

gaming operators and players, and it remains free from corrupt, incompetent, 

unconscionable, and dishonest persons and practices;

(e) Promote, strengthen, and diversify tribal economic development and selfdetermination, and enhance employment opportunities for its members;

(f) Generate revenue to strengthen and improve tribal self-government and the 

provisions of tribal government services;

(g) Ensure that the tribal gaming laws are strictly and fairly enforced against all 

persons involved in gaming activities within the jurisdiction of the Tribe; and

(h) Ensure that the Tribe provides a fair and impartial forum for the resolution of 

gaming disputes. 

6 S.C.T.C. § 02.01(7) Agent of Service

The St. Croix Chippewa Indians of Wisconsin designates the Tribal Chairperson, Chair of 

the St. Croix Gaming Commission, and General Counsel as the agent for service of any 

official determination, order, or notice of violation in accordance with 25 CFR § 519.1. 

Any official determination, order, or notice of violation may be sent to: 

St. Croix Chippewa Indians of Wisconsin

Attn: Tribal Chairperson

24663 Angeline Ave

Webster, WI 54893

St. Croix Chippewa Indians of Wisconsin

Attn: Office of the Tribal Attorney, General Counsel

24663 Angeline Ave

Webster, WI 54893

St. Croix Chippewa Indians of Wisconsin
STCCIW Title 6, Chapter 2

St. Croix Gaming Ordinance

7

Attn: Office of the Gaming Commission, Commission Chair

123 Ostermann Drive

Turtle Lake, WI 54889

6 S.C.T.C. § 02.01(8) Severability and Non-Liability 

If any section, provision, or portion of this ordinance is adjudged unconstitutional or invalid 

by a court of competent jurisdiction, the remainder of this ordinance shall not be affected 

thereby. The Tribe further asserts immunity on its part and that of its employees and / or 

agents from any action or damages that may occur as a result of enforcement of this 

ordinance.

6 S.C.T.C. § 02.01(9) Tribal Court

The St. Croix Chippewa Indians of Wisconsin Tribal Court (the “Tribal Court”) shall 

have jurisdiction over this Ordinance. The Tribal Court may act as an appellate court for 

disputes arising under this Ordinance or policies and procedures developed for the 

gaming enterprises.

ARTICLE II – DEFINITIONS

6 S.C.T.C. § 02.02(1) Definitions

In this Ordinance, except where otherwise specifically provided, or where the context 

otherwise requires, the following terms and expressions shall have the following 

meanings:

(a) “CEO” means the individual hired as the Chief Executive Officer to oversee the 

managerial decisions of all the Tribe’s gaming operations. 

(b) “Cheating” means operating or playing any game in a manner in violation of the 

written or commonly understood rules of the game, with the intent to create for 

oneself or for someone in privity with one an advantage over and above the 

chance of the game, and is subject to civil penalties consistent with this 

Ordinance. 

(c) “Class I Gaming” means:

1. Social games played solely for prizes of minimal value; or 

2. Traditional forms of Indian gaming when played by individuals in 

connection with tribal ceremonies or celebrations.
STCCIW Title 6, Chapter 2

St. Croix Gaming Ordinance

8

(d) “Class II Gaming” means:

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

aids are used) when players: 

i. Play for prizes with cards bearing numbers or other designation; 

ii. Cover numbers or designations when objects, similarly 

numbered or designated, are drawn or electronically determined; 

and 

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

pattern on such cards.

2. If played in the same location as bingo or lotto, pull tabs, punch boards, tip 

jars, instant bingo, and other games similar to bingo.

3. Non-banking card games that:

i. State law explicitly authorizes, or does not explicitly prohibit, 

and are played legally anywhere in the state; and 

ii. Players play in conformity with state laws and regulations 

concerning hours, periods of operation, and limitations on 

wagers and pot sizes.

(e) “Class III Gaming” means all forms of gaming that are not Class I Gaming or 

Class II Gaming, including but not limited to:

1. Any house banking game, including but not limited to:

i. Card games such as baccarat, chemin de fer, blackjack (21), and 

pai gow (if played as house-banking games); 

ii. Casino games such as roulette, craps, and keno.

2. Any slot machines as defined in 15 U.S.C. § 1171(a)(1), and electronic or 

electromechanical facsimiles of any game of chance;

3. Any sports betting and pari-mutuel wagering, including but not limited to, 

wagering on horse racing, dog racing, or jai alai; 

4. Lotteries. 

5. The Tribe shall be permitted to offer any additional Class III games which 

any other federally recognized Indian Tribe in the State of Wisconsin, or 

any other person or entity, is permitted to offer for any purpose.

(f) “Commission” or “NIGC” means the National Indian Gaming Commission. 

(g) “Fraud” means intentional deception resulting in an injury to another. Included in 

this definition, but not limited to, are those crimes and misdemeanors involving 

bad check writing, embezzlement, insurance fraud, and welfare fraud.
STCCIW Title 6, Chapter 2

St. Croix Gaming Ordinance

9

(h) “Gaming Commissioner” means an individual employed as a member of the St. 

Croix Gaming Commission. 

(i) “Gaming Employee” means any person employed by the St. Croix Chippewa 

gaming operation engaged in the conduct of Class II or Class III gaming activity 

as well as Key Employee or Primary Management Official. 

(j) “Gaming Operation” means each economic entity that is licensed by the Tribe, 

operates the games, receives the revenues, issues the prizes, and pays the 

expenses. A gaming operation may be operated by the Tribe directly; by a 

management contractor; or, under certain conditions, by another person or other 

entity. 

(k) “Gaming Related Contract” means any agreement under which the Tribe procures 

for gaming any materials, supplies, equipment, or services that are unique to the 

operation of gaming and are not common to ordinary tribal operations, consistent 

with the Tribal-State Compact. 

(l) “Gaming Related Contractor” means any contractor, service provider, or vendor 

as an individual or as an entity, that provides gaming materials, supplies, 

equipment, or services that are unique to the operation of gaming and not 

common to ordinary tribal operations. 

(m)“General Manager” means a Tribal Council hired position responsible for 

managing the day-to-day business of a Tribal Gaming Enterprise. Each gaming 

facility shall have a General Manager. 

(n) “Key Employee” means a person who: 

1. Performs one or more of the following:

i. All supervisors and assistant supervisors; 

ii. Bingo caller, supervisor, cashier;

iii. Counting room supervisor, and count and drop personnel;

iv. Chief of security, and security personnel;

v. Custodian of gaming supplies or cash;

vi. Floor manager, and shift manager;

vii. Pit boss, and Pit supervisor;

viii. Dealer; 

ix. Cashier;

x. Croupier;

xi. Approver of credit;

xii. Any employee engaged in finance or accounting functions; 

xiii. Custodian of gambling devices including person with access to 

cash and accounting records within such devices;
STCCIW Title 6, Chapter 2

St. Croix Gaming Ordinance

10

2. Whose total cash compensation is in excess of $50,000 per year;

3. Who is one of the four most highly compensated persons in the gaming 

operation; or 

4. Who is designated by the Tribe as a Key Employee. 

(o) “Management Contract” means any contract, subcontract, or collateral agreement 

between the Tribe and a contractor or a contractor and subcontractor if such 

contract or agreement provides for the management of all or part of the Tribe’s 

gaming operation. 

(p) “Net Revenues” means gross gaming revenues of the Tribe’s gaming operation 

less:

1. Amounts paid out as, or paid for, prizes; and

2. Total gaming-related operating expenses, including all those expenses of 

the gaming operation commonly known as operating expenses and nonoperating expenses consistent with professional accounting 

pronouncements, excluding management fees. 

(q) “Non-Key Employee” means any employee of the gaming operation who is not a 

Key Employee or Primary Management Official. Non-Key employees may also 

be licensed by the St. Croix Gaming Commission in accordance with any 

limitations, restrictions, or regulatory requirements deemed appropriate by the St. 

Croix Gaming Commission. Non-Key employees are not subject to background 

checks unless deemed appropriate by the St. Croix Gaming Commission. 

(r) “Primary Management Official” means a person who:

1. Has management responsibility for a management contract;

2. Has authority to: 

i. Hire and fire employees; or

ii. Set up working policy for the gaming operation.

3. Is the chief financial officer or other person who has financial 

management responsibility; or 

4. Has been designated by the Tribe as a Primary Management Official. 

(s) “Provisional License” means the temporary gaming license issued to a gaming 

employee when the St. Croix Gaming Commission determines that at a minimum 

the following requirements are met:

1. The individual is currently a gaming employee in one of the Tribe’s 

gaming operations;

2. The individual has been determined eligible for employment;
STCCIW Title 6, Chapter 2

St. Croix Gaming Ordinance

11

3. The individual has returned a completed gaming license background 

application;

4. The individual has provided one set of fingerprints for their file; and

5. The individual has provided copies of their Social Security Card or Social 

Security Number; Birth Certificate, Tribal ID if applicable, and Driver’s 

License. 

(t) “St. Croix Gaming Commission” means the tribal regulatory authority as 

approved by the Tribal Council. 

(u) “Tribe” means the St. Croix Chippewa Indians of Wisconsin, a federally 

recognized Indian Tribe acting through a duly elected Tribal Council pursuant to 

the Tribe’s Constitution.

(v) “Tribal Council” means the duly elected governing body of the St. Croix 

Chippewa Indians of Wisconsin composed of five members pursuant to the 

Tribe’s Constitution. 

(w)“Tribal Lands” means:

1. All lands within the limits of the Tribe’s reservation; or

2. Land over which the Tribe exercises governmental powers and that is 

either:

i. Held in trust by the United States for the benefit of the Tribe; or 

ii. Held by the Tribe subject to restrictions by the United States 

against alienation. 

(x) “Tribal-State Compact” means an agreement between the Tribe and the State of 

Wisconsin about Class III Gaming. 

ARTICLE III – GAMING REVENUE

6 S.C.T.C. § 02.03(1) License Required

A Tribal License is required for each place, facility, or location on Tribal lands where 

gaming occurs pursuant to 25 C.F.R. § 522.4(b)(6). 

6 S.C.T.C. § 02.03(2) Use of Gaming Revenue 

Pursuant to 25 U.S.C. § 2710 (b)(2)(B), net Revenues from Class II Gaming shall be used 

only for the following purposes:

(a) To fund Tribal government operations and programs;
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(b) To provide for the general welfare of the Tribe and its members;

(c) To promote Tribal economic development;

(d) To donate to charitable organizations; and

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

6 S.C.T.C. § 02.03(3) Per Capita Payments

The Tribe may authorize and issue per capita payments to its tribal members only in 

accordance with the Tribe’s Revenue Allocation Plan submitted to and approved by the 

Secretary of the Interior as required by 25 U.S.C.§ 2710(b)(3). 

