Purpose of the Gaming Commission
The Gaming Commission’s role is defined by the Nottawaseppi Huron Band of the Potawatomi’s Gaming Regulatory Act of 2010 which made gaming lawful within the Tribe’s jurisdiction and delegated the primary regulatory role to the Commission.
The Commission ensures that all gaming within the Tribe’s jurisdiction is conducted in compliance with Tribal and Federal law and the agreement between the Tribe and the State of Michigan. In exercising its regulatory authority the Commission does not interfere with the managerial discretion of gaming operations.
The Commission’s primary mission is to work within the framework created by the Tribe’s Gaming Regulatory Act of 2010, the Federal Government’s Indian Gaming Regulatory Act (IGRA), and the Compact between the Tribe and the State of Michigan. The confluence of the Tribe’s gaming law, the Federal Government’s gaming law and the Tribe-State compact is to:
- Promote Tribal economic development self-sufficiency and strong Tribal governments
- Maintain the integrity of Indian gaming
- Ensure that the Tribe is the primary beneficiary of its gaming activities
The U.S. Supreme Court ruled in 1987 that states had no authority to prosecute gaming conducted on Indian land (California v. Cabazon). State governments reacted with alarm and Congress began consideration of the Indian Gaming Regulatory Act (IGRA). In 1988, IGRA became law after Tribes and states reached a compromise which gave states unprecedented regulatory participation through the negotiation of Tribal-state gaming compacts.
IGRA recognizes the right of Tribes to conduct gaming on Tribal land in states where similar gaming is permitted outside the Reservation for other purposes. IGRA also emphasizes the dire economic need of Tribes, citing gaming as one of the few revenue-producing opportunities that has generated adequate revenues to sustain Tribal governments.
The Indian Gaming Regulatory Act creates three classes of Tribal gaming: Class I Social games played solely for prizes of minimal value or traditional forms of Indian gaming as part of Tribal ceremonies or celebrations;
Class II Bingo and related games, including pull tabs, lotto, punch boards, tip jars, instant bingo and some card games (excluding house-banked card games), and;
Class III All forms of gaming that are not Class I or Class II, including slot machines and house-banked table games, such as blackjack, roulette and dice games. (Only Class III games require Tribal-state compacts.)
NHBP Independent Gaming Regulatory Framework
Tribal Government gaming on the Potawatomi Reservation is governed in accordance with federal laws. In 2000, the band adopted, by resolution, the Tribal Gaming Ordinance and Tribal Gaming Regulations. These are comprehensive controls similar to those enforced in Nevada, which govern the Class II and Class III gaming operations of FireKeepers Casino and Hotel. The mission of the NHBP Gaming Ordinance, Gaming Regulations and Gaming Commission staff is to ensure full compliance with all applicable Tribal, federal and state statutes, as well as the Tribal-state gaming compacts and to protect the integrity of the games for the patrons and the tribe.
The National Indian Gaming Commission (NIGC) is a federal watchdog with extensive regulatory authority over Tribal gaming operations. The NIGC must give final approval to all Tribal gaming ordinances, management contracts and has the power to conduct background investigations and object to any person hired and licensed by a tribal government to work in a casino.
The Administration office is the office of the Commissioners and Executive Director. The office maintains the Gaming Commission staff and records, facilitates and coordinates all administrative functions from the Commission to other regulatory agencies, law enforcement and intelligence agencies while maintaining strong communications with FireKeepers Casino and Hotel operation.
Responsible for accurately and thoroughly managing the Auditing Department and Compliance functions through Tribal, Federal and State regulations the Gaming Commission is required to conduct audits within the casino. This includes all gaming and non-gaming auditing functions. Auditing is responsible for making the determination of the accuracy of all financial documentation generated by casino departments. Maintain statistical information on financial casino reporting. Ensures the casino is in compliance with policies, procedures, internal controls, regulations and applicable laws.
The Regulatory Compliance Department is responsible for completing elements of Daily Title 31 audits. All functions will be performed within the guidelines of the FireKeepers Casino and Hotel policies and procedures as well as Internal Control Standards and objectives.
Compliance is also responsible for compiling, sorting, and reviewing daily casino documents. Maintains compliance files including exception reports and testing results. Prepares internal and external correspondence. Duties, responsibilities, requirements, and expectations pertaining to this job are subject to change as needed. Insures compliance with all casino departments to all regulatory, departmental, company policies & procedures, and internal controls.
