Seventh Amendment to the Tribal – State Compact for Class III Gaming Between the Squaxin Island Tribe and the State of Washington

Issuer: Congressional materials
Date: 2026-01-21

Summary

A tentative agreement for the Seventh Amendment to the Tribal – State Compact for Class III Gaming between the Squaxin Island Tribe and the State of Washington, dated 2026-01-21 in the page record. The amendment states that an attached Amended and Restated Compact supersedes the original compact entered on July 27, 1993, and it replaces, adds or deletes appendices covering standards of operation, off-track horse race wagering, electronic table games, sports wagering, wide area progressives, tribal lottery systems and electronic gambling devices. It provides that the compact takes effect on publication of notice of approval by the Secretary of the Interior under 25 U.S.C. § 2710(d)(3)(B). The restated compact follows, with a table of contents, policy statement, definitions and Appendix Y on requirements for electronic gambling devices.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Cite this document

“Seventh Amendment to the Tribal – State Compact for Class III Gaming Between the Squaxin Island Tribe and the State of Washington.” Original at app.leg.wa.gov, dated 2026-01-21. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2026-01-21-2026-01-21-a33649-d291554-squaxin-island-tribe-seventh-amendment-tentative-agreement/, SHA-256 6568b52b534fabb4ed50a6d763515d7498505aebf7ed78d5634972c816eb7507.

Full text

SEVENTH AMENDMENT TO THE TRIBAL – STATE COMPACT

FOR CLASS III GAMING BETWEEN

THE SQUAXIN ISLAND TRIBE AND THE STATE OF WASHINGTON

The Squaxin Island Tribe (“Tribe”) and the STATE OF WASHINGTON (“State”) (together the
“Parties”) entered into a Class III gaming compact on July 27, 1993, (hereafter the “Original
Compact”), pursuant to the Indian Gaming Regulatory Act (“IGRA”). Over the years, the Parties
amended the Compact. The Parties have now reached an agreement to amend and restate the
Compact as set forth below.

T
COMPACT AMENDMENT

1. The attached Amended and Restated Tribal – State Class III Gaming Compact
supersedes the Original Compact entered on July 27, 1993, as amended, in its
entirety.

AF
The amended and restated Compact contains bargained for concessions, limitations, and
agreements of the Tribe and the State.

2. Replace Appendix A - Standards of Operation and Management for Class III
Activities.

Appendix A “Standards of Operation and Management for Class III Activities” as set
forth in the Tribe’s Original Compact is replaced in its entirety by the attached amended

DR
and restated Appendix A.

3. Replace Appendix B - Satellite (Off-Track) Wagering on Horse Races.
Appendix B “Rules Governing Class III Gaming on the Squaxin Island Indian
Reservation” as set forth in the Tribe’s Original Compact is replaced in its entirety by the
attached amended and restated Appendix B “Satellite (Off-Track) Wagering on Horse
Races”.

4. Delete Appendix C - Class III Gaming Station Transfer Agreement.

Appendix C “Class III Gaming Station Transfer Agreement” added in the Tribe’s Fifth
Amendment is deleted in its entirety.

i
5. Add Appendix E – Limitations on Wagers, Credit, Facilities, and Problem Gambling
Resources.

The Compact is hereby amended to add Appendix E “Limitations on Wagers, Credit,
Facilities, and Problem Gambling Resources,” in the form attached hereto. The attached
Limitations Appendix was bargained for and in exchange for provisions therein and
Section III in the amended and restated Compact.

6. Add Appendix G - Electronic Table Games.
The Compact is hereby amended to add Appendix G “Electronic Table Games,” in the
form attached hereto. The attached Electronic Table Games Appendix was bargained for
and in exchange for provisions therein and Section III in the amended and restated
Compact.

7. Replace Appendix S - Sports Wagering.
T
Appendix S “Sports Wagering” added in the Tribe’s Sixth Amendment is replaced in its

AF
entirety by the attached amended and restated Appendix S. The attached Sports Wagering
Appendix was bargained for and in exchange for provisions therein and Section III in the
amended and restated Compact.

8. Add Appendix W - Rules Governing Wide Area Progressives.

The Compact is hereby amended to add Appendix W “Rules Governing Wide Area
Progressives,” in the form attached hereto.

D
9. Delete Appendix X - Rules Governing Tribal Lottery Systems.

R
Appendix X “Rules Governing Tribal Lottery Systems” added in the Tribe’s Second
Amendment is deleted in its entirety.

10. Replace Appendix X2 - Rules Governing Tribal Lottery Systems.

Appendix X2 “Rules Governing Tribal Lottery Systems” added in the Tribe’s Third
Amendment is replaced in its entirety by the attached amended and restated Appendix
X2. The attached Appendix X2 was bargained for and in exchange for provisions therein,
and Section III, Section XII and Appendix E of the amended and restated Compact.

11. Delete Appendix X2 Addendum.

Because many of the terms in Appendix X2 Addendum were incorporated into Section
XII and Appendix E of the amended and restated Compact, Appendix X2 Addendum
added in the Tribe’s Fourth Amendment has been deleted.

ii
12. Replace Appendix Y - Requirements for Electronic Gambling Devices.

Appendix Y “Appendix Colville” added in the Tribe’s Memorandum of Incorporation,
effective August 11, 2007, is replaced in its entirety by the attached amended and restated
Appendix Y “Requirements for Electronic Gambling Devices.”

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).

IN WITNESS WHEREOF, the Tribe and the State have executed the Seventh Amendment
to the Compact.

THE SQUAXIN ISLAND TRIBE
T STATE OF WASHINGTON

BY:
KRISTOPHER PETERS
Chairman

DATED:
AF BY:

DATED:
BOB FERGUSON
Governor

DR
iii
T
AF
TRIBAL – STATE COMPACT
FOR CLASS III GAMING
DR BETWEEN THE

Squaxin Island Tribe
AND THE

State of Washington
Squaxin Island Tribe – State of Washington
Class III Gaming Compact
TABLE OF CONTENTS

INTRODUCTION .......................................................................................................................... 1

INTENT STATEMENT ................................................................................................................. 1

PARTIES ........................................................................................................................................ 1

T
DECLARATION OF POLICY AND PURPOSE .......................................................................... 1

II.
TITLE ................................................................................................................................. 3

DEFINITIONS .................................................................................................................... 3

III.

AF
NATURE AND SCOPE OF CLASS III GAMING ........................................................... 8

C.
Location of the Gaming Facilities.............................................................................. 8

Ownership of Gaming Facilities and Gaming Operation .......................................... 8

Construction ............................................................................................................... 8

DR
D.

I.
Public Health, Safety and Environmental Protection ................................................ 8

Alcoholic Beverage Service ....................................................................................... 9

Responsible Gaming .................................................................................................. 9

Forms of Payment .................................................................................................... 11

Size of Gaming Floor ............................................................................................... 12

Number of Gaming Stations .................................................................................... 12

J. Wagering Limits ...................................................................................................... 12

K. Hours of Operation .................................................................................................. 12

L. Prohibition on Minors .............................................................................................. 12

Squaxin Island Tribe—State of Washington Gaming Compact (Amended and Restated)
Page i
M. Prohibition on Firearms ........................................................................................... 13

N. Acceptance of Electronic Benefits Cards from the State of Washington ................ 13

IV. CLASS III GAMING ACTIVITIES AND OTHER GAMING ACTIVITIES ................ 13

A. Class III Table Games .............................................................................................. 14

B. Tribal Lottery Systems ............................................................................................. 15

C. Tribal Lottery System Wide Area Progressive ........................................................ 15

D. Electronic Gambling Devices .................................................................................. 15

G.
T
Keno ......................................................................................................................... 15

Sale of Washington State lottery tickets .................................................................. 16

Lottery-type Games ................................................................................................. 16

K.
AF
Satellite (Off-Track) wagering on Horse Races....................................................... 17

Sports Pools ............................................................................................................. 17

Punchboards and Pull Tabs - Separate Locations .................................................... 17

Sports Wagering....................................................................................................... 17

D
V.

R
LICENSING, STATE CERTIFICATION, ELIGIBILITY, AND REGISTRATION
GENERAL REQUIREMENTS ........................................................................................ 18

D.
Gaming Facilities ..................................................................................................... 18

New Facility or Expansion of Existing Facility ....................................................... 18

Gaming Employees .................................................................................................. 18

Manufacturers and Suppliers of Gaming Services................................................... 18

E. Financiers ................................................................................................................. 19

F. Identification Cards .................................................................................................. 19

VI. LICENSING, STATE CERTIFICATION, ELIGIBILITY, AND REGISTRATION
PROCEDURES................................................................................................................. 20

Squaxin Island Tribe—State of Washington Gaming Compact (Amended and Restated)
Page ii
A. Overview – Gaming Employees .............................................................................. 20

B. Gaming Employee State Certification ..................................................................... 22

C. Gaming Employee Eligibility Determination .......................................................... 27

D. Gaming Employee Registration ............................................................................... 33

E. State Role for Issuing State Certification of Manufacturers and Suppliers of Gaming
Services and Financiers............................................................................................ 41

VII. STATE FEES FOR STATE CERTIFICATION, ELIGIBILITY DETERMINATION,
AND REGISTRATION .................................................................................................... 44

C.
T
State Certification – Gaming Employee .................................................................. 44

State Eligibility Determination – Gaming Employee .............................................. 45

State Registration – Gaming Employee ................................................................... 45

VIII.
D.

E.
AF
Alternative Fee Agreements .................................................................................... 45

State Certification of Suppliers, Manufacturers and Financiers .............................. 46

TRIBAL ENFORCEMENT OF COMPACT REQUIREMENTS ................................... 46

A. Tribal Regulation ..................................................................................................... 46

DR
IX.
B.

E.
Tribal Gaming Agency ............................................................................................ 46

Tribal Gaming Agents.............................................................................................. 47

Investigation............................................................................................................. 47

Reporting of Violations............................................................................................ 47

STANDARDS OF OPERATION ..................................................................................... 48

A. Adoption of Standards of Operation and Management ........................................... 48

B. Rules of the Games .................................................................................................. 49

C. Minimum Supervisory Requirements ...................................................................... 49

D. Additional Operation Requirements ........................................................................ 49

Squaxin Island Tribe—State of Washington Gaming Compact (Amended and Restated)
Page iii
E. Records Retention .................................................................................................... 51

X. COOPERATIVE ENFORCEMENT OF COMPACT REQUIREMENTS ...................... 51

A. State Gaming Agents – Monitoring ......................................................................... 52

B. Access to Records .................................................................................................... 52

C. Investigations ........................................................................................................... 53

D. Tribal Gaming Agency Access to State Gaming Agency Records.......................... 53

E. Cooperation With Tribal Gaming Agency ............................................................... 53

XI.

T
JURISDICTION ............................................................................................................... 54

B.
Criminal Matters ...................................................................................................... 54

Civil Matters ............................................................................................................ 54

F.
AF
Sanctions and Civil Fines......................................................................................... 55

Limited Application of State Criminal Law ............................................................ 55

Law Enforcement Coordination ............................................................................... 55

Reporting Requirements. ......................................................................................... 56

D
XII.

R
XIII.
G. Preservation of Tribal Self-Government .................................................................. 56

REIMBURSEMENT FOR REGULATORY EXPENSES INCURRED BY THE STATE
GAMING AGENCY ........................................................................................................ 56

DISPUTE RESOLUTION AND REMEDIES FOR BREACH OF COMPACT ............. 58

B.
Introduction .............................................................................................................. 58

Dispute Resolution Alternatives .............................................................................. 58

C. Injunction Against the State ..................................................................................... 60

D. Injunction Against the Tribe, the Gaming Operation, or any Individual ................. 60

E. Limited Waiver of Sovereign Immunity .................................................................. 61

F. References ................................................................................................................ 61

Squaxin Island Tribe—State of Washington Gaming Compact (Amended and Restated)
Page iv
XIV. LIMITATION OF LIABILITY ........................................................................................ 61

XV. EFFECTIVE DATE, DURATION, AND AMENDMENTS ........................................... 62

A. Effective Date .......................................................................................................... 62

B. Termination .............................................................................................................. 62

C. Subsequent Negotiations .......................................................................................... 62

D. Enactment of Compact Provisions ........................................................................... 62

E. Revision of State Regulations .................................................................................. 62

G. T
Changes to State Law............................................................................................... 63

Clarification, Amendments, and Renegotiations ..................................................... 63

XVI. NOTICES .......................................................................................................................... 65

AF
XVII. SEVERABILITY .............................................................................................................. 65

APPENDIX A - STANDARDS OF OPERATION AND MANAGEMENT FOR CLASS III
ACTIVITIES

APPENDIX B - SATELLITE (OFF-TRACK) WAGERING ON HORSE RACES

D
APPENDIX E – LIMITATIONS ON WAGERS, CREDIT, FACILITIES; AND PROBLEM

R
GAMBLING RESOURCES

APPENDIX G – ELECTRONIC TABLE GAMES

APPENDIX S—SPORTS WAGERING

APPENDIX W – WIDE AREA PROGRESSIVE

APPENDIX X2 - TRIBAL LOTTERY SYSTEMS

APPENDIX X2 ADDENDUM

APPENDIX Y – REQUIREMENTS FOR ELECTRONIC GAMBLING DEVICES

Squaxin Island Tribe—State of Washington Gaming Compact (Amended and Restated)
Page v
INTRODUCTION

This CLASS III TRIBAL-STATE GAMING COMPACT is entered into pursuant to the Indian
Gaming Regulatory Act of 1988, Pub. L. 100-497, codified at 25 U.S.C. §§ 2701-2721 and 18
U.S.C. §§ 1166-1168 (hereafter IGRA).

INTENT STATEMENT

This Class III Tribal-State Gaming Compact supersedes the original Tribal-State Gaming
Compact entered on July 27, 1993, as amended, and is hereby stated as set forth below and
pursuant to the appendices attached hereto.

To the extent they do not conflict, Internal Controls, game rules, Memorandums of

T
Understanding, and similar documents agreed to and still in effect as of the date of the
publication of Amendment 7 remain in full force and effect unless and until they are
subsequently modified pursuant to the process set forth in the Compact.

PARTIES

AF
This Class III Tribal-State Gaming Compact is made and entered into by and between the
Squaxin Island Tribe (hereafter Tribe), a federally recognized Indian tribe, possessed of all
sovereign powers and rights thereto pertaining and the State of Washington (hereafter State), a
sovereign state of the United States, with all rights and powers thereto pertaining.

DECLARATION OF POLICY AND PURPOSE

The Tribe and the State recognize and respect the laws and authority of the respective parties.

D
The Congress of the United States has enacted into law IGRA, Pub. L. 100-497, 25 U.S.C. §§

R
2701-2721 and 18 U.S.C. §§ 1166-1168, which provides in part that a tribal-state compact may
be negotiated between a tribe and a state to govern the conduct of certain Class III Gaming
activities on Tribal Lands within the state if the Gaming activity is not specifically prohibited by
federal law and is conducted within a state which does not, as a matter of criminal law and public
policy, prohibit such Gaming activity.

The Tribe and the State have negotiated the terms and conditions of this Compact in good faith
so as to provide for mutual governmental purposes and to provide a regulatory framework for the
operation of certain Class III Gaming, which is intended to: (a) ensure the fair and honest
operation of such Gaming activities; (b) maintain the integrity of all activities conducted in
regard to such Gaming activities; (c) prevent unsavory and unsuitable persons from having any
direct or indirect involvement with Gaming activities at any time or in any capacity; (d) establish
and maintain responsible accounting practices and procedures; (e) maintain effective control
over the financial practices related to Gaming activities, including establishing the minimum

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 1
procedures for internal fiscal affairs and the safeguarding of assets and revenues and reliable
recordkeeping; (f) prevent cheating and fraudulent practices; and (g) protect the health, welfare
and safety of the citizens of the Tribe and of the State.

An Indian tribe may conduct Class III Gaming in accordance with IGRA. The Tribe and the
State of Washington have mutually agreed that the conduct of Class III Gaming under the terms
and conditions set forth below will benefit the Tribe and protect the citizens of the Tribe and of
the State consistent with the objectives of IGRA.

The parties hereto deem it to be in their respective best interests to enter into this Compact.

A principal goal of federal Indian policy is to promote tribal economic development, tribal self-
determination and a strong government-to-government relationship.

T
The State recognizes the Tribe’s sovereign rights to control Gaming activities on Tribal Lands as
provided by IGRA and this Compact.

It is the policy of the Tribe to exercise and retain its rights to regulate Gaming activities upon its

AF
Tribal Lands for the purposes of encouraging Tribal employment, economic and social
development, and funding of Tribal services while ensuring the fair and lawful operation of
Gaming and the prevention of corrupt and criminal influences. Per 25 U.S.C. § 2710(b)(2)(B),
the Tribe will utilize net revenues generated by Gaming to fund tribal government operations or
programs, to provide for the general welfare of the Tribe and its citizens, to promote tribal
economic development, to donate to charitable organizations, or to help fund operations of local
government agencies.

D
This Compact shall govern the licensing, regulation, and operation of Class III Gaming
conducted by the Tribe on Tribal Lands located within the State.

R
The State and the Tribe are empowered to enter into this Compact due to their inherent power to
contract and pursuant to IGRA, Tribal law, and State law.

In consideration of the mutual undertakings and agreements hereinafter set forth, the Tribe and
the State enter into the following amended Compact.

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 2
I. TITLE

This document will be cited as “Squaxin Island Tribe – State of Washington Gaming Compact.”

II. DEFINITIONS

For purposes of this Compact:

A. “IGRA” means the Indian Gaming Regulatory Act, Pub. L. 100-497, 25 U.S.C. §2701
et seq.

B. “Applicant” means any Individual who has applied for a tribal license, State
Certification, Eligibility Determination or Gaming Employee Registration whether or
not such license, State Certification, Eligibility Determination, or Registration is

C.
ultimately granted.
T
“Available for Lease” means a Player Terminal that is part of an Eligible Tribe’s
Allocation of Player Terminals and is neither in use in any Eligible Tribe’s Gaming

E.
AF
Facility or Facilities, nor leased to another Eligible Tribe.

“Cash" when used as a noun, means currency in the form of coins or bills issued by
the government of the United States.

“Cash Equivalent” means U.S. currency in the form of a treasury check, personal
check, travelers check, wire transfer of funds, money order, certified check, cashier’s
check, a check drawn on the Gaming Operation payable to the patron or to the
Gaming Operation, a patron’s debit or credit card, a patron’s reloadable prepaid card

DR F.
that has been verified as being issued to the patron and is non-transferable, ACH
transfer if the operator has security measures and controls to prevent ACH fraud
regarding failed ACH deposits, or a voucher recording Cash drawn against a credit
card or charge card.

“Certification” means a confirmation conducted and signed by an Independent
Accounting Firm that states the number of Player Terminals Available for Lease in
the State of Washington.

G. “Class III Gaming” means all forms of Gaming as defined in 25 U.S.C. § 2703(8) and
authorized under Compact Section IV.

H. “Closed Surveillance System” means a recording system with a collection of
surveillance cameras in which live signals are recorded and are available to be viewed
within the system and are not publicly distributed or accessible.

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 3
I. “Compact” means the Squaxin Island Tribe – State of Washington Gaming Compact
and Appendices, as stated herein.

J. “Electronic Gambling Device” or “Gambling Device” means any device or
mechanism the operation of which a right to money, credits, deposits or other things
of value may be created, in return for a consideration, as the result of the operation of
an element of chance and any device or mechanism which, when operated for a
consideration, does not return the same value or thing of value for the same
consideration upon each operation thereof. Notwithstanding the foregoing,
“Electronic Gambling Device” does not include a “Class II Gambling Device.”

K. “Eligible Tribe” means a Washington Tribe that has entered into a compact
authorizing operation of a Tribal Lottery System consistent with Appendix X2.

L.
T
“Eligibility Determination” means a process described in Compact Section VI.C.
conducted by the State Gaming Agency to verify a person qualifies for a tribal license
and does not pose a threat to the public or to effective regulation of this Compact.

N.
AF
“Federally Recognized Tribe” means an American Indian or Alaska Native tribal
entity that is recognized as having a government-to-government relationship with the
United States of America, with the responsibilities, powers, limitations, and
obligations attached to that designation, and is eligible for funding and services from
the Bureau of Indian Affairs or successor agency.

“Gaming” or “Gambling” means staking or risking something of value upon the
outcome of a contest of chance or a future contingent event not under the person’s

DR O.

P.
control or influence, upon an agreement or understanding that the person or someone
else will receive something of value in the event of a certain outcome.

“Gaming Code” means the Tribal Ordinance approved by the National Indian
Gaming Commission pursuant to IGRA and codified in Squaxin Island Tribal Code
Chapter 6.08, as amended and any regulations or rules adopted by the Tribe
thereunder.

“Gaming Employee” means any person employed in the operation or management of
the Gaming Operation, whether employed by or contracted by the Tribe or by any
person or enterprise providing on or off-site services to the Tribe within or without
the Gaming Facilities regarding any Class III Gaming, including, but not limited to,
Gaming Operation managers and assistant managers; accounting personnel; security
personnel; surveillance personnel; cashier supervisors; dealers; box men; floormen;
Pit bosses; shift bosses; cage personnel; Sports Wagering personnel; collection
personnel; Gaming consultants; management company employees, officers, and

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 4
Principals; and any other natural person whose employment duties require or
authorize access to restricted areas of the Gaming Facilities not otherwise opened to
the public.

Q. “Gaming Facility” or “Gaming Facilities” means the building or buildings or portions
thereof in which Class III Gaming occurs as authorized by this Compact.

R. “Gaming Operation” means the enterprise or enterprises operated by the Tribe on
Tribal Lands for the conduct of any form of Class III Gaming in any Gaming Facility.

S. “Gaming Promotion” means a way to encourage players to participate in a Gaming
activity. A Gaming Promotion cannot require the participants to give valuable
consideration in order to participate in the promotion.

T.
T
“Gaming Services” means the providing of any goods or services to the Tribe directly
in connection with the operation of Class III Gaming in a Gaming Facility and
involving restricted areas or access. Goods or services include, but are not limited to,

W.
AF
equipment, maintenance, management or security services for the Gaming Facility.

“Gaming Station” means one conventional, physical Gaming table of the general size
and scope as commonly used in Nevada.

“Independent Accountant” means a professional accountant suitably qualified and
sufficiently independent to act as auditor of the Gaming Operation.

“Independent Accounting Firm” means a person or firm licensed by the Washington

DR
X.

Z.
State Board of Accountancy.

“Indian” means an enrolled member of a Federally Recognized tribe.

“Individual” means, but is not limited to, natural persons and business entities
including business sole-proprietorships, partnerships, corporations, joint ventures,
organizations and associations.

“Internal Controls” means the documents that describe the internal operational system
or internal procedures of the Gaming Operation designed to promote efficiency,
safeguard assets, and avoid fraud and error.

AA. “Investigative Report” means a report that accurately reflects the background
investigation conducted by the Tribal Gaming Agency to determine whether a
Gaming Employee/Applicant qualifies to hold a Gaming license. Each Investigative
Report should include at least the following: full legal name, alias, date of birth,
unique identification number, position to be held, summary of investigative results

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 5
found, type of license issued, date license issued, and who completed the
investigation.

BB. “Keno System” means the collection of hardware and software components which
facilitate the play, reporting, and security of the keno game. The system includes
number selection devices, databases, servers, networking devices, management
terminals, kiosks, and other components used as integral parts of the keno game.

CC. “Local Law Enforcement Agency” means any law enforcement agency in the vicinity
of the Gaming Operation that has jurisdiction to enforce local and State laws within
the Tribal Lands or is subject to the terms of a cross-deputization, cooperation, or
mutual aid agreement.

DD.

T
“Memorandum of Understanding” or “MOU” means a document agreed upon by both
the Tribe and State Gaming Agency that clarifies terms or details of agreed upon
Compact provisions and does not add provisions which would require an amendment.

EE.

FF.

GG.
AF
“National Indian Gaming Commission” or “NIGC” means the Commission
established pursuant to Section 5 of IGRA, 25 U.S.C. § 2704.

“Net Win” means the total amount wagered or played less the amounts repaid to
winners.

“Non-Indian” means a person not enrolled as a member of a Federally Recognized
tribe.

DR
HH.

II.
“Pit” means the area enclosed or encircled by an arrangement of Gaming Stations 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.

“Principal” means with respect to any enterprise: (i) each of its officers and directors;
(ii) each of its principal management employees, including any chief executive
officer, chief financial officer, chief operating officer, or general manager; (iii) each
of its owners or partners, if an unincorporated business; (iv) each of its shareholders
who own more than ten percent of the shares of the corporation, if a corporation; and
(v) each person other than a banking institution who has provided financing for the
enterprise constituting more than ten percent of the total financing of the enterprise or
project.

JJ. “Proof of Identity” means legal identification that includes a current photograph such
as a valid driver’s license, state identification card, valid passport, military
identification card, or tribal identification card.

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 6
KK. “Registration” or “Gaming Employee Registration” means the process described in
Compact Section VI. conducted by the State Gaming Agency to determine, from the
State’s perspective, if a person is of good character, honesty, and integrity; the
person’s prior activities do not pose a threat to the public or to effective regulation of
this Compact; and that such person is likely to conduct Class III Gaming activities in
accordance with this Compact.

LL. “RCW” means the Revised Code of Washington, as amended.

MM. “State” means the State of Washington, its authorized officials, agents, and
representatives.

NN. “State Certification” means the process described in Compact Section VI.B. utilized

T
by the State Gaming Agency to ensure that all entities or persons required to be
licensed or certified are qualified to hold such license or State Certification in
accordance with this Compact.

OO.

PP.

QQ.
AF
“State Gaming Agency” means the Washington State Gambling Commission.

“Tribal Gaming Agency” means the Tribal Gaming Commission and/or such other
agency of the Tribe as the Tribe may from time to time designate by written notice to
the State as the single Tribal agency primarily responsible for regulatory oversight of
Class III Gaming as authorized by this Compact.

“Tribal Gaming Agent” means an employee of the Tribal Gaming Agency duly
appointed by the agency as an agent.

DR
RR.

SS.

TT.
“Tribal Lands” means Indian lands as defined by 25 U.S.C. § 2703(4)(A) and (B),
subject to the provisions of 25 U.S.C. § 2719, which lands are subject to the
jurisdiction of the Tribe.

“Tribal Law Enforcement” means any police force established and maintained by the
Tribe pursuant to the Tribe’s powers of self-government to carry out law enforcement
within the Tribal Lands.

“Tribal Licensing” means the licensing process utilized by the Tribe to ensure all
entities or persons required to be licensed are qualified to hold such license in
accordance with provisions of the Tribe’s Gaming Code, regulations, and this
Compact.

UU. “Tribal Member” means an enrolled member of the Squaxin Island Tribe pursuant to
the membership laws of the Tribe.

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 7
VV. “Tribe” means the Squaxin Island Tribe, its authorized officials, agents, and
representatives, and includes federally or tribally chartered entities wholly owned by
the Tribe.

WW. “WAC” means the Washington Administrative Code, as amended.

III. NATURE AND SCOPE OF CLASS III GAMING

A. Location of the Gaming Facilities

(1) The Tribe may establish two (2) Gaming Facilities to be located on Tribal Lands.

(2) Any Gaming Facility may be expanded to include additional buildings or
portion(s) thereof connected to become part of that Gaming Facility. Any

T
connected structures of that Gaming Facility must provide corridors connecting
such buildings or portion(s) thereof with a safe, secure, and direct path for the
public, employees, and assets. All Compact requirements shall apply to such
additional buildings.

C.
AF
Ownership of Gaming Facilities and Gaming Operation

The Gaming Operation, including all Gaming Facilities, shall be owned by the Tribe. The
Tribe may, if it chooses, contract for management of the Gaming Facilities and Gaming
Operation. Any such contract shall subject the manager to the terms of this Compact,
including licensing pursuant to the requirements of Compact Sections V. and VI.

Construction

DR
D.
Any Gaming Facility will comply with all applicable tribal and federal regulations,
including by way of example: zoning, building, environmental review, and water quality
protection.

Public Health, Safety and Environmental Protection

(1) The number of persons permitted in any Gaming Facility will not exceed the
number authorized by applicable fire and building codes.

(2) The Tribe recognizes there may be an increased burden on local jurisdictions’
public safety, emergency response, and other services associated with the
operation of Gaming Facilities and shall make provisions for adequate emergency
accessibility and service to ensure the safety of its patrons and employees.

(3) The Tribe shall comply with and enforce standards no less stringent than those
contained in the following laws, regulations, and codes:

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 8
(a) Indian Health Service public health standards.

(b) All Federal laws establishing minimum standards for environmental
protection.

(d) Federal water quality and safe drinking water standards or the Tribe’s
Surface Water Quality Standards, approved by the United States
Environmental Protection Agency.

(e) International Building Code, including codes for electrical, fire, and

(f)
plumbing.

T
Public health standards for food and beverage handling in accordance with
U.S. Public Health Service requirements.

E.
(4)
(g)

AF
Tribal Codes regarding public health, safety, and environmental protection
standards.

Because air quality is an important part of protecting public health and safety,
when smoking is allowed in the Gaming Facility, Tribe agrees to mitigate the
harm of second-hand smoke by providing a non-smoking area of the Gaming
Facility.

Alcoholic Beverage Service

DR
F.
Standards for alcohol service within the Gaming Facilities shall be subject to applicable
law or applicable agreement between the Tribe and Washington State Liquor and
Cannabis Board, or its successor agency.

Responsible Gaming

The Tribe and State Gaming Agency recognize the importance of responsible gaming as
part of the shared responsibility to protect the health, welfare, and safety of the citizens of
the Tribe and of the State. As part of that responsibility, the Tribe agrees to:

(1) Policy. Create and maintain a responsible gaming policy that, at a minimum,
outlines their commitment to responsible gaming, player protection, and
mitigating gambling related harms. The policy shall include information about
how and where to seek treatment; national or local hotline numbers; a description
of self-imposed limits offered by the Gaming Operation, if any; the process for

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 9
self-exclusion/barring; and preventing underage persons from entering the
Gaming Facility.

(2) Training. Provide annual training and education for all Gaming Employees to
cover how to identify problem gamblers, how to provide assistance when asked,
the self-exclusion/barring process, and where to direct patrons to find resources.
For management, additional training shall cover underage gambling prevention;
unattended children; the self-exclusion/barring process and how to initiate the
process; and the increased risk of gambling harms that gaming employees may
face.

(3) Self-Exclusion.

The Tribe shall:

(a) T
Provide a self-exclusion process for patrons to self-exclude/bar themselves
from the Gaming Facility and describe that process on the Gaming

(b)

(c)
AF
Facility’s website and Player Account applications. Current forms for
initiating the process should be available on the website.

Provide local resources and a toll-free number to a patron who self-
excludes/bars so they can seek further assistance.

Immediately remove a patron who self-excludes/bars from mailing lists
and promotional and marketing materials, and they will be denied all
complimentary items while excluded/barred.

DR (4)
(d) Consider participating in the State Gaming Agency’s statewide self-
exclusion program.

Commitment to Responsible Gaming.

(a) Each cashier station, entrance/exit, Gaming Station, Player Terminal,
Kiosk, ETG Terminal, Mobile Sports Wagering application, and Sports
Wagering Kiosk shall display educational and informational materials that
aim at the prevention of problem gambling, a toll-free helpline number,
and specify where to find problem gambling assistance. Any link to the
Tribe’s responsible gaming policy in (1) above shall be consistent with the
information posted on the Gaming Facility’s website and in a method
determined by the Tribe.

(b) Include a responsible gaming message and toll-free hotline number on
Class III advertising, marketing, and promotional materials.

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 10
(c) Provide recipients of Class III advertising, marketing, and promotional
materials with the ability to opt out of email, direct messaging, SMS
marketing at any time.

(5) Class III Gaming website information. The Tribe shall, within three (3) clicks
from the main website, make the following responsible gaming and problem
gambling information available on the Class III Gaming Facility website:

(a) The responsible gaming policy outlined in (1) above,

(b) A toll-free problem gambling hotline number,

(d)

(e)
T
Responsible gaming information,

The Gaming Operations self-barring/exclusion process, and

(6)
(f)

AFOn-line application/form to start the self-barring/exclusion process.

Self-Imposed Limits.

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 gaming 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.

DR
G.
(7)

(8)
The Tribe shall annually certify to the State Gaming Agency in writing
compliance with (1)-(6) above by December 31 of each year.

Consider additional ways to address problem gambling behaviors of patrons of
the Gaming Facility in future negotiations.

Forms of Payment

All payment for wagers made in authorized forms of Class III Gaming conducted by the
Tribe on its Tribal Lands, including the purchase of chips for use in wagering, shall be
made by Cash or Cash Equivalent. Cash payments for wagers made through near-field
communication (NFC) devices, EMV or smart cards, or similar secure payment
technologies may be utilized upon agreement between the Tribe and the State Gaming
Agency and documented in a Memorandum of Understanding. No credit shall be
extended to any patron of the Gaming Facilities for Gaming activities except as authorized
in this Compact.

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 11
(1) Digital Wallet. The Tribe and State agree that connecting a patron’s Tribal Lottery
System Player Account and Sports Wagering Account “digital wallet”, or other
payment/wagering accounts, at the Gaming Operation shall not be deemed
approved as part of the approval of the Sports Wagering Appendix S. Any future
proposal from the Tribe to make such connections must meet Compact and
applicable Appendices requirements. If the Tribe’s Compact provisions do not
allow this connection, additional amendments/negotiations may be initiated. If the
Tribe determines its proposal meets current Compact requirements, the proposal
will be submitted to and approved by the Tribe and State Gaming Agency, and such
agreement will be documented. The documentation will include at a minimum: how
it complies with Compact and Appendices; security, integrity, and testing
provisions; and related Internal Controls. Nothing in the Sports Wagering Appendix

H.
T
S is intended to prevent the Tribe from offering a “digital wallet” for Sports
Wagering.

Size of Gaming Floor

J.
AF
The actual size of the Class III Gaming Floor within each Gaming Facility shall be
determined by the Tribe.

Number of Gaming Stations

Appendix E, Section 5. governs the number of gaming stations.

Wagering Limits

DR
K.

L.
Unless otherwise specified in this Compact or Appendices, wager limits shall not exceed
five hundred dollars ($500).

Hours of Operation

Operating hours shall be determined by the Tribe.

Prohibition on Minors

No person under the age of eighteen (18) shall participate in any Gaming activities
authorized by this Compact, or be employed in any Gaming Operation, or be allowed on
the Class III Gaming floor during actual hours of operation. PROVIDED, that such age
limitation shall not apply to a person accompanied by an adult for the specific and limited
purpose of proceeding directly and immediately across the Gaming area for legitimate
non-gaming purpose, with no Gaming area loitering or Gaming participation by the
underage person or accompanying adults. Persons between the ages of eighteen (18) and
twenty (20) may patronize and participate in Class III Gaming activities offered by the

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 12
Tribe in its Gaming Facilities, so long as such patrons do not purchase or consume
alcoholic beverages on the premises in accordance with Washington State liquor laws or
an applicable written agreement between the Tribe and Washington State Liquor and
Cannabis Board or successor State agency.

