The Nottawaseppi Huron Band of the Potawatomi Tribal Council
hereby establishes the Nottawaseppi Huron Band of the Potawatomi Gaming
Regulatory Agency (hereinafter the "Gaming Agency" or "Agency") as
an independent governmental subdivision of the Tribe.
As a political subdivision of the Tribe, the Agency is endowed
with all the rights, privileges and immunities of the Tribe, including
but not limited to the sovereign immunity of the Tribe from suit absent
express consent from Tribal Council. The Executive Director and individual
employees of the Commission are officers of the tribal government
and shall be immune from suit when acting in their official capacity
to the fullest extent permitted by law.
Subject only to the general oversight authority of the Gaming
Commission, or as otherwise expressly provided herein, the Tribal
Council delegates to the Gaming Agency sole authority and responsibility
to regulate all gaming conducted within the Tribe's Reservation,
as provided by this chapter, which authority includes without limitation
the authority to regulate gaming operations, gaming establishments
and management contractors, and to license vendors of goods or services,
labor organizations, primary management officials, key employees and
all other persons subject to the Commission's licensing authority
pursuant to this chapter. The Agency shall ensure that all gaming
conducted within the Tribe's Reservation is conducted in conformance
with this chapter, the regulations, the Compact, the IGRA, regulations
promulgated by the NIGC, and other applicable tribal, state and federal
laws.
In all matters within the scope of its delegated regulatory
authority, the Agency shall be and shall act independently and autonomously
from the Tribal Council. No prior or subsequent review by the Tribal
Council of any actions of the Agency taken within the scope of its
regulatory authority shall be required or permitted, except as may
be otherwise explicitly provided in this chapter. No prior review
by the Gaming Commission of any actions of the Agency which are taken
within the scope of its regulatory authority and in accordance with
approved regulations shall be required or permitted, except as may
be explicitly provided in this chapter. Notwithstanding the foregoing,
the Agency shall be subject to all tribal law, including generally
applicable tribal administrative policies and procedures, except to
the extent that an exception for the Agency is expressly provided
in such policies. The Agency's fiscal year shall be the fiscal
year of the Tribe.
Agency funding shall be in an amount sufficient for the Agency
to properly fulfill all of its regulatory responsibilities under this
chapter. The Tribal Council shall not reduce the Agency's annual
budget during any fiscal year but may approve requests by the Agency
to supplement the budget when necessary. The amount of the Agency's
funding shall be established annually for the subsequent fiscal year
through a detailed annual budget to be prepared by the Agency's
Executive Director for Tribal Council approval in its annual budgeting
process. The Agency budget shall take into account any unexpended
funds that may, with approval of the Tribal Council, be retained and
carried over by the Agency at the end of each fiscal year to the next
fiscal year, excluding funds that are obligated for costs or expenses
incurred during the prior fiscal year.
The Agency shall be organized under the Executive Director into
the following departments, which shall be under the management and
supervision of the Executive Director:
A. Administration shall perform the administrative functions of the
Agency, to include:
(1) Maintaining office records.
(2) Coordinating all administrative functions from the Agency to other
regulatory agencies, law enforcement and intelligence agencies while
maintaining strong communications with the gaming operation.
B. Licensing. The Licensing Department shall perform all of the following
duties and responsibilities:
(1) Receiving and processing all license applications.
(2) Conducting background investigations regarding any applicant for
a license and all other suitability investigations on behalf of the
Agency that are required or permitted under this chapter.
(3) Such other matters as the Executive Director may assign to the Department.
C. Auditing and compliance. The Department shall perform the following
duties and responsibilities:
(1) Conducts audits to verify each gaming establishment's compliance
with all audit and financial oversight requirements regarding operational
and gaming revenues;
(2) Serve as the internal audit personnel for purposes of compliance
with 25 CFR § 542.42 by performing the audits of all major
gaming areas of each gaming establishment not less than annually as
required by NIGC regulations;
(3) Monitoring through audit activities each gaming establishment's
compliance with this chapter, the regulations, tribal minimum internal
controls, IGRA, the Compact, and other laws governing gaming activities
and gaming assets applicable to the gaming establishment;
(4) Recommending the initiation of compliance or enforcement actions
resulting from a licensee's failure to comply with the chapter,
the regulations, including the tribal minimum internal controls, the
IGRA and the Compact; and
(5) Such other matters as the Executive Director may assign to the Department.
D. Investigations. The Department shall perform the following duties
and responsibilities:
(1) Ensuring all incidents within the scope of the Agency's delegated
regulatory authority are properly investigated.
(2) Responsible for collecting, organizing and presenting various types
of information in an unbiased manner in order to derive a conclusion
in regards to an event or a series of events.
(3) Monitors the property, identifying potential security and/or safety
hazards and reporting appropriately to ensure the safety and protection
of guests, employees, gaming revenues, assets and the entire facility.