6 S.C.T.C. § 02.03(4) Gaming Revenue Accounts

All monies collected or received from the operation of the Tribe’s gaming enterprises 

shall be deposited into a special bank account(s) of that gaming enterprise, which shall 

contain only such money. All operating expenses shall be withdrawn from such 

account(s) by consecutively numbered checks duly signed by that gaming enterprises’ 

General Manager or their Chief Financial Officer, and a person(s) designated by the 

Tribal Council. 

6 S.C.T.C. § 02.03(5) Cash Prizes

Any cash prize may be paid by check. Such checks shall be signed by that gaming 

enterprises’ General Manager or their designee, and a person(s) designated by the Tribal 

Council. 

6 S.C.T.C. § 02.03(6) Tribal-State Gaming Compact Taxes

The General Manager of each gaming enterprise and the Chief Financial Officer shall 

ensure that the gaming operation(s) complies with the provisions of Section XIII of the 

Tribal-State Gaming Compact pertaining to taxes. 

6 S.C.T.C. § 02.03(7) Title 31 Compliance

The General Manager of each gaming enterprise shall ensure that the gaming facility 

complies with the applicable provisions of Title 31 as amended (The Bank Secrecy Act).

ARTICLE IV – TRIBAL COUNCIL

6 S.C.T.C. § 02.04(1) Tribal Council Delegation Authority

This Ordinance is authorized and adopted by the Tribal Council pursuant to its power 

under the Tribe’s Constitution and By-Laws. The Tribal Council may further delegate 
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responsibilities under the Tribe’s Constitution and By-Laws to subordinate organizations 

in order to carry out the purposes and terms of this Ordinance and to ensure compliance 

with the Indian Gaming Regulatory Act, the Tribal-State Compact, and all other 

regulations, policies, and procedures therefrom. 

6 S.C.T.C. § 02.04(2) Tribal Council Retained Authority

The Tribal Council shall retain the following exclusive power: 

(a) To enter into agreements or compacts with the federal government, states, Tribes, 

counties, municipalities, and other local governments or entities; 

(b) To waive sovereign immunity; 

(c) To enter into contracts and agreements effecting any sale, lease, encumbrance, or 

other disposition of tribal lands, interest in lands, or other assets of the Tribe; 

(d) To enter into business contracts and agreements pertaining to the operation of 

gaming, except in those cases where that power has been expressly delegated to 

another entity, and in such cases of delegation, the Tribal Council shall have 

reviewed said contracts prior to signing; and

(e) To hire the Casino General Manager(s), CEO, and the Casino Financial Manager, 

and to approve any management contractors. The Tribal Council shall also retain 

authority to terminate or discipline these positions, such termination is not to be 

arbitrary but done pursuant to criteria set forth in this Ordinance or in separate 

policies and procedures, or pursuant to an approved management contract.

6 S.C.T.C. § 02.04(3) Use of Gaming Revenues

The Tribal Council shall establish the use of gaming revenues transferred from the 

gaming enterprises in accordance with this Ordinance and applicable laws for use of such 

revenues according to tribal needs and requirements for continued growth. 

6 S.C.T.C. § 02.04(4) Dismissal of Gaming Commissioners

The Tribal Council has the authority to employ and dismiss Gaming Commissioners, 

pursuant to the standards for employment and dismissal set forth in 6 S.C.T.C. § 

02.05(6).

6 S.C.T.C. § 02.04(5) Financial Reports

The Tribal Council shall review all monthly financial reports which should be forwarded 

to them from the Gaming Management or other designated entity. The Tribal Council has 

final approval of the annual gaming operating budget, as well as revisions that may be 

recommended by Casino Management or another designated entity. 
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6 S.C.T.C. § 02.04(6) Structural Changes

The Tribal Council shall have final approval over any proposed structural changes to 

facilities in gaming enterprises are operated. 

6 S.C.T.C. § 02.04(7) Policies and Regulations

All policies and regulations developed pursuant to this Ordinance shall be subject to final 

approval by the Tribal Council before becoming law.

ARTICLE V – ST. CROIX GAMING COMMISSION

6 S.C.T.C. § 02.05(1) Creation of the St. Croix Gaming Commission

The Tribe created and established the St. Croix Gaming Commission, a subordinate 

organization, as a governmental subdivision of the Tribe, while reserving the right of the 

Tribal Council to review actions of this body. The St. Croix Gaming Commission shall 

have perpetual existence and succession in its own name, unless dissolved by the Tribe 

pursuant to tribal law. 

(a) Pay. Each Gaming Commissioner shall receive a wage set by the Tribal Council. 

(b) Number of Gaming Commissioners. The Tribal Council will determine the 

appropriate odd number of Gamming Commissioners to employ on behalf of the 

Tribe. At a minimum, the St. Croix Gaming Commission shall consist of three 

members. If there are less than three members employed as Gaming

Commissioners, the Tribal Council will conduct best efforts to fill the position(s). 

6 S.C.T.C. § 02.05(2) Headquarters

The St. Croix Gaming Commission shall maintain its headquarters, principal place of 

business and office in Turtle Lake, Wisconsin. 

6 S.C.T.C. § 02.05(3) St. Croix Gaming Commission Powers

The St. Croix Gaming Commission shall exercise all powers necessary to effectuate the 

purpose of this Ordinance. The St. Croix Gaming Commission may exercise any proper 

power and authority necessary to perform the duties assigned to it by this Ordinance, and 

is not limited by the enumeration of powers in Article V of this Ordinance. The St. Croix 

Gaming Commission shall promulgate rules and regulations for the operation of any 

gaming establishment and shall hear and resolve all disputes regarding any provision of 

the Ordinance. In all decisions, the St. Croix Gaming Commission shall act to promote 

and ensure integrity, security, honesty, and fairness of the operation and administration of 

gaming and ancillary activities of the gaming operation. The St. Croix Gaming 

Commission shall have the power and authority to deny any application; to limit, 

condition, suspend, or restrict any license; make a finding of suitability or approval of a 
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license, or find suitable the imposition of a fine upon any person or entity licensed, for 

any cause deemed reasonable by the St. Croix Gaming Commission. 

6 S.C.T.C. § 02.05(4) St. Croix Gaming Commission Membership

The Tribal Council shall employ the number of St. Croix Gaming Commission necessary 

to perform the duties of the St. Croix Gaming Commission. The following provisions of 

this Ordinance shall also dictate the membership of the St. Croix Gaming Commission.

(a) Reporting. The St. Croix Gaming Commission shall report directly and only to the 

Tribal Council. 

(b) Elected Positions. The members of the St. Croix Gaming Commission cannot 

serve in any elected position in the Tribe while at the same time serving as a 

Gaming Commissioner. 

(c) St. Croix Gaming Commission Chair. The Tribal Council shall appoint a Gaming 

Commissioner who shall be responsible for the day-to-day management of the 

affairs of the St. Croix Gaming Commission as well as overseeing the 

establishment and operation of all gaming activities for compliance with all 

applicable Federal, State and Tribal gaming laws and regulations. This individual 

shall be the St. Croix Gaming Commission Chair.

(d) Background Investigation. Prior to appointment of a Gaming Commissioner, a 

detailed background investigation shall be conducted. No individual may serve as 

a Gaming Commissioner if: 

1. The proposed Gaming Commissioner’s prior activities, criminal record, if 

any, or reputation, habits or associations pose a threat to the public 

interest; or threaten the effective regulation and control of gaming; 

enhance the dangers of unsuitable, unfair, or illegal practices, methods, or 

activities in the operation of gaming or the carrying on of the business and 

financial arrangements incidental thereto; or

2. If the proposed Gaming Commissioner has been convicted of or entered a 

plea of guilty or no contest to a felony or any gaming offense in any 

jurisdiction or to a misdemeanor involving dishonest, fraud, 

misrepresentation in any connection or any offense involving moral 

turpitude.

(e) Criminal History. Applicants for the St. Croix Gaming Commission shall not be 

eligible for the St. Croix Gaming Commission if their background investigation 

shows a criminal history. A waiver shall not act to rehabilitate the application for 

consideration for the St. Croix Gaming Commission.

1. Criminal history, for purposes of this section shall mean any felony, any 

misdemeanor involving theft, fraud, misrepresentation or gambling related 

offenses, any drug related conviction involving possession or manufacture. 
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6 S.C.T.C. § 02.05(5) St. Croix Gaming Commission Meetings

The St. Croix Gaming Commission shall hold regular meetings that shall take place on 

the date and time determined by the St. Croix Gaming Commission. The St. Croix 

Gaming Commission shall have the authority to reschedule meetings due to weather, 

closures, scheduling conflicts, or other unforeseen events which inhibit the ability to keep 

a regular monthly meeting. 

(a) Quorum. A quorum of all meetings shall consist of a simple majority of the St. 

Croix Gaming Commission. 

(b) Questions. All questions arising in connection with the action of the St. Croix 

Gaming Commission shall be decided by majority vote at a meeting either regular 

or special. 

(c) Special Meetings. Special meetings may be called at the request of the Tribal 

Council, Gaming Management, the Chairperson of the St. Croix Gaming 

Commission, or by a majority of the members of the St. Croix Gaming 

Commission. 

(d) Executive Session. Executive session may be used when deemed necessary by the 

St. Croix Gaming Commission. No decisions shall be made in Executive Session. 

Use of executive session shall include, but not be limited to matters of personnel 

or other issues of a confidential or privileged nature.

(e) Operating Procedures. The St. Croix Gaming Commission shall develop its own 

written operating procedures. The Tribal Council appointed St. Croix Gaming 

Commission Chair should direct meetings. The St. Croix Gaming Commission 

should elect such other officers as the St. Croix Gaming Commission requires. 

