Sixth Amendment, Tribal-State Compact for Class III Gaming — Upper Skagit Indian Tribe, State of Washington
Summary
The Sixth Amendment to the Tribal-State Compact for Class III Gaming between the Upper Skagit Indian Tribe and the State of Washington, with Appendix G, Electronic Table Games. The introduction states that electronic table games are currently prohibited on the Tribe's Gaming Operation under Compact Section III, N. The amendment text revises the definition of "Gaming Station" to include Electronic Table Games, adds a definition of "Pit", and adds Appendix G. Appendix G provides that wager limits for ETGs shall not exceed $500 and that the Compact and its appendices become effective upon publication of notice of approval by the Secretary of the Interior in the Federal Register. The final pages of Appendix G cover problem and responsible gaming.
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“Sixth Amendment, Tribal-State Compact for Class III Gaming — Upper Skagit Indian Tribe, State of Washington.”
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SIXTH AMENDMENT TO THE TRIBAL-STATE COMPACT FOR CLASS III
GAMING BETWEEN
THE UPPER SKAGIT INDIAN TRIBE AND THE STATE OF WASHINGTON
INTRODUCTION
The UPPER SKAGIT INDIAN TRIBE (hereafter, "Tribe") and the STATE OF
WASHINGTON (hereafter, "State") executed a Class III Gaming Compact (hereafter
"Compact") P.L. 100-407, codified at 25 U.S.C. Section 2701 et. seq. and 18 U.S.C. Sections
1166-1668; and
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At the request of the Tribe, the Tribe and State entered into negotiations for further
amendments to the Compact for electronic table games which, despite being authorized to
negotiate for tribal operation pursuant to IGRA, are currently prohibited on the Tribe's
Gaming Operation pursuant to Compact Section III, N. Prohibited activities. The parties
have reached an agreement on Compact amendments as set forth in this document. The
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parties believe the conduct of Class III gaming under the terms and conditions set forth
below will benefit the Tribe and the State and protect members of the Tribe and citizens of
the State consistent with the objectives of IGRA.
COMPACT AMENDMENT
1. Compact Section II, K. is amended to read as follows:
K. "Gaming Station" means one conventional, physical Gaming table of the general
size and scope as commonly used in Nevada or Electronic Table Games, subject
D to Appendix G.
2. Compact Section II is amended to add the definition of “Pit” as follows, and the
R prior definition in Appendix A, Section 1 is stricken:
AA. "Pit" means the area enclosed or encircled by an arrangement of Gaming
Stations, other than Electronic Table Games, in which Gaming Facility
personnel administer and supervise the games played at the Gaming Stations
by the patrons located on the outside perimeter of the area.
3. Compact Section III, A, is amended as follows:
19. Sic-Bo; and
20. Tribal Lottery Systems. Notwithstanding anything in this Compact which could be
construed to be the contrary. Tribal Lottery Systems operated in conformity with
Appendix X are hereby authorized; and
21. Electronic Table Games, subject to Appendix G.
4. Compact Section XIV. A, is amended as follows:
Tribal Codes regarding public health, safety, air quality, and environmental standards.
5. Appendix X2 is amended to remove Section 14.5.
6. The Compact is hereby amended to add:
Appendix G-Electronic Table Games, in the form attached hereto, in its entirety.
IN WITNESS WHEREOF, the Upper Skagit Indian Tribe and the State of Washington have
Executed this Sixth Amendment to the Compact.
UPPER SKAGIT INDIAN TRIBE STATE OF WASHINGTON
BY:__________________________
JENNIFER WASHINGTON
Chair
T BY:______________________
BOB FERGUSON
Governor
AF
DR
UPPER SKAGIT INDIAN TRIBE
and the
STATE OF WASHINGTON
CLASS III GAMING COMPACT
APPENDIX G
ELECTRONIC TABLE GAMES
Table of Contents
SECTION 1. INTRODUCTION ............................................................................................................ 1
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SECTION 2. EFFECTIVE DATE ......................................................................................................... 1
SECTION 3. DEFINITIONS ................................................................................................................. 1
SECTION 4. AUTHORIZATION ......................................................................................................... 2
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SECTION 5. NUMBER OF GAMING STATIONS .............................................................................. 3
SECTION 6. OPERATION AND REPORTING REQUIREMENTS................................................... 3
SECTION 7. APPROVAL OF ELECTRONIC TABLE GAME SYSTEMS ....................................... 5
SECTION 8. PROBLEM AND RESPONSIBLE GAMING ................................................................. 6
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SECTION 1. INTRODUCTION
This Appendix G ("Appendix") describes, authorizes, and sets forth provisions applicable to
the operation of Electronic Table Games. It is the intent of the Parties for the Tribe to operate
Electronic Table Games to enhance the Tribe's existing Gaming Operation while maintaining
the integrity and security of the Electronic Table Games. This Appendix contains the
interrelated concessions, limitations, and agreement of the Tribe and State with respect to the
subject matter addressed herein that must be accepted as a whole in order to adopt this
Appendix.
