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Tribal State Compact Requirements
Section 6.1: Gaming Ordinance and Regulations (a) All Gaming Activities conducted under this Compact shall, at a minimum, comply (i) with a Gaming Ordinance duly adopted by the Tribe and approved in accordance with IGRA, (ii) with all rules, regulations, procedures, specifications, and standards duly adopted by the NIGC, the Tribal Gaming Agency, and the State Gaming Agency, and (iii) with the provisions of this Compact. (b) The Tribal Gaming Agency shall transmit a copy of the Gaming Ordinance, and all of its rules, regulations, procedures, specifications, ordinances, or standards applicable to the Gaming Activities and Gaming Operation, to the State Gaming Agency within twenty (20) days following execution of this Compact, or within twenty (20) days following their adoption or amendment.
Compliance Hierarchy Gaming operations must comply with multiple regulatory layers: tribal ordinances, NIGC regulations, State Gaming Agency rules, and compact provisions.
Documentation Requirements Tribal Gaming Agencies must provide
Coordinated Oversight Successful compact compliance requires seamless coordination between tribal, federal, and state regulatory authorities.
comprehensive documentation to State Gaming Agencies within strict 20-day timeframes for all regulatory materials.
Tribal State Compacts represent negotiated agreements between tribal governments and state governments, establishing the framework for Class III gaming operations. These compacts define regulatory responsibilities, revenue sharing arrangements, and compliance standards that gaming operations must meet. Understanding compact requirements is essential for maintaining operational compliance and regulatory good standing.
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NIGC Final Rule on Key Employees and PMOs In April 2023, the National Indian Gaming Commission issued a comprehensive final rule refining critical definitions and processes related to key employees and primary management officials (PMOs). This updated rule modernizes licensing requirements, clarifies regulatory responsibilities, and provides tribes with greater flexibility in designating positions requiring enhanced scrutiny. Major Updates in the 2023 Final Rule 1. Expanded Designation Authority: Tribes may now designate additional employees or managers, including TGRA staff members, as key employees or primary management officials based on their roles and responsibilities 2. Revised Key Employee Definition: The wage threshold has been removed from the key employee definition. The rule now includes the four highest-paid gaming operation staff members, ensuring positions of significant influence are properly scrutinized 3. TGRA Definition Modernization: Terms "independent" and "governmental" were removed from the Tribal Gaming Regulatory Authority definition to better align with NIGC Part 547 technical standards 4. Streamlined License Revocation: License revocation procedures now only require notifying the Commission and providing the revocation decision, reducing administrative burden while maintaining oversight 5. Modernized Record Retention: The rule updates background investigation and licensing record retention requirements to reflect contemporary best practices and technological capabilities 6. Clarified Hearing Rights: License revocation hearing rights have been further clarified to ensure due process protections for affected individuals
Access the Rule Review the complete final rule text and supporting documentation: Federal Register Notice
These updates represent significant improvements to the tribal gaming regulatory framework, providing greater clarity for tribes while maintaining robust oversight standards. Tribal gaming operations and regulatory authorities should carefully review the final rule to ensure full compliance with updated requirements and to take advantage of enhanced flexibility in employee designation processes.
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