6 S.C.T.C. § 02.05(6) Removal and Vacancies of Gaming Commissioners

The St. Croix Gaming Commissioners may be removed in the following ways: 

(a) Immediate Termination. A Gaming Commissioner shall be immediately 

terminated without the necessity of a hearing, the Tribal Council for any of the 

following: 

1. The Gaming Commissioner is convicted in a Federal, State, Tribal, or 

other court of competent jurisdiction of any felony;

2. The Gaming Commissioner is convicted in a Federal, State, Tribal, or 

other court of competent jurisdiction of any misdemeanor related to 

gambling or moral turpitude;

3. The Gaming Commissioner is convicted of any charge that the Tribal 

Council finds relates to the Gaming Commissioner’s honesty or ability to 

fulfill their duties;
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4. The Gaming Commissioner is found to have violated any part of this 

Ordinance by a court of competent jurisdiction;

5. The Gaming Commissioner is found by a quorum of the Tribal Council to 

be inadequate to perform the duties required of a member of the St. Croix 

Gaming Commission; or

6. The Gaming Commissioner is found by a quorum of the Tribal Council to 

be associated with or to conduct themselves in a way that would bring the 

St. Croix Gaming Commissioner’s integrity or the Tribe’s gaming 

operation into disrepute. 

(b) Removal. Except for Gaming Commissioners whom are immediately terminated 

or whose position is declared vacant, no Gaming Commissioner may be removed 

without notice and an opportunity for a hearing before the Tribal Council. If the 

Tribal Council determines that the immediate removal of a Gaming 

Commissioner is necessary to protect the interests of the Tribe, the Tribal Council 

may immediately remove the Gaming Commissioner temporarily while a 

Removal Hearing is scheduled. 

1. Notice. The Gaming Commissioner being removed must be given written 

notice of the specific charges at least ten (10) days prior to any such 

removal hearing. 

2. Hearing. At the Removal Hearing the Gaming Commissioner shall have 

the opportunity to be heard in person or by counsel and to present 

witnesses on their behalf. At this Removal Hearing the Tribal Council 

shall determine the question of permanent removal of the Gaming 

Commissioner. 

3. Records. A written record of all removal proceedings together with the 

charges and findings thereon shall be recorded by the Treasurer/Secretary 

of the Tribal Council, Tribal Secretary, or other designated individual 

chosen by the Tribal Council. All records shall be kept by the Tribal 

Council with a copy of the record given to the Tribe’s Human Resource 

Department for record keeping purposes. 

(c) Vacancies. If any Gaming Commissioner of the St. Croix Gaming Commission 

should die, resign, be immediately terminated, be removed, or for any reason be 

unable to serve their position the Tribal Council shall declare their position vacant 

and shall hire another individual to fill the position. 

6 S.C.T.C. § 02.05(7) Duties of the St. Croix Gaming Commission

The St. Croix Gaming Commission shall perform all duties, exercise all powers, assume 

and discharge all responsibilities, and carry out and effect all purposes of this Ordinance 

relating to the regulation of all gaming activity. In all decisions, each Gaming 

Commissioner shall act to promote and ensure integrity, security, honesty, and fairness of 

the operation and administration of all gaming activity. The St. Croix Gaming 

Commission duties shall include but not be limited to the following: 
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(a) Contracts. Negotiating contracts for payments by the Tribe for the provision of 

security, surveillance, and outside independent auditing services. Such contracts 

must be approved by the Tribal Council and shall not constitute a waiver of 

jurisdiction by the Tribe.

(b) NIGC. Correspond with the National Indian Gaming Commission and do 

whatever is necessary to ensure compliance with the rules and regulations of that 

agency. Specifically, the St. Croix Gaming Commission, with approval of the 

Tribal Council, shall arrange for an annual outside audit of authorized gaming and 

will provide a copy to the National Indian Gaming Commission.

(c) Safety. The St. Croix Gaming Commission will assure that all gaming activity is 

conducted in a manner which adequately protects the environment and the 

public's health and safety.

(d) Background Investigations. The St. Croix Gaming Commission will ensure that 

background investigations are conducted on all Key Employees and Primary 

Management Officials, of any gaming establishment and that oversight of such 

officials and their management is conducted on an ongoing basis. 

1. The St. Croix Gaming Commission will make suitability determinations 

on the granting of Tribal licenses for all of the gaming operation 

employees. The St. Croix Gaming Commission shall immediately notify 

the National Indian Gaming Commission of the issuance of such licenses 

for Key Employees and Primary Management Officials. 

2. The St. Croix Gaming Commission will review all license applications 

and background investigations to ensure that no person shall be eligible 

for employment if that person's prior activities, criminal record (if any), or 

reputation, habits and associations pose a threat to the public interest or to 

the effective regulation of gaming or create or enhance the dangers of 

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

conduct of gaming or jeopardize the integrity or reputation of the Tribe or 

its gaming operations. The St. Croix Gaming Commission shall notify the 

National Indian Gaming Commission of the results of such background 

checks before the issuance of such licenses to Key Employees and 

Primary Management Officials.

(e) Hiring. Hiring, pursuant to the approval of the Tribal Council, such professional, 

clerical, technical and administrative personnel as may be necessary to carry out 

the provisions of this Ordinance. 

(f) Monitor. Monitor and regulate all tribal gaming activities to ensure compliance 

with tribal law/regulations. The St. Croix Gaming Commission shall have such 

access to tribal gaming facilities and to gaming employees as necessary to carry 

out this responsibility.
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1. The St. Croix Gaming Commission may inspect, review and copy all 

records, documents, equipment and facilities, or anything else necessary 

and pertinent to enforcement of any provisions of this Ordinance.

(g) Sanctions. Make decisions and execute any sanctions on any person subject to the 

jurisdiction of this Ordinance, as deemed necessary, appropriate and lawful.

1. The St. Croix Gaming Commission shall create a list of persons not 

allowed to game in the Tribe’s gaming facilities in order to maintain the 

integrity of the gaming operation. 

2. The St. Croix Gaming Commission should provide referrals and additional 

information to appropriate law enforcement officials when such 

information indicates a violation of Tribal, federal, or state statues, 

ordinances, regulations, codes, or resolutions. 

(h) Outside Agencies. Interact with other regulatory and law enforcement agencies 

regarding the regulation of gaming, as necessary to fulfill their duties.

(i) Rules and Regulations. Be completely familiar with the Indian Gaming 

Regulatory Act, the Federal Regulations promulgated there under, the St. Croix 

Gaming Ordinance, the Tribal-State Compact and related laws. 

1. St. Croix Gaming Commission shall be familiar with the minimum 

internal control standards or procedures for all tribal gaming operations, 

including procedures for acquiring supplies and equipment.

(j) Investigate. Conduct investigations of possible violations and take appropriate 

enforcement action with respect to this Ordinance and related regulations.

1. Issue oaths, take testimony and conduct hearings on regulatory matters, 

including matters related to the revocation of Key Employee and Primary 

Management Official license or any other licenses the St. Croix Gaming 

Commission are authorized to issue under this Ordinance. Hearings may 

also be held for licensing of tribal gaming vendors.

2. Discipline any licensee or other person participating in any gaming 

activity by ordering immediate compliance with this Ordinance or St. 

Croix Gaming Commission regulations and to issue an Order of 

Temporary Suspension of any license issued under this Ordinance, 

consistent with the terms under this Ordinance governing such suspension, 

whenever the St. Croix Gaming Commission is notified of a violation by 

any such person of this Ordinance or any other applicable law. 

(k) Reporting. Provide independent information to the Tribe via the Tribal Council on 

the status of the Tribe's gaming activities.

(l) Licensing. The St. Croix Gaming Commission shall conduct the following:
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1. License all persons who propose to participate in any gaming activity or 

operation;

2. Establish any supplementary criteria for the licensing of Key Employees, 

Primary Management Officials, and other employees, vendors or 

contractors that the Tribe deems necessary;

3. Adopt a schedule of fees to be charged for gaming licenses issued 

pursuant to this Ordinance;

4. Maintain records on licensees and on persons denied licenses including 

persons otherwise prohibited from engaging in gaming activities within 

the tribe's jurisdiction, consistent with applicable law and the Tribal-State 

Compact requirements; and

5. Establish or approve standards for and issue licenses or permits to persons 

and entities who deal with the gaming operation(s) such as manufacturers 

and suppliers of machines, equipment and supplies, such license to be 

called a "vendor license."

(m)Game Rules. Establish or approve the rules of new games consistent with the 

requirements of the Tribal-State Compact and other applicable laws, and inspect 

games, tables, equipment, machines, cards, dice and chips or tokens used in the 

gaming operation. Inspect from time to time the video surveillance standards.

(n) Disputes. Ensure that a mechanism is in place to resolve patron disputes, 

employees' grievances and other problems, pursuant to this Ordinance and other 

tribal regulations and policies that may be in place regarding those issues.

(o) Confidentiality. Provide for an internal system of record keeping with adequate 

safeguards for preserving confidentiality as deemed necessary by the St. Croix 

Gaming Commission. All applications, background investigations and St. Croix 

Gaming Commission decisions related to the licensing of Key Employees, 

Primary Management Officials or any other entity licensed by the St. Croix 

Gaming Commission, shall be retained in St. Croix Gaming Commission files for 

a period of at least seven (7) years and not less than three (3) years from 

termination of employment or business relationship.

(p) Other activities. Engage in any and all activities that directly or indirectly carry 

out the purpose of the Tribe as set forth in this Ordinance.

6 S.C.T.C. § 02.05(8) St. Croix Gaming Commission Confidentiality 

The St. Croix Gaming Commission and each member of the St. Croix Gaming 

Commission may be required to sign a confidentiality agreement and shall be responsible 

for ensuring the strictest standards of confidentiality with respect to all information. 

(a) The St. Croix Gaming Commission and each employee of the St. Croix Gaming 

Commission shall maintain confidentiality of information specified as 

confidential, including information gathered in the background and licensing 
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process and any financial information regarding performance of the gaming 

enterprise. 

(b) Violation of this confidentiality provision shall be subject to disciplinary action 

from the Tribal Council and may be deemed "cause" for suspension or immediate 

termination.

6 S.C.T.C. § 02.05(9) St. Croix Gaming Commission Right of Entry 

The St. Croix Gaming Commission, during regular business hours, may enter upon any 

premises of any gaming operator or gaming facility for the purpose of making inspections 

and examining the accounts, books, papers and documents of any such gaming operator 

or gaming facility. Such gaming operator shall facilitate such inspection or examinations 

by giving every reasonable aid to the St. Croix Gaming Commission. 

(a) Two-Week Inspections of Gaming Operations. A St. Croix Gaming 

Commissioner shall visit each tribally owned or tribally operated gaming facility 

at least once every two weeks during normal business hours for the purpose of 

monitoring its operation. Such visits may be unannounced.

6 S.C.T.C. § 02.05(10) St. Croix Gaming Commission Audits

The St. Croix Gaming Commission and Internal Auditor shall be provided necessary 

access and cooperation from casino personnel when conducting audits or investigations 

scheduled or non-scheduled.