Provisions of the Compact and appendices, as amended (together, the "Compact"), that are
not addressed in this Appendix remain in full force and effect, unless and until they are
subsequently amended pursuant to the process set forth in the Compact. Provisions of the
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Compact that do not conflict with this Appendix shall apply to Electronic Table Games. To
the extent they do not conflict, existing Internal Controls, game rules, and similar
documents in effect as of the date of the publication of the Fifth Amendment remain in full
force and effect, unless and until they are subsequently amended pursuant to the process set
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forth in the Compact.
SECTION 2. EFFECTIVE DATE
The Tribe and State agree that the Compact and its appendices become effective upon
publication of notice of approval by the Secretary of the Interior of the United States in the
Federal Register in accordance with 25 U.S.C. § 2710(d)(3)(B).
SECTION 3. DEFINITIONS
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The following terms apply to this Appendix. All capitalized terms not defined herein, to the
extent they do not conflict, have the same meaning as the definitions as in the Compact.
"Component" means Electronic Table Game Terminals, any dealer interface, the
Electronic Wagering System, hardware, software, and servers that function
D collectively to simulate table game operations and are necessary to operate the
Electronic Table Game System.
"Communal Shoe" means a randomly shuffled and dealt deck or decks of cards,
whether physical or electronic, that removes each card played until the round of play
is completed according to the approved game rules.
"Electronic Table Game" or "ETG" means an electronic version of a Class III table
game.
"Electronic Table Game System" or "ETG System" means a system that utilizes
electronics in connection with the generation, collection, storage, and communication
Upper Skagit Indian Tribe pg. 2
Electronic Table Games Appendix G
of game outcome, accounting, and significant event data, including all Components
thereof, to operate Electronic Table Games.
"Electronic Table Game Terminal" or "ETG Terminal" means a computer housed in a
cabinet with input device(s) and video screen(s) where a player may play Electronic
Table Games.
"Electronic Wagering System" means a Component of the ETG System that includes a
computer or server and any related hardware, software or other device that facilitates
patron play at an Electronic Table Game.
SECTION 4. AUTHORIZATION
4.1 The ETG System must be honest, fair, secure, reliable, auditable, and compliant with
the Compact and the standards contained in this Appendix and any related MOU.
4.2
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ETG System Conditions. An ETG System is authorized when the ETG System does
not allow a patron to play a device prohibited by RCW 9.46.0233(1)(b) and
RCW 67.70.040(1)(a) ("Play Against the Machine"). An ETG System does not
AF
allow Play Against the Machine when:
4.2.1 there is a human dealer involved in the play of the ETG ("Dealer
Controlled"); or
4.2.2 the play of the ETG does not involve a human dealer, and the ETG System is
configured for play between two or more patrons against the same roll of dice or
spin of the wheel, or a Communal Shoe of electronic cards ("Non-Dealer
Controlled"); however, only one patron is needed to initiate game play; or
4.2.3 it is a hybrid of Dealer Controlled and Non-Dealer Controlled, provided that any
ETG played as Dealer Controlled follows applicable Dealer Controlled
4.3
R standards set forth in this Appendix and any ETG offered as Non-Dealer
Controlled follows applicable Non-Dealer Controlled standards set forth in this
Appendix.
Specific Games
D 4.3.1 The Tribe may offer for play an ETG version of any Class III table game approved
in Compact Section III.D. Pay table or odds offered on an ETG must be consistent
with game rules as approved in Compact Section XI. B. 4 ETG game rules must be
displayed on each ETG Terminal.
4.3.2 An ETG Terminal may allow for play any other Class III activity as authorized
under the Compact, other than the Tribal Lottery System or any Gaming activity
with a limited allocation.
4.3.3 Concurrent play. Patrons may play more than one ETG concurrently using a single
ETG Terminal under the following requirements:
Upper Skagit Indian Tribe pg. 3
Electronic Table Games Appendix G
a. An ETG Terminal must display clear information about each ETG available
for play and such information must be available to a patron without the
patron first placing a wager.
b. An ETG Terminal must display each ETG selected for play by the patron.
c. An ETG Terminal must display the decisions and outcomes of play for each
ETG selected by the patron.
d. An ETG may not be added to or removed from an ETG Terminal in use
by a patron.