M. Prohibition on Firearms

The possession of firearms by any person within the Gaming Facilities shall be strictly
prohibited, and the Gaming Operation shall post notice of this prohibition near any
entrance to the Gaming Facilities. This prohibition shall not apply to:

(1) Local Law Enforcement or Tribal Law Enforcement agencies authorized by
federal law, tribal law or by a cooperative, mutual aid or cross-deputization

(2)
agreement;

T
Contracted services, such as armored car services, while performing their
contracted duties as provided in RCW 9.41.300 and RCW 18.170; and

N.
(3)

AF
The State Gaming Agency.

Acceptance of Electronic Benefits Cards from the State of Washington.

The Tribe shall ensure that all Cash dispensing outlets, including without limitation,
automated teller machines (ATM) and point of sale machines located within the Tribe’s
Gaming Facility or Facilities, shall not accept Electronic Benefits Cards.

IV. CLASS III GAMING ACTIVITIES AND OTHER GAMING ACTIVITIES

D
Any Class III Gaming activity not authorized in this Compact is prohibited, and unless

R
authorized by the State, all Class III Gambling Devices are prohibited.

Nothing herein is intended to prohibit or restrict otherwise lawful and authorized Class II
Gaming activities Tribal Lands or within the Gaming Facility.

The Tribe may conduct any or all the following games subject to the terms and conditions of this
Compact:

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 13
A. Class III Table Games

(1) Existing Table Games. The Tribe may offer any Class III table game authorized
for play in the State of Washington pursuant to the table game rules approved at
the time of the effective date of this amended Compact.

(2) Modifications to Table Games. If the Gaming Operation wishes to modify its
table game rules of an approved Class III table game, it shall first provide the
modified game rules to the Tribal Gaming Agency for review and approval. Once
the Tribal Gaming Agency has reviewed and approved the modified game rules,
the Tribal Gaming Agency shall provide the State Gaming Agency with the
approved modifications to the rules for concurrence. If the State Gaming Agency
takes no action on the submitted modifications to the table game rules within the

T
thirty (30) days, the Gaming Operation may begin offering the table game. If,
however, the State Gaming Agency disagrees with the proposed modified game
rules, it shall provide a notice of disagreement to the Tribal Gaming Agency
setting forth with specificity the reasons for such disagreement. Upon a notice of

(3)
AF
disagreement, the Tribal Gaming Agency and State Gaming Agency shall meet,
and in good faith try to resolve the differences.

Table Games Approved in Washington after Effective Date. If the Gaming
Operation wishes to offer any Class III table game not approved at the time of the
effective date of this amended Compact but subsequently authorized for play in
the State of Washington and played in accordance with rules as approved, it shall
first provide the game rules to the Tribal Gaming Agency for review and

DR (4)
approval, and the Tribal Gaming Agency shall provide the table game rules to the
State Gaming Agency at least thirty (30) days prior to the time play shall begin.
If, however, the State Gaming Agency disagrees with the proposed table game
rules, it shall provide a notice of disagreement to the Tribal Gaming Agency
setting forth with specificity the reasons for such disagreement. Upon a notice of
disagreement, the Tribal Gaming Agency and State Gaming Agency shall meet,
and in good faith try to resolve the differences.

New Table Games. If the Gaming Operation wishes to offer any Class III table
game that does not fall under subsections (1), (2) or (3) above, it shall first
provide the game rules to the Tribal Gaming Agency for review and approval.
Once the Tribal Gaming Agency has reviewed and approved the game rules, the
following items shall be submitted to the State Gaming Agency at least sixty (60)
days prior to the time play shall begin:

(a) The proposed rules,

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 14
(b) Manner of regulation,

(d) Any equipment included as part of the proposal. A working model of the
equipment will be submitted to the State Gaming Agency prior to
installation and implementation.

If the State Gaming Agency takes no action on the submission within the sixty
(60) days, the Gaming Operation may begin offering the game. If, however, the
State Gaming Agency disagrees with the submission, it shall provide a notice of
disagreement to the Tribal Gaming Agency setting forth with specificity the
reasons for such disagreement.

B.
(5)
T
Electronic Table Games. The Gaming Operation may offer Electronic Table
Games, operated in conformity with Appendix F.

Tribal Lottery Systems operated in conformity with X2.

E.
AF
Tribal Lottery System Wide Area Progressive operated in conformity with Appendix W.

Electronic Gambling Devices, as defined herein and the Johnson Act, 15 U.S.C. § 1171,
operated in conformity with Appendix Y.

Keno

(1) The wagering limit for Keno is five hundred dollars ($500).

DR
(2)

(3)
Existing Keno Systems. The Tribe may offer any Keno System approved for play
in the State of Washington pursuant to the game rules and Internal Controls
approved at the time of the effective date of this amended Compact.

Keno System Modification or Approved in Washington after Effective Date. If
the Gaming Operation wishes to offer a modification to game rules or Internals
Controls of a currently authorized Keno System or a new Keno System that was
not approved at the time of the effective date of this amended Compact but was
subsequently authorized for play in the State of Washington, it shall first provide
the game rules or Internal Controls to the Tribal Gaming Agency for review and
approval, and the Tribal Gaming Agency shall provide the game rules or Internal
Controls to the State Gaming Agency at least thirty (30) days prior to the time
play shall begin. If, however, the State Gaming Agency disagrees with the
proposed game rules or Internal Controls, it shall provide a notice of disagreement
to the Tribal Gaming Agency setting forth with specificity the reasons for such

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 15
disagreement. If the State takes no action within the thirty (30) days, the Tribe
shall begin offering the game.

(4) New Keno Systems. For a Keno System that does not fall under subsections (2) or
(3) above, the Tribe will submit to the State Gaming Agency at least sixty (60)
days prior to time play shall begin the:

(a) Proposed rules,

(b) Manner of regulation,

(d) The proposed Keno System equipment will be submitted to the State

T
Gaming Agency for testing and approval prior to installation and
implementation.

If the State Gaming Agency disagrees with the proposal, it shall provide a notice

G.
AF
of disagreement to the Tribal Gaming Agency setting forth with specificity the
reasons for such disagreement. If the State takes no action within sixty (60) days,
the Tribe may begin offering the game.

Sale of Washington State lottery tickets on Tribal Lands shall be subject to the provisions
of RCW 67.70, WAC 315, and the Gaming Code.

Lottery-type Games

DR
(1)

(2)
The Tribe may offer games including keno-type games, instant tickets, raffles, or
other lottery-type games authorized for play for any purpose by any person,
organization, or entity in the State of Washington that are not otherwise treated as
Class II Gaming in Washington pursuant to 25 U.S.C. § 2703(7).

At least sixty (60) days prior to the time play shall begin, the Tribe will submit to
the State Gaming Agency the following:

(a) Proposed rules;

(b) Manner of regulation;

(d) If the proposal includes gambling equipment, the proposed equipment will
be submitted to the State Gaming Agency for testing and approval prior to
installation and implementation.

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 16
(3) If the State takes no action within sixty (60) days, the Tribe may begin offering
the game.

H. Satellite (Off-Track) wagering on Horse Races, in conformity with Appendix B.

I. Sports Pools, on regularly scheduled athletic contests, of one hundred (100) squares
wherein each square is sold for not more than one hundred dollars ($100) and all
proceeds, less a tribal administrative charge of no more than fifty cents ($.50) for each
ten dollars ($10) wagered, are awarded as prizes. The sports pool may be conducted only
as follows:

(1) A board or piece of paper is divided into one hundred (100) equal squares, each of
which constitutes a chance to win in the sports pool and each of which is offered

(2) T
directly to prospective contestants;

The purchaser of each chance or square signs their name on the face of each
square purchased;

(3)

(4)

(5)
AF
No later than prior to the start of the subject athletic contest the pool is closed and
no further chances are sold;

After the pool is closed a prospective score is assigned by random drawing to
each square; and

The sports pool board must be available for inspection by any person purchasing a
chance, the State Gaming Agency, and the Tribal Gaming Agency at all times

D
J.

R
K.
prior to the payment of the prize.

Punchboards and Pull Tabs - Separate Locations

The Tribe may utilize punchboards and pull tabs in each Gaming Facility and at other
locations under the Tribe’s jurisdiction subject to regulation and licensing by the Tribe
and operated in a manner consistent with the sale of punchboards and pull tabs under
IGRA.

Sports Wagering, operated in conformity with Appendix S.

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 17
V. LICENSING, STATE CERTIFICATION, ELIGIBILITY, AND REGISTRATION
GENERAL REQUIREMENTS

A. Gaming Facilities

The Gaming Facilities authorized by this Compact shall be licensed by the Tribal Gaming
Agency in conformity with the requirements of this Compact and the Gaming Code prior
to commencement of operation.

B. New Facility or Expansion of Existing Facility

Verification that the Compact and Gaming Code requirements have been met for any new
or additional Gaming Facilities, or for expansion of an existing Gaming Facility shall be

T
made by the Tribal Gaming Agency and State Gaming Agency, through a joint pre-
operation inspection scheduled at least thirty (30) days prior to the scheduled opening to
the public. If a Gaming Facility fails to meet such requirements, the Tribal or State
Gaming Agency must send a written and detailed non-compliance letter and report to the

C.
AF
Tribe and the manager, if any, within seven (7) working days after completion of the
inspection. If the Tribal and State Gaming Agencies do not agree on whether a Gaming
Facility meets the requirements, the agencies will meet within seven (7) working days
from receipt of the non-compliance letter and work together to resolve concerns.

Gaming Employees

The Tribal Gaming Agency shall license Gaming Employees and may either work with
State Gaming Agency to certify those Gaming Employees; or work with State Gaming

DR
D.
Agency to determine eligibility; or work with State Gaming Agency to verify
Registration as described in Compact Section VI. and pursuant to RCW 9.46.070.

Manufacturers and Suppliers of Gaming Services

(1) Each manufacturer and supplier of Gaming Services shall be licensed by the
Tribal Gaming Agency and shall be certified by the State Gaming Agency prior to
the sale of any Gaming Services to the Tribe. If a supplier or manufacturer is
currently licensed or certified by the State Gaming Agency to supply Gaming
Services, pursuant to RCW 9.46.070, it shall be deemed certified to supply the
same Gaming Services to the Tribe for the purposes of this Compact. The
licensing and State Certification shall be maintained annually after the initial State
Certification.

(2) Firms or representatives providing professional legal and accounting services,
when licensed by the Washington State Bar Association or the Washington State
Supreme Court, the Washington State Board of Accountancy, or an equivalent

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 18
State or Provincial licensing body that has a reciprocity agreement with
Washington State, will not be subject to State Certification, and the Tribe will
determine if a license is required.

(3) In the event a manufacturer or supplier demonstrates that their anticipated profits
from sales will be below the cost of obtaining a State Certification, it may apply
for an abbreviated form of State Certification currently known as a special sales
permit.

(4) In the event a manufacturer or supplier provides or intends to provide less than
twenty-five thousand dollars ($25,000) worth of Gaming Services annually, the
licensing and State Certification requirements may be waived upon the mutual
agreement of the Tribal and State Gaming Agencies.

E. Financiers

(1)
T
Any party who extends or intends to extend financing, directly or indirectly, to a

(2)
AF
Gaming Facility or Gaming Operation shall be subject to the annual State
Certification and licensing requirements of the State Gaming Agency and the
Tribal Gaming Agency. Such party shall be required to obtain State Certification
before executing the financing agreement and annually thereafter as long as the
financing agreement is in effect.

These licensing and State Certification requirements do not apply to financing
provided by a federal or State regulated commercial lending institution, the Tribe,
or the federal government. Federal or State regulated commercial lending

DR (3)
institutions are those regulated by the Securities and Exchange Commission, the
Comptroller of the Currency, the Federal Deposit Insurance Corporation, the
United States Federal Reserve System, the National Credit Union Administration,
or the Washington State Department of Financial Institutions.

The source of all funds including financing agreements will be fully disclosed to
the State Gaming Agency, and the Tribe shall make available such disclosures for
review by the State Gaming Agency.

(4) The source of all funds will be fully disclosed, as applicable to the satellite
wagering facility and activities, to the Washington Horse Racing Commission.

F. Identification Cards

The Tribal Gaming Agency shall require all Gaming Employees, representatives of
manufacturers and suppliers of Gaming Services, and representatives of Sports Wagering
Vendors to carry on their person at all times identification cards issued by the Tribal

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 19
Gaming Agency which include the Individual’s photo, first name, an identification
number unique to the Individual’s tribal license, a Tribal seal or signature, and a date of
expiration. The Tribal Gaming Agency will determine which Gaming Employees are not
required to visibly display their identification card and will identify those employees to
the State Gaming Agency upon request.

VI. LICENSING, STATE CERTIFICATION, ELIGIBILITY, AND REGISTRATION
PROCEDURES

A. Overview – Gaming Employees

The Tribal Gaming Agency shall license Gaming Employees and will work with State
Gaming Agency to certify those Gaming Employees as described in Compact Section

T
VI.B. or work with State Gaming Agency to determine eligibility as described in
Compact Section VI.C. or work with the State Gaming Agency to verify Registration as
described in Compact Section VI.D.

(1)

(2)
AF
The options outlined in Compact Sections VI.B., C., and D. below are mutually
exclusive and cannot be utilized at the same time.

Transitioning between State Certification and Eligibility. The Tribal Gaming
Agency may choose to transition from State Certification to the Eligibility
Determination provisions of this Compact. The Tribal Gaming Agency agrees that
it will operate under the Eligibility Determination provisions for at least two (2)
years before returning to the State Certification provisions. If the Tribal Gaming
Agency chooses to return to the State Certification provisions after at least two (2)

DR (3)
years under the Eligibility Determination provisions, it agrees that it will operate
under the State Certification provisions for at least two (2) years before
transferring back to Eligibility Determination.

Transitioning from State Certification or Eligibility Determination to Registration.
If the Tribal Gaming Agency can demonstrate Tribal licensing expertise by
meeting all criteria required in Compact Section VI.D.(1) and the State Gaming
Agency verifies the Tribal Gaming Agency has met the criteria, the Tribal
Gaming Agency may choose to transition from State Certification or Eligibility
Determination to the Registration provisions of this Compact.

(a) The Tribal Gaming Agency must operate under the Registration
provisions for at least two (2) years before returning to the State
Certification or Eligibility Determination provisions. If the Tribal Gaming
Agency chooses to return to the Eligibility Determination or State
Certification provisions after at least two (2) years under the Registration

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 20
provisions, they must operate under the State Certification or Eligibility
Determination provisions for at least two (2) years before transferring
back to Registration.

(b) The Tribal Gaming Agency must demonstrate and verify that it meets all
criteria in Compact Section VI.D.(1), set out in the transition MOU and
every three (3) years thereafter.

(c) If the Tribe determines that the Tribal Gaming Agency no longer meets
the requirements set forth in Compact Section VI.D.(1), the Tribe will
immediately notify the State Gaming Agency of the Tribal Gaming
Agency’s plan to transition back to either a State Certification or
Eligibility Determination process and provide the State Gaming Agency

(d)
T
thirty (30) days’ notice to update their processes and reprogram their
systems.

If the State Gaming Agency finds the Tribal Gaming Agency no longer

(4)
AF
meets the requirements in Compact Section VI.D.(1), the State Gaming
Agency will immediately notify the Tribe and request a meeting to discuss
a transition plan back to either a State Certification or Eligibility
Determination process.

Submitting Transition Plan to State Gaming Agency.

(a) The Tribal Gaming Agency will submit the proposed transition date and
licensing and State Certification, Eligibility Determination, or Registration

DR (b)
plan to the State Gaming Agency at least ninety (90) days prior to
transitioning. The ninety (90) day period will provide the State Gaming
Agency time to reprogram their systems, properly train staff in the new
procedures, and allow time for the State Gaming Agency to verify the
Tribal Gaming Agency meets the Registration criteria.

When transitioning to Registration, the Tribal Gaming Agency must also
provide documentation in their transition plan of how it meets the criteria
in Compact Section VI.D.(1).

(c) When returning to a previous process, the Tribe will notify the State
Gaming Agency of their plan to transition to a previous process and
provide the State Gaming Agency thirty (30) days’ notice to update their
processes and reprogram their systems.

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 21
(5) Transition MOU. If the Tribe wishes to transition to another process, the Tribal
Gaming Agency and State Gaming Agency must enter an MOU (“Transition
MOU”) that includes at a minimum, transition date; fees; the submittal process for
State Certification, Eligibility Determination, or Registration verification; annual
review, including the timing, process, and any costs associated with such; and that
State Certification and Eligibility Determination applications and Registration
information must be submitted online. If the transition is to Registration, the
Transition MOU will also include the Tribal Gaming Agency’s verification that it
meets all criteria in Compact Section VI.D.(1). The MOU may be amended from
time to time and will remain in effect while the TGA operates under either the
Eligibility Determination or Registration verification process.

B. Gaming Employee State Certification

(1)
T
Tribal license and State Certification Required. Any employee who meets the
definition of Gaming Employee, regardless of the employee’s job title, must be
licensed by the Tribal Gaming Agency and relicensed annually, and must also

(2)

(3)
AF
receive State Certification from the State Gaming Agency and be recertified
annually.

The Tribal Gaming Agency may immediately issue a license if the Gaming
Employee has a current State Gaming license or State Certification issued by the
State Gaming Agency.

Procedures for Tribal License Applications and State Certification. Each
Applicant for a Tribal gaming license and for State Certification shall submit the

DR
completed State Certification application form along with the required
information to the Tribal Gaming Agency. Each completed application shall be
accompanied by the Applicants’ fingerprint card(s), Proof of Identity, and the fees
required by the State and Tribal Gaming Agencies. Upon receipt, the Tribal
Gaming Agency will transmit to the State Gaming Agency a copy of all
application materials for each Applicant to be certified, together with a set of
fingerprint cards, Proof of Identity, and the fees required. For Applicants who are
business entities, these provisions shall apply to the Principals and spouses of
such entities.

(4) Background Investigations of Applicants. Upon receipt of a completed
application, attachments and the fee required for State Certification, the State
Gaming Agency shall conduct the necessary background investigation to ensure
the Applicant is qualified for State Certification. Upon completion of the
necessary background investigation, the State Gaming Agency shall either issue a
State Certification or deny the application based on criteria set forth in this

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 22
Compact. If the State Gaming Agency issues a State Certification, the State
Gaming Agency shall forward the State Certification to the Tribal Gaming
Agency. If the application for State Certification is denied, a statement setting
forth the grounds for denial shall be forwarded to the Applicant in accordance
with the provisions of Chapter 230-17 WAC, with a copy forwarded to the Tribal
Gaming Agency. The State Gaming Agency shall not apply to any Applicant for
State Certification required under this Compact a more rigorous standard than that
actually applied in the approval of State Gaming Agency licenses or State
Certifications in non-tribal Gaming activities regulated by the State Gaming
Agency. All background materials compiled by the State Gaming Agency in
connection with the background investigation of any Applicant for State
Certification shall be available to the Tribal Gaming Agency at the State Gaming

T
Agency office upon request, subject to any constraints imposed by the State
Gaming Agency’s accreditation as a law enforcement agency, requirements under
RCW 9.46.210(4) and RCW 10.97, and status as a member of a law enforcement
intelligence sharing organization, such as the Law Enforcement Intelligence Unit

(5)

AF
(LEIU), Fusion Centers, INTERPOL, and similar organizations.

Grounds for Revocation, Suspension, or Denial of State Certification. The State
Gaming Agency may revoke, suspend or deny a State Certification under the
provisions of RCW 9.46.075, and rules promulgated thereunder, for any reason or
reasons it deems to be in the public interest. In addition, these reasons shall
include, but shall not be limited to when an Applicant or holder of a State
Certification or Principal of an entity:

DR
(a)

(b)
Is determined to be a person who, because of prior activities, criminal
record (if any) or reputation, habits or associations poses a threat to the
effective regulation of Gaming or creates or enhances the chances of
unfair or illegal practices, methods, and activities being used in the
conduct of the Gaming activities permitted pursuant to this Compact.

Has violated, failed or refused to comply with the provisions,
requirements, conditions, limitations or duties imposed by any provision
of a tribal-state compact.

(c) Has failed to provide any information reasonably required to investigate
the application for State Certification or to reveal any fact which the
Applicant or holder of State Certification knows or should reasonably
know or is material to such application or has furnished any information
which is untrue or misleading in connection with such application.

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 23
(d) Has had a tribal or State gaming license revoked or denied during the
twelve (12) months prior to the date the Tribe received the application; is
currently on probation imposed by any jurisdiction; or has demonstrated a
willful disregard or failed to comply with the requirements of any Gaming
regulatory authority in any jurisdiction, including offenses that could
subject the Individual to suspension, revocation or forfeiture of any
gaming license. For the purpose of reviewing any application for a State
Certification or for considering the denial of the application, or suspension
or revocation of any State Certification, the State Gaming Agency may
consider any prior criminal conduct or current probationary status of the
Applicant or holder of State Certification and the provisions of RCW
9.95.240 and RCW 9.96A shall not apply to such cases.

(e)
T
Notwithstanding anything herein to the contrary, in the absence of other
violations, it shall not automatically be grounds for revocation, suspension
or denial for an Indian person from a federally recognized tribe to have
been charged or convicted under State law of the following non-gambling

AF
related offenses if the charge or conviction occurred prior to United States
Supreme Court rulings clarifying State jurisdiction over Indians for such
offenses as, but not limited to: (1) fishing or hunting offenses; (2)
cigarette, fireworks or alcohol sales offenses; or (3) cases involving the
exercise of trust or treaty rights. In the absence of other violations,
activities or factors which would warrant denial, revocation or suspension,
these Indian persons shall not be barred solely as a result of such activities
from State Certification.

DR
(f) The State Gaming Agency will consult with the Tribal Gaming Agency
prior to denying State Certification to such an Applicant who does not
meet the criteria for State Certification. For enrolled members of the Tribe
who are Applicants for State Certification, and licensing, the State and
Tribal Gaming Agencies may waive, by mutual agreement, through a
provisional or conditional State Certification, certain criteria for such
enrolled Tribal Members if the waiver does not pose an appreciable risk to
the public or the lawful operation of the Gaming Facility. If the Tribal
Gaming Agency can show extenuating circumstances why an enrolled
Tribal Member who does not meet all criteria should be further considered
for a provisional or conditional State Certification, the Tribal and State
Gaming Agencies may agree to a temporary State Certification, based on
specific conditions and a further detailed review of the Applicant.
Additional fees may be required to maintain a conditional or provisional
State Certification, which the Tribe agrees to pay.

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 24
(6) Right to Hearing for Revocation, Suspension, or Denial of State Certification. If
an application has not been withdrawn by the Tribal Gaming Agency during the
State Certification review process, any Applicant or holder of a State Certification
shall be entitled to notice and a full hearing on any action by the State Gaming
Agency which may result in the revocation, suspension, or denial of State
Certification. The notice and hearing will be conducted in accordance with the
procedures contained in the applicable provisions of RCW 9.46, RCW 34.05, and
WAC 230-17, and the records involved shall be governed by the definitions set
out in RCW 10.97.030. The SGA shall notify the TGA of any determination
under this subsection. The State Gaming Agency, may at its discretion, defer such
actions to the Tribal Gaming Agency. Nothing herein shall prevent the Tribal
Gaming Agency from invoking its own disciplinary procedures and proceedings

(7)
at any time.

T
Denial, Suspension, or Revocation of Licenses Issued by Tribal Gaming Agency.
The denial, suspension, or revocation of any Tribal gaming license by the Tribal
Gaming Agency shall be in accordance with Gaming Code and regulations

(8)
AF
governing such procedures and the grounds for such actions shall not be less
stringent than those of Compact Section VI.B.(5). The Tribe shall notify the State
Gaming Agency of any determination under this paragraph.

Duration and Renewal of Tribal Issued Licenses and State Certifications. Any
Tribal license or State Certification shall be effective for one year from the date of
issuance of the license, State Certification, or temporary license or State
Certification, unless otherwise revoked or suspended. A Gaming Employee who

DR
has applied for renewal prior to expiration may continue to be employed under the
expired Tribal license or State Certification or State Gaming license until the
Tribal Gaming Agency or State Gaming Agency takes action on the renewal
application or the State Certification or license is suspended or revoked.
Applicants seeking renewal of license or State Certification shall provide
information updating originally submitted information as requested, on the
appropriate renewal forms, but shall not be required to re-submit historical data
already available to the Tribal Gaming Agency or the State Gaming Agency. An
additional background investigation shall be required if new information
concerning the Applicant’s continuing suitability or eligibility for a Tribal license
or a State Certification is discovered by either the Tribal or State Gaming Agency.
The State Gaming Agency shall forward a copy of any updated information to the
Tribal Gaming Agency, subject to any constraints imposed by the State Gaming
Agency’s accreditation as a law enforcement agency, requirements under RCW
9.46.210(4) and RCW 10.97, and status as a member of a law enforcement

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 25
intelligence sharing organization, such as the Law Enforcement Intelligence Unit
(LEIU), Fusion Centers, INTERPOL, and similar organizations.

(9) Exchange of Tribal Licensing and State Certification Information. In an effort to
ensure a qualified work force in all areas of Class III Gaming and in all types of
gambling authorized under the laws of the State, any administrative action or
legal proceeding against a Tribal license or State Certification will be
communicated to either the State Gaming Agency or Tribal Gaming Agency, and
the final disposition shall be forwarded to either the Tribal Gaming Agency or the
State Gaming Agency and maintained in accordance with each agency’s
respective record retention requirements for licensing records.

(10) Fees For Tribal License. The Tribal Gaming Agency shall establish the fees for

(11)
Tribal gaming licenses.

T
Summary Suspension of Tribal License. The Tribal Gaming Agency, pursuant to
the laws and regulations of the Tribe, may summarily suspend any Tribal license

(12)

(13)
AF
if the continued licensing of a person or entity constitutes an immediate and
potentially serious threat to the public health, safety, or welfare.

Summary Suspension of State Certification. The State Gaming Agency, pursuant
to RCW 9.46 and WAC 230-17, may summarily suspend any State Certification if
the continued State Certification constitutes an immediate and potential serious
threat to public health, safety, or welfare.

Submission to State Administrative Process. Applicants for State Certification

DR
agree by submitting such application to submit to State jurisdiction to the extent
necessary to determine qualification to hold such State Certification, including all
necessary administrative procedures, hearings and appeals pursuant to RCW 9.46,
WAC 230-17, and the State Administrative Procedures Act, RCW 34.05. Tribal
Members who apply specifically grant a waiver of immunity, defense, or other
objection they might otherwise have to the exercise of State jurisdiction for these
purposes, but only for the purposes discussed in this paragraph. Nothing in this
Section shall be deemed or interpreted as a waiver of immunity or submission to
State jurisdiction for any other purpose or cause of action.

(14) Tribal Certification. The Tribal Gaming Agency may, in its sole election, rely
upon the State Certification of the State Gaming Agency as the Tribe’s
qualification process for a Tribal gaming license.

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 26
C. Gaming Employee Eligibility Determination

(1) Every Gaming Employee shall be licensed by the Tribal Gaming Agency prior to
commencement of employment and at a maximum of every three (3) years
thereafter. Every Gaming Employee eligible for a license shall be verified by the
State Gaming Agency prior to commencement of employment and annually
thereafter. Eligibility Determinations are non-transferable.

(2) The Tribal Gaming Agency may immediately issue a license if the Gaming
Employee has a current State Gaming license or State Certification.

(3) Any employee that meets the definition of Gaming Employee, regardless of the
employee’s job title, must be licensed by the Tribal Gaming Agency and must

(4) T
also receive an Eligibility Determination from the State Gaming Agency.

The Tribal Gaming Agency shall submit a list of the licensed and temporarily
licensed Gaming Employees to the State Gaming Agency at least annually. The

(5)
AF
Tribal Gaming Agency shall include the licensee’s complete name, aliases, and
date of birth in its submission to the State Gaming Agency.

Tribal Application Forms. Application forms shall include, at a minimum, the
information required on State Certification applications and any additional
information required by the Tribal Gaming Agency. All Applicants required to be
licensed by the Tribe shall complete forms furnished by the Tribal Gaming
Agency and must provide information relating to their complete criminal history,
as well as all civil or administrative violations of gambling laws or regulations.

DR (6)
Completed forms shall be accompanied by the application and investigative fees
set forth in the Tribal Gaming Agency’s published schedule of fees.

Procedures for Tribal License Applications. The Tribal Gaming Agency shall be
primarily responsible for the conduct of background investigations for all
Applicants for Gaming Employee licenses. Each Applicant for a Tribal Gaming
Employee license shall submit the completed application along with the required
information and fees to the Tribal Gaming Agency. Each completed application
shall include the Applicant’s fingerprint card(s), Proof of Identity, and any other
information required by the Tribal Gaming Agency.

(7) Background Investigations of Gaming Employee Applicants.

(a) Prior to hiring or licensing a prospective Gaming Employee, the Tribal
Gaming Agency shall obtain sufficient information and identification from
the Applicant on forms to be furnished by the Tribal Gaming Agency to

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 27
permit a thorough background investigation, together with such fees as
may be required by the Tribal Gaming Agency. The information obtained
shall include, at a minimum, name (including any aliases), current address,
date and place of birth, criminal arrest and conviction record, two sets of
fingerprints, sex, height, weight, and Proof of Identity.

(b) When the Tribal Gaming Agency has completed its initial investigation of
the Applicant, and has issued a temporary license, it will, within five (5)
business days, forward the application; Judicial Information System (JIS)
results or its electronic equivalent; a set of fingerprint cards; Proof of
Identity; and the fee required to the State Gaming Agency for a final
criminal history record and non-conviction data review, as authorized
under RCW 9.46.210(4) and as defined in RCW 10.97.030.

(c)
T
The State Gaming Agency shall complete the Eligibility Determination.
The State Gaming Agency may find an Applicant ineligible under the
provisions of RCW 9.46.075, and rules promulgated thereunder, for any

AF reason or reasons it deems to be in the public interest. In addition, these
reasons shall include, but shall not be limited to when an Applicant or
holder of an Eligibility Determination:

i. Is determined to be a person who because of prior activities, criminal
record, if any, or reputation, habits or associations poses a threat to the
effective regulation of Gaming or creates or enhances the chances of
unfair or illegal practices, methods, and activities being used in the

DR
ii.

iii.

iv.
conduct of the Gaming activities permitted pursuant to this Compact;

Has violated, failed or refused to comply with the provisions,
requirements, conditions, limitations, or duties imposed by any
provision of a tribal-state compact;

Has failed to provide any information reasonably required to
investigate the application;

Has failed to reveal any fact which the Applicant or holder knows or
should reasonably know is material to such application;

v. Has furnished any information which is untrue or misleading in
connection with such application; or

vi. Has had a Tribal gaming license, State gaming license, or State
Certification revoked or denied during the twelve (12) months prior to

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 28
the date the State Gaming Agency received the application; is
currently on probation imposed by any jurisdiction; or has
demonstrated a willful disregard or failed to comply with the
requirements of any Gaming regulatory authority in any jurisdiction,
including offenses that could subject the Individual to suspension,
revocation or forfeiture of any Gaming license. For the purpose of
reviewing any application for Eligibility Determination or for
considering the denial, suspension or revocation of any Eligibility
Determination, the State Gaming Agency may consider any prior
criminal conduct or current probationary status of the Applicant or
holder of an Eligibility Determination and the provisions of RCW
9.95.240 and RCW 9.96A shall not apply to such cases.

(d)
T
The State Gaming Agency shall notify the Tribal Gaming Agency that
either: (1) the criminal history and non-conviction data review has
revealed no information which would make the Applicant ineligible for
employment pursuant to Compact Section VI.C.(7)(c); or (2) the criminal

(e) AF
history and non-conviction data review has revealed that the Applicant is
ineligible for employment pursuant to Compact Section VI.C.(7)(c).

The State Gaming Agency will consult with the Tribal Gaming Agency
prior to issuing an ineligibility determination for Tribal Members after a
criminal history and non-conviction data review. For Tribal Members who
are Applicants for Eligibility Determination, the State and Tribal Gaming
Agencies may waive, by mutual agreement, through a conditional Tribal

DR
license, certain criteria for such Tribal Members if the waiver does not
pose an appreciable risk to the public or the lawful operation of the
Gaming Facilities. If the Tribal Gaming Agency can show extenuating
circumstances why a Tribal Member who does not meet all criteria should
be further considered for a conditional Tribal license, the Tribal and State
Gaming Agencies may agree that the State Gaming Agency will issue an
Eligibility Determination with the conditional Tribal license, based on
specific conditions and a further detailed review of the Applicant.
Additional fees may be required to maintain a conditional Tribal license,
which the Tribal Gaming Agency agrees to pay.

(f) An Applicant or Gaming Employee who has been determined ineligible
for licensing by the State Gaming Agency after criminal history and non-
conviction data review will not be licensed by the Tribal Gaming Agency
except in conformity with Compact Section VI.C.(7)(e).

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 29
(g) All background materials compiled by the State Gaming Agency in
connection with the background investigation of any Applicant for Tribal
Licensing or State Gaming Agency Eligibility Determination verification
shall be available to the Tribal Gaming Agency at the State Gaming
Agency office upon request, subject to any constraints imposed by the
State Gaming Agency's accreditation as a law enforcement agency,
requirements under RCW 9.46.210(4) and RCW 10.97, and status as a
member of a law enforcement intelligence sharing organization, such as
the Law Enforcement Intelligence Unit (LEIU), Fusion Centers,
INTERPOL, and similar organizations.

(h) The State Gaming Agency’s determination of a Gaming Employee’s
eligibility for a tribal license is valid at the Tribe’s Gaming Facilities only

(i)
and is non-transferable.
T
The gaming operation shall not hire or continue to employ a Gaming
Employee, and shall terminate any probationary Gaming Employee, if the

AFi.
Tribal Gaming Agency determines that the Applicant or Gaming
Employee:

Has been convicted of any offense related to gambling, or any felony
relating to fraud, misrepresentation, deception or theft, within the past
ten (10) years. Nothing herein shall be interpreted to prevent the Tribal
Gaming Agency and/or the State Gaming Agency from considering
such juvenile convictions in a suitability determination, nor shall be

DR ii.

iii.
interpreted to excuse the Applicant of its obligation to disclose
juvenile convictions or arrests;

Has provided materially false statements or information on their
application or misstated or otherwise attempted to mislead the Tribal
Gaming Agency or the State Gaming Agency with respect to any
material fact contained in the application;

Is a member or associate of organized crime or is of notorious or
unsavory reputation; or

iv. Has a reputation, habits or associations that might pose a threat to the
public interest or to the effective regulation and control of Gaming, or
create or enhance the dangers of unsuitable, unfair, or illegal practices,
methods and activities in the conduct of Gaming or the carrying on of
the Tribal and financial arrangements incidental thereto. It is intended
that Applicants and Gaming Employees have the continuing burden to

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 30
satisfy all doubts as to their fitness. Where doubt remains, an
Applicant or Gaming Employee is not entitled to be hired or to remain
employed.