6 S.C.T.C. § 02.05(11) Investigations

The St. Croix Gaming Commission upon complaint or upon its own initiative or 

whenever it may deem it necessary in the performance of its duties or the exercise of its 

powers, may investigate and examine the operation and premises of any facility that is 

subject to the provisions of this Ordinance. In conducting such investigation, the St. 

Croix Gaming Commission may proceed either with or without a hearing as it may deem 

best, but is shall make no order without affording any affected party notice and 

opportunity for a hearing pursuant to the St. Croix Gaming Commission regulations.

6 S.C.T.C. § 02.05(12) St. Croix Gaming Commission Travel

The St. Croix Gaming Commission shall notify the Tribal Council and Gaming 

Management regarding their travel plans. Travel plans shall be made taking into 

consideration the best duties and responsibilities of the St. Croix Gaming Commission, 

the best interest of the gaming enterprise and the amount of money for such travel 

available in the St. Croix Gaming Commission's operating budget. All travel shall be 

subject to review and approval by the Tribal Council.
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ARTICLE VI – ST. CROIX GENERAL MANAGERS

6 S.C.T.C. § 02.06(1) St. Croix Gaming Management Powers

Each tribal gaming enterprise shall have a Casino General Manager authorized to manage 

the gaming enterprise on a day-to-day basis and to facilitate quick and efficient business 

decision-making, while respecting the broad guidelines of the St. Croix Gaming 

Commission and the Tribal Council. The General Manager shall have such authority as 

the Tribal Council delegates. 

6 S.C.T.C. § 02.06(2) Hiring of Gaming Management

The General Manager of each gaming facilities shall be hired by the Tribal Council. 

(a) Purpose. The purpose of the General Manager and the management structure they 

create is to oversee the day-to-day activities, make the day-to-day business 

decisions and to create a successful gaming enterprise.

(b) Background Check. Each General Manager shall undergo a background check 

and a licensing determination by the St. Croix Gaming Commission. Each 

General Manager shall obtain an employee gaming license before commencing 

work. If a proposed General Manager is denied an employee gaming license they 

cannot be hired as a General Manager or any other gaming employee position.

(1) Qualifications. The General Manager shall have the experience and demonstrated 

skills necessary to manage a growing gaming enterprise according to the job 

description.

(c) Review. The General Manager shall be subject to a semi-annual review by the 

Tribal Council or an entity designated by the Tribal Council for that purpose. 

6 S.C.T.C. § 02.06(3) Duties of Gaming Management

The following shall be responsibility of the Gaming Management. The Tribal Council 

may delegate further duties as they determine is necessary for the management of the 

Tribe’s gaming facilities. 

(a) Business Management. Day-to-day business management, including, but not 

limited to such things as hiring, contracting, payroll, and schedules. Contracting is 

subject to applicable sections of this Ordinance.

(b) NIGC Notices. The General Manager shall be required to respond to all NIGC 

notices pertaining to compliance of operating procedures, Minimum Internal 

Control Standard, and Tribal-State Compact within time allotted by the St. Croix 

Gaming Commission, which time shall not be unreasonable. The General 

Manager may request additional time.
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(c) Hiring. Hiring staff pursuant to the process adopted in the Personnel Policies and 

Procedures for the gaming enterprise.

(d) Operating Policies and Operating Procedures. New Operating Policies must be 

submitted to the Tribal Council for approval before becoming effective. However, 

Operating Procedures are a tool for management to use in running an efficient day 

to day operation in compliance with the Operating Policies and thus only require 

the review of the St. Croix Gaming Commission prior to management 

implementing procedural changes or Operating Procedure revisions.

(e) Annual Plan of Operation. Each General Manager shall submit an Annual Plan to 

the Tribal Council for review and approval. The plan shall be submitted by 

September first to the Tribal Council and a copy shall be forwarded to the NIGC 

for review purposes only. The Plan shall contain the following: 

1. Operating Budget;

2. Capital Budget;

3. Growth Target;

4. Staffing requirements, including training requirements; and 

5. Expense and Revenue Projections.

(f) Budget Revisions. Any expenditures in excess of the approved operating and/or 

capital budgets shall be submitted by gaming management to the Tribal Council 

for approval.

(g) Accounting for Gaming Funds. The General Manager is responsible for keeping 

accurate, up-to-date financial records and accounts of all business and for hiring 

or contracting with necessary resources to do so (subject to the terms of the 

Tribal-State Compact, this Ordinance, and Federal law) except that the Tribal 

Council shall retain hiring authority over the Chief Financial Officer for all tribal 

gaming enterprises.

(h) Tribal-State Compact. The General Manager shall be familiar with all terms of the 

Tribal-State Compact and be directly responsible for managing the gaming 

enterprise in compliance with the Tribal-State Compact.

(i) NIGC Regulations. The General Manager shall be familiar with the terms of the 

National Indian Gaming Commission's regulations, effective February 22, 1993, 

and any amendments or updates thereto, and operate all games in compliance with 

said regulations.

(j) Delegation. The General Manager may delegate that authority necessary to ensure 

compliance with rules and regulations and effect a more efficient and productive 

operating environment. 
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6 S.C.T.C. § 02.06(4) Reporting Requirements for Gaming Management

The General Manager shall provide the St. Croix Gaming Commission and the Tribal 

Council with a monthly report that details the number of patrons served, the amount of 

income generated, the numbers of employees working at the facility, a detailed 

description of any patron complaints, and other problems experienced at the facility. The 

report shall also contain a detailed financial report, a written statement of any changes in 

Key Employees or Primary Management Officials, a listing of all bills that are thirty (30) 

days or more past due and any other information the Tribal Council or the St. Croix 

Gaming Commission may require.

6 S.C.T.C. § 02.06(5) Gaming Management Travel

The General Manager shall inform the St. Croix Gaming Commission regarding travel 

plans. Travel plans shall be made by the General Manager in accordance with any 

applicable Tribal Policies, based on the best interest of the gaming enterprise, and money 

available for such travel in the approved operating budget. Travel plans of the General 

Manager themselves shall be first approved by the Tribal Council. 

6 S.C.T.C. § 02.06(6) Gaming Management Confidentiality 

The General Manager shall maintain confidentiality of information specified as 

confidential, including information gathered in the hiring process and any financial 

information regarding performance of the gaming enterprise. Violation of this 

confidentiality provision shall be subject to disciplinary action from the Tribal Council 

and may be deemed "cause" for suspension or termination.

ARTICLE VII – CHIEF EXECUTIVE OFFICER

6 S.C.T.C. § 02.07(1) St. Croix Chief Executive Officer

The Tribal Council may hire a Chief Executive Officer to oversee all the Tribe’s gaming 

facilities. The CEO shall be responsible for the management, direction, and oversight of 

all the Tribe’s gaming facilities. The CEO will work closely with the Casino General 

Managers to facilitate quick and efficient business decision-making, while respecting the 

broad guidelines of the St. Croix Gaming Commission and the Tribal Council. The CEO 

shall have such authority as the Tribal Council delegates. 

6 S.C.T.C. § 02.07(2) Hiring of Chief Executive Officer

The CEO shall be hired by the Tribal Council. 

(a) Purpose. The purpose of the CEO is to oversee the activities of all the Tribe’s 

gaming facilities and develop a strategic plan to promote revenue, profitability, 

and growth of the Tribe’s gaming enterprise. The CEO will work closely with 

each gaming facilities General Manager to fulfill this purpose. 
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25

(b) Background Check. Any proposed CEO shall undergo a background check and a 

licensing determination by the St. Croix Gaming Commission. The CEO shall 

obtain an employee gaming license before commencing work. If a proposed CEO 

is denied an employee gaming license they cannot be hired as a CEO or any other 

gaming employee position.

(2) Qualifications. The CEO shall have the experience and demonstrated skills 

necessary to manage the Tribe’s gaming facilities and a growing gaming 

enterprise according to the job description.

(c) Review. The CEO shall be subject to a semi-annual review by the Tribal Council 

or an entity designated by the Tribal Council for that purpose. 

6 S.C.T.C. § 02.07(3) Duties of Gaming Management

The following shall be responsibility of the CEO. The Tribal Council may delegate 

further duties as they determine is necessary for the management of the Tribe’s gaming 

facilities. 

(a) Business Management. Overall business management, including, but not limited 

to such things as oversee Casino Departments, create a Tribal Council approved 

business plan, execute the approved business plan, and oversee the direction of 

the gaming facilities to promote the success and growth of the Tribe’s gaming 

enterprise. 

(b) General Managers. The CEO shall work collaboratively with the General 

Managers of each gaming facilities to ensure cooperative and smooth 

performance of the Tribe’s gaming enterprise. Any dispute of authority should 

either be discussed and determined amongst themselves or brought to the 

attention of the Tribal Council and a quorum of the Tribal Council will make the 

final decision. 

(c) NIGC Notices. The CEO shall work collaboratively with the General Managers 

and respond to all NIGC notices pertaining to compliance of operating 

procedures, Minimum Internal Control Standard, and Tribal-State Compact within 

time allotted by the St. Croix Gaming Commission, which time shall not be 

unreasonable. The CEO and/or General Manger may request additional time.

(d) Hiring. Hiring staff pursuant to the process adopted in the Personnel Policies and 

Procedures for the gaming enterprise.

(e) Operating Policies and Operating Procedures. New Operating Policies must be 

submitted to the Tribal Council for approval before becoming effective. However, 

Operating Procedures are a tool for management to use in running an efficient day 

to day operation in compliance with the Operating Policies and thus only require 
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the review of the St. Croix Gaming Commission prior to management 

implementing procedural changes or Operating Procedure revisions.

(f) Annual Plan of Operation. The CEO will work with the General Managers to 

submit an Annual Plan to the Tribal Council for review and approval. The plan 

shall be submitted by September first to the Tribal Council and a copy shall be 

forwarded to the NIGC for review purposes only. The Plan shall contain the 

following: 

1. Operating Budget;

2. Capital Budget;

3. Growth Target;

4. Staffing requirements, including training requirements; and 

5. Expense and Revenue Projections.

(g) Budget Revisions. Any expenditures in excess of the approved operating and/or 

capital budgets shall be submitted to the Tribal Council for approval.

(h) Accounting for Gaming Funds. The CEO is also responsible for keeping accurate, 

up-to-date financial records and accounts of all business and for hiring or 

contracting with necessary resources to do so (subject to the terms of the TribalState Compact, this Ordinance, and Federal law) except that the Tribal Council 

shall retain hiring authority over the Chief Financial Officer for all tribal gaming 

enterprises.