4.4 Wager Limits. Wager limits for ETGs shall not exceed $500.
4.5 Electronic Wagering System. An ETG shall be activated with an Electronic Wagering
System that meets the standards described in Section 6.1.2 of this Appendix. An ETG
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Terminal shall not issue coin or U.S. currency at the conclusion of a patron's play.
SECTION 5. NUMBER OF GAMING STATIONS
Every nine (9) ETG Terminals shall constitute one Gaming Station. If the number of ETG
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Terminals put into play is not perfectly divisible by nine (9), then any remainder less than nine
(9) will constitute a Gaming Station. For example, if ten (10) ETG Terminals are in operation, it
will constitute two (2) Gaming Stations.
SECTION 6. OPERATION AND REPORTING REQUIREMENTS
6.1 Standards for Operation.
6.1.1 Any ETG must comply with the standards established by this Appendix and any
applicable provision of the Compact, and must meet or exceed all applicable
standards of Gaming Laboratories International's Standards GLI-24 (Electronic
R Table Game Systems) ("GLI-24") and GLI-25 (Dealer Controlled Electronic Table
Games), as amended or modified. Any standards that contemplate features or
functionalities of an ETG System that conflict with Section 4 of this Appendix are
not applicable, and such features or functionalities are prohibited.
D
6.2
6.1.2 Any Electronic Wagering System must meet or exceed Gaming Laboratories
International's Standard GLI-16 (Cashless Systems in Casinos), the standards
established by this Appendix, any applicable provision of the Compact, including
Cashless Transaction System as defined in Appendix X2, and any related MOU.
Provided, any "Cashless Systems in Casinos" that would add money to or take
money from a patron's account without a cashier or kiosk would require
negotiations in Compact Section XV D.
The Tribal Gaming Agency and the State Gaming Agency may mutually agree in writing to
alternative standards for any ETG System authorized in Section 4 of this Appendix in lieu
of the GLI standards described in Sections 6.1.1 and 6.1.2 above that maintain the integrity
and security of the ETG System.
Upper Skagit Indian Tribe pg. 4
Electronic Table Games Appendix G
6.3 Internal controls. Prior to offering ETGs for play, the Tribe must implement Internal
Controls as minimum operating standards to govern the operation and management of the
ETG System.
6.3.1 Initial Internal Controls. The Tribal Gaming Agency shall forward to the State
Gaming Agency its initial Internal Controls for ETG Systems for review and
concurrence per Compact Section XI.A.
6.3.2 Minimum Requirements. The Internal Controls will address the following, at a
minimum:
a. Description of Gaming Employees who perform essential functions,
supervisory authority, handling payouts on winning vouchers.
b. User access controls for ETG personnel;
c. Segregation of duties;
d.
e.
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Procedures for receiving, investigating, and responding to patron
complaints;
Accounting and audit procedures;
f
g.
h.
1.
J.
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Procedures to ensure the physical security of the ETG Systems, including
key controls and Closed Surveillance System coverage;
Procedures to ensure the integrity and security of all sensitive data and
software;
Procedures to ensure that access to sensitive data and software is limited
to appropriate personnel;
Procedures to ensure accurate accounting of wagers and payouts;
Procedures to ensure the logging of the events and the availability of
R k.
I.
records to permit an effective audit of the conduct of the ETG System and
the reporting of revenue;
All existing Internal Controls are updated, as necessary, to ensure there are
no conflicts with any Internal Controls governing ETG Systems; and
Any other internal controls deemed necessary by both the State Gaming
D
6.4
6.5
Agency and Tribal Gaming Agency.
Required Reports. Reports necessary to record information as deemed necessary by the
Tribal Gaming Agency or as required by Internal Controls must be generated. These reports
may include, but are not limited to, all applicable reports as outlined in Section 2.21 of GLI-
24.
Training. A manufacturer's prototype (e.g., test cart) of the version of the ETG System that
will be installed at the Gaming Facility will be delivered to the State Gaming Agency for
training purposes prior to field testing. The State Gaming Agency will collaborate with the
Tribal Gaming Agency to provide additional training opportunities related to ETG
Systems. The Tribal Gaming Agency and the State Gaming Agency may mutually
agree to an alternative to a prototype.
Upper Skagit Indian Tribe pg. 5
Electronic Table Games Appendix G
6.6 Technical Revisions. The Parties may mutually agree in writing to revise the provisions
of this Section 6, including revisions to allow alternative technology that meets the
requirements of Section 6.1, provided any revisions adequately preserve and protect the
integrity and security of the ETGs and the interests of the Tribe and the State to reduce
the dangers of unfair or illegal practices.