(j) Additionally, the Tribal Gaming Agency shall not grant a license to an
Applicant unless it is satisfied that:

i. The Applicant is of good character, honesty, and integrity;

ii. The Applicant’s prior activities, criminal record (if any), reputation,
habits, or associations do not pose a threat to the public interest of the
Tribe or the State or the effective regulation and control of Gaming
pursuant to this Compact, or create or enhance the dangers of

T
unsuitable, unfair or illegal practices, methods, and activities in the
conduct of Gaming or the carrying on of the Tribal and financial
arrangements incidental thereto;

(8)
AF
iii.

iv.
In all other respects, the Applicant is qualified to be licensed or found
suitable with the provisions and policies set forth in this Compact; and

The Applicant has adequate Tribal probity, competence, and
experience in Gaming.

Background Investigations of Gaming Employees. The Tribe and the State
Gaming Agency shall retain the right to conduct such additional background
investigations of any Gaming Employee at any time during the term of that

DR (9)
person’s employment. At any time, any Gaming Employee who does not establish
that they satisfy all the criteria set forth above shall be determined ineligible for
licensing and processed as outlined in Compact Section VI.C.(7) above.

Denial, Suspension, or Revocation of Licenses Issued by Tribal Gaming Agency.
The denial, suspension, or revocation of any Tribal gaming license by the Tribal
Gaming Agency shall be in accordance with Gaming Code and regulations
governing such procedures and the grounds for such actions shall not be less
stringent than those of Compact Section VI.C.(7)(c). The Tribe shall notify the
State Gaming Agency of any determination under this paragraph.

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 31
(10) Duration and Renewal of Tribal Issued Licenses and Eligibility Determinations.

(a) Any Tribal license shall be effective for no longer than three (3) years
from the date of issuance unless the holder is otherwise revoked or
suspended.

(b) The Eligibility Determination shall be effective for one year from the date
of Eligibility Determination letter issuance. Should the Tribal licensee
become ineligible during the licensure period, the Tribal Gaming Agency
may either revoke the Tribal license or request that the Tribal Gaming
Agency and State Gaming Agency agree to mutually waive disqualifying
criteria based on the conditional tribal license as outlined in Compact
Section VI.C.(7)(e).

(c)
T
A licensed Gaming Employee that has applied for renewal prior to
expiration may continue to be employed under the expired Tribal license
or Eligibility Determination until the Tribal Gaming Agency or State

AF
Gaming Agency takes action on the renewal application or the license is
suspended or revoked. Applicants seeking renewal of a license, Eligibility
Determination, or State Certification shall provide information updating
originally submitted information as requested, on the appropriate renewal
forms, but shall not be required to re-submit historical data already
available to the Tribal Gaming Agency or the State Gaming Agency. An
additional background investigation shall be required if new information
concerning the Applicant’s continuing suitability or eligibility for a Tribal

DR (11)
license, or a State Certification is discovered by either the Tribal or State
Gaming Agency. The State Gaming Agency shall forward a copy of any
updated information to the Tribe, subject to any constraints imposed by
the State Gaming Agency’s accreditation as a law enforcement agency,
requirements under RCW 9.46.210(4) and RCW 10.97, and status as a
member of a law enforcement intelligence sharing organization, such as
the Law Enforcement Intelligence Unit (LEIU), Fusion Centers,
INTERPOL, and similar organizations.

Exchange of Tribal Licensing Information. In an effort to ensure a qualified work
force in all areas of Class III Gaming, and in all types of gambling authorized
under the laws of the State, any administrative action or legal proceeding against a
Tribal license will be communicated to the State Gaming Agency, and the final
disposition shall be forwarded the State Gaming Agency and maintained in
accordance with the agency’s record retention requirements for licensing records.

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 32
(12) Fees for State Eligibility Determination. The fees for initial and the renewal of
State Eligibility Determination and fees to cover costs to transition between State
Certification, Eligibility Determination and Registration are included in Compact
Section VII.

(13) Fees for Tribal License. The Tribal Gaming Agency shall establish the fees for
Tribal gaming licenses.

(14) Summary Suspension of Tribal License. The Tribal Gaming Agency, pursuant to
Gaming Code and regulations, may summarily suspend any Tribal license if the
continued licensing of a person or entity constitutes an immediate and potentially
serious threat to the public health, safety or welfare.

(15)

T
Annual Onsite Review. The State Gaming Agency will conduct an annual onsite
review in a specific quarter of each calendar year determined in the MOU. The
State Gaming Agency will randomly review the applications and background
information of up to ten percent (10%) of the Eligibility Determinations issued the

D.
AF
previous year and verify original Tribal Gaming Agency records with those
submitted by Tribal Gaming Agency. During this time, the State Gaming Agency
may conduct additional background investigations on Gaming Employees, which
may include, but not be limited to, fingerprinting. If, based upon such random
review, the State Gaming Agency finds discrepancies in the records, the State
Gaming Agency will immediately notify Tribal Gaming Agency.

Gaming Employee Registration

DR
(1) Criteria

Gaming Employee Registration requires the Tribal Gaming Agency to
demonstrate Tribal Licensing expertise without substantial or repeated, material
discrepancies in conducting Gaming Employee background investigations. In
order to qualify for Gaming Employee Registration, the following criteria must be
met:

(a) The Tribe has operated Class III Gaming and the Tribal Gaming Agency
has licensed Gaming Employees for at least 20 years; and

(b) The Tribal Gaming Agency regulations are regularly reviewed and
updated; and

(c) The Tribal Gaming Agency director has demonstrated active involvement
with licensing denial, suspension, and revocation in accordance with the
Tribe’s Gaming Code; and

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 33
(d) The Tribal Gaming Commission has demonstrated a history of active
involvement in the licensing process and license appeal hearings; and

(e) Tribal Gaming Agency licensing staff are fully versed in the Judicial
Information System (JIS) including the Superior Court Management
Information System (SCOMIS) or equivalent systems; and

(f) Tribal Gaming Agency licensing staff reviews all Gaming Employee
information provided in JIS, FBI records, and Lexis Nexis reports or
equivalent systems.

The Tribe has demonstrated it meets all the criteria above as required in Compact
Section VI.A.(3) and documented it in the transition MOU.

(2) Overview

(a)
T
Every Gaming Employee shall be licensed by the Tribal Gaming Agency
prior to commencement of employment and at least every three (3) years

(b)
AF
thereafter. Every Gaming Employee must be registered with the State
Gaming Agency and shall have their Gaming Employee Registration
verified by the State Gaming Agency annually. Registration verifications
are non-transferable.

The Tribal Gaming Agency may immediately issue a license if the
Gaming Employee has a current State Gaming license or State
Certification issued by the State Gaming Agency.

DR
(c)

(d)
Any employee that meets the definition of Gaming Employee, regardless
of the employee’s job title, must be licensed by the Tribal Gaming Agency
and must also receive Registration verification from the State Gaming
Agency.

The Tribal Gaming Agency shall provide a list of licensed and temporarily
licensed Gaming Employees to the State Gaming Agency during the
annual comparison review in the quarter of each calendar year as
determined in the MOU. The Tribal Gaming Agency shall include the
licensee’s complete name, aliases, date of birth, and identification number
unique to the Individual’s tribal license in its submission to the State
Gaming Agency.

(e) The Tribal Gaming Agency, pursuant to the Gaming Code and regulations,
may summarily suspend any Tribal license if the continued licensing of a

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 34
person or entity constitutes an immediate and potentially serious threat to
the public health, safety or welfare.

(f) Tribal Gaming Employees shall be licensed by the Tribal Gaming Agency
in accordance with the Gaming Code and regulations.

(g) The Tribal Gaming Agency shall establish the fees for Tribal gaming
licenses.

(h) In order to ensure a qualified work force is maintained throughout the
State in all areas of Class III Gaming as well as in all other types of
gambling authorized in the State, the Tribal Gaming Agency will forward
to the State Gaming Agency a copy of the final disposition of any

(3)
T
administrative action or legal proceeding taken by the Tribal Gaming
Agency against a Tribal Gaming license holder.

Respective Roles for Background Investigations for Tribal Gaming Employee

AF
Licenses and State Registration

(a)

ii.
Tribal Gaming Agency:

The Tribal Gaming Agency will be responsible for the issuance of all
Tribal Gaming Employee licenses.

The Tribal Gaming Agency shall be primarily responsible for
conducting background investigations for all Applicants for Tribal

DR iii.
Gaming Employee licenses. Each Applicant for a Tribal Gaming
Employee license shall submit the completed application along with
the required information and fees to the Tribal Gaming Agency.

Each completed application at a minimum shall include:

1) Personal Information, including at least the following:

a. complete name, aliases,

b. date of birth,

c. current address, and

d. Proof of Identity;

2) Fingerprint card(s);

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 35
3) Information relating to the Applicant’s complete criminal history,
as well as all civil or administrative violations of gambling laws or
regulations; and

4) Any other information required by the Tribal Gaming Agency.

iv. The Gaming Operation shall not hire, or continue to employ a Gaming
Employee, and shall terminate any Gaming Employee, if the Tribal
Gaming Agency determines that the Applicant or Gaming Employee:

1) Has been convicted of any offense related to gambling, or any
felony relating to fraud, misrepresentation, deception, theft, or
physical harm to a person within the past ten (10) years;

2)
T
Has provided materially false statements or information on the
person’s application or misstated or otherwise attempted to
mislead the Tribal Gaming Agency or the State Gaming

AF 3)

4)
Agency with respect to any material fact contained in the
application;

Is a member or associate of organized crime or is of notorious
or unsavory reputation; or

Has a reputation, habits or associations that might pose a threat
to the public interest or to the effective regulation and control
of Gaming, or create or enhance the dangers of unsuitable,

DR v.

vi.
unfair, or illegal practices, methods and activities in the
conduct of Gaming or the carrying on of the Tribal and
financial arrangements incidental thereto.

It is intended that Applicants and Gaming Employees have the continuing
burden to satisfy all doubts as to their fitness. Where doubt remains, an
Applicant or Gaming Employee is not entitled to be hired or to remain
employed.

Nothing herein shall be interpreted to prevent the Tribal Gaming Agency
from considering juvenile convictions in a suitability determination, nor
shall be interpreted to excuse the Applicant of its obligation to disclose
juvenile convictions or arrests.

vii. Additionally, the Tribal Gaming Agency shall not grant an application for
a license unless it is satisfied that the Applicant’s prior activities, criminal
record (if any), reputation, habits, or associations do not pose a threat to

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 36
the public interest of the Tribe or the State or the effective regulation and
control of Gaming pursuant to this Compact, or create or enhance the
dangers of unsuitable, unfair or illegal practices, methods, and activities in
the conduct of Gaming or the carrying on of the Tribal and financial
arrangements incidental thereto.

viii. When the Tribal Gaming Agency has completed its investigation of the
Gaming Employee Applicant and has issued a temporary license, it will
within five (5) business days:

1) Register online with the State Gaming Agency a new or renewing
Gaming Employee or notify the State Gaming Agency of a Change
of Name and pay the respective fees; or

2)
T
Mail a new or renewal Gaming Employee Registration or Change
of Name application with respective fees.

ix.

x.
AF The Registration will include the Tribal Gaming Agency’s Investigative
Report; the Applicant’s personal information; identification number
unique to the Individual’s tribal license; results of the investigation; Proof
of Identity; two sets of fingerprints; JIS results or its electronic equivalent,
and the applicable fees to the State Gaming Agency.

The Tribal Gaming Agency will use the State Gaming Agency’s online
process to notify the State Gaming Agency when a Gaming Employee is
no longer employed and/or licensed by the Tribal Gaming Agency.

DR
(b) The State Gaming Agency

ii.
The State Gaming Agency will conduct an annual verification of
Gaming Employee Registrations that are received either online or by
mail.

The State Gaming Agency will complete the verification and notify the
Tribal Gaming Agency if the results indicate the person may be
unqualified pursuant to this Section of this Compact. If the State
Gaming Agency does not object, the Gaming Employee Registration
will expire no later than three (3) years from the date of the Gaming
Employee Registration, or upon notification of a tribal license
revocation, or the person is no longer licensed by the Tribal Gaming
Agency, whichever occurs earlier.

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 37
iii. The State Gaming Agency retains the right to conduct an additional
verification of Gaming Employee Registration of any Gaming
Employee at any time. There will be no additional cost to the Tribe.

iv. The State Gaming Agency’s verification of the Gaming Employee’s
Registration is valid at the Tribe’s Gaming Facilities only and is non-
transferable.

v. For verification of Gaming Employee Registration, the State Gaming
Agency may consider any prior criminal conduct or current
probationary status of the Gaming Employee, and the provisions of
RCW 9.95.240 and of Chapter 9.96A RCW shall not apply to such
cases.

vi.
T
The Gaming Employee Registration will also include information as
authorized under RCW 9.46.210(4) and as defined in RCW 10.97.030.

AF
vii. The State Gaming Agency may find a person to be unqualified under
the provisions of RCW 9.46.075 and rules promulgated thereunder.
The State Gaming Agency may also find a person to be unqualified if
such person has engaged in an activity contrary to the public interest,
including but not limited to the following:

1) Who, because of prior activities, criminal record, if any, or
reputation, habits, or associations, poses a threat to the
effective regulation of Gaming or creates or enhances the

DR 2)

3)
chances of unfair or illegal practices, methods, and activities
being used in the conduct of the Gaming activities permitted
pursuant to this Compact;

Has violated, failed or refused to comply with the provisions,
requirements, conditions, limitations or duties imposed by any
provision of a Tribal-State Compact;

Has failed to provide any information reasonably required for
Gaming Employee Registration;

4) Has failed to reveal any fact which the person knows or should
reasonably know is material to Gaming Employee Registration;

5) Has furnished anything untrue or misleading in connection
with Gaming Employee Registration information;

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 38
6) Has had a Gaming license suspended for a year or longer,
revoked or denied during the twelve (12) months prior to the
date of Gaming Employee Registration with the State Gaming
Agency; is currently on probation imposed by any jurisdiction;
or has demonstrated a willful disregard or failed to comply
with the requirements of any Gaming regulatory authority in
any jurisdiction, including offenses that could subject the
Individual to suspension, revocation or forfeiture of any
Gaming license; or

7) Has demonstrated a willful disregard or failed to comply with
the requirements of any Gaming regulatory authority in any
jurisdiction, including offenses that could subject the person to

viii.
T
suspension, revocation or forfeiture of any Gaming license.

The State Gaming Agency will work with the Tribal Gaming Agency
when determining whether a person may be unqualified for Gaming

AF
ix.
Employee Registration.

If a person may be unqualified for Gaming Employee Registration, the
materials compiled by the State Gaming Agency will be available to
the Tribal Gaming Agency at the State Gaming Agency office upon
request, subject to any constraints imposed by the State Gaming
Agency’s accreditation as a law enforcement agency, requirements
under RCW 9.46.210(4) and RCW 10.97, and status as a member of

DR x.
the Association of a law enforcement intelligence sharing
organization, such as the Law Enforcement Intelligence Unit (LEIU),
Fusion Centers, INTERPOL, and similar organizations.

State Gaming Agency licensing personnel and Tribal Gaming Agency
representatives will conduct an annual Gaming Employee comparison
review in a specific quarter of each calendar year determined in the
MOU. This review will ensure that State Gaming Agency and Tribal
Gaming Agency Gaming Employee records agree with one another.
Any discrepancies found will be resolved by the Tribal Gaming
Agency, and notification provided to the State Gaming Agency.
Unresolved discrepancies will be resolved in accordance with
Compact Section XIII. The Tribal Gaming Agency and the State
Gaming Agency will update their respective records as needed.

xi. The State Gaming Agency will conduct an annual comparison review
in a specific quarter of each calendar year determined in the MOU, to

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 39
include random sampling of Gaming Employee applications to
demonstrate all the criteria for licensure and Gaming Employee
Registration as set forth in this Compact have been met.

i. A licensed Gaming Employee seeking renewal of their Gaming
Employee license or re-registering with the State Gaming Agency
shall update information originally submitted, as requested, on the
appropriate renewal forms, but shall not be required to re-submit
historical data already available to the Tribal Gaming Agency or State
Gaming Agency. A Gaming Employee who has applied for renewal
prior to expiration may continue to work under the expired Tribal

ii.
T
license until the Tribal Gaming Agency or State Gaming Agency takes
action on the renewal application.

For persons found to be unqualified at any time they are registered by

AF the State Gaming Agency, the Tribal Gaming Agency and State
Gaming Agency will work together to determine if the person should
work for the Tribe’s Gaming Facilities in a position that requires a
Gaming Employee License. If the Tribe can show extenuating
circumstances why a person who does not meet all criteria should be
further considered, the Tribal Gaming Agency may waive, through a
conditional Gaming Employee License, if the waiver of certain criteria
does not pose an appreciable risk to the public or the lawful operation

DR iii.
of the Gaming Facilities or meet the criteria under Compact Section
VI.D.(3)(a)iv.

If, after working with the Tribal Gaming Agency, the State Gaming
Agency still finds the person unqualified, the State Gaming Agency
will provide written notice to the Tribe itemizing the objections. The
Tribe, however, will make the final decision whether to issue a license
or continue employment of the person. The State Gaming Agency’s
Gaming Employee Registration of the person will be limited to the
Tribe only, and the Tribe will continue to register the person with the
State Gaming Agency as long as the person is employed by the Tribe
in a Class III Gaming position.

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 40
E. State Role for Issuing State Certification of Manufacturers and Suppliers of Gaming
Services and Financiers

(1) Process

(a) The State Gaming Agency shall be primarily responsible for conducting
background investigations for all who apply for financier, manufacturer,
and/or supplier of Gaming Services certification and their representatives.
Each completed application for a financier, manufacturer, and/or supplier
of Gaming Services Tribal Gaming license submitted to the Tribal Gaming
Agency will include the required information and fees, as set by the Tribal
Gaming Agency. In addition, each financier, manufacturer, and/or supplier
of Gaming Services and their representatives shall apply for State

T
Certification and shall submit the completed application(s) along with the
required information and fees to the State Gaming Agency. Each
completed application shall include fingerprint card(s), Proof of Identity,
and any other information required by the State Gaming Agency. For

(b)
AF
business entity applications, these provisions shall also apply to Principals
of the entity and their spouses, who must be able to meet the same State
Certification requirements and who may be required to submit this
information.

Upon completion of the necessary background investigation, the State
Gaming Agency shall either issue a State Certification to the financier,
manufacturer, and/or supplier of Gaming Services or deny the

DR (c)

(d)
application(s) based on criteria set forth in this Compact and/or RCW 9.46
and WAC 230-17.

Each manufacturer and supplier of Gaming Services shall obtain a State
Certification and Tribal License before the sale or installation of any
Gaming Services, except as provided under Compact Section V.D.

If a financier is licensed by the State Gaming Agency, it will be deemed
certified.

(2) Duration and Renewal of Tribal Issued Licenses and State Certifications.

(a) Any Tribal license or State Certification shall be effective for one year
from the date of issuance of the license or State Certification, unless the
holder is otherwise revoked or suspended.

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 41
(b) Applicants seeking renewal of a license or State Certification shall provide
information updating originally submitted information as requested, on the
appropriate renewal forms, but shall not be required to re-submit historical
data already available to the Tribal Gaming Agency or the State Gaming
Agency. Additional background investigation shall be required if new
information concerning the applicant’s continuing suitability or eligibility
for a Tribal license or a State Certification is discovered by either the
Tribal or State Gaming Agency. Any updated information received by the
State Gaming Agency shall be available to the Tribal Gaming Agency at
the State Gaming Agency’s office upon request, subject to any of the
constraints imposed by the State Gaming Agency’s accreditation as a law
enforcement agency, requirements under RCW 9.46.210(4) and RCW

(3)
T
10.97, and status as a member of a law enforcement intelligence sharing
organization, such as the Law Enforcement Intelligence Unit (LEIU),
Fusion Centers, POL, and similar organizations.

Grounds for Revocation, Suspension, or Denial of State Certification

(a)

AF The State Gaming Agency may deny, suspend, or revoke a State
Certification under the provisions of RCW 9.46.075, and rules
promulgated thereunder, for any reason or reasons it deems to be in the
public interest. In addition, these reasons shall include, but shall not be
limited to, when an Applicant or holder of a State Certification or
Principal of an entity:

DR
i.

ii.
Is determined to be a person who, because of prior activities,
criminal record, if any, or reputation, habits, or associations, poses
a threat to the effective regulation of Gaming or creates or
enhances the chances of unfair or illegal practices, methods, and
activities being used in the conduct of the Gaming activities
permitted pursuant to this Compact;

Has violated, failed, or refused to comply with the provisions,
requirements, conditions, limitations, or duties imposed by any
provision of a Tribal-State Compact;

iii. Has failed to provide any information reasonably required to
investigate the application for State Certification;

iv. Has failed to reveal any fact which the Applicant or holder knows
or should reasonably know is material to such application;

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 42
v. Has furnished any information which is untrue or misleading in
connection with such application; or

vi. Has had a Tribal or State Gaming license or State Certification
revoked or denied during the twelve (12) months prior to the date
the State Gaming Agency received the application; is currently on
probation imposed by any jurisdiction; or has demonstrated a
willful disregard or failed to comply with the requirements of any
Gaming regulatory authority in any jurisdiction, including offenses
that could subject the Individual to suspension, revocation, or
forfeiture of any Gaming license. The Tribal Gaming Agency will
forward to the State Gaming Agency a copy of the final disposition
of any administrative action or legal proceeding taken by the Tribal

(b)
T
Gaming Agency against a Tribal license issued to a financier,
manufacturer, and/or supplier of Gaming Services.

For the purpose of reviewing any application for State Certification or for

(c)
AFconsidering the denial, suspension, or revocation of any State
Certification, the State Gaming Agency may consider any prior criminal
conduct or current probationary status of the Applicant or holder of State
Certification, and the provisions of RCW 9.95.240 and RCW 9.96A shall
not apply to such cases.

The State Gaming Agency will consult with the Tribal Gaming Agency
prior to denying State Certification when the Tribe is considering using

DR
(4)
the financier, manufacturer, or supplier of Gaming Services.

Right to Hearing for Revocation, Suspension, or Denial of State Certification

Any Applicant for State Certification or holder of a State Certification shall be
entitled to notice and a full hearing on any action by the State Gaming Agency
which may result in the revocation, suspension, or denial of State Certification.
The notice and hearing will be conducted in accordance with the procedures
contained in the applicable provisions of RCW 9.46, RCW 34.05, and WAC 230-
17, and the records involved shall be governed by the definitions set out in RCW
10.97.030. Nothing herein shall prevent the Tribal Gaming Agency from
invoking its own disciplinary procedures and proceedings at any time. The Tribe
shall have the right to appear and present argument and/or evidence in any
hearings held pursuant to this Section. Nothing herein shall be interpreted to
preclude the Tribe from invoking the dispute resolution provisions of this
Compact to challenge a State Gaming Agency decision to revoke, suspend or
deny State Certification.

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 43
(5) Denial, Suspension, or Revocation of Licenses Issued by Tribal Gaming Agency.
The denial, suspension, or revocation of any Tribal gaming license by the Tribal
Gaming Agency shall be in accordance with the Gaming Code and regulations
governing such procedures, and the grounds for such actions shall not be less
stringent than those of Compact Section VI.E.(3).

(6) Summary Suspension of Tribal License. The Tribal Gaming Agency, pursuant to
the laws and Gaming Code of the Tribe, may summarily suspend any Tribal
license if the continued licensing of a person or entity constitutes an immediate
and potentially serious threat to public health, safety, or welfare.

(7) Summary Suspension of State Certification

T
The State Gaming Agency, pursuant to RCW 9.46 and WAC 230-17, may
summarily suspend any State Certification if the continued State Certification
constitutes an immediate and potential serious threat to public health, safety, or
welfare.

(8)

AF
Submission to State Administrative Process

Applicants for State Certification agree by submitting such application to submit
to State jurisdiction to the extent necessary to determine qualification to hold such
State Certification, including all necessary administrative procedures, hearings,
and appeals pursuant to RCW 9.46, WAC 230-17, and the State Administrative
Procedure Act, RCW 34.05.

DR
A.
VII. STATE FEES FOR STATE CERTIFICATION, ELIGIBILITY
DETERMINATION, AND REGISTRATION

State Certification – Gaming Employee

The fees for the initial and the renewal of State Certification shall be determined pursuant
to WAC 230-05.

(1) PROVIDED, should actual costs incurred by the State Gaming Agency exceed the
stated fees, those costs will be assessed to the Applicants during the investigation
process. Payment in full to the State Gaming Agency will be required prior to
beginning or continuing the investigation for the issuance of State Certification.

(2) The State Gaming Agency may modify any of the above fees consistent with like
fees charged by the State Gaming Agency for non-Compact gaming elsewhere in
the State by giving the Tribe sixty (60) days’ notice of intent to modify fees.

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 44
B. State Eligibility Determination – Gaming Employee

The Tribal Gaming Agency and the State Gaming Agency shall enter into an MOU,
which may be amended from time to time regarding fees and submittal process for
Eligibility Determinations.

(1) The initial fees for State Eligibility Determination will be based on State
Certification fees and adjusted based on efficiencies.

(2) The State Gaming Agency may adjust the fees based on additional efficiencies or
cost increases by giving the Tribe sixty (60) days’ notice of intent to modify fees.

(3) PROVIDED, should actual costs incurred by the State Gaming Agency exceed the

(4)
T
stated fees, those costs will be assessed to the Tribal Gaming Agency during the
investigation process.

Transition costs. The Tribal Gaming Agency will reimburse the State Gaming

C.
(5)

AF
Agency for the costs to transition to Eligibility Determination.

Annual Onsite Review. Tribal Gaming Agency will reimburse State Gaming
Agency for the reasonable costs of this onsite review within sixty (60) days of
receiving a bill.

State Registration – Gaming Employee

Fees for State Gaming Employee Registration and renewal will be as follows:

DR
(1)

(2)

(3)

(4)
Initial and renewal fees for the Three-Year Gaming Employee will be
documented in a Memorandum of Understanding.

Registration and renewal fees may be adjusted by mutual agreement three years
from the initial adoption thereof, or at any time thereafter.

Transition costs. The Tribal Gaming Agency will reimburse the State Gaming
Agency for the costs to transition to Registration.

Annual Comparison Review. The Tribe will reimburse the State Gaming Agency
for the time it takes for the comparison review within 60 days of receiving a bill.

D. Alternative Fee Agreements

Notwithstanding any other provision of this Compact, the Tribal Gaming Agency and the
State Gaming Agency may enter into a Memorandum of Understanding regarding fees.

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 45
E. State Certification of Suppliers, Manufacturers and Financiers

The fees for initial and renewal of State Certification shall be determined pursuant to
WAC 230-05 for service suppliers, manufacturers, and their representatives.
HOWEVER, should actual costs incurred by the State Gaming Agency exceed the stated
fees, those costs will be assessed to the Applicants during the investigation process.
Payment in full to the State Gaming Agency will be required before beginning the
investigation for the issuance of State Certification.

VIII. TRIBAL ENFORCEMENT OF COMPACT REQUIREMENTS

A. Tribal Regulation

T
The ultimate responsibility for ensuring the regulation, control and integrity of the
Gaming activities authorized by this Compact will be that of the Tribe and/or its
delegated designee. The Tribe will provide for and oversee or delegate the following
functions:

B.
(1)

(2)

(3)
AF
Enforcement of all applicable laws and regulations in the Gaming Facilities;

Ensuring the physical safety of patrons in the Gaming Facilities; and

Ensuring the physical safety of personnel employed by the Gaming Operation.

Tribal Gaming Agency

The primary responsibility for the on-site regulatory compliance of the Gaming

DR
Operation authorized by this Compact, and for the enforcement of such compliance on
Tribal Lands will be that of the Tribal Gaming Agency.

As part of its structure, the Tribal Gaming Agency will perform the following functions
or ensure that they are being performed by the Tribe or its designee, as related to the
regulation and integrity of Gaming:

(1)

(2)
Ensure the physical safeguarding of Gaming assets;

Protect the patrons’ and the Gaming Facilities’ property from illegal activity;

(3) Temporarily detain persons who may be involved in illegal acts, for the purpose
of notifying law enforcement authorities; and

(4) Record, in a permanent and detailed manner, any unusual occurrences, all
incidents requiring further review, alleged violations, and investigations occurring
within the Gaming Facilities.

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 46
C. Tribal Gaming Agents

(1) No employee or member of the Tribal Gaming Agency may be an employee of
the Gaming Operation.

(2) A Tribal Gaming Agent shall be present in the Gaming Facilities during such
times as prescribed by the Tribe through its Gaming Code in an amount sufficient
to perform the Tribal Gaming Agency’s responsibilities and duties under the
Compact. The Tribal Gaming Agency shall notify the State Gaming Agency of
any proposed changes to the Gaming Code that would revise such on-site hours,
and no changes in hours will be implemented until the State Gaming Agency has
commented or thirty (30) days has lapsed, whichever occurs first.

D. Investigation

(1) T
The Tribal Gaming Agency shall investigate any reported, observed or suspected
violation of the Compact provisions or Gaming Code and shall require the

E.
(2)
AF
Gaming Operation to correct the violation upon such terms and conditions as the
Tribal Gaming Agency determines are necessary.

If requested by the Tribal Gaming Agency, the State Gaming Agency shall assist
in any investigation initiated by the Tribal Gaming Agency and provide other
related investigation services for which the Tribe agrees to reimburse the State
Gaming Agency for its costs.

Reporting of Violations

DR
(1)

(2)
Any violation of the provisions of this Compact or illegal activity by the Gaming
Operation, a Gaming Employee, manufacturer or supplier of Gaming Services or
any person on the premises, whether or not associated with the Gaming Operation
shall be reported immediately to the Tribal Gaming Agency. The Tribal Gaming
Agency shall notify the State Gaming Agency within seventy-two (72) hours of
the time a significant violation or Gambling crime, Gambling-related crimes or
suspected Gambling crime were reported.

The Tribal Gaming Agency shall make available all completed incident and
investigation reports and final dispositions to the State Gaming Agency on a
continuing basis.

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 47
IX. STANDARDS OF OPERATION

A. Adoption of Standards of Operation and Management

The Internal Controls, which govern the operation and management of the Tribe’s
Gaming Operation, have been approved by the Tribal Gaming Agency and concurred by
the State Gaming Agency based on the minimum operating standards set forth in
Appendix A. Any new or revised Internal Controls adopted by the Tribe shall ensure that
the interests of the Tribe and the State relating to Class III Gaming are preserved and
protected; maintain the integrity of the Gaming Operation; and reduce the dangers of
unfair or illegal practices in the conduct of the Class III Gaming Operation.

(1) The Tribal Gaming Agency shall forward to the State Gaming Agency any

T
proposed changes to the Internal Controls for review and concurrence.

(a) Each such proposal shall contain a narrative representation of the Internal
Controls system, including copies of the forms to be used.

(b)

(c)
AF
The Tribal Gaming Agency shall detail how such changes in the
provisions adequately preserve and protect the integrity and security of the
standard it is replacing.

The State Gaming Agency’s concurrence with the Tribal Gaming Agency
proposal shall be deemed granted after sixty (60) days of receipt of the
Tribal Gaming Agency proposal if no disapproval in writing is received
from the State Gaming Agency.

DR
(d)

(e)
The State Gaming Agency shall only disapprove such portions of a
proposal it finds would have a material adverse impact on public interest
or on the integrity of the Gaming Operation and shall detail the reasons for
disapproval.

The Tribal Gaming Agency shall ensure a proposal is not implemented
until the State Gaming Agency has concurred or sixty (60) days has lapsed
and the Tribe has not received a written disapproval within that time.

(2) The Tribe may choose to automate any processes, reports, or data collection
provided in the minimum operating standards with advance notice to the State
Gaming Agency. PROVIDED, the Tribal Gaming Agency certifies how the
automation maintains the integrity of the Gaming Operation, reduces the dangers
of unfair or illegal practices in the conduct of the Class III Gaming Operation,
adequately preserves and protects the integrity and security of the control, and

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 48
complies with the Compact. This section cannot be used to modify other sections
of the Compact.

B. Rules of the Games

Summaries of the rules of each game relevant to the method of play and odds paid to
winning bets shall be displayed or available in the Gaming Facilities and as specified in
the Compact. Betting limits applicable to any Gaming Station shall be displayed at such
Gaming Station.

C. Minimum Supervisory Requirements

The Gaming Operation shall provide the Tribal Gaming Agency and the State Gaming

T
Agency with a description of its minimum requirements for supervisory staffing for each
Pit operated in its Gaming Facilities, and in the event that the State Gaming Agency
regards such supervisory staffing as inadequate, the Tribal and State Gaming Agencies
shall promptly confer in good faith in an effort to reach agreement on supervisory staffing

D.
requirements.

AF
Additional Operation Requirements

(1) At the close of the fiscal year, the Gaming Operation shall, at its own expense,
have its annual financial statements audited in accordance with generally accepted
auditing standards by an Independent Accountant.

(a) The annual financial statements shall be prepared on a comparative basis

DR (b)

i.
for the current and prior calendar or fiscal year and shall present the
financial position and results of operations in conformity with generally
accepted accounting principles.

The Gaming Operation shall require its Independent Accountant to render
the following reports:

The audited financial statements, together with the report thereon
of the Gaming Operation’s Independent Accountant.

ii. A report on material weakness in accounting and Internal Controls.
Whenever, in the opinion of the Independent Accountant, there
exists no material weaknesses in accounting and Internal Controls,
the report shall say so; and

iii. A report expressing the opinion of the Independent Accountant
that, based on their examination of the financial statements, the

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 49
Gaming Operation has followed, in all material respects, during the
period covered by their examination, the system of accounting and
Internal Controls on file with the Tribal Gaming Agency.
Whenever, in the opinion of the Independent Accountant, the
Gaming Operation has deviated from the system of accounting and
Internal Controls filed with the Tribal Gaming Agency, or the
accounts, records, and control procedures examined are not
maintained by the Gaming Operation in accordance with the
Compact and these standards, the report shall enumerate such
deviations regardless of materiality, the areas of the system no
longer considered effective and shall make recommendations in
writing regarding improvements in the system of accounting and

T
One copy of each of the reports required by subsection (a) and (b) above
and copies of any other reports on accounting and Internal Controls,
administrative controls, or other matters relating to the Gaming

AF
Operation’s accounting or operating procedures rendered by the Gaming
Operation’s Independent Accountant, shall be filed with the Tribal
Gaming Agency within one hundred and twenty (120) days following the
end of each fiscal year or within thirty (30) days of receipt whichever is
earlier. Notification will be sent to the State Gaming Agency not later than
one hundred and twenty (120) days following the end of the calendar or
fiscal year when these statements are available for review. PROVIDED,
extensions may be granted for extenuating circumstances by the Tribal

DR
(2)
Gaming Agency.