(i) Tribal-State Compact. The CEO shall be familiar with all terms of the TribalState Compact and be directly responsible for managing the gaming enterprise in 

compliance with the Tribal-State Compact.

(j) NIGC Regulations. The CEO shall be familiar with the terms of the National 

Indian Gaming Commission's regulations, effective February 22, 1993, and any 

amendments or updates thereto, and operate all games in compliance with said 

regulations.

(k) Delegation. The CEO may delegate that authority necessary to ensure compliance 

with rules and regulations and effect a more efficient and productive operating 

environment. 

6 S.C.T.C. § 02.07(4) Reporting Requirements for CEO

The CEO shall assist the General Managers to provide the St. Croix Gaming Commission 

and the Tribal Council with a monthly report that details the number of patrons served, 

the amount of income generated, the numbers of employees working at the facility, a 

detailed description of any patron complaints, and other problems experienced at the 

facility. The report shall also contain a detailed financial report, a written statement of 

any changes in Key Employees or Primary Management Officials, a listing of all bills 
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that are thirty (30) days or more past due and any other information the Tribal Council or 

the St. Croix Gaming Commission may require.

6 S.C.T.C. § 02.07(5) Chief Executive Officer Travel

The CEO shall inform the St. Croix Gaming Commission regarding travel plans. Travel 

plans shall be made by the CEO in accordance with any applicable Tribal Policies, based 

on the best interest of the gaming enterprise, and money available for such travel in the 

approved operating budget. Travel plans of the CEO themselves shall be first approved 

by the Tribal Council. 

6 S.C.T.C. § 02.07(6) Gaming Management Confidentiality 

The CEO shall maintain confidentiality of information specified as confidential, 

including information gathered in the hiring process and any financial information 

regarding performance of the gaming enterprise. Violation of this confidentiality 

provision shall be subject to disciplinary action from the Tribal Council and may be 

deemed "cause" for suspension or termination.

6 S.C.T.C. § 02.07(7) Chief Executive Officer Disestablishment

The Tribal Council via a quorum may disestablish the CEO position upon determination 

that the position is no longer necessary for the effective operation of the Tribe’s gaming 

enterprise, the position is no longer financially feasible, or any other reason deemed 

appropriate by the Tribal Council. Additionally, the CEO position may be reestablished 

by a quorum of the Tribal Council. All Tribal Council members must be present at either 

a disestablishment or reestablishment of the CEO position. All changes in the Tribe’s 

gaming management structure must be done in accordance with applicable federal and 

Tribal laws and NIGC regulations. 

ARTICLE VIII – AUDIT

6 S.C.T.C. § 02.08(1) Annual Audit Engagement

Annually, the St. Croix Gaming Commission shall engage an independent certified public 

accountant to audit the books and records of all gaming operations. The audit shall be 

completed within ninety (90) days after the close of the fiscal year. The ninety-day 

deadline will not apply when events outside the control of the St. Croix Gaming 

Commission prohibit compliance but the audit shall be completed as soon as practical. 

(a) Deadlines. The St. Croix Gaming Commission shall be responsible for keeping 

track of deadlines regarding audits, shall submit requests for proposals to eligible 

audit firms and shall have the authority to engage an audit firm to comply with the 

terms of the Tribal-State Compact. All provisions of the Tribal-State Compact 

shall be adhered to in this process.
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(b) Tribal-State Compact. The Tribal-State Compact terms for both financial and 

security audits shall be followed for the audit of Class III gaming.

6 S.C.T.C. § 02.08(2) Submitting Audit Reports

The independent certified public accountant shall submit the resulting audit reports to the 

National Indian Gaming Commission, the Tribal Council, the State Gaming Board and 

General Manager of all gaming operations. 

6 S.C.T.C. § 02.08(3) Audit of Gaming Related Contracts 

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

concessions in excess of Twenty-Five Thousand Dollars ($25,000.00) annually, except 

contracts for professional legal and accounting services, shall be included within the 

scope of the audit that is described above.

ARTICLE IX – PUBLIC HEALTH AND SAFETY

6 S.C.T.C. § 02.09(1) Gaming Facilities

Class II and Class III Gaming Operations shall be constructed, maintained and operated 

in a manner that adequately protects the environment and the health and safety of the 

public.

6 S.C.T.C. § 02.09(2) State Certified Inspector 

The Tribe shall engage a state certified inspector to conduct inspections of all facilities 

for Class III gaming on a periodic basis, but not less than annually, and shall promptly 

repair or correct any and all instances of non-compliance. An inspection report shall be 

prepared by the Tribe in connection with each inspection and copies of said reports shall 

be forwarded to the appropriate State of Wisconsin Department, Division, or Board.

ARTICLE X – EMPLOYEE LICENSING

6 S.C.T.C. § 02.10(1) St. Croix Gaming Commission Authority 

The St. Croix Gaming Commission shall license and supervise the conduct of Class I, 

Class II, and Class III gaming operations within the exterior boundaries of the St. Croix 

Indian Reservation.
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6 S.C.T.C. § 02.10(2) Agent for Service of Process

The St. Croix Chippewa Indians of Wisconsin designates the Regulatory Processing and 

Licensing Office as agent for service of process. This service of process does not 

designate the Regulatory Processing and Licensing Office as the agent for service of any 

official determination, order, or notice of violation, as outlined in 6 S.C.T.C.§ 02.01(7).

The Regulatory Processing and Licensing Office may be contacted at: 

1-715-986-4383 or 1-800-845-8401 

6 S.C.T.C. § 02.10(3) Separate Licenses

A separate license shall be required for each place, facility, or location on tribal lands 

where the Tribe allows Class II, or Class III gaming.

6 S.C.T.C. § 02.10(4) Employee Gaming License Requirements

Any license for Class I, Class II, or Class III gaming shall contain the following 

conditions, restrictions, regulations or information: 

(a) Name of licensee, operator and chief executive officer;

(b) Authorized games;

(c) Effective or Renewal date;

(d) Specific location;

(e) Specify where gaming receipts may be deposited; 

(f) Specify the method of transfer to the St. Croix Chippewa Indians of Wisconsin of 

gaming profits on a monthly basis;

(g) Required reports and frequency;

(h) Permissible hours of operation;

(i) Compliance with all Class III Tribal-State Compact standards;

(j) Compliance with all applicable Indian Gaming Regulatory Act Standards; and

(k) Preferences for Indian hiring.

6 S.C.T.C. § 02.10(5) Licensee Requirements

The licensee shall permanently maintain the following records: 

(a) Revenues, expenses, assets, liabilities and equity for each location at which any 

gaming is conducted;
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(b) Daily cash transactions for each game at each location;

(c) Contracts, correspondence and other transaction documents relating to all vendors 

and contracts;

(d) All audits;

(e) Personnel information on all Class II and Class III gaming employees or agents 

including work schedules, hours worked and background checks; and

(f) Any other records required to be maintained by Section X of the Tribal-State 

Compact.

6 S.C.T.C. § 02.10(6) Licensee Acceptance 

The licensee by accepting a St. Croix Gaming License agrees:

(a) To abide by the rules and regulations of the Tribe and with all other applicable 

legal authority as to all aspects associated with the conduct of licensed games;

(b) To pay all applicable license fees and assessments; 

(c) To make all books and records of gaming operations upon the St. Croix Indian 

Reservation available for inspection by the Tribal Council or the St. Croix 

Gaming Commission during all normal business hours; 

(d) To provide preferential hiring to qualified members of the Tribe as to all positions 

open for employment; 

(e) To promptly pay to all winners such prizes as they might respectfully be entitled 

to; 

(f) To provide audits as required by Section XII of the Tribal-State Compact;

(g) To conspicuously post any gaming license granted; and 

(h) To monthly execute and file a report of operation on a form prescribed by the St. 

Croix Gaming Commission. The report shall include:

1. The date of each gaming occasion;

2. The type of games played;

3. An itemized statement of the gross receipts from gaming during the 

reporting period;

4. An itemized statement of gross receipts from all nongaming activities 

including concession and tobacco sales; and
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5. An itemized statement of expenditures including amounts paid for prizes, 

supplies and equipment, wages, utilized fees, and all other expenses 

associated with gaming.

6 S.C.T.C. § 02.10(7) Employee Gaming License Notices

The following notices shall be placed on the application form for a Non-Key Employee, 

Key Employee, or a Primary Management Official before that form is filled out by an 

applicant: 

(a) “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 (NIGC) 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’s being unable to license you for a primary management 

official or key employee position”

(b) “The disclosure of your Social Security Number (SSN) is voluntary. However, 

failure to supply a SSN may result in errors in processing your application."

(c) “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)."

6 S.C.T.C. § 02.10(8) Failure to Provide Notice 

Existing Non-Key Employees, Key Employees and Primary Management Officials who 

have not filled out applications with the privacy act notice or false statement notice as 

described above shall be notified in writing that they shall complete a new application 

which contains the appropriate privacy act notice and/or false statement notice.

6 S.C.T.C. § 02.10(9) Employee Gaming License Restrictions

No person may be employed by the Tribe in the operation or conduct of gaming or by a 

gaming related contractor in the course of performance under the contract, if that person:

(a) Has been convicted of, or entered a plea of guilty or no contest to, any of the 

following unless the person has been pardoned:
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1. A felony, other than a felony conviction of an offense under subdivision 

(2), (3), or (4), during the immediately preceding 10 years;

2. Any gambling related offense;

3. Fraud or misrepresentation in any connection; or

4. A violation of any provision of Chapter 562 or 565, Wis. Stats., a rule 

promulgated by the Lottery Board, or Wisconsin Racing Board, or a Tribal 

Ordinance regulating or prohibiting gaming.

(b) Has been determined by the Tribe to be a person whose prior activities, criminal 

record if any, or reputation, habits, and associations pose a threat to the public 

interest or to the effective regulation and control of gaming or create or enhance 

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

operation of gaming or the carrying on of the business and financial arrangements

incidental thereto.

6 S.C.T.C. § 02.10(10) Employment License Requirement

All Non-Key Employee, Key Employees, and Primary Management Officials shall apply 

for and be granted a Tribal gaming license prior to employment in the gaming operation. 

The Tribe shall ensure that the policies and procedures set out in this Article are 

implemented with respect to anyone employed at any Class II or Class III gaming 

operation operated on Tribal lands:

(a) The Tribe cannot employ persons who refuse to voluntarily cooperate with the 

licensing process.