SECTION 7. APPROVAL OF ELECTRONIC TABLE GAME SYSTEMS
7.1 Purpose. The general purpose of testing an ETG System pursuant to this Section 7 is to
determine the compliance of the ETG System with this Appendix and any applicable
MOU(s).
7.2 Independent Test Laboratory (ITL) Testing for ETG System, Upgrades, and New
Equipment; Modifications.
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7.2.1 ITL Requirement. Each new or upgraded ETG System may be offered for play
only if it has been tested and certified as meeting the applicable standards of
this Appendix and any related MOU by an ITL selected by the Tribe from
SGA's approved ITL list.
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7.2.2 ITL Reports and Certification. At the conclusion of testing, the ITL shall
provide to the Tribal Gaming Agency and the State Gaming Agency its
certification and supporting documentation. If the ITL provides sufficient
documentation that the ETG System or relevant Component has been tested
and certified by that ITL in any other jurisdiction and it meets the requirements
of this Appendix, without any subsequent modifications, that shall be sufficient
to satisfy this requirement.
7.2.3 Modifications. No substantive modification to any ETG System may be made
after testing, certification, and approval without certification of the
R modification by an ITL. The following modifications are not considered
substantive and do not require ITL certification or notification to the State
Gaming Agency: (a) changes to content not related to any regulated feature;
(b) adding or removing users; (c) any system configuration changes that have
no impact on the accuracy of report information including gaming revenue; and
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7.3
(d) minor modifications to hardware.
Field Testing for ETG Systems.
7.3.1 A new ETG System may only be offered for play subject to field testing at the
Tribe's Gaming Facility as described below.
7.3.2 The terms, conditions, criteria, and objectives for each ETG System to be field
tested must be jointly agreed to by TGA and SGA in writing prior to field testing
and must include at least:
a. The requirements and standards that must be met to determine
successful field testing.
b. The number of ETG Terminals to be included in the field test.
Upper Skagit Indian Tribe pg. 6
Electronic Table Games Appendix G
c. The demarcation of the testing area of the gaming floor and
necessary signage.
d. The appropriate length of the testing period.
e. Identification of who will receive updates, how the updates will be sent,
and when they will be sent.
7.3.3 Approval.
a. After a minimum of thirty (30) days of active operation of field testing
free of substantial errors, the Tribal Gaming Agency and State Gaming
Agency may end field testing and approve the ETG System if the final
joint field testing report provides, at a minimum, the details of testing, any
issues identified, the resolution of those issues, and overall performance
and compliance of the ETG System with applicable standards.
b.
c.
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The ETG System shall be deemed approved after ninety (90) days of
active operation unless disapproved in writing by the Tribal Gaming
Agency or State Gaming Agency detailing the reasons for disapproval.
Field testing may be suspended by the Tribal Gaming Agency, State
7.4 AFGaming Agency, or the manufacturer at any time for non compliance.
Once the Tribal Gaming Agency and State Gaming Agency agree the
non-compliance issue is resolved, field testing may resume.
Implementation of Approved ETG by another tribe. The Tribe may conduct its own field
testing period as outlined above or, once field testing is completed for another tribe, the
Tribe may rely on that testing for approval when its ETG System is the same and
configured in the same way.
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SECTION 8. PROBLEM AND RESPONSIBLE GAMING
Commitment to Responsible Gaming. The Tribe and State Gaming Agency recognize the
importance of responsible gambling as part of the shared responsibility to protect the health,
welfare, and safety of the citizens of the Tribe and of the State.
D To further the commitment to responsible gambling, the Tribe agrees to:
8.1.
8.2.
Create and maintain a responsible gambling policy that, at a minimum, includes
information about responsible gambling and identifies resources for individuals
seeking information about problem gambling. The policy may include information
about how and where to seek treatment, national or local hotline numbers, and a
description of self-imposed limits offered by the Gaming Operation, if any;
Display a commitment to responsible gambling and a link to the Gaming Operation's
responsible gambling policy on each ETG Terminal, cashier station, entrance/exit, TLS
Kiosk, and Keno Kiosk. The display will be in a manner determined by the Tribe;
Upper Skagit Indian Tribe pg. 7
Electronic Table Games Appendix G
8.3. Within five (5) years, or as soon as feasible thereafter based on reliable technological
availability, include in the Tribe’s education and awareness program an interactive
responsible gambling application or program for players; such gambling application or
program may be separate and need not be integrated into the authorized Class III
Gaming Activities and other Gaming Activities;
8.4. Include responsible gambling information on Class III Gaming marketing and
promotional materials, in a manner determined by the Tribe; and
8.5. Consider additional ways to address problem gambling behaviors of patrons of the
Gaming Facility in future negotiations.
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Upper Skagit Indian Tribe pg. 8
Electronic Table Games Appendix G
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