August 1, 1997
SMOKE SIGNALS
5
to be an unsuitable method of operation and subject to a disciplin
ary response by the Commission.
Based on the criteria reflected below, the Commission's disci
plinary response shall be as follows:
(a) LelteiLDlNQJtCoinpJiancfi.
(1) The director shall issue a Letter of Non-Compliance in re
sponse to an incident Or activity by a licensee which is incon
sistent with the gaming regulations or minimum internal con
trol standards; however, such incident or activity is deemed by
the director to be an isolated occurrence and generally of a pro
cedural nature.
(2) Likewise, such incident or activity shall not be a signifi
cant breach of the TribeState Compact or federal or state laws
or regulations.
(3) The objective of a Letter of Non-Compliance is to notify
the gaming facility that an incident or activity has occurred
which is inconsistent with the gaming regulations or minimum
internal control standards; however, a response from the lic
ensee is not warranted.
(4) The director will forward a copy of the Letter of Non-Compliance
to the gaming facility's chief executive officer and each
Commission member.
(5) Each commissioner reserves the right to place an item on
the Commission's Executive or General Session Agenda and
to call forward any licensee to review the facts justifying a Let
ter of Non-Compliance.
(b) Regulation Violation Letter.
(1) The director shall issue a Regulation Violation Letter in
response to an incident or activity of a licensee which is incon
sistent with the gaming regulations or minimum internal con
trol standards and such incident or activity is deemed by the
director to jeopardize or have the potential of jeopardizing the
integrity of gaming, security of tribal assets, or reputation of
the Tribe or its gaming facility.
(2) Likewise, such incident or activity may be a significant
breach of the TribeState Compact or federal or state laws or
regulations.
(3) The objective of a Regulation Violation Letter is to notify
the gaming facility that an incident or activity has occurred
which is inconsistent with the gaming regulations or minimum
internal control standards and to require that the licensee re
spond within ten (10) working days advising the remedial ac
tion to be undertaken to ensure the violation does not recur.
(4) The director will forward a copy of the Regulation Viola
tion Letter to the gaming facility's chairman of the Board of
Directors, chief executive officer and each Commission mem
ber. (5) In any event in which an individual or contractor possess
ing a gaming license is issued three Regulation Violation Let
ters relevant to the same regulation or minimum internal con
trol standard within the same calendar quarter, the director will
place an item oh the Commission's next regularly scheduled
Executive Session Agenda to review that individual's compli
ance with the gaming regulations and minimum internal con
trol standards.
(6) Each commissioner reserves the right to place an item on
the Commission's Executive or General Session Agenda and
to call forward any licensee to review the facts justifying a Regu
lation Violation Letter.
(c) Disciplinary Action.
(1) The director shall initiate a Disciplinary Action in accor
dance with Regulation 7 in response to an incident or activity
of a licensee which is inconsistent with the gaming regulations
or minimum internal control standards and such incident or
activity is deemed by the director to be a pervasive disregard
for a regulation or standard or is a single act or incident which
materially breaches the regulations or standards. To warrant a
disciplinary action, such incident(s) or activities will jeopar
dize the integrity of gaming, security of tribal assets or reputa
tion of the Tribe or its gaming facility.
(2) Likewise, such incident(s) or activity will generally be a
significant breach of the TribeState Compact or federal or state
laws or regulations.
(3) The objective of a Disciplinary Action is to bring about
compliance with the gaming regulations or minimum internal
control standards through a disciplinary response by the Com
mission. Such response may include, but is not limited to,
monetary penalties, gaming license suspensions and revoca
tions, imposition of remedial actions or any other response af
forded the Commission by the Tribal Gaming Ordinance.
(4) This regulation shall not inhibit or preclude the director
from entering into a disciplinary settlement agreement in lieu
of pursuing a disciplinary action in accordance with Regula
tion 7; however, such settlement agreements must be negoti
ated in an expeditious manner and must be approved by the
commissioners who shall have the right to approve or deny the
agreement in whole or in part. Should the commissioners choose
not to approve the agreement, they may refer it back to the
director to continue negotiations or instruct the director to pre
pare and go forward with a disciplinary action in accordance
with Regulation 7.
(5) The director will forward a copy of the approved disciplin
ary settlement agreement or Commission decision arising from
a disciplinary action to the gaming facility's chairman of the
board of directors and chief executive officer.
NOTE: DUE TO THE LENGTH OF THE FOLLOWING
REGULATIONS, WE ARE NOT ABLE TO PRINT THEM
IN THEIR ENTIRETY. A COMPLETE COPY MAY BE
OBTAINED BY CONTACTING THE GAMING COMMIS
SION AT (503) 879-2362.
REGULATION!! - PAI GOW POKER
17.010 Authority and Applicability.
17.020 Definitions.
17.025 Pai Gow Poker game drop box procedures.
17.030 Cards; number of decks.
17.035 Pai Gow Poker rankings; cards; poker hands.
17.040 Wagers
17.040 Irregularities; invalid roll of the dice.
1 7.050 A player wagering on more than one betting area.