6 S.C.T.C. § 02.10(11) Application for Employee Gaming License 

The applications for gaming employees shall provide the basis for background 

investigations performed by the St. Croix Gaming Commission and shall be confidential. 

Such applications shall include, but is not limited to the following: 

(a) The applicant's full name, including all other names used (oral or written), social 

security number, date of birth, place of birth, citizenship, gender, all languages 

(spoken or written), current home and work addresses, and telephone numbers;

(b) Currently and for the previous five (5) years: business and employment positions 

held, ownership interest in those businesses, business and residence addresses, 

and drivers' license numbers;

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

including one personal reference who was acquainted with the applicant during 

each period of residence listed in subsection (b) above;

(d) Current business and residence telephone numbers;
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(e) A description of any existing and previous business relationships with Indian 

Tribes, including ownership interests in those businesses;

(f) A description of any existing and previous business relationships with the gaming 

industry generally, 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) 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;

(i) For each gaming offense and for each felony for which there is an ongoing 

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

and the date and disposition, if any;

(j) For each criminal charge (excluding minor traffic charges) whether or not there is 

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

application and is not otherwise listed, the criminal charge, the name and address 

of the court involved, and the date and disposition;

(k) For each misdemeanor conviction or ongoing misdemeanor prosecution 

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

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

disposition;

(l) A current Driver's License or State Certified photo ID;

(m)A notarized birth certificate or Tribal I.D;

(n) Social Security Card or Social Security Number;

(o) Fingerprints which shall be taken by the Regulatory Processor and forwarded to 

the FBI and CIB to determine the applicant's criminal history, if any; and 

(p) Written permission giving the St. Croix Gaming Commission the right to 

investigate information including but not limited to the applicant's background, 

including his or her criminal record, civil and criminal judgments, educational 

record, military record and credit history.

6 S.C.T.C. § 02.10(12) Fingerprint Procedure

The Regulatory Processing & Licensing Department shall take fingerprints from 

proposed Key Employees and Primary Management Officials to conduct the background 
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investigation. The background investigation shall include a check of criminal history 

record information maintained by the Federal Bureau of Investigations (“FBI”).

(a) Taken fingerprints shall be sent to the Crime Information Bureau in Madison, 

Wisconsin for processing. 

(b) The Regulatory Processing & Licensing Department shall have an account with 

the Wisconsin Department of Justice online System (“WORCS”) for obtaining the 

proposed Key Employees and/or Primary Management Officials background 

investigation. 

(c) All conducted background investigations will be forwarded to the St. Croix 

Gaming Commission for their review and determination. 

6 S.C.T.C. § 02.10(13) Confidentiality of Identity

The St. Croix Gaming Commission and Regulatory Processing & Licensing Department 

shall keep confidential the identity of each individual interviewed in the course of 

conducting any background investigation regardless of whether that individual is hired or 

not. Any other Department, Employee, or individual who may require access to 

conducted background investigations shall also keep confidential the identity of each 

individual interviewed in the course of conducting any background investigation. 

6 S.C.T.C. § 02.10(14) Application Review Procedure

Before issuing a gaming employee license, the St. Croix Gaming Commission shall:

(a) Be responsible for conducting, reviewing and either approving or disapproving 

the investigative work;

(b) The St. Croix Gaming Commission may require asset and liability disclosure for 

Key Employees and Primary Management Officials when it deems that 

information necessary to adequately protect the gaming operation(s) and 

determine the suitability of a particular individual for employment or continued 

employment; 

(c) Review the person's prior activities, criminal record, if any, 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(s). Where 

the St. Croix Gaming Commission determines that employment of the person 

poses a threat to the public interests or to the effective regulation of gaming, or 

creates or enhances dangers of unsuitable, unfair or illegal practices and methods 

and activities in the conduct of gaming, a tribal gaming operation(s) shall not 

employ that person in a Key Employee or Primary Management Official position; 

and
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(d) Be responsible for reporting the results of the background investigations to the 

National Indian Gaming Commission for Key Employees and Primary 

Management Officials only. 

6 S.C.T.C. § 02.10(15) Forwarding Applications to the NIGC 

The following will be the 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 begins work at a gaming 

operation authorized by this Ordinance, the St. Croix Gaming Commission shall 

forward to the National Indian Gaming Commission a completed application for 

an employee gaming license, conduct the background investigation and make the 

eligibility determination regarding the issuance of an employee gaming license;

(b) The St. Croix Gaming Commission shall forward the notice of results referred to 

below to the National Indian Gaming Commission no later than sixty (60) days 

after an employee begins work; and

(c) The notice of results shall include the following information:

1. The applicant’s name, date of birth, and social security number;

2. The date on which the applicant began, or will begin, working as a Key 

Employee or Primary Management Official;

3. A summary of the information presented in the investigative report, 

including: 

i. License(s) that have previously been denied;

ii. Gaming licenses that have been revoked, even if subsequently 

reinstated;

iii. Every known criminal charge brought against the applicant within 

the last 10 years of the date of the application; and

iv. Every felony offense of which the applicant has been convicted or 

any ongoing prosecution.

4. A copy of the eligibility determinations made.

6 S.C.T.C. § 02.10(16) Forwarding Investigative Reports to the NIGC

The St. Croix Gaming Commission shall notify the National Indian Gaming Commission 

of the issuance of a license to a Key Employee or Primary Management Official within 

thirty (30) days of the issuance. The St. Croix Gaming Commission shall prepare and 

forward to the National Indian Gaming Commission an investigative report on each 

background investigation of a Key Employee or Primary Management Official. 

(a) An investigative report shall include all of the following:
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1. Steps taken in conducting a background investigation;

2. Results obtained;

3. Conclusions reached; and

4. The basis for those conclusions.

(b) The St. Croix Gaming Commission shall submit, with the report, a copy of the 

eligibility determination.

(c) Objection Timeline. The National Indian Gaming Commission (“NIGC”) shall 

have thirty (30) days after the date which the NIGC received notice of a Key 

Employee or Primary Management Official license to issue any objection. If, 

within the thirty (30) day period, the St. Croix Gaming Commission does not 

receive an objection to a license application and investigative report filed for a 

Key Employee or Primary Management Official from the NIGC, the St. Croix 

Gaming Commission may issue a license to such applicant. 

(d) Additional Information. The St. Croix Gaming Commission shall respond to a 

request for additional information from the Chairman of the NIGC concerning a 

Key Employee or Primary Management Official who is the subject of a report. 

Such a request shall suspend the thirty-day (30) period under subsection (c) above 

until the Chairman of the NIGC receives the additional information.

(e) Objections. If, within the thirty-day (30) period described above, the NIGC 

provides the St. Croix Gaming Commission with a statement itemizing objections 

to the issuance of a license to a Key Employee or to a Primary Management 

Official for whom the St. Croix Gaming Commission has provided an application 

and investigative report, the St. Croix Gaming Commission shall reconsider the 

application, considering the objections itemized by the NIGC. The St. Croix 

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

such applicant.

1. If the St. Croix Gaming Commission has issued a license to a Key 

Employee or Primary Management Official before receiving the NIGC’s 

statement of objection, a notice and hearing shall be provided to the 

licensee. 

6 S.C.T.C. § 02.10(17) Granting Employee Gaming Licenses

The St. Croix Gaming Commission is responsible for granting and issuing gaming license 

to Key Employees and Primary Management Officials. The St. Croix Gaming 

Commission may license Non-Key Employees.

(a) Provisional License. The St. Croix Gaming Commission may issue a provisional 

or temporary employee gaming license. A provisional license may be issued when 

the St. Croix Gaming Commission determines an applicant is suitable after an 

initial background check and the following requirements are met: 
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1. The individual has been determined eligible for employment;

2. The individual has returned a completed gaming license application;

3. The initial background screen returns no disqualifying offenses;

4. The individual has passed pre-employment drug and/or alcohol 

screenings; and 

5. The individual has provided one set of fingerprints for their file. 

(b) Primary Management Officials. The St. Croix Gaming Commission may license a 

Primary Management Official after submitting notice of results of the applicant’s 

background investigation to the NIGC. 

1. All Primary Management Officials must have gaming licenses issued by 

the Tribe.

2. The Tribe shall not employee an individual in a Primary Management 

Official position who does not have a license after ninety (90) days of 

beginning work at a gaming facility. 

(c) Key Employees. The St. Croix Gaming Commission may license a Key Employee 

after submitting notice of results of the applicant’s background investigation to 

the NIGC. 

1. All Key Employees must have gaming licenses issued by the Tribe.

2. The Tribe shall not employee an individual in a Key Employee position 

who does not have a license after ninety (90) days of beginning work at a 

gaming facility.

6 S.C.T.C. § 02.10(18) Denying Employee Gaming Licenses

An applicant may be denied an employee gaming license for failure to complete any 

portion of the application process or any reason listed pursuant to 6 S.C.T.C. § 02.10(9). 

If a license is not issued to an applicant, the St. Croix Gaming Commission shall:

(a) Automatic Denial. The St. Croix Gaming Commission shall not license a Key 

Employee or Primary Management Official if in applying the eligibility standards, 

the Gaming Commission determines that the individual:

1. Poses a threat to the public interest;

2. Poses a threat to the effective regulation of gaming; or 

3. Creates or enhances the danger of unsuitable, unfair or illegal practices, 

methods, and/or activities in the conduct of gaming. 

(b) NIGC Notice. If the St. Croix Gaming Commission denies a proposed Key 

Employee or Primary Management Official an employee gaming license, or 

revokes a previously issued license, the St. Croix Gaming Commission shall:

1. Notify the National Indian Gaming Commission; and
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2. Forward copies of eligibility determination and investigative report (if 

any) to the National Indian Gaming Commission for inclusion in the 

Indian Gaming Individuals Records System. 

6 S.C.T.C. § 02.10(19) Suspension of Employee Gaming Licenses

The St. Croix Gaming Commission may suspend any employee gaming license. Upon 

determination that an employee gaming license will be suspended the St. Croix Gaming 

Commission shall send written notice of the suspension to the individual. The St. Croix 

Gaming Commission may suspend an employee gaming license for any of the following 

reasons:

(a) The employee has been charged with, convicted of, or entered a plea of guilty or 

no contest to any offense that may result in a bar to obtaining a gaming license;

(b) The Tribe received notice from the NIGC that the individual is not eligible for 

employment; 

(c) The employee has made a materially false statement in their license application or 

application for employment;

(d) The employee has participated in gaming activity unauthorized by their employee 

gaming license;

(e) The employee's continued employment as a Key Employee or Primary 

Management Official of a gaming enterprise or gaming activity poses a threat to 

the general public or reputation and/or financial stability of the gaming enterprise;

(f) The employee has refused to comply with any directive from the St. Croix 

Gaming Commission; or

(g) The employee has failed to provide the St. Croix Gaming Commission with any 

change in status of the material originally submitted in their gaming application. 