Responsible for the successful overall development, installation, operation, and maintenance of all network management information systems for the Gaming Commission; including computers, software, audio and visual equipment. Also, manages the day to day operation of all commission computer & network systems. Plans, implements, and directs all departmental procedures for the Gaming Commission, for the accomplishment of business objectives in regards to Information Technology.
The Investigations Department of the NHBP Gaming Commission has various responsibilities that are not limited to investigating gaming-related theft and fraud. The Investigations Department also investigates crimes that are considered felonies in most non-Tribal jurisdictions. The Investigations Department is responsible for compliance and enforcement of the Tribal Minimum Internal Control Standards, Indian Gaming Regulatory Act, Tribal Gaming Ordinance, Compact between the Nottawaseppi Huron Band of the Potawatomi and the State of Michigan, and the Regulations. Therefore, the range of Investigations duties may overlap with the Commission’s Auditing and Licensing Departments and FireKeepers’ personnel. Another important role of Investigations is to ensure the integrity of the gaming operation by testing and approving all gaming-related equipment such as software for slot machines. Investigations also work with casino personnel to ensure that the casino is operating within the parameters established by the Tribal Minimum Internal Control Standards. Finally, Investigations maintains a list of excluded patrons and resolves gaming-related disputes between patrons and FireKeepers.
The Licensing Department conducts background investigations on all casino employees, gaming vendors, non-gaming vendors, and facilities licensing. Each casino employee must successfully pass a comprehensive background investigation. All Licensing staff perform work of considerable difficulty in analyzing, conducting investigation, inquiries, research, and documentation of detailed and specific information. The Licensing Department’s mission is to adhere to regulations while protecting the interest of the Tribe, casino and the reputation of the gaming commission.
Use this confidential submission system to report potential crimes, potential fraudulent and/or suspicious activities, or to notify the Commission of possible unethical conduct.
What to report
- Unlawful acts such as theft, fraud, embezzlement, solicitation/acceptance of bribes or kickbacks, extortion, possession or sale of illegal substances, and counterfeiting.
- Misrepresentation, falsifying documents, forgery.
- Gaming related cheats or scams.
If you have a gambling problem, you can request the NHBP Gaming Commission to permanently exclude or ban you from the FireKeepers Casino and Hotel. To better assist you with self-excluding, the Commission has provided several options:
1. You may come into the Firekeepers Casino and Hotel, request to meet with a Gaming Commission Investigator who will explain the self-exclusion process and prepare your self-exclusion application.
2. You may obtain a self-exclusion application from the FireKeepers Security podium and follow the steps on page #2 of the application.
3. You may download the self-exclusion application from the NHBP Gaming Commission’s website, print the application, and then follow the steps on page #2 of the application.
The United States regulatory agency responsible for overseeing Indian gaming.
The National Indian Gaming Association (NIGA) is a nonprofit organization of 168 Indian Nations engaged in tribal gaming enterprises.
The purpose of the NTGC/R is to:
Promote cooperative relationships among the commissioners/regulators of Tribal gaming enterprises and other organizations; Promote exchange of thoughts, information and ideas which foster regulatory standards and enforcement that lead to consistent regulatory practices and methods of operations among the NTGC/R members; Promote educational seminars, which include commission/regulatory training, and other related activities; and The NTGC/R may act as a gaming regulatory advisory group to Tribal gaming organizations and others.
The mission of NW3C is to provide a nationwide support system for agencies involved in the prevention, investigation, and prosecution of economic and high-tech crimes and to support and partner with other appropriate entities in addressing homeland security initiatives, as they relate to economic and high-tech crimes.
FireKeepers Casino and Hotel is owned and operated by the Nottawaseppi Huron Band of the Potawatomi Indians.
Why does the Gaming License application require so much information?
The Federal Government includes Indian gaming operations, conducted under or pursuant to the Indian Gaming Regulatory Act (IGRA), in the definition of a financial institution i.e.: banks, credit unions, etc. Financial institutions must conduct thorough background checks for all applicants desiring to work for them; therefore, the NHBP Gaming Commission also must be thorough in determining suitability for licensing someone who wants to work for FireKeepers Casino and Hotel. The information within the application is used in collaboration with the background investigation to make a suitability determination. The following is reviewed and considered, but is not limited to:
d. All information within application
What is NHBPGC going to do with this information?
How is my information protected?
Who will have access to my information?
Why does NHBPGC need financial information?
I have a bad credit score; does that mean I will not be able to work at the FireKeepers Casino & Hotel?
Why does it matter who lives in my household?
Evaluation of close relationships and associations, especially within an applicant’s household, is necessary to determine any potential risks that may include, but are not limited to:
• Conflicts of interest
• Other types of illegal and/or fraudulent activity