Maintain the following written or computerized records:

(a)

(b)
security logs, maintained in accordance with the specifications set out in
Tribe’s Internal Controls; and

surveillance logs, maintained in accordance with the specifications set out
in the Tribal Gaming Agency’s standard operating procedure,

which shall be available for inspection by the Tribal Gaming Agency and the
State Gaming Agency in accordance with Compact Section X.B.

(3) The Gaming Operation shall provide the Tribal Gaming Agency with copies of its
floor plan and Closed Surveillance System and any modifications thereof for
review by the Tribal Gaming Agency. If the floor plan or Closed Surveillance
System does not provide unobstructed camera views in accordance with such

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 50
regulations, the Tribal Gaming Agency shall modify such floor plan or Closed
Surveillance System in order to remedy such deficiency. The Tribal Gaming
Agency shall make available to the State Gaming Agency the floor plan and
Closed Surveillance System to review for compliance with Compact.

(4) The Gaming Operation shall install a Closed Surveillance System according to the
specifications set out in Appendix A and the Tribe’s Internal Controls.

(5) The Tribal Gaming Agency shall establish a list of persons barred from the
Gaming Facilities because their criminal history, association with career
offenders, or association with career offender organizations poses a threat to the
integrity of the Gaming activities of the Tribe. The Gaming Operation shall
employ reasonable efforts to exclude persons on such list from entry into its

T
Gaming Facilities. The Tribal Gaming Agency shall make a copy of its list
available to the State Gaming Agency on a continuing basis. Copies of reports
will be forwarded to the State Gaming Agency as requested.

E.
(6)

AF
Standards for management and operation of satellite wagering activities shall be
consistent with the provisions of this Compact, including Appendix B., and those
applicable to non-tribal satellite wagering facilities and activities in the State to
the extent not inconsistent with this Compact.

Records Retention

(1) All information required in Compact Section IX. will be documented in a
permanent form.

DR
(2) Unless otherwise specified in these standards or exempted by the Tribal Gaming
Agency, all forms, records, documents, and required stored data shall:

(a)

(b)
Be located on Tribal Lands or such other location as approved by the
Tribal Gaming Agency; and

Be retained for at least two (2) years in a manner and location that assures
reasonable access by the Tribal and State Gaming Agencies.

X. COOPERATIVE ENFORCEMENT OF COMPACT REQUIREMENTS

The Tribe recognizes the benefit of cooperative monitoring, investigating, and reporting between
the Tribe and State to further the goal of fair and honest Gaming. The cooperative enforcement
of the Compact requirements will be conducted as described in this section.

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 51
A. State Gaming Agents – Monitoring

(1) The State Gaming Agency and Tribal Gaming Agency shall work together
cooperatively to monitor the Gaming Operation to ensure that it is conducted in
compliance with the provisions of this Compact. The State Gaming Agency will
coordinate inspections or investigations with the Tribal Gaming Agency prior to
onsite monitoring of the Gaming Operation, unless coordination would
compromise the purpose of the inspection or investigation.

(2) State agents shall provide proper identification at the time of inspection to the
appropriate Tribal representatives; PROVIDED the State Gaming Agency
Director may assign agents to work in an undercover capacity to assist in
monitoring the provisions of this Compact. The Tribal Gaming Agency and the

T
State Gaming Agency shall establish protocols that allow the Tribal Gaming
Agency to confirm that the State agent is duly authorized by the State to monitor
the Gaming Operation.

(3)

(4) AF
Agents of the State Gaming Agency and, as applicable, the Washington Horse
Racing Commission, shall have access to all areas of the Gaming Facility during
operating hours with or without giving prior notice to the Gaming Operation.

Following the investigation, and to the extent such disclosure does not jeopardize
the investigation or the personal safety of any person, the State shall provide the
Tribal Gaming Agency with a report of the investigation, including information
about evidence gathered in connection with the investigation.

D
B.

R
Access to Records

(1)

(2)
Agents of the State Gaming Agency may review and copy, during operating
hours, all applicable Class III Gaming records maintained by the Gaming
Operation as necessary to verify compliance with provisions of this Compact and
all records related to gambling and related crimes.

Regardless of the storage system used for Class III Gaming records, the records
shall be in a format accessible by Agents of the State Gaming Agency

(3) The State Gaming Agency is mindful of the Tribe’s desire for privacy and agrees
to examine all records at the Gaming Facilities, to the extent practical. The State
Gaming Agency further agrees that its agents will only retain copies of records
necessary for investigative purposes. Any information shall be deemed strictly
confidential and proprietary information of the Tribe and shall not be disclosed
except as required under law or the terms of this Compact.

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 52
(4) The State Gaming Agency or, as applicable, the Washington Horse Racing
Commission, shall notify the Tribe, by certified mail, or by other mutually agreed
upon means, of requests for disclosure of the Tribe’s information and shall not
disclose any such information until the Tribe, the State, or both have had a
reasonable opportunity to challenge the request.

C. Investigations

(1) The Tribal Gaming Agency and the State Gaming Agency will have concurrent
jurisdiction to investigate violations of the provisions of this Compact and
gambling and related crimes, and to bring administrative and criminal charges, in
accordance with this Compact, and applicable Tribal and State laws and
regulations.

(2)
T
The State Gaming Agency will notify the Tribal Gaming Agency of any alleged
violations of the provisions of this Compact and may request the Tribal Gaming
Agency take appropriate enforcement and/or corrective action. Failure of the

D. AF
Tribal Gaming Agency to take the action recommended by the State Gaming
Agency will constitute a dispute or disagreement between the parties subject to
the dispute resolution provisions contained in Compact Section XIII.

Tribal Gaming Agency Access to State Gaming Agency Records

At the completion of any inspection or investigation, copies of the investigative report
will be forwarded to the Tribal Gaming Agency along with copies of evidence and
information pertinent to the inspection. The Tribal Gaming Agency may inspect and

DR
E.
copy records maintained by the State Gaming Agency concerning Class III Gaming by
the Tribe subject to any constraints imposed by the State Gaming Agency's accreditation
as a law enforcement agency, requirements under RCW 9.46.210(4) and RCW 10.97,
and status as a member of a law enforcement intelligence sharing organization, such as
the Law Enforcement Intelligence Unit (LEIU), Fusion Centers, INTERPOL, and similar
organizations.

Cooperation With Tribal Gaming Agency

(1) To maintain the partnership for enforcement of the provisions of this Compact,
representatives of the Tribal Gaming Agency and the State Gaming Agency shall
meet at least once every twelve (12) months to review the regulatory program for
the Gaming Facilities.

(2) The State Gaming Agency and, as applicable, the Washington Horse Racing
Commission, shall promptly notify the Tribal Gaming Agency of any activity

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 53
suspected or occurring, whether within a Gaming Facility or not, which adversely
affects State, Tribal or public interests relating to the Gaming Facilities and
Gaming Operation. PROVIDED, such disclosure shall not compromise the
interest sought to be protected.

(3) Closure Notification. The Tribal Gaming Agency will make reasonable efforts to
notify the State Gaming Agency in a timely fashion in the event a Gaming
Facility closes to the public for more than twenty-four (24) hours.

XI. JURISDICTION

A. Criminal Matters

(1) Investigative Authority

T
The Tribal Gaming Agency, Tribal Law Enforcement, Local Law Enforcement
Agencies, and the State Gaming Agency under RCW 9.46.210, will have the
authority to investigate and make arrests if necessary for all Gambling and related

(2) AF
crimes against the laws of the Tribe and applicable laws of the State that occur
within the Gaming Facilities or within Tribal Lands.

Jurisdictional Forums

Following investigation and arrest, formal charges will be brought in the
appropriate venue. Criminal prosecution of non-Indians will be through the proper
State or Federal Courts. Criminal prosecution of Indians will be through the

D
B.

R
proper Tribal Court, State or Federal Courts.

Civil Matters

(1) Concurrent Jurisdiction

The Tribal Gaming Agency and State Gaming Agency have concurrent
jurisdiction to investigate violations of the provisions of this Compact and to
bring administrative charges in the appropriate forum, in accordance with Tribal
Laws or the provisions of RCW 9.46 and WAC 230-17, made applicable by this
Compact, against any Applicant and/or Individual that is licensed by the Tribal
Gaming Agency, and/or holds a State Certification or is subject to Eligibility
Determination, or Gaming Employee Registration or is licensed by the State
Gaming Agency in accordance with the provisions of this Compact.

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 54
(2) Tribal Jurisdiction

Civil disputes arising from the conduct of Gaming under the Gaming Code may
be heard in the Northwest Intertribal Court or appropriate administrative forum as
established by the Gaming Code.

C. Sanctions and Civil Fines

(1) The Tribal Gaming Agency and the State Gaming Agency shall enter into a
Memorandum of Understanding, which may be amended from time to time, to
define the schedule of civil fines and sanctions.

(2) Any civil fines collected against the Gaming Operation shall be distributed to a

D.
T
non-tribal, bona fide nonprofit or charitable organization in the State of
Washington selected by the Tribe. Any civil fines assessed pursuant to the
provisions of this Compact shall be paid within thirty (30) days of assessment.

Limited Application of State Criminal Law

AF
For the purposes of 18 U.S.C. § 1166(d) and enforcing the provisions of this Compact,
and of protecting the public health, safety and welfare, and to the extent not inconsistent
with other provisions of this Compact, RCW 9.46.0245; 9.46.0269; 9.46.0364;
9.46.0368; 9.46.037; 9.46.038; 9.46.155; 9.46.160; 9.46.170; 9.46.180; 9.46.185;
9.46.190; 9.46.195; 9.46.196; 9.46.1961; 9.46.1962; 9.46.198; 9.46.212; 9.46.215;
9.46.217; 9.46.220; 9.46.221; 9.46.222; 9.46.225; 9.46.228 (1), (2), (4) & (5); 9.46.231;
9.46.235; 9.46.240; 67.04; 67.16; 67.24; 67.70; 74.08.580; 9A.52; 9A.56; 9A.60; 9A.68;

DR
E.
9A.82; 9A.83.020; 9.35.010; 9.35.020; as now or hereinafter amended, to the extent such
amendments concern the same subject matter as the old statutory provisions, shall be
applicable and incorporated herein as part of this Compact and the Tribe consents to this
transfer of jurisdiction to the State with respect to Gaming on Tribal Lands.

Law Enforcement Coordination

In an attempt to foster a spirit of cooperation between the Tribal Law Enforcement and
Local Law Enforcement Agencies authorized to enforce the criminal laws of the State,
the Tribe and those laws affecting the public health, safety and welfare of the
surrounding communities, representatives of those Law Enforcement Agencies shall
meet periodically or as requested by any of the Law Enforcement Agencies to discuss

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 55
mutual concerns and coordinate the enforcement actions necessary to minimize those
concerns.

F. Reporting Requirements.

The Tribe shall cooperate with requests from the State Gaming Agency to provide the
information required for the State Gaming Agency’s reporting requirements under RCW
9.46.090. If the Tribe determines that providing any specific information requested is
inconsistent with its sovereignty and its need to protect its proprietary business
information, the Tribe will not provide such information and will notify the State
Gaming Agency of such determination.

G. Preservation of Tribal Self-Government

T
Nothing in this Compact will be deemed to authorize the State:

(1) To regulate in any manner the government of the Tribe, or

A.
(2)

AF
To interfere with the Tribe’s selection of its governmental officers, including
members of the Tribal Gaming Agency.

XII.

Set-up Fee
REIMBURSEMENT FOR REGULATORY EXPENSES
INCURRED BY THE STATE GAMING AGENCY

As part of the recoverable cost of regulating Tribal Lottery Systems under Appendix X2,

DR
the State Gaming Agency shall be entitled to the reasonable cost of initially setting up
such regulation ("Set-up Fee"), of one hundred eighty-four thousand, eight hundred sixty-
six dollars ($184,866). The Tribe paid its pro rata share of the Set-up Fee (i.e., dividing
the entire amount due by the number of Eligible Tribes at the time such determination is
made). In the event the Tribe paid the State Gaming Agency more than its pro-rata share
of the Set-up Fee, it shall be reimbursed by way of future Regulatory Fee credits based on
the collection by the State Gaming Agency of additional pro-rata payments from other
Eligible Tribes, the addition of such tribes and resulting recalculation of the pro-rata
amount per tribe, or both, as the case may be. The pro-rata amount per tribe shall be
redetermined by the State Gaming Agency at least once a year to take into account the
collection of further tribal pro-rata payments or the addition of new Eligible Tribes, and
further credits due as a result thereof shall be applied to the next billing period.

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 56
B. Annual Regulatory Fees

The Tribe agrees to pay its share of the State Gaming Agency’s Actual Costs which are
reasonably incurred in order to commence and carry out its regulatory functions with
respect to the Tribe’s Gaming under this Compact, through the payment of an annual
“Regulatory Fee”. For the sake of convenience and efficiency, the Regulatory Fee shall
also include any Actual Costs which were incurred by the State Gaming Agency in
connection with the Tribe’s Class III Gaming. "Actual Costs" as used herein shall mean
those costs that were reasonably incurred in order to protect the honesty and integrity of
the Gaming being operated by Tribe under, and to monitor the Tribe’s compliance with,
the Compact. Costs incurred in common for more than one tribe shall be allocated among
such tribes. For purposes of this section, prior years’ Actual Costs shall be based on those
such costs incurred for the twelve months ending June 30. Regulatory Fees shall be
calculated and paid as follows:

(1)
T
Cost Allocation. Notwithstanding anything in the Compact to the contrary, the
Regulatory Fees for all Class III Gaming activities under the Compact, shall be set

(2)
AF
by determining the cost of regulating the Tribe’s Class III Gaming activities using
the State Gaming Agency’s cost allocation model currently in use.

Billing and Payment. The State Gaming Agency shall notify the Tribe of the
forthcoming Regulatory Fee at least forty-five (45) days prior to it becoming due.
Regulatory Fees may be paid for an entire year in advance of the date on which
the billing year commences (calendar year) or in no more than twelve (12) equal
monthly installments, each of which shall be due on the first day of each month,

DR (3)

(4)
which monthly payments shall commence on the first day of the first month of the
billing year, or within forty-five (45) days following notification of the amount of
the forthcoming year’s Regulatory Fee, whichever is later.

Audit. The SGA shall send the Tribe an annual audited accounting of actual costs
on or before April 30 of the following year.

Revisions to State’s Cost Allocation Model. The State Gaming Agency may
revise its cost allocation model, which shall become effective upon ninety (90)
days’ notice to the Tribe. If the Tribe disputes the revised model, the State
Gaming Agency and Tribe shall meet and confer in an attempt to resolve the
matter within 30 days. If the parties cannot resolve the dispute, the dispute
resolution provisions set forth in Compact Section XIII below shall apply.

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 57
C. Regulatory Fee Disputes

If the Tribe disputes the State's determination of the Regulatory Fee, the Tribe shall pay
no less than the amount of the fee which is not in dispute to the State Gaming Agency
when due and deposit the disputed amount into an escrow account that is restricted until
such dispute is resolved. The dispute will be resolved pursuant to the binding arbitration
provisions of this Compact. If the Tribe fails to make the required payment to the State
Gaming Agency or deposit into escrow, the State may pursue any of the remedies set
forth in Compact Section XIII for the Tribe’s breach thereof.

D. Alternative Fee Agreements

Notwithstanding any other provision of this Compact, the Tribal Gaming Agency and the

XIII.

A.
T
State Gaming Agency may enter into an MOU regarding fees.

DISPUTE RESOLUTION AND REMEDIES FOR BREACH OF COMPACT

Introduction

AF
In recognition of, and consistent with, the government-to-government relationship of the
Tribe and State, the parties shall make their best efforts to resolve disputes by good faith
negotiations whenever possible. Therefore, the parties hereby establish a method of non-
judicial dispute resolution in order to foster a spirit of cooperation and efficiency in the
administration and monitoring of performance and compliance by each other with the
terms, provisions and conditions of this Compact.

D
B.

R
Dispute Resolution Alternatives

(1) Meet and Confer

In the event of a dispute or disagreement between the parties regarding the
implementation and compliance with any terms, conditions, and provisions of this
Compact, or otherwise by mutual agreement of the parties, disputes shall be
resolved as follows:

a) Either party shall give the other, as soon as possible after the event giving
rise to the concern, written notice setting forth the nature of the dispute
(including reference to the relevant portions of this Compact), and the
issues to be resolved.

b) The parties shall meet and confer in a good faith attempt to resolve the
dispute through negotiation not later than twenty (20) business days from
receipt of the notice.

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 58
(2) Mediation

If the dispute is not resolved to the satisfaction of either party within twenty (20)
business days of the first meeting, then the parties, by agreement, may seek and
cause to have the dispute resolved by formal mediation, in which event the parties
shall use their best efforts to select a mediator as soon as possible. The mediator’s
fees and attendant costs of mediation shall be borne equally by the parties.

The parties understand that informal and formal mediation may not always lead to
satisfactory results. In the event either party is dissatisfied with informal and/or
formal mediation, they may seek judicial resolution of any disagreement relating
to the administration, monitoring of performance and compliance with the terms,
provisions and conditions of this Compact. However, the parties are free under

(3) T
this Compact to agree to other alternative dispute resolution mechanisms.

Standard Arbitration

(a)

(b)
AF
In the event informal and/or formal mediation fails to resolve the dispute
between the parties, the parties may choose by mutual agreement to
resolve the dispute by arbitration. In no event may the request be made
earlier than twenty (20) days after a party has properly notified the other
party under the procedures set forth in Compact Section XIII.B.(1).

Sites for such arbitrations shall alternate between Tribal Lands and the
State Gaming Agency or Washington Horse Racing Commission offices,
as applicable, after each arbitration dispute, as follows: the first arbitration

DR (c)
dispute, until completed, shall be held on Tribal Lands; the next arbitration
dispute, until completed, shall be held at the State Gaming Agency or
Washington Horse Racing Commission offices; and so forth.

In the event the parties agree to arbitration, the Tribe and the State Gaming
Agency shall, within five (5) days, agree upon an arbitrator to decide the
matter at issue, or agree upon a procedure for the selection of an arbitrator.
The parties shall also agree on the rules, policies and procedures to be
used in the arbitration.

(d) The arbitration, unless another date is stipulated to by the parties, shall
occur no later than fourteen (14) business days from the date an arbitrator
is named. The arbitrator may, in their discretion, impose a case
management schedule on the parties to provide for reasonable time needed
for discovery, fact gathering, expert witnesses, etc. Time periods shall be
reasonable and necessary as required by the circumstances, without

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 59
providing undue delay. In all circumstances, however, the arbitrator shall
issue a final decision no later than one (1) year from the initial written
request for arbitration. The parties may, by mutual agreement, continue
the mediation process set out in Compact Section XIII.B.(2) until the
arbitration begins.

(e) The decision of the arbitrator shall be final for the purpose of concluding
the non-judicial phase of the arbitration process, but the final decision of
the arbitrator may be subject to judicial review.

(f) The arbitrator shall, consistent with this Compact, have the power to
impose fines and award equitable relief in their discretion and as the
circumstances warrant.

(g)
T
Each party to the arbitration shall bear its own costs and attorney fees, and
the costs of the arbitrator(s) shall be borne equally by the parties.

AF
Injunction Against the State

If the Tribe believes the State, whether or not through the State Gaming Agency or the
Washington Horse Racing Commission, is in breach or default or is otherwise acting
contrary to or failing to act in the manner required by the provisions of this Compact, the
Tribe may bring an action to seek injunctive or other relief in the U.S. District Court for
the Western District of Washington, pursuant to RCW 9.46.36001. Prior to bringing such
action the Tribe will notify the State and State Gaming Agency of the alleged
violation(s). For purposes of this remedy, the State consents to this suit and waives any

D
D.

R
defense it may assert by way of its sovereign immunity.

Injunction Against the Tribe, the Gaming Operation, or any Individual

The State may bring an action to enjoin the Tribe, the Gaming Operation, or any
Individual if the State determines that any Gaming authorized by the provisions of this
Compact is being conducted in violation of the provisions of this Compact, or if any
Class III Gaming activity is being conducted on Tribal Lands in violation of the
provisions of this Compact. Such action will be brought in the U.S. District Court,
pursuant to 25 U.S.C. § 2710(d)(7)(A)(ii). Prior to bringing such action, the State will
notify the Tribe of the alleged violation(s). For purposes of this remedy, the Tribe
consents to this suit and waives any defense it may assert by way of its sovereign
immunity.

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 60
E. Limited Waiver of Sovereign Immunity

The Tribe and the State agree and understand that waivers of sovereign immunity
defenses must be express and unambiguous, and are narrowly construed. Nothing
contained in this Compact shall be construed or interpreted to be a consent, grant or
waiver of any sovereign right or immunity either the Tribe and/or its citizens or the State
enjoy, except as expressly provided hereinafter:

(1) The Tribe hereby agrees to a limited waiver of sovereign immunity for the sole
purpose, and no other purpose, of consenting to the suits specified in Compact
Section XIII.B., such waiver to be in effect only so long as this Compact is in
effect, but in no event shall the limited waiver be construed to allow for monetary
relief against assets of the Tribe other than revenue from the Gaming Facility or

(2) T
from the sale of gaming-related assets.

The State and the State Gaming Agency represent and acknowledge that the State
has waived its sovereign immunity with respect to suits interpreting or enforcing

AF
any contract to which the State and/or its subordinate agencies have entered into
with a private party, which includes an Indian tribe. See RCW 4.92.010 and
Architectural Woods, Inc. v. Washington, 92 Wn.2d 521, 598 P.2d 1372 (1979).
In addition, the State and the State Gaming Agency represent and acknowledge
that the State has waived its immunity from those suits set forth in RCW
9.46.36001. Notwithstanding such statutory waivers of immunity, the State
hereby reiterates and agrees to a limited waiver of sovereign immunity for the
sole purpose, and no other purpose, of consenting to the suits specified in

DR
F.
Compact Section XIII.B., and any other suits set forth in RCW 9.46.36001, such
waivers to be in effect only so long as this Compact is in effect.

References

The parties are aware that some sections of this Compact contain an explicit reference to
Compact Section XIII. in the event a dispute arises under that section. Notwithstanding
such explicit references, and with respect to all other sections of this Compact, it is the
parties’ intent that any dispute of whatever kind, type or nature arising under this
Compact shall be subject to the provisions of Compact Section XIII.

XIV. LIMITATION OF LIABILITY

Neither the Tribe nor the State are creating, or intend to create, any rights in third parties which
would result in any claims of any nature whatsoever against the Tribe or the State as a result of
this Compact. Neither the Tribe nor the State have waived their immunity from third party suits

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 61
or claims of any kind or nature whatsoever against them, and nothing contained in this Compact
shall be construed to effect a waiver, in whole or in part, of said immunity.

XV. EFFECTIVE DATE, DURATION, AND AMENDMENTS

A. Effective Date

This amended Compact will be 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).

B. Termination

This Compact will be in effect until terminated by written agreement of both parties,

T
under the provisions of IGRA. PROVIDED, the Tribe will provide written notice to the
Governor of the State sixty (60) days prior to termination of the Compact. Suspension of
or an injunction against Class III Gaming activities will not constitute termination for the
purpose of this subsection.

AF
Subsequent Negotiations

Nothing in this Compact will be deemed to waive the right of the Tribe to request
negotiations for a Tribal-State Compact with respect to a Class III Gaming activity which
is to be conducted on Tribal Lands, but is not permitted under the provisions of this
Compact, including forms of Class III Gaming which were not permitted by the State for
any purpose by any person, organization, or entity at the time when this Compact was

DR
D.

E.
negotiated or amended but are subsequently so permitted by the State, in accordance with
25 U.S.C. § 2710(d)(3)(A).

Enactment of Compact Provisions

Pursuant to the general rule-making authority of the agencies, the Tribal Gaming Agency
or the State Gaming Agency may each enact all or part of the provisions of this Compact
as part of their regulations or rules governing Gaming.

Revision of State Regulations

Whenever the State adopts or revises any rule or regulation which corresponds to any
provision of the Tribe’s standards of operations and management as set forth in Compact
Section IX.A. relating to the same type of Gaming, the State Gaming Agency may notify
the Tribal Gaming Agency that it requests analogous changes in such standards. The
Tribal Gaming Agency will promptly confer with the State Gaming Agency in good faith
concerning the appropriateness and applicability of such changes.

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 62
F. Changes to State Law

If the laws of the State authorizing the activities set forth herein as Class III Gaming
activities are repealed, thereby prohibiting such Gaming for any purpose by any person,
organization or entity, it is the State’s position that the provisions of this Compact
providing for such Gaming would not be authorized and the continued operation of such
Gaming would constitute a violation of the Compact for which the State could bring an
action in Federal District Court pursuant to 25 U.S.C. § 2710(d)(7)(A)(ii).

The Tribe disagrees that such subsequent State legislation would have this effect under
the provisions of the IGRA and this Compact, but does agree that such an action, if
commenced in that forum, is the appropriate State recourse and for that purpose consents
to the suit and waives any defense it may assert by way of its sovereign immunity.

T
Notwithstanding any other provisions of this Compact, if the laws of the State
authorizing any Class III Gaming activities are so repealed, the State may bring an action
as set forth above only after it provides twenty (20) business days written notice to the

G. AF
Tribe of the State’s intention to bring such action and affords the Tribe a reasonable
opportunity to meet and confer with the State in a good faith attempt to resolve the
issue(s) intended to be addressed by such action.

Clarification, Amendments, and Renegotiations

(1) Compact Clarification

The parties recognize that circumstances may arise in implementation, operation,

DR (2)
and regulation of the Class III Gaming Facilities that require clarification of
Compact provisions. For such mutually agreed-upon clarification, the State and
Tribe will execute and sign a Memorandum of Understanding that will be
attached to and made part of this Compact.

Amendments

Either party may, in writing, request renegotiation of any of the provisions of this
Compact consistent with the requirements of the Indian Gaming Regulatory Act
and its implementing regulations, and RCW 9.46.360. The mutual agreement of
both parties achieved through renegotiations will be documented in an
amendment. The Terms and provisions of the Compact will remain in effect
unless and until the parties agree on the renegotiated terms.

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 63
(3) Amending Nature and Scope

The terms and conditions of this Compact related to the nature and/or scope of
Class III Gaming shall be amended upon written notice and request by the Tribe
to the State, if and when:

(a) The laws of the State are amended, expanding Gaming beyond that which
is now allowed under the terms of this Compact; or

(b) A State or Federal court within the State of Washington or a Federal court
interpreting the laws of the State of Washington issues a final and
unappealable decision permitting participation in a Gaming activity that
was not authorized for any purpose by any person, organization, or entity

If the State enters into or amends a compact with another tribe that is

AF
approved by the Secretary of the Interior, the Tribe may request to amend
its Compact as follows:

i. When the Tribe requests terms and conditions from the other
tribe’s compact be incorporated into the Tribe’s compact, the State
will agree to the Tribe’s proposal in a Memorandum of
Incorporation so long as all interrelated terms and conditions from
the other tribe’s compact are included and identical in substance to
the other tribe’s.

DR (d)
ii. If an advantage afforded the other tribe cannot be addressed in a
Memorandum of Incorporation, the Parties will negotiate in good
faith to complete a responsive amendment under Compact Section
XV.G.(2), above.

If the Washington State Lottery approves a purchase price per ticket
greater than that provided under this Compact, the Gaming Operation may
increase its maximum wagers and purchase price for scratch tickets or On-
Line Lottery Wagers to match the Washington State Lottery increase,
provided that the State and Tribe agree to incorporate into this Compact
only the specific provisions and restrictions related to the purchase price,
and such agreement will be documented in a memorandum of
incorporation.

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 64
(4) State Authorization of Additional Class III Gaming Activities

In the event the State hereafter authorizes any additional Class III activity, the
Tribe will be authorized to conduct such activity before completion of the
subsequent negotiations as provided in this Compact, if such activity is conducted
in accordance with all the limitations, regulations, and requirements of the State.

(5) Process and Negotiation Standards

The parties will confer, and the required negotiations will commence within thirty
(30) days of a request to amend or renegotiate. All matters involving negotiations
or other amendatory processes under this section will be otherwise governed,
controlled, and conducted in conformity with the provisions and requirements of

T
25 U.S.C. § 2710(d), except in subsections where a different resolution is
specifically provided in the event of an unsettled dispute or where agreement is
not reached by the parties.

AF XVI. NOTICES

All notices required or authorized to be served will be in writing and will be sent by first-class or
priority mail or be delivered by other expedited service to the following addresses, which can be
updated with advance notification to all parties:

Tribal Chairman
Squaxin Island Tribe
10 Squaxin Lane
Governor
State of Washington
State Capitol

DR
Shelton, Washington 98584

Squaxin Island Legal Department
3711 SE Old Olympic Hwy
Kamilche, WA 98584
Olympia, Washington 98504

Director
Washington State Gambling Commission
P. O. Box 42400
Olympia, Washington 98504-2400

Executive Secretary
Washington Horse Racing Commission
3700 Martin Way
Olympia, Washington 98504-5052

XVII. SEVERABILITY

In the event that any section or provision of this Compact is held invalid by a court of law, or its
application to any particular activity held invalid by a court of law, it is the intent of the parties

Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 65
that the remaining sections of the Compact, and the remaining applications of such section or
provision will continue in full force and effect.

IN WITNESS WHEREOF, the Tribe and the State have executed this Compact.

THE SQUAXIN ISLAND TRIBE STATE OF WASHINGTON

BY: BY:
KRISTOPHER PETERS BOB FERGUSON
Chairman Governor

DATED: DATED:

T
AF
DR
Squaxin Island Tribe—State of Washington
Gaming Compact (Amended and Restated) Page 66
SQUAXIN ISLAND TRIBE – STATE OF WASHINGTON
CLASS III GAMING COMPACT

APPENDIX A
Standards Of Operation and Management for Class III Activities
(Amended and Restated)

Table of Contents
SECTION 1. INTRODUCTION............................................................................................. 1
SECTION 2. DEFINITIONS .................................................................................................. 1
SECTION 3. ALTERNATIVE CONTROL PROVISIONS ................................................ 3
SECTION 4.
SECTION 5.
SECTION 6.
SECTION 7.
T
SYSTEM OF ACCOUNTING AND INTERNAL CONTROLS ................. 3
ADOPTION OF RULES FOR CLASS III ACTIVITIES ............................ 4
PROGRESSIVE AND PLAYER SUPPORTED JACKPOTS ..................... 5
ACCOUNTING RECORDS ............................................................................ 6
SECTION 8.
SECTION 9.

AF
FORMS, RECORDS, DOCUMENTS AND RETENTION .......................... 6
ORGANIZATION OF THE GAMING OPERATION ................................. 7
SECTION 10. CAGES ............................................................................................................. 11
SECTION 11. ACCOUNTING CONTROL WITHIN THE CASHIER'S CAGE ............ 12
SECTION 12. DROP BOXES................................................................................................. 13
SECTION 13. DROP BOXES TRANSPORTATION AND STORAGE............................ 15
SECTION 14. CHECKS AND CREDIT CARDS ................................................................. 15

D
SECTION 15. ACCEPTANCE OF GRATUITIES FROM PATRONS ............................. 16
SECTION 16. GAMING STATION INVENTORY REQUIREMENTS AND

R PROCEDURES ................................................................................................................ 16
SECTION 17. PROCEDURES FOR DISTRIBUTING AND REMOVING GAMING
CHIPS AND COINS TO AND FROM GAMING STATIONS ................................... 17
SECTION 18. COUNT ROOM: CHARACTERISTICS ..................................................... 18
SECTION 19. PROCEDURE FOR COUNTING AND RECORDING DROP BOXES
CONTENTS ...................................................................................................................... 19
SECTION 20. SIGNATURES................................................................................................. 20
SECTION 21. SURVEILLANCE DEPARTMENT ............................................................. 21
SECTION 22. CLOSED SURVEILLANCE SYSTEM ........................................................ 22

i
1. INTRODUCTION
This Appendix contains minimum standards of operation. (“Standards”). Specific procedures will
be handled as documented in these Standards and further detailed in the Gaming Operation’s
system of accounting and Internal Controls required by Compact.

2. DEFINITIONS
The following definitions apply to these Standards. To the extent they do not conflict, the
definitions contained in the Compact and Appendices also apply.

2.1. "Accounting Department" is that established in the Gaming Operation's system of
organization in accordance with these Standards.

2.2.

2.3.
T
"Cage Cashiers" means a Gaming Employee performing any of the functions in the Cage
as set forth in these Standards.

"Chief Executive Officer" means the position responsible for performing the functions of

2.4.

2.5.
AF
the senior executive of the Gaming Operation exercising the overall management or
authority over all the operations of the Gaming Operation and the carrying out by
employees of the Gaming Operation of their duties.

“Chief Financial Officer” means the executive of the Gaming Operation exercising the
overall management and authority over all financial matters.

"Closer" means the Gaming Station inventory slip upon which each Gaming Station
inventory is recorded at the end of each shift or gaming day, which shall be dropped into

DR
2.6.

2.7.

2.8.
the Drop Box upon completion of the inventory count.

"Credit Slip" or "Credit" is the three-part document reflecting the removal of Gaming
chips and coins from a Gaming Station in accordance with these Standards.

“Dealer” means a Gaming Employee who operates a Gaming Station, individually or as a
part of a crew, as authorized under approved Internal Controls and/or game rules.

“Drop" means the sum of the total amounts of currency, coin, Gaming chips, and
vouchers removed from a Drop Box.

2.9. “Drop Box” means the container attached to a Gaming Station, Player Terminal or Kiosk
for deposit of Cash and certain documents received as provided by these Standards.

Squaxin Island Tribe-State of Washington Gaming Compact
Appendix A - Standards of Operation and Management for Class III Activities (Amended and
Restated)
1
2.10. "Fill Slip" or "Fill" is the three-part document reflecting the distribution of Gaming chips
and coins to a Gaming Station as provided in these Standards.

2.11. “Gaming Facility Manager” means the position responsible for the operation and conduct
of all Class III activities conducted in the Gaming Facility.

2.12. “Gaming Facility Shift Manager” means the position responsible for performing the
functions of the supervisor assigned to each shift with the responsibility for the
supervision of Gaming activities conducted in the Gaming Facility. In the absence of the
Gaming Facility Manager, the Gaming Facility Shift Manager shall have the authority of
a Gaming Facility Manager.

2.13.
T
"Gaming Facility Supervisor” is a reference to a person in a supervisory capacity and
required to perform certain functions under these Standards, including but not limited to,
Pit Bosses, Gaming Facility Shift Managers, the Assistant Gaming Facility Manager and

2.14.

2.15.
AF
the Gaming Facility Manager.

"Imprest Basis" means the basis on which Cashier's Cage funds are replenished from time
to time by exactly the amount of the net expenditures made from the funds and amounts
received and in which a review of the expenditure is made by a higher authority before
replenishment.

"Incompatible Function" means a function, for accounting and Internal Controls
purposes, that places any person or department in a position to both perpetrate and

DR
2.16.

2.17.
conceal errors or irregularities in the normal course of his or her duties. Anyone both
recording transactions and having access to the relevant assets is in a position to
perpetrate errors or irregularities.

