12/6/18
Very Broad Standard l Allowing Investigation into Virtually Every Aspect of an Applicant’s Life l Little Statutory or Regulatory Guidance l Little Judicial Precedent l Broad Discretion Delegated to Licensing Officials l Severe Consequences to the Individual in Event of Negative Determination with Regard to Suitability
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l Key Question: What Purpose is Served? l Licensure is an important tool for safeguarding a tribal gaming operation from: l Criminal Infiltration l Employment of Persons with Propensity for Dishonesty,, Theft , Violence l Unwillingness to Comply with Procedures, Rules, Policies, and Standards l Unfair Dealings l Corrupt Practices l Threats to Public Safety l Findings of Non-compliance
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