6 S.C.T.C. § 02.10(20) Revocation of Employee Gaming Licenses

The St. Croix Gaming Commission may revoke any employee gaming licenses. Upon 

determination that an employee gaming license will be revoked the St. Croix Gaming 

Commission shall send written notice of the suspension to the individual. Should a 

license be revoked, the revocation shall result in the termination of the employee. The St. 

Croix Gaming Commission may revoke an employee gaming license for any of the 

following reasons:

(a) The individual has been convicted or entered a plea of guilty or no contest to any 

felony;
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(b) The Tribe received notice from the NIGC that the individual is not eligible for 

employment; 

(c) If there is evidence a person has participated in organized crime or unlawful 

gambling or is a person whose prior activities, criminal record, reputation, habits, 

and/or associations pose a threat to the public interest or to the effective 

regulation and control of gaming, or create or enhance the dangers of unsuitable, 

unfair, or illegal practices and methods and activities in the conduct of gaming or 

to the carrying on of the business and financial arrangements incidental to the 

conduct of gaming; 

(d) The individual is found to have intentionally supplied false or misleading material 

information or has omitted material information on their license application or 

application for employment; or 

(e) The employee has refused to comply with any directive from the St. Croix 

Gaming Commission.

6 S.C.T.C. § 02.10(21) NIGC Notice of Ineligibility for Employment 

If after a license is issued, the Tribe receives notice from the NIGC that the individual is 

not eligible for employment, the St. Croix Gaming Commission shall do the following:

(a) Immediately suspend the license;

(b) Provide the licensee with written notice of the suspension and proposed 

revocation; and

(c) Provide the licensee with notice of a time and place for a hearing on the proposed 

revocation of the license.

1. Following the revocation hearing, the St. Croix Gaming Commission will 

decide whether to revoke or reinstate the license at issue. 

2. The St. Croix Gaming Commission will notify the NIGC of its decision to 

revoke or reinstate a license within forty-five (45) days of receiving 

notification from the NIGC that the individual is not eligible. 

6 S.C.T.C. § 02.10(22) Appeal Process

Any decision resulting in approving, disapproving, revoking, suspending, limiting or 

conditioning a license, or the imposition of other sanctions under this Ordinance shall be 

made by the St. Croix Gaming Commission. Should an applicant or licensee disagree 

with the determination of the St. Croix Gaming Commission, they may appeal as follows: 

(a) The individual may file a written appeal with the St. Croix Gaming Commission 

within fifteen (15) days, excluding holidays or closures, of their approval, 
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disapproval, revocation, suspension, limitation or condition, or other sanction they 

are appealing.

(b) The St. Croix Gaming Commission shall then schedule a hearing to review the 

decision within thirty (30) working days from the date of the submitted appeal. At 

the hearing the appellant may present any relevant information to the St. Croix 

Gaming Commission. 

(c) Following such hearing, the St. Croix Gaming Commission shall, within three (3) 

working days reach a determination concerning:

1. The accuracy of the facts presented at the hearing;

2. Whether the license in question should be granted, denied, reinstated 

suspended, revoked, conditioned or limited; and

3. Whether any other action recommended to the St. Croix Gaming 

Commission including, but not limited to fines and forfeitures, should be 

taken. 

(d) Within ten (10) working days following this determination, the St. Croix Gaming 

Commission shall inform the subject in writing of the determination. The 

determination of the St. Croix Gaming Commission shall be final and not subject 

to further appeal. 

(e) Deadlines do not include any closures, holidays, or events outside the control of 

the individual or the St. Croix Gaming Commission. 

6 S.C.T.C. § 02.10(23) License Retention 

With respect to license applicants, the Regulatory Processing and Licensing Office, or 

appropriate office determined by the St. Croix Gaming Commission shall retain 

applications for licensing, eligibility determinations, and reports (if any) of background 

investigations for inspection by the Chairman of the National Indian Gaming 

Commission or their designee for no less than three (3) years from the date of denial or 

revocation of a license, or termination of employment, whichever is later.

ARTICLE XI – VENDOR LICENSING

6 S.C.T.C. § 02.11(1) Vendor Licensing Purpose

The purpose of Article X is to regulate and determine licensing suitability of all vendors 

who provide to Tribe various products and/or services. The St. Croix Gaming 

Commission shall establish regulations, criteria, and procedures to issue "Vendor 

Licenses" to those that meet the required standards.
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6 S.C.T.C. § 02.11(2) Vendor License Application

The St. Croix Gaming Commission will provide an application to prospective and current 

vendors upon request of either the vendor, the Tribe, or its Enterprises. Upon receipt of 

an application, The St. Croix Gaming Commission shall investigate of the applicant and 

each of its principals and shall include a criminal record check on the applicant and on 

each of the applicant's principals.

(a) The purpose of the application is to determine the eligibility of those individuals, 

companies, corporations and/or partnerships that will do business with the Tribe. 

Therefore, failure to submit the required information on the application will be 

grounds to "deny" licensing. The information submitted may be disclosed to the 

Tribal government and may be reviewed by other organizations relevant to civil, 

criminal, or regulatory investigations as required.

6 S.C.T.C. § 02.11(3) Vendor Contracts Agreement

The Tribe and its Enterprises agree that, subject to the Licensing Requirements of the 

Vendor License Policy, the Tribe and its Enterprises may enter into a Vendor contract for 

the operation of its businesses including its Class II and Class III Gaming facilities under 

this Ordinance.

6 S.C.T.C. § 02.11(4) Vendor Contracts Approval

Before approving such contracts, the Tribe and its Enterprises shall ensure that the 

following information is supplied to the St. Croix Gaming Commission on or before the 

Tribe or its Enterprises approval of the contract:

(a) Name, address, and contact person of vendor;

(b) Approximate monthly revenue paid to vendor;

(c) Product or service supplied by vendor; and

(d) Copy of any proposed contract and thereafter, copies of any subsequent draft or 

update of the contract.

6 S.C.T.C. § 02.11(5) Duties Regarding Vendor Contracts

Upon receipt of the Vendor contract information, the St. Croix Gaming Commission 

shall:

(a) Determine the appropriate license status;

(b) Forward required Application packet to the Vendor (Application packet may be 

faxed to Vendor); 
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(c) Upon receipt of completed Application and required fees, the St. Croix Gaming 

Commission will review the returned license application for a period of not more 

than 15 working days; and

1. An incomplete application is reason to "deny" licensing, as is failure to 

comply with any requests from the St. Croix Gaming Commission for 

additional information which will extend the 15-day review period.

(d) In addition to the information submitted on the vendor license application, the St. 

Croix Gaming Commission will also review the prior activities, criminal record, 

reputation, habits, and associations of the vendor and/or the company and/or its 

employees to determine if any person or prior activity could pose a threat to 

Tribal or public interest, or to effective regulation and control of gaming, or create 

or enhance the dangers of unsuitable, unfair, or illegal practices, methods or 

activities in the operation of gaming, or the carrying on of business and financial 

arrangements incidental thereto.

6 S.C.T.C. § 02.11(6) Approval of Vendor Contracts

Upon St. Croix Gaming Commission approval, a Tribal Vendor License will be issued to 

the approved vendor. The License will be valid for one year from the time it is issued and 

license fees will be based on the dollar amount of business conducted annually. 

(a) Renewal Applications. Renewal applications will be provided prior to the 

expiration date of the license. Upon receipt of the license fee and review of the 

renewal application, the St. Croix Gaming Commission will send a new license 

certificate to the vendor. 

6 S.C.T.C. § 02.11(7) Disclosure of Relationship

Included with the application will be a "Disclosure of Relationship" form which must be 

signed indicating that no current employee, Tribal Council member, and/or member of St. 

Croix Gaming Commission is receiving any direct or indirect payment or gratuity from 

the business and/or its representative. It is further understood that no gift, payment or 

gratuity in any form, may be given by the business to anyone employed by the Tribe. 

(a) Exempt Gifts. Exempt are any gifts given under traditional Ojibwe practices. And 

any purchasing discounts, special promotions, rebates, etc., that may be returned 

to the St. Croix Chippewa Indians of Wisconsin.

6 S.C.T.C. § 02.11(8) Vendor Responsibility

The Vendor is responsible to respond within seven (7) working days upon receipt of a 

tribal letter of inquiry from the St. Croix Gaming Commission as to its association, the 

relationship, and the agreement of a person or firm which may or may not be associated 

with the business. Such agreement or arrangement will cause denial of license and void 

any purchase agreements or leases. The applicant will, by written and/or oral request, 

allow the St. Croix Gaming Commission to inspect all documents that may indicate that 
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such activity may have occurred. Failure to comply will result in license termination, and 

loss of product or service agreements. 

(a) The Vendor may request an extension of the seven (7) working days from the St. 

Croix Gaming Commission if they require additional time. The St. Croix Gaming 

Commission has discretion as to whether they approve an extension or not. 

6 S.C.T.C. § 02.11(9) Granted Vendor Licenses 

Persons, businesses, corporations, and/or partnerships that have been granted a "Vendor 

License" by the St. Gaming Commission will be allowed to do business with the various 

businesses owned and operated by the Tribe. A vendor must have a current Tribal Vendor 

License to continue to conduct business with the Tribe. Likewise, no purchase order will 

be accepted and/or paid without total compliance of a license being issued.

(a) List of Vendors. The list of approved vendors will then be used by the Tribe and 

its agents as a source for various products/services, and for bidding on various 

projects within all Tribal Enterprises. 

6 S.C.T.C. § 02.11(10) Disposition of Vendor Licensing Fees

All fees will be received, by the St. Croix Gaming Commission to be recorded and for 

endorsement and deposit in the Tribe’s designated Vendor Account.

6 S.C.T.C. § 02.11(11) Vendor Document Storage

All vendor information will be kept in a data base to enable a complete print out of all 

vendors utilized. In addition, a hard copy file will be kept containing Vendor application, 

copy of fee check, contract information, and determination made. 