“Key” means an instrument for locking or a device that operates a lock designated to
secure and protect assets. A Key could include a unique hard Key, a plastic card with an
encoded magnetic strip or chip, magnetic lock, or similar device.

"Master Game Report" means a record of the computation of the Win or Loss for each
Gaming Station, each game, and each shift and includes the total amount of currency and
coin counted, amount of the Opener and Closer, Fill and Credit serial numbers, individual
and total amounts of Fills and Credits, and Win or Loss.

Squaxin Island Tribe-State of Washington Gaming Compact
Appendix A - Standards of Operation and Management for Class III Activities (Amended and
Restated)
2
2.18. "Opener" means the Gaming Station inventory slip upon which each Gaming Station
inventory is recorded at the end of each shift and serves as the record of each Gaming
Station inventory at the beginning of the next succeeding shift.

2.19. “Pit Boss” means the position responsible for the overall supervision of the operation and
conduct of Gaming at the Gaming Stations within a single Pit and shall oversee any
intermediate supervisors assigned by the Gaming Operation to assist in supervision of
Gaming Stations in the Pit.

2.20. "Request for Credit" is the two-part document reflecting the authorization for preparation
of a Credit with respect to removal of Gaming chips and coins from a Gaming Station in
accordance with these Standards.

2.21.
T
"Request for Fill" is the two-part document reflecting the request for the distribution of
Gaming chips and coins to a Gaming Station as provided in these Standards.

2.22.

2.23. AF
"Security Department Member" means a Gaming Employee who is a member of the
Security Department as provided in the organization of the Gaming Operation in
accordance with these Standards.

"Win or Loss" is determined by adding the amount of Cash or coin, the amount recorded
on the Closer, removed from a Drop Box, plus Credits, and subtracting the amount
recorded on the Opener and the total of the amounts recorded on Fills removed from a
Drop Box.

DR
3. ALTERNATIVE CONTROL PROVISIONS

An alternative method to the procedures in this Appendix may be approved by mutual agreement
of the Tribal Gaming Agency and State Gaming Agency as set out in Compact Section IX.

4. SYSTEM OF ACCOUNTING AND INTERNAL CONTROLS

The Gaming Operation shall submit to the Tribal Gaming Agency and the State Gaming Agency
a description of its system of internal procedures and administrative and accounting controls.
Before new or modified controls are implemented they must be approved in accordance with
Compact requirements related to approval and concurrence with Internal Controls.

Squaxin Island Tribe-State of Washington Gaming Compact
Appendix A - Standards of Operation and Management for Class III Activities (Amended and
Restated)
3
5. ADOPTION OF RULES FOR CLASS III ACTIVITIES

Game rules will be submitted in accordance with requirements of the Compact or related
Appendix. Game rules adopted by the Tribal Gaming Agency shall include:

5.1. Procedures of play;

5.2. Minimum and maximum permissible wagers;

5.3. Shuffling, cutting and dealing techniques, as applicable;

5.4.

5.5. T
Payout odds or prizes, including any payout limitations, on each form of wager;

Procedures to be followed on occurrence of irregularities, including definition of
irregularities as applicable to each game;

5.6.

5.7.
AF
Prohibition on side betting between and against players and against the house; and

Specifications provided by the equipment manufacturer or supplier applicable to Gaming
equipment:

5.7.1. Physical characteristics of chips; and

5.7.2. Physical characteristics of the following:

DR
(a) Authorized Class III Gaming tables;

(b) Table layouts;

(d) Roulette balls and keno balls;

(e) Cards (including procedures for receipt, storage, and destruction);

(f) Dice (including procedures for receipt, storage, and destruction);

(g) Dealing shoes (including procedures for receipt and storage);

Squaxin Island Tribe-State of Washington Gaming Compact
Appendix A - Standards of Operation and Management for Class III Activities (Amended and
Restated)
4
(h) Shuffle machines;

(i) Keno systems;

(j) Progressive computers and displays; and

(k) Such other equipment as may be required for use in authorized Class III
activities.

6. PROGRESSIVE AND PLAYER SUPPORTED JACKPOTS

T
Unless governed by Appendix W. (Rules for Governing Wide Area Progressive), any progressive
or player supported jackpot prizes available on Class III Gaming activities will be submitted as
part of game rules in accordance with the requirements of the Compact and related Appendices.

6.1.

6.2.

6.3.
AF
Rules submissions submitted under the requirements of the Compact and related
Appendices will include how each Gaming Facility accounts for funds collected from
each progressive or player supported jackpot separately and how funds are accrued.

Summaries of the rules posted for patrons required by Compact Section IX.B. will
include how funds are accrued and prizes available.

If the Tribe discontinues a progressive or player supported jackpot, they must distribute
the funds to the patrons:

DR
6.3.1. Within sixty (60) days;

6.3.2. The balance, less any seed money or money contributed by the Gaming
Operation; and

6.3.3. In a method approved by both the Tribal Gaming Agency and State Gaming
Agency, to include:

(a) offering a drawing

(b) transferring the funds to another jackpot;

Squaxin Island Tribe-State of Washington Gaming Compact
Appendix A - Standards of Operation and Management for Class III Activities (Amended and
Restated)
5
(d) other method of distribution that returns the balance to the Gaming public.

7. ACCOUNTING RECORDS

7.1. The Gaming Operation shall maintain complete, accurate, and legible records of all
transactions relating to the revenues and costs of the Gaming Operation.

7.2. General accounting records shall be maintained on a double entry system of accounting
with transactions recorded on the accruals basis, and detailed, supporting, subsidiary
records, sufficient to meet the requirements of subsection 7.4. below.

7.3.

7.4.
T
The forms of accounts adopted should be of a standard form which would ensure
consistency, comparability, and effective disclosure of financial information.

The detailed, supporting and subsidiary records shall include, but not necessarily be
limited to:

AF
7.4.1. Statistical game records to reflect Drop and Win or Loss amounts for each station,
for each game, and for each shift;

7.4.2. Investments in property and services, including equipment used in connection
with the operation of Class III Gaming;

7.4.3. Records of amounts payable by the Gaming Operation; and

DR
8.1.
7.4.4. Records which identify the purchase, receipt and destruction of Gaming chips
used in wagering.

8. FORMS, RECORDS, DOCUMENTS AND RETENTION

All information required by these Standards to be placed on a form, record or document
shall be recorded in ink or stored in another permanent format.

8.2. Whenever duplicate or triplicate copies are required of a form, record or document:

8.2.1. The original, duplicate, and triplicate copies shall be color-coded, unless digitally
or electronically generated;

Squaxin Island Tribe-State of Washington Gaming Compact
Appendix A - Standards of Operation and Management for Class III Activities (Amended and
Restated)
6
8.2.2. If under these Standards, forms, records, and documents are required to be
inserted in a locked dispenser, the last copy shall remain in a continuous unbroken
form in the dispenser;

8.2.3. If under these Standards, forms or serial numbers of forms are required to be
accounted for or copies of forms are required to be compared for agreement and
exceptions noted, such exceptions shall be reported immediately in writing to the
Tribal Gaming Agency for investigation; and

8.2.4. These forms, records or documents may be digitally or electronically generated
and stored as data.

8.3.

8.4.
T
Unless otherwise specified in these Standards, all forms, records, documents, and stored
data shall have the title imprinted or pre-printed or saved thereon or therein.

Unless otherwise specified in these Standards, all forms, records, documents, and stored

8.5.
AF
data required to be prepared, maintained and controlled shall be located on Tribal Lands
or such other location as is approved by the Tribal Gaming Agency. The records shall be
stored in a manner that assures reasonable accessibility to Agents of the Tribal Gaming
Agency and personnel of the State Gaming Agency.

Unless otherwise specified in these Standards, all records shall be kept for a period not
less than two (2) years from their respective dates. If not dated, then for two (2) years
from their time of creation.

DR
9.1.
9. ORGANIZATION OF THE GAMING OPERATION

The Gaming Operation shall have a system of accounting and Internal Controls that
includes the following:

9.1.1. Administrative control, which includes but is not limited to the plan of
organization including an organization chart, job descriptions, or comparable
information, and the procedures and records that are concerned with the decision
processes leading to management's authorization of transactions; and

9.1.2. Accounting control which includes the plan of organization and the procedures
and records that are concerned with the safeguarding of assets and the reliability
of financial records and are consequently designed to provide reasonable
assurance that:

Squaxin Island Tribe-State of Washington Gaming Compact
Appendix A - Standards of Operation and Management for Class III Activities (Amended and
Restated)
7
(a) Transactions are executed in accordance with the management's general and
specific authorization which shall include the requirements of these Standards;

(b) Transactions are recorded as necessary to permit preparation of financial
statements in conformity with generally accepted accounting principles and
with these Standards, and to maintain accountability for assets;

(c) Access to assets is permitted only in accordance with management's
authorization which shall include the requirements of these Standards; and

(d) The recorded accountability for assets is compared with existing assets at

9.2.
T
reasonable intervals and appropriate action is taken with respect to any
differences.

The Gaming Operation's system of accounting and Internal Controls shall provide for:

9.3.
AF
9.2.1. Competent personnel with an understanding of prescribed procedures; and

9.2.2. The segregation of Incompatible Functions so that no employee is in a position to
perpetrate and conceal errors or irregularities in the normal course of his or her
duties.

The Gaming Operation shall, at a minimum, establish the following departments:

DR
9.3.1. A security department supervised by the head of the security department who
shall cooperate with, yet perform independently of, all other departments and
shall report directly to the Chief Executive Officer of the Gaming Operation
regarding matters of policy, purpose, and responsibilities. The head of security
shall be responsible for, but not limited to the following:

(a) The physical safety of all patrons and employees, as well as their property, as
authorized by the Tribal Gaming Agency;

(b) The physical safety of the facility and assets of the Tribe, to include Keys, as
authorized by the Tribal Gaming Agency;

Squaxin Island Tribe-State of Washington Gaming Compact
Appendix A - Standards of Operation and Management for Class III Activities (Amended and
Restated)
8
as authorized by the Tribal Gaming Agency; and

(d) The physical control of Gaming equipment inventories. Such inventories shall
specifically include cards, dice, shoes, and other Gaming equipment deemed
appropriate. The security department shall control the receipt, storage,
issuance, collection, disposition, and/or destruction of same, subject to
oversight by operations management and as authorized by the Tribal Gaming
Agency.

9.3.2. A Gaming Facility department supervised by a Gaming Facility Manager who
shall perform independently of all other departments and shall report directly to
the Chief Executive Officer. The Gaming Facility Manager shall be responsible

T
for the operation and conduct of all Class III activities conducted in the Gaming
Facility.

9.3.3. A Gaming Facility Accounting Department supervisor who shall report directly to

AF
the Chief Financial Officer or equivalent. The supervisor responsibilities shall
include, but not be limited to, the following:

(a) Accounting controls;

(b) The preparation and control of records and data required by these Standards;
and

DR
comparing of forms used in the Gaming Operation and required by these
Standards.

9.3.4. A cashier's cage supervised by a cage manager who shall supervise Cage Cashiers
and cooperate with, yet perform independently of, the Gaming Facility and
security departments, and shall be under the supervision of, and report directly to
the Chief Financial Officer or equivalent. The cage shall be responsible for, but
not limited to the following:

(a) The custody of currency, coin, patron checks, Gaming chips, and documents
and records normally associated with the operation of a cashier's cage;

(b) The approval, exchange, redemption and consolidation of patron checks

Squaxin Island Tribe-State of Washington Gaming Compact
Appendix A - Standards of Operation and Management for Class III Activities (Amended and
Restated)
9
received for the purpose of Gaming in conformity with the Gaming
Operation's Standards;

(d) Such other functions normally associated with the operation of a cashier's
cage.

9.3.5. An information technology department with limited administrative access to
electronic equipment and information systems for the purpose of technical
support, supervised by a head of information technology manager, who shall

T
cooperate with, yet perform independently of, all other departments and shall
report directly to the Chief Operating Officer of the Gaming Operation regarding
matters of policy, purpose, and responsibilities. For purposes of this section,
limited administrative access means troubleshooting any issues within the system;

AF
patching, updating, and keeping the system secure; administrative support for
information technology issues; verifying that back-ups of data are proceeding as
normal, and monitoring the health of the network/system infrastructure. The head
of information technology shall be responsible for, but not limited to, the
following:

(a) Understanding the complex role of technology in each Gaming Facility;

(b) Ensuring information technology functions for electronic equipment and

DR
information systems throughout each Gaming Facility are separated into
distinct job duties to prevent an information technology department employee
from harming, manipulating, concealing, or damaging an operational system
or the services it provides, whether by an accidental act, omission, or
intentional act; and

(c) No present or former information technology department employee shall be
employed in any other capacity in the Gaming Operation unless the Tribal
Gaming Agency, upon written petition, approves such employment in a
particular capacity upon a finding that:

i. Each Gaming Facility’s electronic equipment and information systems
will not be compromised; and

Squaxin Island Tribe-State of Washington Gaming Compact
Appendix A - Standards of Operation and Management for Class III Activities (Amended and
Restated)
10
ii. Incompatible Functions, errors, irregularities, or illegal acts cannot be
concealed or perpetrated.

9.4. The Gaming Operation’s personnel shall be trained in all accounting and Internal
Controls practices and procedures relevant to each employee's individual function.
Special instructional programs shall be developed by the Gaming Operation in addition to
any on-the-job instruction sufficient to enable all members of the departments required by
this Standard to be thoroughly conversant and knowledgeable with the appropriate and
required manner of performance of all transactions relating to their function.

10. CAGES
10.1. As part of the Gaming Operation there shall be on or immediately adjacent to the Gaming

T
floor a physical structure known as the cage to house the cashiers and to serve as the
central location for the following:

10.1.1. The custody of the cage inventory comprising currency, coin, patron checks,

AF
Gaming chips, forms, documents, and records normally associated with the
operation of a cage;

10.1.2. The approval of patron checks for the purpose of Gaming in conformity with
these Standards;

10.1.3. The receipt, distribution, and redemption of Gaming chips in conformity with
these Standards; and

DR
10.2.
10.1.4. Such other functions normally associated with the operation of a cage.

As part of the cage there may be a separate physical structure known as satellite cage(s)
located on or immediately adjacent to the Gaming floor which can include, but are not
limited to, keno, OTB, or Tribal Lottery System cashiers who:

10.2.1. Buy and sell keno tickets, OTB vouchers, and/or Tribal Lottery System vouchers;
and

10.2.2. Such other functions normally associated with the operation of a cage.

10.3. The Gaming Operation shall have a reserve Cash bankroll in addition to the funds
normally maintained by the cashier's cage, on hand in the cashier's cage or readily

Squaxin Island Tribe-State of Washington Gaming Compact
Appendix A - Standards of Operation and Management for Class III Activities (Amended and
Restated)
11
available to the cashier's cage at the opening of every shift in a minimum amount
established by the Gaming Operation.

10.4. Each cage will be designed and constructed to provide maximum security including, at a
minimum, the following:

10.4.1. An enclosed structure except for openings through which items such as Gaming
chips, checks, cash, records, and documents can be passed to service the public
and Gaming Stations;

10.4.2. Manually triggered silent alarm systems connected to the monitoring rooms of the
Closed Surveillance System and the security department office;

T
10.4.3. Access will be through a locked door; and

10.4.4. The system shall have surveillance coverage which will be monitored by the

10.5.

10.6.
AF
surveillance department.

The Gaming Operation will place on file with the Tribal Gaming Agency the names of all
persons authorized to enter the cage, those who possess the combination or the Keys or
who control the mechanism to open the locks securing the entrance to the cage, and those
who possess the ability to operate the alarm systems.

The cashier’s cage shall be responsible for establishing procedures and controls necessary
to comply with the Bank Secrecy Act, 31 U.S.C. § 5311 et seq., as now or hereafter

DR
11.1.
amended.

11. ACCOUNTING CONTROL WITHIN THE CASHIER'S CAGE

The assets for which the cashiers are responsible shall be maintained on an Imprest Basis;
provided, the cage may operate on a float basis if documented in the system of
accounting and Internal Controls and approved by the Tribal Gaming Agency. At the end
of each shift, the cashiers assigned to the outgoing shift, shall record on a cashier's count
sheet the face value of each cage inventory item counted and the total of the opening and
closing cage inventories and will reconcile the total closing inventory with the total
opening inventory.

11.2. Cashiers’ functions will be, but are not limited to the following:

Squaxin Island Tribe-State of Washington Gaming Compact
Appendix A - Standards of Operation and Management for Class III Activities (Amended and
Restated)
12
11.2.1. Receive currency, coin, checks, Gaming chips, vouchers, or Cash Equivalents
from patrons for Gaming chip consolidations, total or partial redemptions or
substitutions;

11.2.2. Receive documentation with signatures thereon, required to be prepared for the
effective segregation of functions in the cage;

11.2.3. Process Fills and Credits by exchanging chips, currency, coin and paperwork as
authorized in these Standards;

11.2.4. Receive currency and coin from count rooms and kiosks;

T
11.2.5. Prepare the overall cage reconciliation and accounting records; and

11.2.6. Perform such other functions as necessary to ensure proper accountability
consistent with these Standards.

11.3.

11.4.
AF
Cashier signatures from the incoming and outgoing shifts attesting to the accuracy of the
information will be at a minimum on the following sheets: the cashiers count sheet, the
Fill bank closeout sheet, and the main bank closeout sheet.

At the conclusion of Gaming activity each day, at a minimum, copies of the cashier's
count sheet, reconciliation, Fill, main, and related documentation, will be forwarded to
the Accounting Department for agreement of opening and closing inventories, and
agreement of amounts thereon to other forms, records and documentation required by

DR
12.1.
these Standards or for the recording of transactions.

12. DROP BOXES

In the Gaming Facility, each Gaming Station and each Player Terminal and Kiosk will
have attached to it a container known as a ‘Drop Box’, in which will be deposited all
Cash, vouchers, duplicate Fills and Credits, Requests for Fills and Credits, station
inventory forms, or other forms. Gaming Stations will have metal Drop Boxes and each
Player Terminal or Kiosk will have either plastic or metal Drop Boxes.

12.2. Each Drop Box will have:

12.2.1. One separate lock securing the contents placed into the Drop Box, the Key to
which will be different from any other Key;

Squaxin Island Tribe-State of Washington Gaming Compact
Appendix A - Standards of Operation and Management for Class III Activities (Amended and
Restated)
13
12.2.2. A separate lock securing the Drop Box to the Gaming Stations, the Key to which
will be different from the Key to the lock securing the contents of the Drop Box;

12.2.3. An opening through which currency, coins, forms, records, and documents can be
inserted into the Drop Box;

12.2.4. Permanently imprinted or impressed thereon, and clearly visible, a number
corresponding to a distinct number on the Gaming Station, Player Terminal, or
Kiosk to which it is attached, and a marking to indicate game, table number, and
shift, except that emergency Drop Boxes may be maintained without such number
or marking, provided the word “emergency” is imprinted or impressed thereon

T
and, when put into use, are temporarily marked with the number of the Gaming
Station and identification of the game and shift.

12.2.5. Gaming Operation may use alternative Drop Box labels which can electronically

AF
store the identification number of the device or station to which it is attached.

(a) In the event barcodes are used, a distinct barcode will be attached on each Drop
Box that, when scanned, assigns to that Drop Box the date, shift and Gaming
Station number that corresponds to a permanently marked number on the
Gaming Station, Player Terminal, or Kiosk to which it is attached.

(b) In the event “smart cans” are used, the Gaming Station number will be
maintained on a chip located in each individual smart can Drop Box. This

DR
12.3.

12.4.
Gaming Station, Player Terminal, or Kiosk number will be tracked and may
be cleared and reset in a manner and a form acceptable to the Tribe and
documented in the Gaming Operation’s system of accounting and Internal
Controls.

The Key utilized to unlock the Drop Boxes from the Gaming Stations will be maintained
and controlled by the security department.

The Key to the lock securing the contents of the Drop Boxes will be maintained and
controlled by the Tribal Gaming Agency.

Squaxin Island Tribe-State of Washington Gaming Compact
Appendix A - Standards of Operation and Management for Class III Activities (Amended and
Restated)
14
13. DROP BOXES TRANSPORTATION AND STORAGE

13.1. All Drop Boxes removed from the Gaming Stations, Player Terminals, or Kiosks will be
transported, at a minimum, by one Security Department Member and one employee of
the Gaming Operation and secured in the count room at the completion of the Drop. A
member of the Tribal Gaming Agency will be required to observe, either remotely or in-
person, while boxes are removed from Gaming Stations.

13.2. All Drop Boxes, not attached to a Gaming Station, Player Terminal, or Kiosk, will be
stored in the count room in an enclosed storage cabinet or trolley and secured in such
cabinet or trolley by a separately keyed, double locking system. The Key to one lock will

13.3.
T
be maintained and controlled by the security department and the Key to the second lock
will be maintained and controlled by the Tribal Gaming Agency Agent.

Drop Boxes, when not in use during a shift may be stored on the Gaming Stations

14.1.
AF
provided that there is adequate security. If adequate security is not provided during this
time, the Drop Boxes will be stored in the count room in an enclosed storage cabinet or
trolley as required in subsection 13.2 above.

14. CHECKS AND CREDIT CARDS

Except as otherwise provided in this section or in Appendix E, no employee of the
Gaming Operation, and no person acting on behalf of or under any arrangement with the
Gaming Operation, will make any loan, or otherwise provide or allow to any person any

DR
14.2.
credit or advance of anything of value or which represents value to enable any person to
take part in Gaming activity as a player.

The acceptance of patron checks, paper or electronic, is allowed in accordance with
normal commercial practices.

14.2.1. Withholding checks received from any deposit is considered an extension of
credit.
14.2.2. Records will be maintained documenting all dishonored checks until paid in full.
The records must include at a minimum, the person’s name, check amount, date
dishonored, and any amounts paid against balance.
14.2.3. If a check is dishonored, it may be re-deposited if there is sufficient reasons to
believe the check will be honored the second time. If the check is dishonored a

Squaxin Island Tribe-State of Washington Gaming Compact
Appendix A - Standards of Operation and Management for Class III Activities (Amended and
Restated)
15
second time, the person shall be prohibited from submitting any future check until
the amount is paid in full.
14.2.4. Any checks processed and pre-approved through an outside check guarantee
company will not be subject to the provisions of (b) and (c) above unless the
Gaming Operation chooses not to use their guarantee service to pre-approve a
particular check.

14.3. Cash advances on patrons' credit cards or bank cards in accordance with normal
commercial practices is allowed.

15. ACCEPTANCE OF GRATUITIES FROM PATRONS

15.1.

T
No Gaming Employee can solicit or accept any tip or gratuity from any player or patron
when directly concerned with:

15.1.1. Management,

15.2.
AF
15.1.2. Accounting,

15.1.3. Security, or

15.1.4. Surveillance.

Management refers to an person having the authority to approve policies or procedures
for the Gaming Facility or to direct persons to perform outside the scope of the Internal
Controls.

D
15.3.

R 16.

16.1.
The Gaming Operation shall establish a procedure for accepting and accounting for all
tips received by other Gaming Employees.

GAMING STATION INVENTORY REQUIREMENTS AND PROCEDURES

Gaming chips or coins cannot be added to or removed from station inventory during the
Gaming day except:

16.1.1. In exchange for Cash;

16.1.2. In payment of winning wagers and collection of losing wagers made at such
Gaming Station;

Squaxin Island Tribe-State of Washington Gaming Compact
Appendix A - Standards of Operation and Management for Class III Activities (Amended and
Restated)
16
16.1.3. In exchange for Gaming chips received from a patron having an equal aggregate
face value; and

16.1.4. In conformity with the Fill and Credit procedures described in these Standards.

16.2. Gaming Station inventory slips, Opener, Closer, and triplicate, are serially numbered and
document the value of each denomination of Gaming chips and coins on each Gaming
Station at a specified period of time, which will be at a minimum when a Gaming Station
is opened and closed.

16.2.1. Signatures attesting to the accuracy of the station inventory shall be of the
Gaming Facility Supervisor assigned to the Gaming Station and Dealer or another
table games employee.

T
16.2.2. Each copy of the Gaming Station inventory slip, Opener, Closer, and triplicate,
will be distributed in accordance with approved accounting and Internal Controls.

16.3.
AF
16.2.3. Each station inventory shall be stored in a separate locked, clear container secured
to the Gaming Station while not in use with the information on a copy of the
Gaming Station inventory slip visible from outside the container.

The Keys to the locked containers containing the station inventories shall be maintained
and controlled by the Gaming Facility Supervisor in a secure place and will not be
accessible to any cashier's cage or security personnel.

D
16.4.

R
17.
Any discrepancy between the station inventory and the Gaming Station inventory slip
shall be immediately reported to at least the Gaming Facility Shift Manager, the security
department, and the Tribal Gaming Agency. A Notification of Error (NOE) or security
report shall be completed in conformity with agreed upon system of accounting and
Internal Controls.

PROCEDURES FOR DISTRIBUTING AND REMOVING GAMING CHIPS AND
COINS TO AND FROM GAMING STATIONS

17.1. Gaming chips or coins cannot be added to or removed from station inventory unless:

17.1.1. Request for Fill is completed to transfer Gaming chips or coins from the cage to the
Gaming Station with the signatures of at least the Gaming Facility Supervisor
requesting the transfer of Gaming chips.

Squaxin Island Tribe-State of Washington Gaming Compact
Appendix A - Standards of Operation and Management for Class III Activities (Amended and
Restated)
17
17.1.2. Request for Credit is completed to transfer Gaming chips or coin from the Gaming
Station to the cage with the signatures of at least the Gaming Facility Supervisor
requesting the transfer and a Security Department Member completing the transfer.

17.2. A Fill or Credit is serially numbered and documents at a minimum the date, time,
Gaming Station number, and the value of each denomination of Gaming chips and coins
being transferred.

17.2.1. Signatures attesting to the accuracy of the Fill or Credit shall be at least the
Gaming Facility Supervisor assigned to the Gaming Station, the Dealer assigned
to the Gaming Station, Security Department Member transferring the Gaming

T
chips or coins, and the Cage Cashier preparing the forms.

17.2.2. One copy of the Fill or Credit shall be placed in the Gaming Station Drop Box,
one (1) copy shall be kept with the Cage Cashier records, and one (1) copy shall

AF
be secured for comparison by the Accounting Department.

17.2.3. If an error is found, mark "VOID" on the original and duplicate, and the preparer
shall sign. All voided forms shall be forwarded to the Accounting Department.

17.2.4. Kept in a locked dispenser that will permit an individual slip in the series and its
copies to be written upon simultaneously, and that will discharge the original and
duplicate while the triplicate remains in a continuous, unbroken form in the
dispenser or other secure method approved in the system of accounting and

DR
Internal Controls.

17.2.5. Computer applications, alternative documentation, and/or alternative procedures
may be used in place of the procedures described in this subsection so long as
they provide at least the level of control described by the manual standards in this
subsection. The Gaming Operation’s approved system of Internal Controls shall
include the information and procedures as specified in Compact Section IX.

18. COUNT ROOM: CHARACTERISTICS

18.1. The Gaming Operation will have a count room specifically designated for counting the
contents of at a minimum Drop Boxes and banks.

Squaxin Island Tribe-State of Washington Gaming Compact
Appendix A - Standards of Operation and Management for Class III Activities (Amended and
Restated)
18
18.2. The count room shall be designed and constructed to provide maximum security to
include at a minimum, the following:

18.2.1. A door equipped with two separately Keyed locks securing the interior of the
count room. The Keys shall be different from any other Keys. One Key shall be
maintained and controlled by the security department and the other Key
maintained and controlled by the Gaming Facility department or Tribal Gaming
Agency;

18.2.2. The security department shall establish a sign out procedure for all Keys removed
from the security department; and

18.3.
T
18.2.3. An alarm device connected to the entrance of the count room that signals the
surveillance room whenever the door to the count room is opened.

Located within the count room shall be count table(s) constructed of clear glass or similar

19.

19.1.
AF
material for the emptying, counting, and recording of the contents of the Drop Boxes and
banks.

PROCEDURE FOR COUNTING AND RECORDING DROP BOXES CONTENTS

The opening, counting and recording of the contents of Drop Boxes will be done by at
least three (3) employees assigned by the Gaming Operation to perform the count, known
as the "count team", and who have no Incompatible Functions.

D
19.2.

R
19.3.
Surveillance will be notified at the start of the count. Immediately prior to the opening of
any Drop Boxes, the doors to the count room shall be securely locked and except as
otherwise authorized by this Standard, no person shall be permitted to enter or leave the
count room until the entire counting, recording, and verification process is completed;
provided a person may leave or enter the count room during a normal work break after
the last opened Drop Box has been counted, verified, and recorded, or in an emergency.
Each Drop Box will be uniquely identified to and recorded by surveillance.

As the contents of each Drop Box are counted separately at least twice, which counts may
be made by a currency counter, the amounts will be recorded and/or compared to the
Master Game Report for Gaming Stations, and Tribal Lottery System reports for Player
Terminals and Kiosks.

Squaxin Island Tribe-State of Washington Gaming Compact
Appendix A - Standards of Operation and Management for Class III Activities (Amended and
Restated)
19
19.4. After completion of the Drop and verification of the Master Game Report and Tribal
Lottery System reports, each count team member shall sign the report attesting to the
accuracy of the information recorded thereon.

19.5. All Cash and Gaming chips removed and counted shall be presented in the count room to
a cashier who shall verify the Cash and Gaming chips received and shall sign the report
evidencing the fact that both the cashier and count team have agreed on the total amount
of Cash and Gaming chips counted. Then the cashier shall take a copy of the signed
Master Game Report and Tribal Lottery System reports and the Cash and Gaming chips
into the cage.

19.6. At no time after the entire count team has signed the master game report shall any change

19.7. T
be made to it without prior written approval of the Tribal Gaming Agency.

The paperwork from the Drop Boxes shall not be available to any cashier's cage
personnel and shall be transported directly to the Accounting Department with one (1)

19.8.

19.9.
AF
copy of the signed Master Game Report and Tribal Lottery System reports.

The originals and copies of the Master Game Report and Tribal Lottery System reports,
Request for Fills, Fills, Request for Credits, Credits, and station inventory slips shall be
audited on a daily basis in the Accounting Department.

The master game report will be maintained for inspection and provided to the Tribal
Gaming Agency daily.

DR
20.1.
20. SIGNATURES

Signatures of each person required by these Standards to sign or initial forms, records and
documents shall:

20.1.1. Be, at a minimum, the signer's first initial and last name;

20.1.2. Include his or her certificate or permit number; and

20.1.3. Signify that the signer has prepared forms, records, and documents, and/or
authorized to a sufficient extent to attest to the accuracy of the information
recorded thereon, in conformity with these Standards and the Gaming Operation's
system of accounting and Internal Controls.

Squaxin Island Tribe-State of Washington Gaming Compact
Appendix A - Standards of Operation and Management for Class III Activities (Amended and
Restated)
20
20.2. Signature records shall be prepared for each person required by these Standards to sign or
initial forms, records, and documents, and shall include specimens of signatures, initials
of signers, and department. Such signature records shall be maintained on a dated
signature card filed alphabetically by last name. The signature records shall be adjusted
on a timely basis to reflect changes of personnel.

20.3. Signature records shall be securely stored in the Accounting Department or human
resource department.

20.4. Electronic signature records may be used in place of the above and shall be maintained in
a secure electronic format and shall be immediately available to the Tribal Gaming
Agency and State Gaming Agency upon request.

21.
T
SURVEILLANCE DEPARTMENT

A surveillance department shall be supervised by the head of the surveillance department, who

AF
shall cooperate with, yet perform independently of all other departments and shall report directly
to the head of the Tribal Gaming Agency regarding matters of policy, purpose, and responsibilities.

21.1. The head of surveillance shall be responsible for, but not limited to, the following:

21.1.1. The clandestine surveillance of the operation and conduct of the Gaming
activities;
21.1.2. The clandestine surveillance of the operation of the cashier's cage(s);
21.1.3. The video and audio recording of activities in the count rooms;

DR
21.2.
21.1.4. The detection of cheating, theft, embezzlement, and other illegal activities in the
Gaming Facility, count rooms, and cashier's cage(s);
21.1.5. The video recording of illegal and unusual activities monitored; and
21.1.6. The notification of appropriate Gaming Facility Supervisors, and the Tribal
Gaming Agency upon the detection and recording of cheating, theft,
embezzlement, or other illegal activities.

No present or former surveillance department employee shall be employed in any other
capacity in the Gaming Operation unless the Tribal Gaming Agency, upon written
petition, approves such employment in a particular capacity upon a finding that:

21.2.1. Surveillance and security systems will not be jeopardized or compromised by the
proposed employment of the former surveillance department employee in the
capacity proposed; and

Squaxin Island Tribe-State of Washington Gaming Compact
Appendix A - Standards of Operation and Management for Class III Activities (Amended and
Restated)
21
21.2.2. Errors, irregularities, or illegal acts cannot be concealed or perpetrated by the
former surveillance department employee's knowledge of the Closed Surveillance
System in the capacity in which the former surveillance department employee will
be employed.

22. CLOSED SURVEILLANCE SYSTEM

22.1. The Tribal Gaming Agency shall install a Closed Surveillance System according to the
following specifications.

22.2. The Closed Surveillance System shall include at least the following:

T
22.2.1. Light sensitive cameras some with zoom, scan, and tilt capabilities to effectively
and clandestinely monitor in detail and from various vantage points, the
following:

AF
(a) All Gaming activities conducted in the Gaming Facility;

(b) The operations conducted at and in the cashier's cage and satellite cages;

(c) The entire count process and any other activities conducted in the count room
and the storage cabinets or trolleys used to store Drop Boxes;

(d) The movement of Cash, Gaming chips, and Drop Boxes in the establishment;

DR
(e) The entrances and exits to the Gaming Facility and the count rooms; and

(f) Such other areas as the Tribal Gaming Agency designates.

22.2.2. Video recording units with time and date insertion capabilities for recording what
is being viewed by any camera of the system;

22.2.3. Audio capability of the entire count process and any other activities in the count
room; and

22.2.4. One or more monitoring rooms in each Gaming Facility which shall be in use at
all times by the employees of the Tribal Gaming Agency and may be used as
necessary by agents of the State Gaming Agency.

Squaxin Island Tribe-State of Washington Gaming Compact
Appendix A - Standards of Operation and Management for Class III Activities (Amended and
Restated)
22
22.3. Adequate lighting shall be present in all areas, including Gaming activities and Pits,
where closed surveillance coverage is required.

22.4. The surveillance department shall be required to maintain a surveillance log of all
surveillance activities in the monitor room. The log shall be maintained by monitor room
personnel and shall include, at a minimum, the following:

22.4.1. Date and time of surveillance;

22.4.2. Person initiating surveillance;

22.4.3. Reason for surveillance;

T
22.4.4. Time of termination of surveillance;

22.4.5. Summary of the results of the surveillance; and

22.5.

22.6.
AF
22.4.6. A record of any equipment or camera malfunctions.

The surveillance log shall be available for inspection at any time by agents of the of the
State Gaming Agency.