(4) Coordinates with the Agency's Auditing and Compliance Departments
to investigate potential violations of the chapter, regulations, including
tribal minimum internal controls, the Compact and other laws within
the Agency's jurisdiction which may be identified through audit
activities.
(5) Coordinates with the gaming establishment's surveillance and
security department on security-related matters.
(6) Monitors the functionality of technical slot machine components for
certification by the Agency; such as EPROMS, flash drives, and other
software configurations.
(7) Such other matters as the Executive Director may assign to the Department.
E. Information technologies. The Department shall perform the following
duties and responsibilities:
(1) Manages the day-to-day operation of all Commission and Agency computer
systems, network and interfaces with all casino departments, regarding
current information technology.
(2) Assist the Investigations Department, as needed, with monitoring
the functionality of technical slot machine components for certification
by the Agency; such as EPROMS, flash drives, and other software configurations.
(3) Monitors the functionality, security and integrity of all computer
systems, network and interfaces, associated with any internet wagering
systems operated by, or on behalf of, the gaming establishment.
(4) Conducts information technologies audits for the Agency of the gaming
establishment's compliance with information technology internal
controls and reviews the results of internal and external information
technology audits performed by the gaming establishment's Information
Technology Department.
(5) Such other matters as the Executive Director may assign to the Department.
The Executive Director shall have the authority and the duty
to carry out on behalf of the Agency the administrative and executive
requirements of the Agency under this chapter, the regulations, and
the IGRA, including, without limitation:
A. Agency administration. The Executive Director shall provide administrative
direction and support to the Agency, including managing and supervising
all Agency staff, consultants and contractors, records management,
and the development and oversight of the budget.
B. Agency staff. The Executive Director shall be responsible for personnel
matters, including the recruitment, hiring, supervision and discipline
of Agency staff, whose positions shall be established by written position
descriptions, subject to all applicable hiring and employment laws
and policies of the Tribe.
C. Contracting. The Executive Director may negotiate and enter into
contracts for the acquisition of goods and services required by the
Agency and may otherwise expend funds as needed for the operation
of the Agency, subject to such requirements as the Agency may establish,
provided that the Executive Director shall ensure that all such contracts
and expenditures are within the Agency's approved budget, and
any contracts which require the Agency or Tribe to waive its sovereign
immunity from suit or consent to the jurisdiction of any court or
dispute resolution process shall require approval by the Tribal Council
unless such authority is expressly delegated to the Executive Director
by Tribal Council resolution or statute.
D. Administration of agency operations. The Executive Director shall
be responsible for overseeing the day-to-day operations of the Agency,
including maintaining oversight of the Administration, Licensing,
Investigation, Information Technologies, Auditing/Compliance Departments,
and such other departments, sections or offices of the Agency. In
overseeing the Agency, the Executive Director shall ensure that the
following activities are performed effectively and in accordance with
applicable law and applicable government policies and procedures:
(1) Investigations of any matter within the scope of authority of the
Agency, including, without limitation, background investigations necessary
to determine the suitability of any applicant for license, are conducted
efficiently and professionally.
(2) Issue and assist, as necessary, the Commission with the issuance
of subpoenas, prepare evidence, and cooperate with the Agency's
legal counsel in presenting to the Commission, cases in all appeals
of or challenges to the Agency's or the Commission's decisions
asserted in accordance with the standards and procedures provided
in this chapter and the regulations.
(3) Monitor all gaming operations and gaming establishments at random
or periodic intervals with or without prior notification to the gaming
operation to determine compliance with this chapter, the regulations,
IGRA, the Compact and other applicable law and, upon receiving any
credible report of a violation thereof, conduct a timely investigation
with regard to such report.
(4) Address and, as needed, investigate all disputes between gaming patrons
and gaming operations pursuant to the standards and procedures set
forth in this chapter and the regulations.
(5) Maintain and enforce compliance with a list of persons prohibited,
or who have self-excluded themselves, from participating in gaming
conducted at or with the gaming establishment and other persons who
are subject to temporary or permanent bans prohibiting such persons
entering the gaming establishment.
(6) Assist in enforcing Agency or Commission orders and decisions and,
in coordination with appropriate law enforcement agencies, investigate
and pursue prosecution of criminal violations of gaming laws and in
pursuing criminal and civil enforcement of other applicable tribal,
state and federal laws.
E. Licensing. The Executive Director may grant temporary licenses as
authorized under this chapter and may grant any other licenses on
behalf of the Agency as expressly provided by the regulations.
F. Records management. The Executive Director shall develop and maintain
a suitable records management and retention system and shall ensure
that all confidential and sensitive records and information are maintained
and protected from unauthorized release.
G. Evaluate the gaming regulatory system. Evaluate the effectiveness
of the Tribe's gaming regulatory system and recommend any changes
that may be necessary or desirable.
H. Other duties. Perform such other duties as the Executive Director
deems necessary as are within the scope of authority delegated to
the Agency under this chapter.