17.055 Dealing training requirements.
17.060 Maximum table bet limits.
17.065 Posting of rules.
REGULATLQN18 - LET IT RIDE POKER
18.010 Authority and applicability.
18.020 Definitions.
18.025 Let It Ride Poker game drop box procedures.
18.030 Cards; number of decks.
18.035 Let It Ride Poker rankings.
18.040 Wagers
18.045 Payout odds.
18.050 Irregularities.
18.055 Dealing training requirements.
18.060 Maximum table bet limits.
18.065 Posting of rules.
REGULATION 20 - ROULETTE
20.010 Authority and applicability.
20.020 Roulette game drop box procedures.
20.025 Roulette: placement of wagers; permissible and optional
wagers.
20.030 Roulette: payout odds.
20.035 Roulette: rotation of wheel and ball.
20.040 Roulette: Irregularities.
20.045 Dealing training requirements.
20.050 Posting of rules.
MINIMUM INTERNAL CONTROLSTANDARJDS -POKER
GAME
Opening of the table for gaming
Shuffle and cut of the cards
Dice Cup and dice; computerized random number generator
Procedures for dealing the cards from the hand
Dealing the cards from an automated dealing shoe
Determining the starting position for dealing cards or deliver
ing stacks of cards.
Completion of each round of play; setting of hands; payment
and collection of wagers; payout odds; vigorish.
Player bank; selection of bank; procedures for dealing
IT RIDE
Opening of the table for gaming
Shuffle and cut of the cards
Procedures for dealing the cards from the hand
Procedures for dealing the cards from an automated dealing
shoe
Procedures for completion of each round of play
MINIMUM INTERNAL CONTROL STANDARDS
ELECTRONIC GAMING DEVICES
Jackpot payouts, fills and short pays.
Commission denied petition to modify noted Minimum
Internal Control Standard.
MINIMUM INTERNAL CONTROLJSTAJNDARDS -GAMING
INTEGRITY
Dice; receipt; storage; inspections and removal from use,
Commission referred petition back to staff for further
consideration.
MARCH 21, 1997
5.013 Gaming by persons licensed by the Commission.
Referred back to staff with instructions to the Director not to
petition the Commission to consider allowing employees to
gaming at poker or any other table game prior to January 1998.
11.010 Officials not to hold gaming licenses or related
approvals.
Prohibits the granting of a gaming license, finding of
suitability, or approval, which requires an application to be made
to the Commission, to any person holding office in, or employed
by, any agency, department, or division of Tribal government or
any of its political subdivisions when the duties of such office or
agency pertain to the enforcement of the provisions of the Gaming
Regulations.
This Regulation applies specifically, but without limitation, to
persons affiliated with county sheriffs offices, Tribal police
department or local police department in which jurisdiction
includes any Tribal gaming establishment; except for unpaid
volunteers and reserve officers.
14.085 Tribal gaming inventory dccal.
No person other than the director and authorized state personnel
or their agents may affix or remove a tribal inventory dccal. The
placement of the tribal gaming inventory decal on any equipment
by the director of the Commission or his agents represents that the
terminal has been certified, inspected and approved for operation
in the state and shall constitute documentation that the
certification has been and will be kept on file by the Commission.
No persons other than the director or his agents may affix or
remove the tribal gaming inventory decal.
MIC, Gaming integrity - Electronic gaming devices (b) was
modified to read as follows:
Stationary cameras shall be placed to view all progressive
electronic games capable of being in excess of $10,000.00. This
video footage will be taped on a 24 hour basis to a dedicated
recording device. Any progressive electronic game that does not
have a stationary camera on the game and goes in excess of
$10,000.00 will be monitored on a 24-hour basis with a PTZ.
Roulette Game, Pai Gow Poker game and Let It Ride Game.
Application for approval of new games in accordance with
REG. 5.090.
Commission approved Roulette, Pai Gow Poker and Let It Ride
as authorized games, subject to the following conditions:
1. Upon opening of the new games, the Commission will
perform a final inspection of the Surveillance System to ensure
adequate coverage.
2. For the first thirty (30) days after commencement of the new
game, the Table Gaines and Surveillance Departments will
forward to the Commission a copy of all incident reports relating
to procedural errors, incorrect payouts or any other activity or
event reflecting upon the integrity of the games.
3. Prior to opening the new games, management will ensure
that all dealers and supervisory personnel employed in the new
games have a copy of REG.'s 5, 7A, 12, 17, 18, 20 and the
Minimum Internal Control Standards governing the specific
games.
SUMMATION;.
As the Commission's fourth quarter report predicted, the first
quarter of 1997 was a sizzling blur of activity. As staff attempted
to gain training in the new games and also conduct a compliance
audit, the audit time line was stretched from five to six weeks to
eight weeks. Complicating the workload of the Commissioners
and staff was Mikohn Gaming, supplier of the casino's centralized
accounting system. The continuing effort to bring the gaming
regulations and minimum internal control standards into
compliance with the Compact is likely to also impact the
Commission's work-flows through the second quarter. We
expect a request from casino management during the first part of
the second quarter seeking approval of Craps and Big Six as
authorized games and that will require considerable analysis by
staff and consideration by commissioners. We expect the second
quarter of 1997 to be as equally demanding as the first.