Video or audio recordings shall be retained for at least seven (7) days and at least thirty
(30) days in the case of recordings of evidentiary value, or for such longer period as the
Tribal Gaming Agency or the State Gaming Agency may require.

D
22.7.

R
22.8.
Entrances to the closed surveillance monitoring rooms shall not be visible from the
Gaming Facility area.

Digital Surveillance

22.8.1. Digital images record and playback of images with sufficient magnification and
clarity that shows fluid motion and allows the viewer to clearly distinguish the
value of currency, coins, Gaming chips, playing cards, and outcome of the game
and effectively monitor in detail all areas in the Gaming Facility where Class III
Gaming is conducted, including but not limited to table games, TLS, poker, keno

Squaxin Island Tribe-State of Washington Gaming Compact
Appendix A - Standards of Operation and Management for Class III Activities (Amended and
Restated)
23
stations, cages, count rooms, information technology department, and all Gaming
activity conducted by Gaming Employees, patrons or players.

22.8.2. The recording systems must be equipped with an alarm that notifies the operator
in the event of an equipment malfunction.

22.8.3. The system is to provide an authentication process such as encryption and/or
watermark to prevent and/or detect tampering.

22.8.4. Digital cameras can be on motion detection setting, recording only when motion
is detected which occurs anytime there is a pixel change viewed by the camera.
The pictures are still observable to the operator but it does not provide a

T
continuous recording when no motion is detected.

22.8.5. The recording system is password protected with only system administrator user
rights having the password to disable the erase and reformat functions. This is to

AF
prevent access to system files by unauthorized personnel.

22.8.6. Recordings from the digital Closed Surveillance System can only be viewed/read
by Individuals with access to the proprietary reader software. Only employees
who are licensed by the Tribal Gaming Agency and certified, registered,
determined eligible, or licensed by the State Gaming Agency as a Class III
Gaming Employee, Tribal Gaming Agents, State Gaming Agents, members of
Local Law Enforcement, and Individuals authorized by the Tribal Gaming
Agency may have access to live or recorded camera coverage.

DR
22.8.7. Digital surveillance suppliers may have periodic remote access to perform routine
upgrades and maintenance under the following conditions:

(a) The Tribal Gaming Agency must approve the remote access prior to it
occurring.

(b) A log must be kept of the remote access to include who was accessing, how
long they were remotely connected and the address of the remote connection.

(c) All supplier representatives remotely accessing the Closed Surveillance
System must be licensed by the Tribe and certified by the State Gaming
Agency.

Squaxin Island Tribe-State of Washington Gaming Compact
Appendix A - Standards of Operation and Management for Class III Activities (Amended and
Restated)
24
(d) At no time will the supplier representatives have access to manipulate or
change live or recorded camera coverage.

(e) The physical connections must only be made for service work and must be
disconnected immediately after work is completed.

T
AF
DR
Squaxin Island Tribe-State of Washington Gaming Compact
Appendix A - Standards of Operation and Management for Class III Activities (Amended and
Restated)
25
SQUAXIN ISLAND TRIBE - STATE OF WASHINGTON
GAMING COMPACT

APPENDIX B
Satellite (Off-Track) Wagering on Horse Races
(Amended and Restated)

Table of Contents
1. DEFINITIONS .................................................................................................................... 1
2. APPLICABILITY OF LAWS. ........................................................................................... 1
3. REGULATION OF SATELLITE (OFF-TRACK) WAGERING. ..................................... 2

T
AF
DR
Squaxin Island Tribe - State of Washington Gaming Compact
Appendix B - Satellite (Off-Track) Wagering on Horse Races (Amended and Restated)
i
1. DEFINITIONS
The following definitions apply to these standards. All capitalized terms, to the extent they
do not conflict, shall have the definition as in the Compact. Except as otherwise provided
herein, meanings ascribed to terms used in the Horse Racing Law, RCW 67.16, and the
Commission Regulations, WAC 260, are hereby adopted by reference wherever such terms
are applicable in this Appendix.

1.1 "Conventional parimutuel pool" means the total wager under the parimutuel system
on any horse or horses in a particular race to win, place, or show.

1.2 "Exotic parimutuel pool" means the total wagers under the parimutuel system on the
finishing position of two or more horses in a particular race, such as Quinella or
Exacta wagers, or on horses to win two or more races, such as Daily Double wagers,

1.3
T
Pick Six wagers, or on other wagers other than Conventional Parimutuel Pool wagers.

"Parimutuel wagering" means a form of wagering on the outcome of horse races in
which those who wager purchase tickets of various denominations on a horse or

1.4

1.5
AF
horses in one or more races. When the outcome of the race or races has been declared
official, there is a distribution of the total wagers comprising each pool, less any
amounts permitted to be retained by law or under this Compact, to holders of winning
tickets on the winning horse or horses.

"Satellite Wagering" means Parimutuel Wagering on Simulcast results.

"Satellite wagering facility" means any facility in which Satellite Wagering is

DR
1.6

1.7
conducted.

"Simulcast" means the simultaneous television or radio transmission of a race to a
facility other than where the race meet is being held.

"Wagering employee" means any person who is employed by the Tribe or at any
Satellite Wagering Facility hereunder to handle any monies, materials, records or
equipment related to the Satellite Wagering permitted herein, or who supervises any
person who does so or supervises any such supervisor.

2. APPLICABILITY OF LAWS.
Wagering at the Tribe’s Satellite Wagering Facility will be conducted in accordance with this
Compact, the Indian Gaming Regulatory Act, the Interstate Horseracing Act, any ordinances
or regulations adopted by the Tribe, and Washington Horse Racing Laws as made applicable

Squaxin Island Tribe - State of Washington Gaming Compact
Appendix B - Satellite (Off-Track) Wagering on Horse Races (Amended and Restated)
1
herein. Nothing herein shall otherwise be deemed a prohibition upon or limitation upon tribal
operation of a Satellite Wagering Facility by the Tribe or on behalf of the Tribe.

3. REGULATION OF SATELLITE (OFF-TRACK) WAGERING.
3.1 Wagering Permitted. The Tribe is entitled to operate a single Satellite Wagering
Facility pursuant to this Compact subject to the following terms and conditions:

a. Unless permitted in accordance with subparagraph 3.1.c, below, Tribe may
conduct Satellite Wagering only on events Simulcast from any Washington State
track (whether of a live race, or an authorized Simulcast of an out-of-state signal)
on the same terms and conditions permitted any other Satellite Wagering Facility
in the State without limitation on the distance such tribal facility is from a live
race meet, provided, the Tribe is entitled to receive Simulcast signals from each

T
Washington State track on terms at least as advantageous as those made available
by such track to any other satellite facility operated at a track holding a Class A or
Class B Washington Horse Racing Commission (“Commission”) license or at any
other facility operated or leased by an entity holding such a license. Negotiations

AF
conducted between the Tribe and the track shall cover areas including, but not
limited to, the following: percent of handle received; equipment required and who
provides such equipment; who provides Wagering Employees; and how and on
what schedule funds will be transferred. All wagers accepted at the tribal facility
on such events shall be made into the parimutuel pool of the Washington State
track which provides the Simulcast signal and shall be deemed to have been made
at the location of such pool for the purposes of assessment of fees, charges, taxes
or other assessments. Nothing herein shall prohibit assessment by the Tribe of

DR
taxes, fees or other charges for wagering conducted at the tribal facility, nor shall
the State or any of its political subdivisions be authorized to impose any taxes,
fees, charges or assessments upon the Tribe or any person or entity authorized to
conduct such activities on behalf of the Tribe for the Satellite Wagering activities
regulated hereunder, other than those generally applicable to the parimutuel pool.

b. In the event the Tribe believes it is not offered Simulcast signals from a
Washington State track on terms at least as advantageous as those made available
by such track to the other Satellite Wagering operators as set forth in
subparagraph 3.1.a, above, the Tribe may request a formal determination from the
Commission. The sole issues in such determination will be whether the
Washington State track provides terms to those other Satellite Wagering operators
which are more advantageous than those offered to the Tribe and, if so, what
terms are less advantageous to the Tribe. Provided, the Commission shall conduct
a hearing and render a decision within ninety (90) days after receipt of the request

Squaxin Island Tribe - State of Washington Gaming Compact
Appendix B - Satellite (Off-Track) Wagering on Horse Races (Amended and Restated)
2
for a determination from the Tribe, and further provided, that if the Commission
decision is not rendered within that time, the Tribe is entitled to conduct Satellite
Wagering in accordance with the provisions of subparagraph 3.1.c, below. If the
Commission determines that the terms offered the Tribe are less advantageous,
the Washington State track shall have thirty (30) days to offer terms that are at
least as advantageous to the Tribe, or the Tribe will be entitled to conduct Satellite
Wagering in accordance with subparagraph 3.1.c, below. If the Tribe disputes the
determination of the Commission regarding whether the terms offered to the Tribe
are less advantageous, the Tribe or State may request arbitration under Compact
Section XIII.B.

c. If, following an adverse determination from the Commission, the Washington
State track does not offer the terms identified by the Commission in accordance

T
with subparagraph 3.1.b, above, the Tribe shall be entitled to negotiate for and
receive Simulcast signals from out-of-state races for an equivalent number of
races, to be offered within the subsequent twelve (12) month period, on such
terms and conditions as it may obtain. Acceptance of signals from out-of-state

AF
tracks shall be made in compliance with the Interstate Horseracing Act, 15 USC
§3001, et seq. Nothing in this section shall be deemed to limit acceptance of
satellite wagers to the extent permitted under the Interstate Horseracing Act.
Consent of the Commission, as required under the Interstate Horseracing Act shall
not be unreasonably withheld. For disputes concerning whether the Commission
has unreasonably withheld its consent, the Tribe or the State may request
arbitration under Compact Section XIII.B.

DR
3.2

3.3
Hours of Operation. The wagering authorized in the Tribe's Satellite Wagering
Facilities shall be conducted within the hours authorized for Class III gaming under
this Compact.

Approval of Facility. Subject to approval of the physical adequacy of the facility, the
Tribe’s Reservation is hereby approved as location for the conduct of Satellite
Wagering as permitted under this Compact. The right of the Tribe to conduct Satellite
Wagering from a facility at such location shall not be affected by its distance from
any live race meet being broadcast to such facility, and statutes and regulations
imposing distance limitations on the location of Satellite Wagering Facilities relative
to live race meets, including but not limited to RCW 67.16.200(c), shall not be
applicable to the Tribe.

Squaxin Island Tribe - State of Washington Gaming Compact
Appendix B - Satellite (Off-Track) Wagering on Horse Races (Amended and Restated)
3
3.4 Wagering Rules. All of the rules set forth in WAC 260-48 ("Mutuels") are hereby
incorporated by reference as being applicable to any Satellite Wagering Facility
authorized hereunder, subject to the following qualifications:

a. References therein to "racing associations" shall mean the Tribe.

b. References therein to "enclosure of any race track" shall mean the Satellite
Wagering Facilities authorized hereunder.

c. Parimutuel machines shall be locked at the time and by the same means as are
applicable to parimutuel machines at other Satellite Wagering Facilities within the
State or as otherwise required by the parimutuel pool operator at the host race
track or other authorized source, if different therefrom, but in all cases prior to the

T
start of any race for which bets are being accepted.

d. References to "the manager of the parimutuel department" shall refer to any
person appointed to manage the Satellite Wagering Facility authorized under this

3.5
AF
Compact.

e. The Tribe may accept exotic bets, including but not limited to daily doubles,
quinellas, exactas, wagering on "short fields", daily triples, "Pick n", trifectas, and
other exotic bets to the extent made available through parimutuel pools by the
parimutuel pool operator.

Other Facilities Within Area. In the event the Commission considers allocation of

DR 3.6
exclusive or limited areas in which Satellite Wagering Facilities may be located, the
Commission will give good faith consideration to designating the Tribe’s Satellite
Wagering Facility as one of those exclusive or limited area Satellite Wagering sites.
Notwithstanding the foregoing, the conduct of Satellite Wagering at any other
facility, including a live racing facility, in the State shall not affect the right of the
Tribe to operate its Satellite Wagering Facility at any time.

Amounts Received by Tribe. The Tribe may receive from parimutuel wagers made at
its Satellite Wagering Facility such amounts as may be negotiated between it and the
operator of the parimutuel pool (track).

3.7 Security Control. The Tribe shall maintain such security controls over any Satellite
Wagering Facility authorized hereunder as would be required by the Commission for
a comparable facility off the Reservation. The Tribe shall remove, deny access to,
eject or exclude persons whose presence within such facility would be contrary to the

Squaxin Island Tribe - State of Washington Gaming Compact
Appendix B - Satellite (Off-Track) Wagering on Horse Races (Amended and Restated)
4
interests of the Tribe or the State in operating an honest, legitimate facility or in
meeting the goals and objectives of this Compact or the Act.

3.8 Accounting Practices and Audits. Any Satellite Wagering Facility authorized
hereunder shall maintain its books and records in accordance with generally accepted
accounting principles and State and Federal rules and regulations applying to Satellite
Wagering Facilities.

T
AF
DR
Squaxin Island Tribe - State of Washington Gaming Compact
Appendix B - Satellite (Off-Track) Wagering on Horse Races (Amended and Restated)
5
SQUAXIN ISLAND TRIBE
and the
STATE OF WASHINGTON
CLASS III GAMING COMPACT

APPENDIX E
Limitations on Wagers, Credit, Facilities, and
Problem Gambling Resources

Table of Contents

SECTION 1.
SECTION 2.
SECTION 3.
SECTION 4.
T
CONDITIONS AND LIMITATIONS ............................................................. 1
HIGHER WAGER LIMITS AT GAMING STATIONS ................................ 1
EXTENSION OF CREDIT.............................................................................. 3
WAGERING LIMITS—PLAYER TERMINALS .......................................... 4
SECTION 5.
SECTION 6.
SECTION 7.
SECTION 8.
AF
FACILITY LIMITS—GAMING STATIONS ................................................ 4
FACILITY LIMITS—PLAYER TERMINALS ............................................. 5
COMMUNITY CONTRIBUTIONS ............................................................... 8
RESPONSIBLE GAMING.............................................................................. 9

DR
i
SECTION 1. CONDITIONS AND LIMITATIONS

This Appendix contains the concessions, limitations, and agreement of the Tribe and State with
respect to the subject matter addressed herein. However, Compact provisions that are not
addressed in this Appendix remain in full force and effect, unless and until they are subsequently
amended pursuant to the processes set forth in the Compact. This Appendix contains
interdependent conditions and consequences that must be accepted as a whole.

The Tribe and State agree that, although 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) the Tribe shall provide notice to
the State when implementation of Appendix E commences.

T
All capitalized terms not defined herein, to the extent they do not conflict, shall have the same
definitions as in the Tribe’s Compact, as amended.

SECTION 2. HIGHER WAGER LIMITS AT GAMING STATIONS

AF
While the Tribe is unsure it will offer Gaming Stations with higher limits frequently, the Tribe
would make such limits available to its patrons in the following ways.

2.1. High Limit Room

2.1.1 “High Limit Room” means a clearly identified area of the Gaming Facility
separated by a permanent, physical barrier or a separate room in the Gaming
Facility. “Permanent, physical barrier” includes a partial wall, fence or similar

DR 2.1.2

2.1.3
separation. Stanchions or similar movable barriers are not considered a
permanent, physical barrier.

The Gaming Operation may offer Gaming Station wager limits in the High Limit
Room not to exceed five thousand dollars ($5,000) subject to the limitations of
subsection 2.4 below and subsection 5.2.

“Restricted Access Tables” are Gaming Stations where wagers above $1,000 and
not to exceed $5,000 are allowed, subject to the limitations of subsection 2.4
below and subsection 5.2.

2.2. Flex High Limit Room

Due to the expected infrequency of higher limit play, constructing a High Limit Room
may not be financially feasible for the Tribe. Constructing a High Limit Room could also
unnecessarily stress operational and regulatory resources needed to protect these and

Squaxin Island Tribe – State of Washington Gaming Compact
Appendix E—Limitations on Wagers, Credit, Facilities, and Problem Gambling Resources
1
other Gaming activities within the Gaming Facility without substantial benefit to the
Gaming Operation. For these reasons, the parties agree to the following provisions related
to a Flex High Limit Room:

2.2.1 “Flex High Limit Room” means a multi-purpose room in the Gaming Facility that
is used on a limited basis. The Flex High Limit Room must have the same
operational requirements as a High Limit Room.

2.2.2 In the Flex High Limit Room, the Gaming Operation may offer up to four (4)
Restricted Access Tables, subject to subsection 5.2.

2.2.3 The Gaming Operation may operate the Flex High Limit Room up to one hundred
twenty (120) Gaming days per year.

2.3.
2.2.4
T
The process for approving the schedule for use of Restricted Access Tables in the
Flex High Limit Room will be outlined in the Internal Controls.

High Limit Tables

2.3.1

2.3.2
AF
“High Limit Table” means a designated Gaming Station in the Gaming Facility
separated by a movable or non-movable barrier, such as stanchions or partial wall,
prominently labeled with signage designating it as a High Limit Table, and with
wager limits higher than those provided in Compact Section III.J, subject to the
requirements and limitations of this Appendix.

The Gaming Operation may offer Gaming Station wager limits not to exceed one

DR
2.4.
thousand dollars ($1,000) at the Gaming Facility’s High Limit Table(s) subject to
the limitations of subsection 2.4 below and subsection 5.2.

Limitations

2.4.1 Gaming at the Gaming Stations at the Restricted Access Tables shall be limited to
customers pre-screened by the Gaming Operation. The pre-screening
qualifications and screening process will be set forth in an MOU agreed upon by
the State Gaming Agency and the Tribe, as may be amended from time to time.

2.4.2 No customers may participate in Gaming in the High Limit Room, in the Flex
High Limit Room, or at a High Limit Table if they are known to the Gaming
Operation to have a history of problem gambling, are barred for self-exclusion, or
are identified by the Tribal Gaming Agency as demonstrating significant
characteristics associated with problem gambling.

Squaxin Island Tribe – State of Washington Gaming Compact
Appendix E—Limitations on Wagers, Credit, Facilities, and Problem Gambling Resources
2
2.4.3 The Gaming Operation must follow the requirements of Title 31 (money
laundering).

SECTION 3. EXTENSION OF CREDIT

3.1. Notwithstanding Compact Section III.G., the Gaming Operation may extend credit to
qualified patrons who seek an extension of credit and who meet the criteria set forth in
credit procedures developed by the Gaming Operation. At a minimum, the credit
procedures must specify:

3.1.1 All patrons requesting credit are required to submit a complete tribal credit
application and be provided problem gambling information;

3.1.2

3.1.3 T
The minimum and maximum amount any patron can request;

The process for review and verification of the credit application. The review
process shall include, at a minimum, proof of identity, obtaining a credit report,
gaming report unless this is the first casino credit for the patron (from Central

3.1.4

3.1.5
AF
Credit Inc. or similar provider that provides information on the patron’s prior
casino credit), and bank verification of accounts;

When a patron’s credit application will be reviewed after initial application and
preapproval;

Patrons will not be extended credit if known to the Gaming Operation to have a
history of problem gambling, if actively barred for self-exclusion, or if the

DR 3.1.6

3.1.7
Gaming Operation’s review of a credit report indicates the patron is proposing to
make wagers beyond their means;

How each patron’s credit application information is kept confidential and secure
from unauthorized access, including who is authorized to access the credit
application information;

Information about patrons requesting credit is not shared or used for marketing or
promotional purposes with entities outside the Gaming Operation;

3.1.8 How the preapproval amount is determined to be consistent with their credit
report, the preapproval amount is documented, and the patron is notified;

3.1.9 The preapproval is granted by a member of the management of the Gaming
Operation that is independent of the patron; and

Squaxin Island Tribe – State of Washington Gaming Compact
Appendix E—Limitations on Wagers, Credit, Facilities, and Problem Gambling Resources
3
3.1.10 The repayment and debt collection requirements and notification includes:

(a) Repayment timeframes not to exceed ninety (90) days from the day of
extension of credit.

(b) Any late payment fees, penalties, interest charges, or similar fees or
charges, settlement process and reports, and prohibition of further credit
extension with an unpaid balance.

(d) Agreeing to the Squaxin Island Tribal Court for venue and personal
jurisdiction.

3.2.
T
The Tribal Gaming Agency shall forward to the State Gaming Agency a copy of
approved credit procedures, and any changes to those procedures for review and
concurrence prior to implementation per Compact Section IX.

4.1.

4.2.
AF
SECTION 4. WAGERING LIMITS—PLAYER TERMINALS

The purchase price for a single Scratch Ticket may not exceed $30.00, provided that the
minimum and maximum wagers must be visibly displayed on such machines.

Each On-line Lottery Game may offer more than one method of winning a prize, and
each method may be represented by a separate wager, but each wager may not exceed
$30.00.

D SECTION 5. FACILITY LIMITS—GAMING STATIONS

The maximum number of Class III Gaming Stations within the Gaming Facilities combined shall

R
not exceed a total of one hundred twenty-five (125) Gaming Stations. The Tribe, in its sole
discretion, shall determine the allocation of the 125 Gaming Stations between the Gaming
Facilities.

5.1. The Tribe is required to obtain transfers of a Class III Gaming Station authorization from
another tribe which has entered into a compact with the State for the use of Class III
Gaming Stations, as defined in this Compact for any Class III Gaming Stations, except
for nonprofit stations, beyond sixty (60) in total for all Gaming Facilities. The transfer of
a Gaming Station authorization from another tribe shall be effectuated through the use of
an agreement, the form of which will be determined by the Tribe; provided, however, the
transfer agreement is not effective until State Gaming Agency has received notice of the
transfer, and such notice must include: the identity of the parties to the transfer

Squaxin Island Tribe – State of Washington Gaming Compact
Appendix E—Limitations on Wagers, Credit, Facilities, and Problem Gambling Resources
4
agreement, the number of Gaming Stations transferred under the agreement, and the start
and end date of the transfer agreement.

5.2. No more than thirty (30) of the maximum number of one-hundred twenty-five (125)
Gaming Stations authorized above, or 25% of the total Gaming Stations in operation
within a Gaming Facility, whichever is fewer, may be operated with wager limits greater
than $500.

SECTION 6. FACILITY LIMITS—PLAYER TERMINALS

6.1. Allocation. The Tribe shall be entitled to an allocation of, and may operate or transfer the
ability to operate, up to one thousand one hundred twenty-five (1125) Player Terminals
(“Allocation”).

6.1.1
T
If the Tribe has not previously operated a gaming facility, the State Gaming
Agency shall conduct a standard compliance review commencing on the one-year
anniversary of the facility’s opening to determine whether the following

AF
requirements have been satisfied:

(a) There have been no violations of the provisions of the Compact that have
resulted in sanctions imposed by the Federal District Court;

(b) There have been no violations of the Compact which are substantial or would
be deemed material due to repetition;

DR
of the surrounding communities in the nature of criminal activities directly
related to the operations of the Class III Gaming Facility;

(d) Any changes in the operating requirements that are necessary to accommodate
any increase in the number of Player Terminals in use have been
implemented; and

(e) All fees due from Tribe under Compact Section XII. have been paid, or in the
alternative either a memorandum of understanding with the State Gaming
Agency ("MOU") has been entered into or an arbitration has been demanded,
has not been resolved, and the Tribe has complied with the provisions of
Compact Section XII.

A summary of the results of the compliance review will be provided to both the
Tribe and the TGA.

Squaxin Island Tribe – State of Washington Gaming Compact
Appendix E—Limitations on Wagers, Credit, Facilities, and Problem Gambling Resources
5
6.2. Further Conditions. The Tribe may acquire the ability to operate additional Player
Terminals that have been allocated by compact to any other Washington tribe and may
also transfer any of its own Allocation of Player Terminals, or the ability to operate such
allocated Terminals to another Washington tribe that has entered into a compact
authorizing operation of a Tribal Lottery System consistent with Appendix X2 ("Eligible
Tribe"), subject to the following conditions:

6.2.1 Subject to Section 6.3 below, the Tribe may operate no more than 3,000 Player
Terminals in total (“Total Operating Ceiling"). It is also agreed that the Total
Operating Ceiling for the Muckleshoot Tribe, Tulalip Tribes, and Puyallup Tribe
shall be 4,000 for each of those same three tribes. It is further agreed that the
Tribe shall not be entitled as a matter of right to an increase in its Total Operating
Ceiling based on the fact that the Muckleshoot Tribe, the Tulalip Tribes, and the

T
Puyallup Tribe are entitled under Appendix X2 to operate up to the separate,
higher Total Operating Ceiling(s) established specifically for them in Appendix
X2.

6.2.2

AF
The Tribe agrees that its acquisitions and transfers of the ability to operate
additional Player Terminals shall be made only pursuant to a plan approved by no
less than a majority of the tribes that were Eligible Tribes at the time such plan
was adopted. Development and approval of the plan shall follow notice to all
Eligible Tribes and an opportunity to participate in creating the plan. Once
adopted or amended, the plan shall stay in effect without change for at least one
year, even if additional tribes become Eligible Tribes thereafter, but such
additional tribes may participate in the plan. Changes in the plan shall not affect

DR 6.2.3
the validity or terms of prior transactions conducted between or among tribes
under the plan. The State shall have no responsibility whatsoever with respect to
the plan, including but not limited to responsibility for providing notices to tribes,
determining if the plan has been agreed to properly, monitoring its rules or
implementation, or any other aspect of such plan, the entire responsibility for
which shall be upon the Eligible Tribes.

The Tribe waives the ability to operate a Player Terminal pursuant to its
Allocation if the ability to operate such a Terminal has been transferred to another
tribe until such time as the ability to operate such a Terminal has been re-acquired
by the Tribe.

6.2.4 The Tribe may not utilize the ability to operate a Player Terminal that was
allocated to, and subsequently acquired from, another tribe, until it completes

Squaxin Island Tribe – State of Washington Gaming Compact
Appendix E—Limitations on Wagers, Credit, Facilities, and Problem Gambling Resources
6
delivery to the State of documentation confirming the number of transfers of the
ability to operate such Terminals it has acquired.

6.3. Other Circumstances. Except as specifically provided in Section 6.2.1. of this Appendix,
in the event the State agrees (or is required by law or a court ruling to agree) to permit an
allocation of Player Terminals to a tribe which is greater, or is on terms which are more
favorable, than as set forth herein, the Tribe shall be entitled to such greater Allocation or
more favorable terms.

6.4. Increases to Tribe’s Allocation of Player Terminals

6.4.1 The Tribe’s Allocation of Player Terminals as set forth in subsection 6.1 above
may increase by fifty (50) Player Terminals upon meeting the procedures and

6.4.2 T
conditions set forth in this subsection 6.4.

The Tribe shall provide the State Gaming Agency with written notice, along with
Certification from an Independent Accounting Firm, that there are five hundred

6.4.3
AF
(500) or fewer Player Terminals Available for Lease among all tribes
participating in the Tribal Lottery System under Appendix X2. The Tribe shall
derive its notice and Certification from information provided by participants in
the plan described in subsection 6.2.2 above.

Upon receipt of the Tribe’s notice, the State Gaming Agency shall review the
Certification and verify the Player Terminals Available for Lease in the state. To
facilitate the State Gaming Agency’s review and verification process, the Tribe
shall authorize the Independent Accounting Firm to make available for review by

DR
6.4.4

6.4.5
the State Gaming Agency all supporting records used to develop the Certification.

The State Gaming Agency has thirty (30) days to review, verify, and provide
written notification to the Tribe of the additional Allocation of Player Terminals
set forth in subsection 6.4.1 above. Any such increase to the Tribe’s Allocation
shall become effective thirty (30) days after notification by the State Gaming
Agency.

Such notice by the State Gaming Agency shall for all purposes increase the
Allocation of Player Terminals for the Tribe until such time as, if ever, another
notice and Certification is delivered to the State Gaming Agency for an increase
to the Allocation.

Squaxin Island Tribe – State of Washington Gaming Compact
Appendix E—Limitations on Wagers, Credit, Facilities, and Problem Gambling Resources
7
6.4.6 Except as set forth in subsection 6.4.7 below, additional increases to the Tribe’s
Allocation of Player Terminals under this Section are limited to one (1) increase
per twelve (12) month period.

6.4.7 Notwithstanding the limitation set forth in Sections 6.4.5 and 6.4.6 above, if the
Tribe, or another Eligible Tribe, licenses a new Gaming Facility on tribal lands
that will operate more than one thousand seventy-five (1,075) Player Terminals at
its initial opening, the Tribe may provide written notification to the State Gaming
Agency of such licensure. After receipt of such notification, the State Gaming
Agency has thirty (30) days to review, concur, and provide written notification to
the Tribe that the Tribe’s Allocation of Player Terminals shall increase by an
additional fifty (50) Player Terminals.

6.4.8

T
In the event any other Eligible Tribe becomes entitled to an increased Allocation
of Player Terminals under that tribe’s version of Section 6.4.4 or 6.4.7 above, the
Tribe shall be automatically entitled to the same Allocation increase authorized to
that other Washington tribe by its version of Section 6.4.4 or 6.4.7 above, and the

6.5.
AF
State shall provide prompt notification of the increase to the Tribe.

Dispute Resolution

6.5.1 If a dispute arises between the Tribe and the State with respect to the terms and
conditions set forth in this Addendum, including but not limited to the number of
Player Terminals Available for Lease, the State and Tribe shall meet and attempt
to resolve the dispute not later than 30 days prior to the increased Allocation of
Player Terminals going into effect.

DR
6.5.2 If either party believes, after the meet and confer has commenced, that a
resolution by the parties cannot be achieved, then either or both parties shall be
entitled to have the dispute resolved pursuant to the dispute resolution provisions
of the Compact.

SECTION 7. COMMUNITY CONTRIBUTIONS

In order to provide for impacts to local community services that may arise as a result of the
Gaming authorized under Compact, the Tribe agrees to the following:

7.1. Charitable Contributions. The Tribe and the State acknowledge the funding impacts to
local charitable and non-profit community services of the Gaming authorized in the
Compact and Appendices. The State recognizes the Tribe’s substantial and significant
charitable support and investment in the health and welfare of the community that benefit

Squaxin Island Tribe – State of Washington Gaming Compact
Appendix E—Limitations on Wagers, Credit, Facilities, and Problem Gambling Resources
8
Tribal and Non-Tribal members/citizens. The State encourages the Tribe to continue its
support of local charitable and non-profit community services at its discretion.

7.2. Community Impact. The Tribe recognizes there may be an increased burden on local
jurisdictions’ public safety, emergency response, and other services associated with the
operation of Class III Gaming Facilities and shall make provisions for adequate
emergency accessibility and service to ensure the safety of its patrons and employees.
The State encourages the Tribes’ continued support of local community investments that
support public safety at its discretion.

SECTION 8. RESPONSIBLE GAMING

Compact Section III.F. provisions are incorporated herein.

T
AF
DR
Squaxin Island Tribe – State of Washington Gaming Compact
Appendix E—Limitations on Wagers, Credit, Facilities, and Problem Gambling Resources
9
SQUAXIN ISLAND TRIBE - STATE OF WASHINGTON
CLASS III GAMING COMPACT

APPENDIX G
Electronic Table Games

Table of Contents
SECTION 1. CONDITIONS AND LIMITATIONS ...................................................................... 1

SECTION 2. EFFECTIVE DATE .................................................................................................. 1

T
SECTION 3. DEFINITIONS .......................................................................................................... 1

SECTION 4. AUTHORIZATION .................................................................................................. 2

SECTION 5. NUMBER OF GAMING STATIONS...................................................................... 3

AF
SECTION 6. OPERATION AND REPORTING REQUIREMENTS ........................................... 3

SECTION 7. APPROVAL OF ELECTRONIC TABLE GAME SYSTEMS ................................ 5

SECTION 8. PROBLEM AND RESPONSIBLE GAMBLING .................................................... 7

SECTION 9. ANTI-MONEY LAUNDERING .............................................................................. 7

DR
i
SECTION 1. CONDITIONS AND LIMITATIONS

This Appendix contains the interrelated concessions, limitations, and agreement of the Tribe and
State with respect to the subject matter addressed herein. Provisions of the Compact, as
amended, that are not addressed in this Appendix remain in full force and effect, unless and until
they are subsequently amended pursuant to the processes set forth in the Compact. This
Appendix contains interdependent conditions and consequences that must be accepted as a whole
in order to adopt this Appendix.

Any provisions of the Compact that do not conflict with these standards 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 Seventh Amendment remain
in full force and effect unless and until they are subsequently modified pursuant to the process
set forth in the Compact.

T
SECTION 2. EFFECTIVE DATE

AF
The Tribe and State agree that the Compact and its appendices become effective upon
publication of notice of approval by the Secretary of Interior of the United States in the Federal
Register in accordance with 25 U.S.C. § 2710(d)(3)(B).

SECTION 3. DEFINITIONS

The following terms apply to this Appendix. All capitalized terms not defined herein, to the
extent they do not conflict, shall have the same definitions as in the Compact.

D
3.1.

R
3.2.

3.3.
“Component” means Electronic Table Game Terminals, any dealer interface, the
Electronic Wagering System, and hardware, software, and servers that function
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.

3.4. “Electronic Table Game System” or “ETG System” means a system that utilizes
electronics in connection with the generation, collection, storage, and communication of
game outcome, accounting, and significant event data, including all Components thereof,
to operate Electronic Table Games.

Squaxin Island Tribe - State of Washington Gaming Compact
Appendix G - Electronic Table Games
1
3.5. “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.

3.6. “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.

T
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 allow Play Against the Machine
when:

AF
4.3.1. there is a human dealer involved in the play of the ETG (“Dealer Controlled”); or

4.3.2. 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

4.3.3. it is a hybrid of Dealer Controlled and Non-Dealer Controlled, provided that any

DR
4.3.
ETG played as Dealer Controlled follows applicable Dealer-Controlled 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

4.3.1. The Tribe may offer for play an ETG version of any Class III table game
approved in Compact Section IV.A. Pay table or odds offered on an ETG shall be
consistent with approved game rules. 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.

Squaxin Island Tribe - State of Washington Gaming Compact
Appendix G - Electronic Table Games
2
4.3.3. Concurrent play. Patrons may play more than one ETG concurrently using a
single ETG Terminal under the following requirements:

(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.

(d) An ETG may not be added to or removed from an ETG Terminal in use by a

4.4.

4.5.
patron.

T
Wager Limits. Wager limits for ETGs shall not exceed $500.

Electronic Wagering System. An ETG shall be activated with an Electronic Wagering

AF
System that meets the standards described in Section 6.1.2. An ETG 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
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.

DR
6.1.
SECTION 6. OPERATION AND REPORTING REQUIREMENTS

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
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 3 of this Appendix
is not applicable, and such features or functionalities are prohibited.

6.1.2 Any Electronic Wagering System must meet or exceed Gaming Laboratories
International’s Standard GLI-16 (Cashless Systems in Casinos), the standards

Squaxin Island Tribe - State of Washington Gaming Compact
Appendix G - Electronic Table Games
3
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 Section XV.G.

6.1.3 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 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.

6.2. 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.