6 S.C.T.C. § 02.11(12) Vendor Fee Exemption

The Tribe recognizes that due to the nature of certain businesses, exemptions to licensing 

have been established. These include, but are not limited to: 

(a) Any person or group of persons engaged in the ministry of healing by purely 

spiritual means or other religious activity;

(b) A vendor engaged to perform at or to sell authentic traditional Native American 

crafts at tribally sponsored Pow-wow's or events. However, this does not prevent 

the committee or group from obtaining basic information, documentation for tax 

purposes, or from charging lot space fees;

(c) Any business that is 51 % or more owned by the St. Croix Chippewa Indians of 

Wisconsin;

(d) All youth activity events sponsored by the St. Croix Chippewa Indians of 

Wisconsin are exempt;
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(e) Any person engaged in the production of the traditional Ojibwe crafts whose 

gross sales are less than Ten Thousand Dollars ($10,000.00) per calendar year;

(f) Any person engaged in the harvesting or processing of "wild rice" in traditional 

Ojibwe manner;

(g) Any person engaged in the harvesting and processing of maple syrup in traditional 

Ojibwe manner; 

(h) Any person that engages in a business or activity from their place of residence 

upon property held in trust for the St. Croix Chippewa Indians of Wisconsin, 

which is less than Ten Thousand Dollars ($10,000.00) per calendar year;

(i) Any Tribal or government agency;

(j) Insurance and all utility companies;

(k) Any person or company engaged in training or education; and

(l) Those vendors who at the determination of the Tribe shall be exempt. 

ARTICLE XII – GENERAL PROVISIONS GOVERNING 

OPERATION

6 S.C.T.C. § 02.12(1) Maintenance of Records

The St. Croix Gaming Commission shall ensure that all accounting records of each 

tribally licensed gaming facility is kept on a double entry system of accounting, 

maintaining detailed, supporting, subsidiary records. The St. Croix Gaming Commission 

shall also ensure that both the operator and the St. Croix Gaming Commission maintain 

the following records for not less than seven (7) years: 

(a) Revenues. Expenses, assets, liabilities and equity by game at each location where 

any component of Class III gaming, including ticket sales, is conducted;

(b) Cash Transactions. Daily cash transactions for each game at each location at 

which any component of Class III gaming is conducted, including but not limited 

to transactions relating to each gaming table bank, game drop box and gaming 

room bank;

(c) Analytic Reports. For electronic games of chance, analytic reports that, by each 

machine, compare actual hold percentages to theoretical hold percentages;
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(d) Documents. Contracts, correspondence and other transaction documents relating 

to all vendors and contractors;

(e) Enforcement Activities. Records of all tribal enforcement activities relating to 

gaming operated under the Tribal-State Compact and other tribal laws;

(f) Audits. All audits prepared by or on behalf of the Tribe;

(g) Personal Information. Personnel information on all Class III gaming employees or 

agents, including complete sets of each employee's fingerprints, employee 

photographs, and employee profiles and background investigations, except that 

employee work schedules shall be maintained for a period of at least two (2) 

years. This provision shall not include personnel records of tribal members as to 

matters that are not related to gaming;

(h) Background Investigations. Records of background investigations and 

determinations for licensing; and 

(i) The St. Croix Gaming Commission shall also be responsible for all the above 

information pertaining to Class II Gaming owned or operated by the Tribe.

6 S.C.T.C. § 02.12(2) Management Contracts

Each management contract shall fully comply with applicable federal regulations and is 

subject to the prior approval of the NIGC. 

(a) Before Submission. Before submission to the NIGC, each management contract 

shall be approved by the Tribal Council with the advice and comment of the St. 

Croix Gaming Commission. Before considering any proposed management 

contract, the Tribal Council shall direct the St. Croix Gaming Commission to 

conduct a complete background investigation of persons and entities with a 

financial interest in, or having management responsibility for, the management 

contract including requiring the submission of all information required under 25 

CFR Section 537.1, as amended, incorporated herein by this reference.

(b) Background Investigation. Background information on the proposed management 

contractor will be collected including: its name; address; the names and addresses 

of each persons or entity having a direct financial interest or management 

responsibility for the proposed management contractor; and in case of a 

corporation, the names and addresses of each member of its board of directors and 

all stockholders who hold directly or indirectly ten (10%) percent or more of its 

issued or outstanding stock.

(c) Other Gaming Contracts. A description of any previous experience that each 

person listed in subsection above has had with other gaming contracts with Indian 

tribes or with any gaming activity or operation wherever, located, including the 

name and address of any tribal government or licensing agency with which such 
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person has applied, or held a contract, license, or other agreement or permit 

relating to gaming, whether granted or not should also be maintained. 

(d) Financial Statements. A complete financial statement of each person listed in 

subsection (b) for the past three (3) years.

(e) Verification. The St. Croix Gaming Commission shall obtain an independent 

verification of the completed financial statements of the proposed management 

contractor.

(f) Performance History. The St. Croix Gaming Commission shall contact each of the 

tribal governments and licensing agencies in subsection (c) above to determine 

the performance history of the proposed management contractor.

(g) Criminal Records. The St. Croix Gaming Commission shall arrange to have each 

proposed management contractor investigated to learn of his or her personal 

attributes and to determine whether he or she has a prior criminal record or any 

pending criminal charges.

(h) Additional Steps. The St. Croix Gaming Commission shall undertake any 

additional steps it can to determine the character and reputation of the proposed 

management contractor and each person listed in subsection (b) above.

6 S.C.T.C. § 02.12(3) Tribal Council Approval of Management Contracts

If the Tribal Council, after reviewing the information described above, still desires to 

enter into a management contract with the proposed management contractor, such 

management contract shall be made in writing and submitted to the Tribe's attorney for 

review.

(a) Approval. Any management contract approved by the Tribal Council must 

include at a minimum, with respect to the gaming activity to which the contract is 

applicable, all of the required provisions contained in 25 CFR Section 531.1, as 

amended, incorporated herein by this reference.

(b) Gaming License Requirement. All persons who possess an ownership or 

management position in the proposed management contract shall apply for an 

employee gaming license under this Ordinance. No management contract shall be 

approved by the Tribal Council until all employee gaming license applications 

have been reviewed and the St. Croix Gaming Commission has submitted written 

findings on such application(s) to the Tribal Council.

(c) NIGC Submission. If the Tribal Council is satisfied with the information it 

receives it shall submit the proposed contract along with all of the above 

described information to the Chairman of the NIGC for approval.
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6 S.C.T.C. § 02.12(4) Liability Insurance

Each tribally owned or tribally operated gaming facility shall carry sufficient liability 

insurance to protect the public in the event of an accident, and in any event, such 

coverage must meet the level required by the Tribal-State Compact.

6 S.C.T.C. § 02.12(5) Conflicts of Interest

No person employed by the gaming enterprise may have a direct or indirect interest in 

any gaming-related contract with the Tribe, nor may they be employed by any person 

who has a gaming-related contract with the Tribe.

(a) Definition. A direct or indirect interest is one in which the employee has an 

economic interest or receives personal gain from the transaction in question.

(b) Exception. An employee of the gaming enterprise may have an interest in a 

nongaming related contract with the Tribe or with the gaming enterprise if such 

employee makes a full disclosure to the St. Croix Gaming Commission prior to 

such contract and the St. Croix Gaming Commission finds that the contract is not 

unfair to the gaming enterprise and is satisfied that the contract is non-gaming 

related. This clause seeks to avoid the appearance of a conflict of interest while 

not altering the original conflict of interest prohibition contained in the TribalState Compact.

6 S.C.T.C. § 02.12(6) Age Restriction for Game Play

No person under twenty-one (21) years of age may play, or be permitted by the Tribe to 

play, any game authorized by the Tribal-State Compact. If any person below the age of 

twenty-one (21) plays and otherwise qualifies for a prize or winnings, the prize or 

winnings shall not be paid, and the estimated amount wagered during the course of the 

game shall be returned to the minor. No person under the age of twenty-one (21) shall be 

permitted access to any portion of any facility in which any Class III game is conducted, 

except for purposes of employment pursuant to Section V.B of the Tribal-State Compact, 

or to gain access to the Tribe's non-gaming facilities. 

6 S.C.T.C. § 02.12(7) Age Restriction for Employment 

No person under eighteen (18) years of age may be employed in the conduct of gaming 

under the Tribal-State Compact.

6 S.C.T.C. § 02.12(8) Intoxicated Individuals

No person who is visibly intoxicated shall be permitted to play any game authorized by 

the Tribal-State Compact.

6 S.C.T.C. § 02.12(9) Restriction of Extended Credit for Gaming

All gaming shall be conducted on a cash basis. Except as herein provided, no person shall 

be extended credit for gaming by any tribal gaming facility, nor shall the Tribe permit 
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any other person to offer such credit for a fee. This section shall not restrict the right of 

the Tribe to install or accept bank card or credit card transactions in the same manner as 

would normally be permitted at any retail business within the State of Wisconsin.

6 S.C.T.C. § 02.12(10) Impartial Resolution of Player Dispute

The Tribe shall provide and publish procedures of impartial resolution of a player dispute 

concerning the conduct of a game which shall be made available to customers upon 

request.

6 S.C.T.C. § 02.12(11) Alcoholic Beverages

Alcohol beverages may be served at locations where games authorized under the TribalState Compact are conducted only during the hours prescribed in sec. 125.32 (3), Wis. 

Stats. Alcohol beverages may not be sold for the purpose of off-premises consumption at 

locations where games authorized under the Tribal-State Compact are conducted.

6 S.C.T.C. § 02.12(12) Employee Gambling

The St. Croix Gaming Commission with Tribal Council approval, shall develop and 

regulate all Employee Gambling Policies & Procedures to ensure protection of Tribal 

revenue and the integrity of the Gaming Enterprise.

6 S.C.T.C. § 02.12(13) Patron Dispute Resolution

Any dispute which cannot be immediately resolved to the patron's satisfaction by the first 

employee contacted by the patron regarding the dispute is referred to the shift manager. It 

is the first employee's obligation to notify the shift manager (or to cause another 

employee to notify the shift manager) that a patron has a dispute. The shift manager 

should then conduct themselves as follows: 

(a) The shift manager should attempt to resolve the dispute; 

(b) If the patron is not satisfied, the patron should be given a preprinted card with the 

name, address, phone number, and fax number of the St. Croix Gaming 

Commission. The patron should be instructed to contact the St. Croix Gaming 

Commission for final resolution of the dispute; and

(c) Once the St. Croix Gaming Commission receives the patron's complaint, they 

should decide the appropriate response. The decision of the St. Croix Gaming 

Commission is final.