6.2.1 T
Initial Internal Controls. The Tribal Gaming Agency shall forward to the State
Gaming Agency its initial Internal Controls for ETG Systems for review and

6.2.2 AF
concurrence as outlined in Compact Section IX.A. The Tribal Gaming Agency
shall detail how the Internal Controls meet or exceed the requirements described
in this Appendix or any related MOU.

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.

DR
(b)

(c)

(d)

(e)
User access controls for ETG personnel;

Segregation of duties;

Procedures for receiving, investigation and responding to patron
complaints;

Accounting and audit procedures;

(f) Procedures to ensure the physical security of the ETG Systems, including
key controls and Closed Surveillance System coverage;

(g) Procedures to ensure the integrity and security of all sensitive data and
software;

Squaxin Island Tribe - State of Washington Gaming Compact
Appendix G - Electronic Table Games
4
(h) Procedures to ensure that access to sensitive data and software is limited to
appropriate personnel;

(i) Procedures to ensure accurate accounting of wagers and payouts;

(j) Procedures to ensure the logging of the events and the availability of
records to permit an effective audit of the conduct of the ETG System and
the reporting of revenue;

(k) All existing Internal Controls are updated, as necessary, to ensure there are
no conflicts with any Internal Controls governing ETG Systems; and

(l) Any other internal controls deemed necessary by the State Gaming

6.3. T
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

6.4.
AF
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.

DR
7.1.

7.2.
SECTION 7. APPROVAL OF ELECTRONIC TABLE GAME SYSTEMS

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).

Independent Test Laboratory (ITL) Testing for ETG System, Upgrades, and New
Equipment; Modifications.

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 State
Gaming Agency’s approved ITL list.

Squaxin Island Tribe - State of Washington Gaming Compact
Appendix G - Electronic Table Games
5
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 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

7.3.
T
report information including gaming revenue; and (d) minor modifications to
hardware.

Field Testing for ETG Systems.

7.3.1

7.3.2 AF
A new ETG System may only be offered for play subject to field testing at the
Tribe’s Gaming Facility as described below.

The terms, conditions, criteria, and objectives for each ETG System to be field
tested must be jointly agreed to by Tribal Gaming Agency and State Gaming
Agency in writing prior to field testing and must include at least:

(a) The requirements and standards that must be met to determine successful field

DR
testing.

(b) The number of ETG Terminals to be included in the field test.

(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

Squaxin Island Tribe - State of Washington Gaming Compact
Appendix G - Electronic Table Games
6
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) 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.

(c) Field testing may be suspended by the Tribal Gaming Agency, State Gaming
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.

7.4.
T
Implementation of Approved ETG by another tribe. The Tribe may conduct their 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

AF
configured in the same way.

SECTION 8. PROBLEM AND RESPONSIBLE GAMBLING

Commitment to Responsible Gambling. In addition to the requirements in the Compact Section
VIII.F, the provisions of which are incorporated herein, the Tribe agrees to display on each ETG
Terminal a commitment to responsible gambling and a link to the Tribe’s responsible gambling
policy created pursuant to the Compact Section IV. The display will be in a manner determined
by the Tribe.

DR
SECTION 9. ANTI-MONEY LAUNDERING

The Tribe’s Internal Controls will describe how the Tribe will comply with applicable federal
requirements including requirements imposed by the Federal Trade Commission (FTC), Office
of the Comptroller of the Currency (OCC), Financial Crimes Enforcement Network (FinCEN),
Consumer Financial Protection Bureau (CFPB), Office of Foreign Assets Control (OFAC) and
the US Department of Treasury.

Squaxin Island Tribe - State of Washington Gaming Compact
Appendix G - Electronic Table Games
7
SQUAXIN ISLAND TRIBE - STATE OF WASHINGTON
GAMING COMPACT

APPENDIX S
Sports Wagering
(Amended and Restated)

Table of Contents

SECTION 1. INTRODUCTION................................................................................................ 1
SECTION 2. DEFINITIONS ..................................................................................................... 1
SECTION 3. SPORTS WAGERING ACTIVITIES AND LOCATION ............................... 4
3.1 Sportsbook ............................................................................................................. 4
3.2
3.3 T
Server ..................................................................................................................... 4
Mobile Sports Wagering ........................................................................................ 4
SECTION 4. KIOSKS ................................................................................................................ 5
4.1
4.2
4.3
4.4
AF
Location ................................................................................................................. 5
On Gaming Floor ................................................................................................... 5
Off Gaming Floor .................................................................................................. 5
Pre-operation Inspection ........................................................................................ 5
SECTION 5. STANDARDS OF CONDUCT AND OPERATION ........................................ 5
5.1
5.2
Approved Sports Wagers ....................................................................................... 5
Prohibited Activities and Participants .................................................................... 7

DR
5.3
5.4
5.5
5.6
5.7
5.8
5.9
Sports Wagering System ........................................................................................ 9
Wagering Limits .................................................................................................. 11
Reserve Requirement ........................................................................................... 11
Player Accounts ................................................................................................... 11
Surveillance.......................................................................................................... 12
Accounting Records ............................................................................................. 12
Internal Controls .................................................................................................. 12
5.10 House Rules ......................................................................................................... 16
SECTION 6. SPORTS WAGERING LICENSING AND CERTIFICATION ................... 16
6.1 Applicability of Compact Provisions ................................................................... 16
6.2 Sports Wagering Vendors .................................................................................... 16
6.3 Tribal Licensing of Sports Wagering Vendors .................................................... 18

i
6.4 State Certification of Sports Wagering Vendors ................................................. 18
6.5 Fees for State Certification .................................................................................. 18
SECTION 7. CRIMINAL ENFORCEMENT ........................................................................ 19
7.1 Anti-Money Laundering ...................................................................................... 19
7.2 Sports Integrity..................................................................................................... 19
7.3 Information Sharing ............................................................................................. 20
SECTION 8. PROBLEM AND RESPONSIBLE GAMBLING ........................................... 20
8.1 Display Commitment to Responsible Gambling ................................................. 21
8.2 Offer Self-Imposed Limits ................................................................................... 21

T
AF
DR
ii
SECTION 1. INTRODUCTION

It is the intent of the parties for the Tribe to operate Sports Wagering that will enhance the Tribe’s
existing Gaming Operation and draw customers into regulated Sports Wagering and away from
illegal sports wagering. Tribes in Washington State have more than twenty-five (25) years’
experience with, and a proven track record of, successfully operating gaming in accordance with
their compacts. Tribes in Washington and the State Gaming Agency have a proven track record of
successfully regulating gaming together in accordance with respective compacts. The parties agree
that Sports Wagering must be fair, secure, and maintain the highest integrity to ensure public
confidence.

Sports Wagering conducted under this Appendix is authorized bookmaking and is not subject to
civil or criminal penalties under RCW 9.46. Gambling information transmitted over the internet for

T
any Sports Wagering conducted and operated under this Appendix is authorized. Mobile Sports
Wagering does not constitute online gambling when operated within the limitations of this
Appendix and requirements of the Federal Wire Act, 18 U.S.C. § 1084, as now or hereafter
amended.

AF
This Appendix describes, authorizes, and sets forth, consistent with House Bill 2638 (2020),
provisions applicable to the operation of Sports Wagering. This Appendix sets out conditions under
which the Tribe and State will share information about significant events that reflect on the conduct
of Sports Wagering so that both parties are informed of such events in this highly regulated
environment. Compact provisions that are not addressed in this Appendix remain in full force and
effect, unless and until they are subsequently amended pursuant to the processes set forth in the
Compact. This Appendix contains interdependent conditions and consequences that must be
accepted as a whole in order to operate or participate in Sports Wagering.

DR
SECTION 2. DEFINITIONS

The following terms apply to this Appendix. All capitalized terms not defined herein, to the extent
they do not conflict, shall have the same definitions as in the Compact, as amended.

2.1.

2.2.
“Authorized Sports Wagering Menu” means the list of leagues, organizations, and types of
wagers approved for Sports Wagering.

“Cloud Storage” means data which is stored on remote servers accessed from the internet.

2.3. “Collegiate Sport or Athletic Event” means a sport or athletic event offered or sponsored by,
or played in connection with, a public or private institution that offers education services
beyond the secondary level, other than such an institution that is located within the state of
Washington.

Squaxin Island Tribe - State of Washington Gaming Compact
Appendix S – Amended and Restated
1
2.4. “Electronic Sports or Esports Competition or Event” means a live video game event or
tournament attended or watched by members of the public where games or matches are
contested in real time by player(s) and team(s), and player(s) or team(s) can win a prize
based on their performance in the live video game event or tournament.

2.5. “Geofence” means any technology used to create a virtual geographic boundary or
technology used to detect the physical location of a device a patron is using to attempt to
engage in Mobile Sports Wagering.

2.6. “Integrity Monitoring Provider” means a Sports Wagering Vendor approved by the Tribal
Gaming Agency and the State Gaming Agency to receive reports of Unusual Wagering
Activity from the Gaming Operation for the purpose of assisting in identifying Suspicious
Wagering Activity.

2.7.

2.8.
T
“Layoff Wager” means a wager placed or accepted between gaming operations for the
purpose of offsetting the tribal Sports Wagering liability.

“Minor League” means a lower professional league or division within a sport, such as

2.9.

2.10.
AF
American baseball or hockey, where a professional team has the exclusive contractual rights
to promote and relegate players.

“Mobile Device” means portable electronic equipment used in Mobile Sports Wagering,
including but not limited to a mobile phone, tablet, personal computer, electronic device,
and any other portable electronic device.

“Mobile Sports Wagering” means any Sports Wagering on a Mobile Device platform,
including Sports Wagers deployed and accessed through the internet or an application

D
2.11.

R
2.12.
installed on a Mobile Device.

“Player Account” means an electronic account established by a patron for the purpose of
Sports Wagering, including deposits, withdrawals, wagered amounts, payouts on winning
wagers, or similar adjustments.

“Premises” means buildings that comprise a Gaming Facility and adjacent or adjoining
amenities, such as hotels, restaurants, conference or entertainment spaces, common areas,
parking lots, garages, and other improved areas; provided that such areas constitute Squaxin
Island Tribal Lands, and provided further, that such areas do not include non-adjoining
convenience stores or golf courses.

2.13. “Professional Sport Event or Athletic Event” means an event that is not a Collegiate Sport
Event or Collegiate Athletic Event at which two or more persons participate in a sports or
athletic event and receive compensation in excess of actual expenses for their participation

Squaxin Island Tribe - State of Washington Gaming Compact
Appendix S – Sports Wagering (Amended and Restated)
2
in the event. “Professional Sport or Athletic Event” does not include any Minor League
sport.

2.14. “Sports Governing Body” means the organization that prescribes final rules and enforces
codes of conduct with respect to a sporting event and participants therein.

2.15. “Sports Wager” or “Mobile Sports Wager” means the actual bet placed on sporting events,
athletic events, or competitions. A sports wager does not include wagers on horse racing
authorized pursuant to RCW 67.16.

2.16. “Sports Wagering” means the business of accepting wagers on any of the following sporting
events, athletic events, or competitions by any system or method of wagering: (a) a
Professional Sport or Athletic Event; (b) a Collegiate Sport or Athletic Event; (c) an
Olympic or international sports competition or event; (d) an Electronic Sports or Esports

T
Competition or Event; (e) a combination of sporting events, athletic events, or competitions
listed in (a) through (d) of this subsection; or (f) a portion of any sporting event, athletic
event, or competition listed in (a) through (d). Sports Wagering does not include the
business of accepting wagers on horse racing authorized pursuant to RCW 67.16.

2.17.

2.18.
AF
“Sports Wagering Kiosk” means an unattended, self-service terminal, machine, or other
device provided by the Gaming Operation through which a patron may place or redeem a
Sports Wager.

“Sports Wagering Net Win” means the total amount wagered or played less the amounts
repaid to winners as reported as gaming revenue on the annual audited financial statements
in accordance with Generally Accepted Accounting Principles (GAAP). The number of
wagers placed by the Gaming Operation and amounts received by the Gaming Operation as

D
2.19.

R
payments on Layoff Wagers shall not affect the computation of Sports Wagering Net Win.

“Sports Wagering System” means all equipment, hardware, data networks, communications
technology, and software used in the operation of Sports Wagering that directly affect the
wagering and results of Sports Wagering offered under this Appendix, including the
following: (a) Sports Wagering interactive components, including all associated equipment
and software that comprise the Sports Wagering platform used in a Sportsbook or used for
online or Mobile Sports Wagering; (b) Sports Wagering Kiosks; and (c) ticket or voucher
redemption devices. “Sports Wagering System” does not include a Mobile Device owned
and used by a patron to place a Sports Wager.

2.20. “Sports Wagering Vendor” means an organization that provides any gaming goods or
services in connection with the operation of Sports Wagering.

Squaxin Island Tribe - State of Washington Gaming Compact
Appendix S – Sports Wagering (Amended and Restated)
3
2.21. “Sportsbook” means the Sports Wagering area where transactions are conducted from a
counter located in a Sports Wagering lounge or other window locations as approved by the
Tribal Gaming Agency, and any window in the cashier’s cage designated only for the
redemption of winning Sports Wagering tickets.

2.22. “Suspicious Wagering Activity” means Unusual Wagering Activity that cannot be explained
and is indicative of match fixing, the manipulation of an event, misuse of inside information,
or other prohibited activity.

2.23. “Unusual Wagering Activity” means abnormal wagering exhibited by a patron or patrons
and deemed by the Gaming Operation as a potential indicator of suspicious activity.
Abnormal betting activity may include, but is not limited to, the size of a patron’s wager, or
increased wagering volume on a particular event or wager type.

3.1 T
SECTION 3. SPORTS WAGERING ACTIVITIES AND LOCATION

Sportsbook. The Sportsbook must be located within a Gaming Facility. A Sportsbook
authorized by this Appendix will be inspected by the Tribal Gaming Agency and the State

AF
Gaming Agency prior to commencement of operation to verify its conformity with the
requirements of this Appendix. If a Sportsbook fails to meet any requirements of this
Appendix, the Tribal Gaming Agency and/or State Gaming Agency will send a non-
compliance letter to the Tribe and Gaming Facility manager or responsible person within
seven (7) working days after completion of the inspection. If the Tribal and State Gaming
Agencies do not agree on whether a Sportsbook meets the requirements, the Gaming
Agencies will meet within seven (7) working days from receipt of the non-compliance letter
and work together to resolve concerns. If a dispute regarding this inspection cannot be
resolved by the Gaming Agencies within thirty (30) days, the parties may seek dispute

DR
3.2

3.3
resolution pursuant to the Compact.

Server. The server or other equipment used to accept and redeem Sports Wagers must be
located within a Gaming Facility. Cloud Storage may be used for duplicate or backup Sports
Wagering data, provided that such Cloud Storage facilities are located in Washington State.

Mobile Sports Wagering. The Gaming Operation must use a Geofence to ensure that all
Mobile Sports Wagering must occur within the Premises. No less than thirty (30) days prior
to offering Mobile Sports Wagering, the Gaming Operation must submit a proposal to the
Tribal Gaming Agency and State Gaming Agency for review and concurrence, which at a
minimum must include, as applicable: (a) a description of the Geofence technology that it
will use to prevent patrons from placing a Sports Wager using a Mobile Device outside of
the Premises; and (b) a map of the Premises. If the Tribal and State Gaming Agencies take
no action within thirty (30) days of receipt, the Tribe may implement the proposal. Any
substantial change in the Geofence technology will require that the Gaming Operation

Squaxin Island Tribe - State of Washington Gaming Compact
Appendix S – Sports Wagering (Amended and Restated)
4
submit a revised proposal to the Tribal Gaming Agency and State Gaming Agency for
review and concurrence in accordance with this Section. The Tribal and State Gaming
Agencies may only disapprove such portions of a proposal they find do not meet the
requirements of this Appendix and must detail the reasons for disapproval. If a dispute
regarding a proposal cannot be resolved by the Tribal and State Gaming Agencies within
thirty (30) days, the parties may seek dispute resolution pursuant to the Compact.

SECTION 4. KIOSKS

4.1 Location. Sports Wagering Kiosks may be located anywhere within the Premises and are
subject to the surveillance requirements imposed by subsection 5.7 below.

4.2 On Gaming Floor. Sports Wagering Kiosks located on the gaming floor are subject to the
limits on anonymous Sports Wagers described in subsection 7.1.1 below.

4.3

4.4
T
Off Gaming Floor. Sports Wagering Kiosks located off the gaming floor may not allow
anonymous Sports Wagers or cash redemption.

Pre-operation Inspection. Sports Wagering Kiosks authorized by this Appendix will be

AF
inspected by the Tribal Gaming Agency and the State Gaming Agency prior to
commencement of operation to verify its conformity with the requirements of this Appendix.
If a Sports Wagering Kiosk fails to meet any requirements of this Appendix, the Tribal
Gaming Agency and/or State Gaming Agency will send a non-compliance letter to the Tribe
and Gaming Facility manager or responsible person within seven (7) working days after
completion of the inspection. If the Tribal and State Gaming Agencies do not agree on
whether a Sports Wagering Kiosk meets the requirements, the Gaming Agencies will meet
within seven (7) working days from receipt of the non-compliance letter and work together

DR
5.1
to resolve concerns. If a dispute regarding this inspection cannot be resolved by the Gaming
Agencies within thirty (30) days, the parties may seek dispute resolution pursuant to the
Compact.

SECTION 5. STANDARDS OF CONDUCT AND OPERATION

Approved Sports Wagers. The Gaming Operation may accept a Sports Wager on any event
conducted by a league or organization, provided that the league, organization, and wager
type are listed on the Authorized Sports Wagering Menu.

5.1.1 Posting.

(a) A list of Sports Wagers available at the Gaming Operation will be made
available to its patrons.

Squaxin Island Tribe - State of Washington Gaming Compact
Appendix S – Sports Wagering (Amended and Restated)
5
(b) The State Gaming Agency will post the Authorized Sports Wagering Menu
on its website or otherwise make it available to the public.

5.1.2 Initial Authorized Sports Wagering Menu. The initial Authorized Sports Wagering
Menu will include every league, organization, and wager type authorized by any
U.S. jurisdiction or jurisdictions as mutually agreed upon by the parties as of the
effective date of this Appendix, except for Prohibited Activities as listed in
subsection 5.2 below.

5.1.3 Additions to Authorized Sports Wagering Menu.

(b) The Gaming Operation may apply to the Tribal Gaming Agency, in the form
required by Tribal Gaming Agency, to add additional leagues, organizations,
or wager types to the Authorized Sports Wagering Menu. The Tribal Gaming

T
Agency will provide notice to the State Gaming Agency of any approval no
fewer than five (5) business days before the Gaming Operation intends to
offer a Sports Wager on the new league, organization, or wager type.

(c)

AF
If the State Gaming Agency believes that the new league, organization, or
wager type violates RCW 9.46.037, RCW 9.46.038, or this Appendix or
otherwise lacks integrity, the State Gaming Agency will immediately notify
the Tribal Gaming Agency, and no Sports Wagers will be offered by the
Gaming Operation on the new league, organization, or wager type. The
Tribal Gaming Agency and the State Gaming Agency will meet within five
(5) business days of the Tribal Gaming Agency’s initial notice to the State
Gaming Agency of its approval to discuss the State Gaming Agency’s
concerns. The timeframe for meeting may be extended by mutual agreement.

DR 5.1.4
If after meeting, the Tribal Gaming Agency and State Gaming Agency cannot
come to agreement on the Tribal Gaming Agency’s determination, the
Gaming Operation may offer the Sports Wager(s) at issue and the State
Gaming Agency may initiate dispute resolution pursuant to the Compact.

Removals from the Authorized Sports Wagering Menu.

(a) The Tribal Gaming Agency and State Gaming Agency will immediately
notify the other Agency if they believe a league, organization, or wager type
on the Authorized Sports Wagering Menu violates RCW 9.46.037,
RCW 9.46.038, or this Appendix, lacks integrity, or has otherwise become
compromised and believe it should be removed from the Authorized Sports
Wagering Menu.

Squaxin Island Tribe - State of Washington Gaming Compact
Appendix S – Sports Wagering (Amended and Restated)
6
(b) If the Tribal and State Gaming Agencies agree on the removal, the State
Gaming Agency will provide statewide notice to each tribal gaming agency
of a tribe that operates sports wagering, and inquire whether each tribal
gaming agency agrees with the removal. The State Gaming Agency may
remove a league, organization, or wager type when all such tribal gaming
agencies affirmatively consent to removal.

(c) If the Tribal Gaming Agency and State Gaming Agency disagree on whether
an item should be removed, the Tribal Gaming Agency and the State Gaming
Agency will meet within five (5) business days of the notice to discuss each
Agency’s concerns. The timeframe for meeting may be extended by mutual
agreement. If after meeting, the Tribal Gaming Agency and State Gaming
Agency cannot come to agreement on whether to remove the league,

T
organization, or wager type from the Authorized Sports Wagering Menu, the
Gaming Operation may continue to offer the Sports Wager(s) at issue and the
State Gaming Agency may initiate dispute resolution pursuant to the
Compact.

5.1.5

5.1.6
AF
Removals from the Gaming Operation’s List of Available Sports Wagers. If the
Tribe intends to remove a league, organization, or wager type from its list of
available Sports Wagers as described in subsection 5.1.1(a), it will notify the State
Gaming Agency within five (5) business days after removal.

Layoff Wagers. The Gaming Operation may, in its discretion and subject to
limitations imposed by state and federal laws, make or accept Layoff Wagers. The
Gaming Operation must disclose its identity to the entity that is accepting the wager.

D
5.2

R
Such wagers must be reported to the Tribal Gaming Agency.

Prohibited Activities and Participants.

5.2.1 Prohibited Activities.

(a) The Gaming Operation may not accept any Sports Wager on a Collegiate
Sport Event or Collegiate Athletic Event offered or sponsored by a
Washington collegiate institution. “Offered or sponsored by” does not
include hosting a Collegiate Sport or Athletic Event; therefore, hosting is not
foreclosed by the section, so long as wagers are not accepted on specific
events where a Washington collegiate institution is competing.

(b) The Gaming Operation may not accept any Sports Wager on a Minor League
sport.

Squaxin Island Tribe - State of Washington Gaming Compact
Appendix S – Sports Wagering (Amended and Restated)
7
(c) Sports Wagers are not transferrable between patrons.

(d) No Gaming Employee may advise or encourage patrons to place a Sports
Wager of any specific type, kind, subject, or amount. This restriction does not
prohibit general advertising, promotional activities, or answering general
questions about Sports Wagers.

(e) The Gaming Operation will not knowingly accept a Sports Wager on an
event where the outcome has already been determined (past posting).

5.2.2 Prohibited Participants. The Gaming Operation will make all reasonable efforts to
confirm that any patron seeking to engage in Sports Wagering is not a Prohibited
Sports Wagering Participant. Prohibited Sports Wagering Participant means:

(a)

(b)

Any individual placing a wager as an agent or proxy;

Any athlete whose performance may be used to determine, in whole or in

(d)

(e)
AF
part, the outcome of such wagering;

Any person who is an athlete, player, coach, manager, referee or other game
official, physician, trainer, team employee or governing body employee, in
any sports event overseen by such person’s Sports Governing Body;

Any person with access to material, exclusive, non-public confidential
information about a sports event that is the subject of such wagering;

DR
(f)

(g)

(h)
Any person identified to the Tribal Gaming Agency and State Gaming
Agency by a Sports Governing Body that the Tribal Gaming Agency and
State Gaming Agency agree is a person who should be a Prohibited Sports
Wagering Participant;

Any person who holds a position of authority or influence sufficient to exert
influence over the participants in a sports event that is the subject of a wager;

Any person which the Gaming Operation knows or reasonably should know,
is placing a wager by, or on behalf of a Prohibited Sports Wagering
Participant; and

(i) Any person whose participation may undermine the integrity of wagering on
a sports event or the conduct of such sports event itself, or any person who is
prohibited for other good cause.

Squaxin Island Tribe - State of Washington Gaming Compact
Appendix S – Sports Wagering (Amended and Restated)
8
5.3 Sports Wagering System. No Sports Wagering System may be offered for play unless it has
been tested and certified by an Independent Test Laboratory as meeting the requirements set
forth in subsection 5.3.2, and approved in accordance with subsection 5.3.6.

5.3.1 Independent Test Laboratory. Any Independent Test Laboratory shall have
demonstrated it is competent and qualified to conduct scientific tests and evaluations
of the Sports Wagering System and must be licensed by the Tribal Gaming Agency
and certified by the State Gaming Agency. The State Gaming Agency will maintain
a list of licensed Independent Test Laboratories.

5.3.2 Minimum Standards. The Sports Wagering System must meet or exceed Gaming
Laboratories International’s GLI-33: Standards for Event Wagering Systems, and its
appendices, as amended or modified (“GLI-33”), and the standards established by
this Appendix and any applicable provision of the Compact and Appendices.

5.3.3
T
Alternative standards may be agreed to by the Tribal and State Gaming Agencies if
the standards meet the requirements established in this Appendix.

Independent Test Laboratory Reports and Certification. At the conclusion of testing,

AF
the Independent Test Laboratory shall provide to the Tribal Gaming Agency and the
State Gaming Agency a report that contains findings, conclusions, and a certification
that the Sports Wagering System conforms to the requirements contained in this
Appendix. If the Independent Test Laboratory determines that the Sports Wagering
System fails to conform to such requirements or technical standards, and if
modifications can be made which would bring the Sports Wagering System into
compliance, the report may contain recommendations for such modifications. If the
Independent Test Laboratory provides sufficient documentation that the Sports

DR 5.3.4
Wagering System or a component thereof has been tested and certified by that
Independent Test Laboratory, without any subsequent modifications, within the past
one hundred and eighty (180) days, the Independent Test Laboratory may provide to
the Tribal Gaming Agency and the State Gaming Agency a report that contains
findings, conclusions and the certification from the previous testing and that shall be
sufficient to satisfy this requirement.

Modifications. No substantive modification to any Sports Wagering System may be
made after testing, certification, and approval of a Sports Wagering System without
certification of the modification by an Independent Test Laboratory. The following
modifications are not considered substantive and do not require notification to the
State Gaming Agency: (a) Changes to content not related to any regulated feature;
(b) Installation or changes to backup software; (c) Adding or removing users; and
(d) any system configuration changes that have no impact on the accuracy of report
information including gaming revenue.

Squaxin Island Tribe - State of Washington Gaming Compact
Appendix S – Sports Wagering (Amended and Restated)
9
5.3.5 Emergency Certifications. Nothing in this subsection prevents the immediate
resolution of a critically urgent problem as long as documentation is submitted to the
Tribal and State Gaming Agencies that details the specifics of the emergency
situation and the steps taken to remedy the emergency. Once the emergency situation
has passed, any substantive modification must go through the process described in
subsection 5.3.3 above.

5.3.6 Approval of Certification; Revocation. The Tribal Gaming Agency shall approve or
disapprove of the Sports Wagering System or a component thereof after reviewing
the certification, technical standards tested, and results of testing from the
Independent Test Laboratory, and will notify the State Gaming Agency of its
findings and decision. The State Gaming Agency will notify the Tribal Gaming
Agency if the State Gaming Agency determines a certification from the Independent

T
Test Laboratory was issued in error. The Gaming Agencies will meet and confer to
discuss the State Gaming Agency’s concerns. Tribal Gaming Agency may revoke its
approval of the Sports Wagering System or a component thereof if it finds that the
certification was erroneous.

5.3.7

5.3.8
AF
Training. The State Gaming Agency will collaborate with the Tribal Gaming Agency
to provide training opportunities at agreed upon location(s).

Security Assessment. Prior to offering Sports Wagering and annually thereafter, the
Gaming Operation must perform a system integrity and security assessment of the
Sports Wagering System, which shall be conducted by an independent technical
expert selected by the Gaming Operation and licensed by the Tribal Gaming Agency
and certified by the State Gaming Agency. The independent technical expert’s report

DR 5.3.9
will be submitted to the Tribal Gaming Agency and the State Gaming Agency and
will include: (a) the scope of review, (b) name and company affiliation of the
individuals who conducted the assessment, (c) date of assessment, (d) findings,
(e) recommended corrective action, if applicable, and (f) the Gaming Operation’s
response to the findings and recommended corrective action, if applicable.

Required Reports. The Sports Wagering System must be capable of generating those
reports necessary to record the adjusted gross receipts, wagering liability, ticket
redemption, and such other information relating to Sports Wagering as deemed
necessary by the Tribal Gaming Agency or as required by Internal Controls. These
reports may include, but are not limited to: (a) Gaming Operation Revenue reports;
(b) Gaming Operation Liability reports; (c) Future Events reports; (d) Significant
Events and Alterations reports; (e) Wager Record Information reports; (f) Market
Information reports; (g) Contest/Tournament Information reports; (h) Player Account
Information reports; (i) Sports Wagering System Information reports; (j) Significant

Squaxin Island Tribe - State of Washington Gaming Compact
Appendix S – Sports Wagering (Amended and Restated)
10
Event Information reports; (k) User Access Information reports; and (l) any other
reports required by the Tribal Gaming Agency.

5.3.10 Future Technology Permitted. Upon approval by both parties, any technology not
specifically authorized by this Appendix may be utilized if the proposed technology
will protect, maintain, or enhance current integrity and security standards in the
Compact or this Appendix.

5.4 Wagering Limits. Appropriate Sports Wagering limits will be set by the Gaming Operation,
consistent with limitations on anonymous Sports Wagering in accordance
with subsection 7.1.1 and the Reserve Requirement in subsection 5.5 below.

5.5 Reserve Requirement. The Gaming Operation must have the ability to cover all outstanding
Sports Wagering liabilities.

5.6 Player Accounts.

5.6.1
T
Account Required. A Player Account is required to engage in Mobile Sports

5.6.2
AF
Wagering. The Gaming Operation will limit each patron to one active account and
username. The Gaming Operation will implement rules and procedures to terminate
all accounts of any patron who knowingly and intentionally establishes or seeks to
establish multiple active accounts, whether directly or by use of another person as a
proxy.

In-Person Registration. To establish a Player Account, a patron must register in-
person at the Gaming Facility and provide, at a minimum, the following information:
(a) legal name; (b) date of birth; (c) social security number, or the last four digits

DR
thereof, or an equivalent identification number for a noncitizen patron, such as a
passport or taxpayer identification number; (d) residential address; (e) email address,
if any; and (f) telephone number, if any. The Gaming Operation must verify the
patron’s identity against a form of valid, federal, state, or tribal government-issued
photo identification. The Gaming Operation may utilize a third-party know your
customer services or governmental database to authenticate a patron’s identity or
information. Prior to issuing a patron a Player Account, the patron must accept the
Gaming Operation’s terms and conditions for Sports Wagering, which must, at a
minimum, notify the patron that the Player Account is non-transferrable and that that
the patron is prohibited from allowing any other person to access or use the Player
Account.

5.6.3 Account Funding. A Player Account may be funded with U.S. currency through the
use of: (a) Cash; (b) Cash Equivalent; (c) a patron’s deposit of cash or vouchers at
the Sportsbook or other cashiering location, (d) promotional credit; (e) winnings; (f)

Squaxin Island Tribe - State of Washington Gaming Compact
Appendix S – Sports Wagering (Amended and Restated)
11
adjustments made by the Gaming Operation with documented notification to the
patron; or (g) any other means approved by the Tribal Gaming Agency and State
Gaming Agency.

5.6.4 Player Account Controls. The Gaming Operation must implement Player Account
controls that meet or exceed those in Gaming Laboratories International’s GLI-33
(Standards for Event Wagering Systems), as amended or modified, or equivalent
standards as approved by the Tribal Gaming Agency with concurrence from the State
Gaming Agency, and the standards established by this Appendix.

5.7 Surveillance. All physical components of the Sports Wagering System, except wiring,
cables, and conduit in which they are located, shall have the ability to be effectively and
clandestinely monitored and recorded by means of a Surveillance System in accordance with
Compact, Appendix A, or as otherwise provided in the Tribe’s Internal Controls. Mobile

T
Devices owned by the Gaming Operation that are utilized by a patron as part of the Sports
Wagering System may have lesser surveillance requirements outlined in the Tribe’s Internal
Controls.

5.8

5.9
AF
Accounting Records. As part of the accounting records required to be kept in accordance
with the Compact and Appendix A, the Gaming Operation must keep detailed, supporting,
and subsidiary Sports Wagering records to support those accounting records in accordance
with its Internal Controls. The Internal Controls must also establish minimum audit
standards.

Internal Controls. Prior to beginning Sports Wagering operations, the Tribe must implement
Internal Controls as minimum operating standards to govern the operation and management
of Sports Wagering.

DR
5.9.1 Initial Internal Controls. The Tribal Gaming Agency shall forward to the State
Gaming Agency its initial Internal Controls for review and concurrence. The
proposal will contain a narrative representation of the internal control system. The
Tribal Gaming Agency shall detail how the Internal Controls meet or exceed the
requirements described in this subsection 5.9. The State Gaming Agency
concurrence with the Tribal Gaming Agency proposal shall be deemed granted after
twenty (20) days of receipt of the Tribal Gaming Agency proposal if no disapproval
in writing is received from the State Gaming Agency. The State Gaming Agency
shall only disapprove such portions of a proposal it finds would have a material
adverse impact on public interest or on the integrity of Sports Wagering and shall
detail the reasons for disapproval. If a dispute regarding this process cannot be
resolved by the Gaming Agencies within thirty (30) days, the parties may seek
dispute resolution pursuant to the Compact.

Squaxin Island Tribe - State of Washington Gaming Compact
Appendix S – Sports Wagering (Amended and Restated)
12
5.9.2 Minimum Requirements. The Internal Controls will address the following, at a
minimum:

(a) Description of Gaming Employees who perform essential functions,
including management of Sports Wagering, supervisory authority over daily
operation of Sports Wagering, overseeing technology issues related to the
Sports Wagering System, acceptance of Sports Wagers in the Sportsbook,
handling payouts on winning tickets/vouchers, and coordination of
compliance efforts related to Sports Wagering;

(b) In the event of a failure or malfunction of the Sports Wagering System’s
ability to pay winning Sports Wagers, the Gaming Operation shall have
internal controls detailing the method of paying winning Sports Wagers. The
Gaming Operation shall also file an incident report for each system failure

(c)
T
and document the date, time, and reason for the failure along with the date
and time the system is restored with the Tribal Gaming Agency;

User access controls for Sports Wagering personnel;

(d)

(e)

(f)
AF
Segregation of duties;

Automated and manual risk management procedures;

Procedures for identifying and reporting fraud and suspicious conduct,
including identifying Unusual Wagering Activity and Suspicious Wagering
Activity and reporting such activity to an Integrity Monitoring Provider;

DR
(g)

(h)

(i)
Procedures for identifying and preventing Sports Wagering by Prohibited
Sports Wagering Participants;

Description of anti-money laundering compliance standards, which must
include limitations placed on anonymous wagering and prohibit anonymous
single Sports Wagers of two thousand dollars ($2,000) or more, and include
the retention of the wager record information with patron identification;

Process for submitting or receiving approval of all types of wagers available
to be offered by the Sports Wagering System;

(j) Description of process for accepting Sports Wagers and issuing pay outs, plus
any additional controls for accepting Sports Wagers and issuing pay outs in
excess of ten thousand dollars ($10,000);

Squaxin Island Tribe - State of Washington Gaming Compact
Appendix S – Sports Wagering (Amended and Restated)
13
(k) Description of a process for accepting multiple Sports Wagers from one
patron in a 24-hour cycle, including a process to identify patron structuring of
Sports Wagers to circumvent recording and reporting requirements;

(l) Opening and closing Sportsbook windows;

(m) Procedures for reconciliation of assets and documents contained in a Sports
Wagering area cashier’s drawer, Sports Wagering Kiosk, and Mobile Sports
Wagering, which must include the drop and count procedures for Sports
Wagering Kiosks;

(n) Procedures for cashing winning tickets at the cage after the Sportsbook has
closed, if applicable;

(o)

(p)
T
Procedures for accepting value game chips for Sports Wagering, if
applicable;

Procedures for issuance and acceptance of promotion funds and free wagers

(q)

(r) AF
for Sports Wagering, if applicable;

Description of all integrated third-party systems;

If Cloud Storage is utilized, a description of how the Cloud Storage complies
with applicable federal laws and a description of how the Cloud Storage
meets or exceeds the security standards from Center for Internet Security
(CIS), as amended or modified, or equivalent standards as approved by the
Tribal Gaming Agency with concurrence from State Gaming Agency;

DR
(s)

(t)

(u)
Procedures for closing out dormant Player Accounts;

Procedures for making adjustments to a Player Account, including the
process for a patron to close out a Player Account, and a process whereby a
patron will be refunded after the closure of a Player Account;

If the Sports Wagering System includes Mobile Sports Wagering, a method
for verifying patrons’ wagers placed within the Premises;

(v) Procedures to maintain the security of identity and financial information of
patrons;

(w) Procedures for securely issuing, modifying, and resetting a Player Account
password, personal identification number, biometric login, or other approved
security feature, when applicable;

Squaxin Island Tribe - State of Washington Gaming Compact
Appendix S – Sports Wagering (Amended and Restated)
14
(x) Procedures for patron notification including any password or security
modification via electronic or regular mail, text message, or other manner
approved by the Tribal Gaming Agency, provided that such methods will
include, at a minimum: (A) if in person, verify the patron’s identity against a
form of valid, federal, state, or tribal government-issued, photo identification,
(B) the correct response to two or more challenge questions, (C) strong
authentication, or (D) two-factor authentication;

(y) Controls to prevent ACH fraud regarding failed ACH deposits into a Player
Account and policies regarding Player Account closure, dormant Player
Account, unclaimed funds in a dormant Player Account, and suspension and
subsequent restoration of a Player Account;

(z) Change control procedure;

(aa)

(bb)
T
Procedures for receiving, investigating and responding to patron complaints;

Procedures to ensure security of the servers;

(cc)

(dd)

(ee)
AF
Procedures for line setting and line moving;

Procedures regarding redemption of winning tickets, including but not
limited to a method for redeeming lost tickets, if allowed, and a method for
redeeming tickets by U.S. Mail, if allowed;

Description of the circumstances, limitations, and method by which the
Gaming Operation will cancel wagers, which must at a minimum require

DR (ff)

(gg)

(hh)
cancellation in the event of an obvious error and require that only a
supervisory employee of the Gaming Operation can void or cancel a wager;

Procedures for voiding wagers;

Accounting and audit procedures; and

Any other internal controls deemed necessary by the State Gaming Agency
and Tribal Gaming Agency by memorandum of agreement.

5.9.3 Revisions. Any new or revised Internal Controls adopted by the Tribe shall ensure
that the interests of the Tribe and the State relating to Sports Wagering are preserved
and protected; maintain the integrity of Sports Wagering; and reduce the dangers of
unfair or illegal practices in the conduct of Sports Wagering. The Tribal Gaming
Agency shall forward to the State Gaming Agency any proposed changes to the
Internal Controls for review and concurrence. The Tribal Gaming Agency shall

Squaxin Island Tribe - State of Washington Gaming Compact
Appendix S – Sports Wagering (Amended and Restated)
15
detail how such changes in the provisions adequately preserve and protect the
integrity and security of the standard it is replacing. The State Gaming Agency
concurrence with the Tribal Gaming Agency proposal shall be deemed granted after
twenty (20) days of receipt of the Tribal Gaming Agency proposal if no disapproval
in writing is received from the State Gaming Agency. The State Gaming Agency
shall only disapprove such portions of a proposal it finds would have a material
adverse impact on public interest or on the integrity of the Gaming. Operation and
shall detail the reasons for disapproval.

5.10 House Rules. The Gaming Operation will adopt comprehensive house rules, which must be
approved by the Tribal Gaming Agency, and made available to patrons at the Gaming
Facility and through the Sports Wagering System. House Rules shall include: (1) Method for
calculation and payment of winning wagers; (2) Description of the process for handling

T
incorrectly posted events, odds, wagers, or results; (3) Effect of schedule changes; (4)
Method of notifying patrons of odds or proposition changes; (5) Acceptance of wagers at
other than posted terms; (6) Expiration of any winning ticket; (7) Lost ticket policy; (8)
Method of contacting the operator for questions and complaints; (9) A policy by which

AF
Gaming Operation can cancel or void wagers; and (10) Description of Prohibited Sports
Wagering Participants.

SECTION 6. SPORTS WAGERING LICENSING AND CERTIFICATION

The Tribe and State will share information about significant licensing and certification matters that
reflect on the conduct of Sports Wagering.

6.1 Applicability of Compact Provisions. Sports Wagering Vendors will be licensed and
certified in accordance with this Appendix; however, to extent they are not addressed herein,

DR
the following sections of the Compact will also apply to this Appendix: Section V,
Licensing, State Certification, Eligibility, and Registration Requirements, and Section VI,
Licensing, State Certification, Eligibility, and Registration Procedures, including but not
limited to licensure of Gaming Employees and exemptions from licensure. All
manufacturers, suppliers of Gaming Services, and Financiers not expressly identified in this
Appendix will be licensed and certified in accordance with Section V of the Compact, unless
exempted therein. Consistent with Section V of the Compact, in the event a Sports Wagering
Vendor provides or intends to provide less than twenty-five thousand dollars ($25,000) in
Sports Wagering goods or services annually, the licensing requirements may be waived
upon the mutual agreement of the Tribal and State Gaming Agencies. This waiver does not
apply to Sports Wagering Vendors whose compensation is contractually determined by the
Tribe’s Sports Wagering revenue.

6.2 Sports Wagering Vendors. Each Sports Wagering Vendor must be licensed by the Tribal
Gaming Agency and certified by the State Gaming Agency prior to the sale or delivery of

Squaxin Island Tribe - State of Washington Gaming Compact
Appendix S – Sports Wagering (Amended and Restated)
16
any component of the Sports Wagering System or Sports Wagering services to the Tribe. If
a Sports Wagering Vendor is certified by the State Gaming Agency to supply any
component of the Sports Wagering System or Sports Wagering services to any other tribe in
Washington State, it shall be deemed certified to supply similar goods or services to the
Tribe for the purposes of this Appendix, provided that such goods and services are within
the same Sports Wagering Vendor category, each of which are described in
subsections 6.2.1 – 6.2.3 below.

6.2.1 Major Sports Wagering Vendor. Any person or entity that provides goods or services
integral to Sports Wagering must be licensed as a Major Sports Wagering Vendor by
the Tribal Gaming Agency and certified by the State Gaming Agency. The following
vendors are integral to Sports Wagering:

(a) Manager of the Tribe’s Sports Wagering activities pursuant to an agreement

(b) T
approved by the National Indian Gaming Commission;

When the Tribe manages its own Sports Wagering activities, the Tribe’s
primary consultant who provides substantial Sports Wagering related

(c)

(d)

(e)
AF
services;

Any manufacturer or distributor of the Sports Wagering System or a
component thereof;

Provider of book-making services; or

Provider of Sports Wagering risk management services.

DR
6.2.2 Mid-Level Sports Wagering Vendor. Any entity that provides security or integrity
services directly related to Sports Wagering must be licensed as a Mid-Level Sports
Wagering Vendor by the Tribal Gaming Agency and certified by the State Gaming
Agency. For the purpose of this subsection, security or integrity services include the
following:

(a)

(b)
Integrity monitoring services;

Services related to compilation, furnishing, or storage of official data for use
in Sports Wagering;

(c) System security testing or certification services directly related to initial or
annual testing or assessment of the Sports Wagering System security;

(d) Services directly related to the creation and maintenance of a Geofence to
ensure that wagers are placed within the Premises;

Squaxin Island Tribe - State of Washington Gaming Compact
Appendix S – Sports Wagering (Amended and Restated)
17
(e) Player account management services, including Software-as-a-Service
(SaaS); and

(f) Any other provider of security or integrity services that the Tribal and State
Gaming Agencies agree must be licensed and certified as a Mid-Level Sports
Wagering Vendor because the provider’s services are directly related to
Sports Wagering.

6.2.3 Ancillary Sports Wagering Vendors. Any entity that provides necessary support
services to Sports Wagering must be licensed as an Ancillary Sports Wagering
Vendor by the Tribal Gaming Agency and certified by the State Gaming Agency.
For the purpose of this subsection, support services include at least the following:

(a) Services related to the offering of mobile payment processing for use in

(b)
Mobile Sports Wagering;

T
Know your customer services for use in Mobile Sports Wagering; and

6.3

6.4
(c)

AF
Marketing services in which compensation for such services is, by contract,
determined by the Tribe’s Sports Wagering revenue.

Tribal Licensing of Sports Wagering Vendors. All applicants required to be licensed by the
Tribe shall complete forms furnished by the Tribal Gaming Agency. The Tribal Gaming
Agency shall establish the Tribal licensing fees for Sports Wagering Vendors.

State Certification of Sports Wagering Vendors. Each Sports Wagering Vendor and its
representatives shall apply for certification by the State Gaming Agency and shall submit the

DR
completed applications along with the required information and fees to the State Gaming
Agency. The State Gaming Agency shall expedite Sports Wagering Vendor certification
requests. For applicants who are business entities, the State’s application and investigation
will extend to each Principal of the entity but will not apply to spouses of any Principals.
The State Gaming Agency will conduct interviews virtually and review documents
electronically when possible. The State Gaming Agency will perform a site visit if an
applicant requests a site visit or if the State Gaming Agency determines that the information
sought is critical to its investigation and such information cannot be obtained by other
reasonable measures.

6.5 Fees for State Certification. The fees for initial and renewal State Certification shall be
determined pursuant to WAC 230-05, now or as amended, for Sports Wagering Vendors and
their representatives.

Squaxin Island Tribe - State of Washington Gaming Compact
Appendix S – Sports Wagering (Amended and Restated)
18
SECTION 7. CRIMINAL ENFORCEMENT

7.1 Anti-Money Laundering.

7.1.1 Limits on Anonymous Wagering.

(a) No patron shall engage in Mobile Sports Wagering, as provided in
subsection 5.6.1 above, without a Player Account.

(b) No patron may anonymously place a single Sports Wager of two thousand
dollars ($2,000) or more. The Internal Controls will detail acceptable forms
and methods of identifying a patron who places a wager of two thousand
dollars ($2,000) or more.

7.1.2 Federal Requirements. The Tribe is responsible for the regulatory oversight of Sports

T
Wagering player accounts and patron funds held on deposit. The Tribe’s Internal
Controls will describe how the Tribe will comply with applicable federal
requirements including requirements imposed by the Federal Trade Commission
(FTC), Office of the Comptroller of the Currency (OCC), Financial Crimes

7.2 AF
Enforcement Network (FinCEN), Consumer Financial Protection Bureau (CFPB),
Office of Foreign Assets Control (OFAC) and the US Department of Treasury.

Sports Integrity.

7.2.1 Collaboration. The State Gaming Agency and Tribal Gaming Agency shall
collaborate in an effort to prevent and detect competition manipulation through
education and enforcement of the provisions of RCW 9.46 , RCW 67.04 , or RCW

DR 7.2.2
67.24, or any other State laws related to the integrity of sporting events, athletic
events, or competitions within the State.

Integrity Monitoring Provider.

(a) To ensure the Tribal Gaming Agency and State Gaming Agency can monitor
the integrity of Sports Wagering, the Gaming Operation will require the
collection of aggregate Sports Wagering information, in a format that can be
efficiently utilized, provided to, and analyzed by an approved Integrity
Monitoring Provider.

In order to identify Unusual Wagering Activity and Suspicious Wagering
Activity, the Integrity Monitoring Provider will monitor Sports Wagering
information as outlined in the Internal Controls that includes industry best
practices.

Squaxin Island Tribe - State of Washington Gaming Compact
Appendix S – Sports Wagering (Amended and Restated)
19
Upon receiving any report of Unusual Wagering Activity or Suspicious
Wagering Activity from an Integrity Monitoring Provider, the Gaming
Operation will review such reports and notify the Integrity Monitoring
Provider of whether or not it has experienced similar activity.

(b) As a condition of licensure by the Tribal Gaming Agency, the Integrity
Monitoring Provider will be required to:

i. Share information about any Unusual Wagering Activity with other
Integrity Monitoring Providers and required to disseminate all reports of
Unusual Wagering Activity to all tribes offering Sports Wagering in
Washington; and

ii. Immediately notify all other Integrity Monitoring Providers, the Tribal

T
Gaming Agency, and the State Gaming Agency if the Integrity
Monitoring Provider finds any Suspicious Wagering Activity, including a
previously reported Unusual Wagering Activity that rises to the level of
Suspicious Wagering Activity.

7.3
7.2.3

AF
Annual Report. The Tribe shall submit a yearly report to the State Gaming Agency,
which details services provided by the Integrity Monitoring Provider and
summarizes any Unusual Wagering Activity or Suspicious Wagering Activity
notifications issued during that time period.

Information Sharing. In addition to the information sharing provisions contained in the
Compact, the Tribe will establish an information disclosure policy that meets the
information sharing requirements in RCW 9.46.0364, at a minimum, sets forth the Tribe’s

DR
process for sharing information with Local Law Enforcement Agencies and State Gaming
Agency, when such officials are investigating Sports Wagering related crimes, including
money laundering and sports integrity, believed to have occurred within the Gaming Facility
or within Squaxin Island Tribal Lands. The Tribe will share the Sports Wagering
information disclosure policy, and any changes to the policy, with the State Gaming Agency
and provide the State Gaming Agency a thirty (30) day comment period before
implementation. The Tribe will provide personal identifiable information of patrons with
Local Law Enforcement Agencies and State Gaming Agency in accordance with its
information sharing policy.

SECTION 8. PROBLEM AND RESPONSIBLE GAMBLING

Commitment to Responsible Gambling. In addition to the requirements in the Compact Section
III.F, the provisions of which are incorporated herein, the Tribe agrees to the following:

Squaxin Island Tribe - State of Washington Gaming Compact
Appendix S – Sports Wagering (Amended and Restated)
20
8.1 Display Commitment to Responsible Gambling. Each Mobile Sports Wagering application
and each Sports Wagering Kiosk shall display a commitment to responsible gambling and a
link to the Tribe’s responsible gambling policy created pursuant to Compact Section
III.F(1). The display will be in a manner determined by the Tribe.

8.2 Offer Self-Imposed Limits. Either through the Mobile Sports Wagering application or
through the Player Accounts, the Tribe shall include the option to self-impose limitations on
wagering parameters including, at a minimum, (a) limits on the dollar amount of deposits a
player can make into his or her Player Account within a specified time period, (b) limits on
dollar amount to spend/wager within a specified time period, and (c) limits on the total
amount of time available for play or wagering during a specified time period. Changes to
these limitations made by patrons shall be effective twenty-four (24) hours after making the
change.

T
AF
DR
Squaxin Island Tribe - State of Washington Gaming Compact
Appendix S – Sports Wagering (Amended and Restated)
21
SQUAXIN ISLAND TRIBE - STATE OF WASHINGTON
GAMING COMPACT

APPENDIX W
Rules Governing Wide Area Progressives
(Amended and Restated)

Table of Contents
STATEMENT OF CONDITIONS AND LIMITATIONS ............................................................. 1
1. INTRODUCTION .............................................................................................................. 1

2.
1.1
1.2

2.1
T
Definitions ......................................................................................................................... 1
Intent .................................................................................................................................. 2
REQUIREMENTS .............................................................................................................. 2
General Requirements ....................................................................................................... 2

3.
2.2

3.1
3.2
3.3
3.4
3.5
AF
Submission Process ........................................................................................................... 3
TESTING AND APPROVAL ............................................................................................ 5
Independent Gaming Test Laboratory ............................................................................... 5
General Testing Requirements .......................................................................................... 5
Materials Provided to Gaming Test Laboratory ................................................................ 6
Approval by the State Gaming Agency ............................................................................. 6
Installation ......................................................................................................................... 6

DR
4.
5.
3.6
3.7

5.1
WAP Operator Certification .............................................................................................. 7
Payment of Fees ................................................................................................................ 7
INSPECTIONS ................................................................................................................... 7
PARTICIPATION IN ANOTHER APPROVED WAP ..................................................... 8
Requirements for participation in another approved WAP: .............................................. 8

Squaxin Island Tribe – State of Washington Gaming Compact
Appendix W – Rules Governing Wide Area Progressives (Amended and Restated)
i
STATEMENT OF CONDITIONS AND LIMITATIONS

The Squaxin Island Tribe (Tribe) and the State of Washington (State) believe that conducting
Class III gaming under the terms, limitations, and conditions set forth below will benefit the
Tribe and the State, will be fair and protect the members of the Tribe and the other citizens of the
State, and is consistent with the objectives of the federal Indian Gaming Regulatory Act. The
parties have agreed upon conditions of the terms, provisions, and limitations contained in this
Appendix W.

This Appendix contains interdependent conditions and consequences that must be accepted as a
whole in order to operate or participate in a Wide Area Progressive (WAP). As a result,
authorization to operate or participate in a WAP requires the Tribe to operate and participate in
accordance with all of the requirements of both this Appendix and the subsequent memorandum

T
of understanding agreed to under subsection 2.2.3.

SECTION 1. INTRODUCTION

1.1 Definitions

AF
The following definitions apply to these Standards. All capitalized terms, to the extent
they do not conflict, shall have the same definition as in the Compact.

1.1.1. “Component” means hardware, software, and any integral parts or combination
thereof necessary to operate the WAP.

1.1.2. “Fair” means the odds of winning prizes being equal to other devices connected to

DR
the same WAP within accepted statistical industry standards as verified by an
approved Gaming Test Laboratory.

1.1.3. “Participant Tribe” means a tribal government within the State that has been
accepted to join in a specific approved WAP.

1.1.4. “Progressive Prize” means a prize that increases by a predetermined amount
based on play on a Class III Tribal Lottery System (TLS).

1.1.5. “Wide Area Progressive” or “WAP” means a jackpot sharing system between
multiple participating jurisdictions and/or governments within and outside the
State.

1.1.6. "WAP Controller" means a component at each participating jurisdiction’s and/or
government's gaming facility that accumulates Progressive Prizes and provides
Progressive Prize information to display for players.

Squaxin Island Tribe – State of Washington Gaming Compact
Appendix W – Rules Governing Wide Area Progressives (Amended and Restated)
1
1.1.7. “WAP Operator” means the licensed manufacturer or gaming service supplier that
maintains the WAP central system which communicates with individual WAP
Controllers.

1.2 Intent

The intent of the parties is to allow the Tribe to use a WAP where players are entered into
a pool for a Progressive Prize without the insertion of additional consideration.

1.2.1 The WAP must be Fair, secure, and auditable.

1.2.2 The WAP does not constitute a mechanical gambling or lottery device activated
by the insertion of a coin or by the insertion of any object purchased by any

1.2.3 T
person taking a chance by gambling in respect to the device.

The WAP does not constitute an electronic or mechanical device or video
terminal which allows for individual play against such device or terminal.

2.1
AF
General Requirements
SECTION 2. REQUIREMENTS

The basic requirements for a WAP authorized under Compact Section IV-Class III
Gaming Activities of the Compact are as follows:

2.1.1 Any WAP Controller utilized by the Tribe may operate only in conjunction with
the TLS and may not offer a game where the player may play against the device.

DR
2.1.2

2.1.3

2.1.4

2.1.5
The restrictions on the use and operation of the TLS as governed by Appendix
X2, including prohibiting individual play against such devices or terminals, are
not changed by this Appendix.

The WAP will be Fair for players in the State.

The rules of play will be posted for the customer.

The WAP will conform with 25 U.S.C. § 2710 (d)(1)(A), (B), and (C).

2.1.6 The WAP will allow the State Gaming Agency to remotely view the Tribe’s
reports and activity in real time as specifically provided for in a full submission.

2.1.7 The Tribe will make available for review agreements and contracts regarding
WAP participation in accordance with Compact Section X.B Access to Records.

Squaxin Island Tribe – State of Washington Gaming Compact
Appendix W – Rules Governing Wide Area Progressives (Amended and Restated)
2
2.1.8 Employees and/or representatives of a WAP Operator must meet the applicable
licensing and certification requirements in accordance with Compact Section V
Licensing, State Certification, Eligibility, and Registration Requirements and VI
Licensing, State Certification, Eligibility, and Registration Procedures.

2.1.9 Each specific type of WAP approved will conform to the standards documented in
a Memorandum of Understanding after a full submission has been approved, and
the Tribe shall not begin operation of said WAP until the testing and certification
requirements referred to in Section 3 of this Appendix are met.

2.1.10 The Tribe will notify the State Gaming Agency of its participation in a specific
type of WAP and will follow the requirements in an approved Memorandum of
Understanding for the specific type of WAP in order to participate in that WAP.

2.2 Submission Process
T
2.2.1 Each full submission made must meet the requirements contained in the Compact,

AF
Appendix X2, and this Appendix, and shall set the technical standards and
Internal Controls for the operation of that type of WAP. Except for the TLS as
governed by Appendix X2, the Tribe and the State Gaming Agency shall enter
into a separate Memorandum of Understanding for each specific type of WAP the
Tribe wishes to operate.

2.2.2 A "full submission," as that term is used in this Appendix, shall include a detailed
description of technical standards and other information that includes at least the
following:

DR
(a)

(b)

(c)
How the system operates with the TLS, including connections to the
system and other jurisdictions, probability, and summary of game rules
which must be posted for the customer in any format;

WAP illustrations, schematics, block diagrams, circuit analyses, program
object and source codes, and hexadecimal dumps which means the
compiled computer program represented in base 16 format;

Technical and operation manuals including operation, interface,
Progressive Prize verification, and random number generator standards;

(d) System hardware specifications including all key Components including
the WAP Controller;

Squaxin Island Tribe – State of Washington Gaming Compact
Appendix W – Rules Governing Wide Area Progressives (Amended and Restated)
3
(e) Base software which means the software platform upon which games are
loaded;

(f) Game software for one or more games, including game set size and point
of overlap;

(g) System security including encryption, firewalls, key controls, and
surveillance;

(h) Odds for winning the Progressive Prize, the base Progressive Prize
amount, the reset Progressive Prize amount, the incremental increases of
the Progressive Prize, and any secondary pool increment(s);

(i)

T
Accounting system requirements and reports which must include at least a
progressive balancing report and report of unusual events such as critical
memory clears, changes to Progressive Prizes, offline equipment, multiple
site prizes, and related reports;

(j)

(k)

(l)
AF
Reports which must include at least a progressive summary, aggregate,
and payoff and any adjustments made by the WAP Operator on
Progressive Prize pools;

Procedures for handling simultaneous Progressive Prize winners in
multiple locations or jurisdictions;

Procedures to make changes or adjustments to or be removed from the

DR
(m)

(n)

(o)
WAP, including notice requirements to the Participant Tribes and players;

Procedures for accepting additional Participant Tribes or participating
jurisdictions and/or governments into the WAP;

Procedures to handle system malfunctions and reporting those
malfunctions to participating jurisdictions and/or governments;

Player dispute procedures;

(p) Procedures, including a timeframe, for Gaming Operations staff or WAP
Operator to provide notice to the Tribal Gaming Agency and State
Gaming Agency of WAP non-compliance;

(q) Capability and process to allow the State Gaming Agency to remotely
view the Tribe’s WAP to review reports and activity real time; and

Squaxin Island Tribe – State of Washington Gaming Compact
Appendix W – Rules Governing Wide Area Progressives (Amended and Restated)
4
(r) Any agreement, written specifications, or limitations required of a WAP
Operator by any other state or tribal government and affecting a WAP.

2.2.3 The Tribe may present to the State Gaming Agency, at any time, a WAP full
submission it believes satisfies the requirements of the Compact and this
Appendix. Within ninety (90) days of the Tribe's providing of a complete, full
submission for its proposed WAP to the State Gaming Agency, the Tribe and the
State Gaming Agency will execute a Memorandum of Understanding as required
by subsection 2.1.9.

SECTION 3. TESTING AND APPROVAL

3.1 Independent Gaming Test Laboratory

3.1.1
T
Designation. The Tribe shall select one or more gaming test laboratories
(hereinafter "Gaming Test Laboratory") to perform the testing required in this
Appendix. The selection of a Gaming Test Laboratory will be done according to

3.2
3.1.2

AF
Appendix X2, Section 10.1.

Gaming Test Laboratory Duty of Loyalty. The Tribe shall inform the Gaming
Test Laboratory, in writing, that irrespective of the source of payment of its fees,
the Gaming Test Laboratory's duty of loyalty and reporting requirements run
equally to the State Gaming Agency and the Tribe.

General Testing Requirements

DR
The general purpose of testing the WAP and related Components is to determine the
compliance of the WAP with the Memorandum of Understanding agreed to by the Tribe
and the State Gaming Agency. Prior to operation of the WAP, the WAP and related
Components shall be tested by a licensed Gaming Test Laboratory, to verify:

3.2.1

3.2.2
Compliance with the applicable requirements of the Compact, Appendix X2, and
this Appendix; and

The WAP is Fair for both the players and the participating gaming facilities; and

3.2.3 Compliance with the Memorandum of Understanding and currently accepted
gaming test industry standards with respect to multi-jurisdictional WAPs.

Squaxin Island Tribe – State of Washington Gaming Compact
Appendix W – Rules Governing Wide Area Progressives (Amended and Restated)
5
3.3 Materials Provided to Gaming Test Laboratory

3.3.1 The Tribe shall provide or require that the WAP Operator provide to the Gaming
Test Laboratory a copy of the executed Memorandum of Understanding, and any
other information requested by the Gaming Test Laboratory. The Tribe shall
make all such materials available to the State Gaming Agency upon request;

3.3.2 If requested by the Gaming Test Laboratory, the Tribe shall require the WAP
Operator to transport not more than two (2) working models of the WAP
associated player terminals, and any required system elements to a location
designated by the Gaming Test Laboratory for testing, examination or analysis.
Neither the State nor the Gaming Test Laboratory shall be liable for any costs
associated with the transportation, testing, examination, or analysis, including any

T
damage to the Components of the WAP. If requested by the Gaming Test
Laboratory, the Tribe shall require the WAP Operator to provide specialized
equipment or the services of an independent technical expert to assist with the
testing, examination and analysis. The Gaming Test Laboratory will notify the

3.4
AF
State Gaming Agency of the request and need for the request;

Approval by the State Gaming Agency

Upon receiving the certification, technical standards tested, and results of testing from the
Gaming Test Laboratory, the State Gaming Agency shall either approve or disapprove
the WAP or Component thereof, based on the criteria contained in this Appendix and the
Memorandum of Understanding. The Tribe or WAP Operator may request a temporary
suspension of the State Gaming Agency’s review of the WAP or Component for a

DR
mutually agreed upon time period through a written request to the State Gaming Agency
Director.

During the State Gaming Agency approval process, the Gaming Test Laboratory will
meet with the State Gaming Agency and respective Tribal Gaming Agency to inform
regulatory staff of the certification process and technical standards tested and provide
training so that these personnel have an understanding of the WAP, can create a
regulatory program, and can better respond to questions and complaints.

3.5 Installation

3.5.1 No WAP may be offered for play unless:

Squaxin Island Tribe – State of Washington Gaming Compact
Appendix W – Rules Governing Wide Area Progressives (Amended and Restated)
6
3.5.1.1 Such WAP is approved as provided in this Appendix; and

3.5.1.2 The WAP prototype thereof has been tested and certified by the
Gaming Test Laboratory as meeting the requirements and
Memorandum of Understanding specified by this Appendix.

3.5.2 The State Gaming Agency and Tribal Gaming Agency will meet to confer on
WAP initial implementation and Internal Controls changes to prepare for WAP
operation. Initial Internal Controls and any subsequent changes are to be
completed in conformance with Compact Section IX. Standards of Operation.

3.6 WAP Operator Certification

T
Before any Component of a WAP may be placed into operation, the Tribe shall first have
obtained a written certification from the WAP Operator that, upon installation, each such
Component:

3.6.1 Conforms to the specifications of the WAP as certified by the Gaming

3.7
3.6.2
AF
Test Laboratory; and

Operates and plays in accordance with the applicable requirements of the
Compact, Appendix X2, this Appendix, and the Memorandum of
Understanding.

Payment of Fees

3.7.1 The Gaming Test Laboratory shall not accept a WAP submission from a WAP

DR 3.7.2
Operator without first receiving an executed Memorandum of Understanding
from the Tribe. All Gaming Test Laboratory fees related to a WAP submission
shall be the responsibility of the WAP Operator.

All State Gaming Agency testing fees related to a WAP submission shall be the
responsibility of the WAP Operator.

SECTION 4. INSPECTIONS

4.1 The Tribe shall allow the State Gaming Agency to inspect any Components of a WAP for
the purposes of confirming that such Component is operating in accordance with the
requirements of the Compact, Appendix X2, this Appendix, and the Memorandum of
Understanding and that such Component is identical to that tested by a Gaming Test
Laboratory. Inspections shall be pursuant to the Compact.

Squaxin Island Tribe – State of Washington Gaming Compact
Appendix W – Rules Governing Wide Area Progressives (Amended and Restated)
7
4.2 The WAP Operator shall allow the Tribal Gaming Agency and State Gaming Agency to
inspect any Components of a WAP for the purposes of confirming that such Component
is operating in accordance with the requirements of the Compact, Appendix X2, this
Appendix, and the Memorandum of Understanding and that such Component is identical
to that tested by a Gaming Test Laboratory.

4.3 When the Tribal Gaming Agency or State Gaming Agency determine there is a failure to
comply with the Memorandum of Understanding, either will immediately suspend a
WAP’s operation.

4.4 Reinstatement of a WAP’s operation shall occur once the Tribal Gaming Agency and
State Gaming Agency agree that a suspended WAP complies with the Memorandum of
Understanding as determined by follow-up testing by the Gaming Test Laboratory.

4.5
T
If after an investigation the Tribal Gaming Agency or State Gaming Agency believe the
WAP is not operating in a Fair manner, either may request a mathematical review by an
independent third party. The WAP Operator will pay the cost of this review.

AF
SECTION 5. PARTICIPATION IN ANOTHER APPROVED WAP

The Tribe may participate in more than one approved WAP. When the Tribe elects to participate
in a WAP that has already been approved by the State Gaming Agency, Sections 1-4 of this
Appendix do not apply except as required by subsection 5.1.3 below.

5.1 Requirements for participation in another approved WAP:

DR
5.1.1. When participating in a WAP that has already been approved by the State Gaming
Agency, the Tribe must follow the requirements in the Memorandum of
Understanding related to that WAP.

5.1.2. The Tribe will notify the State Gaming Agency of its participation in or
withdrawal from another WAP and will make any and all copies of its
participation agreements available for review.

5.1.3. When the Tribe participates in an already approved WAP, the Tribe will follow
the requirements listed in Sections 1, 2.1, 3.5, 3.6, 4, and 5 of this Appendix.

Squaxin Island Tribe – State of Washington Gaming Compact
Appendix W – Rules Governing Wide Area Progressives (Amended and Restated)
8
SQUAXIN ISLAND TRIBE - STATE OF WASHINGTON

CLASS III GAMING COMPACT

APPENDIX X2
Rules Governing Tribal Lottery Systems
(Amended and Restated)

TABLE OF CONTENTS

SECTION 1. OVERVIEW ............................................................................................................. 1
SECTION 2. DEFINITIONS ......................................................................................................... 1
All capitalized terms not defined herein, to the extent they do not conflict, shall have the same

T
definitions as in the Tribe’s Compact, as amended. ................................................................... 1
2.1 Cashless Transaction System. ........................................................................................... 1
2.2 Central Computer .............................................................................................................. 2
2.3 Electronic Accounting System .......................................................................................... 2
2.4 Electronic Scratch Ticket .................................................................................................. 2

AF
2.5 Electronic Scratch Ticket Game ........................................................................................ 2
2.6 Electronic Scratch Ticket Game Set .................................................................................. 3
2.7 Electronic Scratch Ticket Game Subset ............................................................................ 3
2.8 Game Play Credits ............................................................................................................. 3
2.9 Kiosks ................................................................................................................................ 3
2.10 Manufacturing Computer .................................................................................................. 3
2.11. On-line Lottery Game ...................................................................................................... 3
2.12 On-line Lottery Game Ticket ........................................................................................... 4
2.13 Player Terminals................................................................................................................ 4
2.14 Template ............................................................................................................................ 4

D 2.15 Tribal Lottery System ........................................................................................................ 4
SECTION 3. TRIBAL ELECTRONIC SCRATCH TICKET LOTTERY GAME SYSTEM ...... 5

R3.1 Description of System Operation ...................................................................................... 5
3.2 Game Set and Subset Requirements .................................................................................. 6
3.3 Data Required to be Available Prior to Commencement of an Electronic Scratch Ticket
Game. ......................................................................................................................................... 8
3.4 Data Required to be Available Following the Completion of a Scratch Ticket Game. .... 8
3.5 Software Auditing Tool to be Made Available. ................................................................ 9
3.6 No Auditing of Game Sets While in Play; Dispute Process.............................................. 9
3.7 Manufacturing Computer ................................................................................................ 10
3.8 Central Computer Used in Connection With Electronic Scratch Ticket Game. ............. 11
3.9 Player Terminals Used in Electronic Scratch Ticket Games........................................... 11
3.10 Data Available for Inspection.......................................................................................... 12
SECTION 4. TRIBAL ON-LINE LOTTERY GAME SYSTEM................................................ 12
4.1 Description of System Operation .................................................................................... 12
4.2 Central Computer Used for On-line Lottery Game ......................................................... 14
4.3 Player Terminals Used for On-line Games ..................................................................... 14

i
4.4 Verification and Viewing Requirements for On-line Game Results ............................... 15
4.6 Redemption Period .......................................................................................................... 15
4.7 Other Game Rules ........................................................................................................... 15
4.8 Prizes; Jackpots ............................................................................................................... 15
SECTION 5. PLAYER TERMINALS......................................................................................... 16
5.1 Use as a Stand-Alone Gambling Device Prohibited ....................................................... 16
5.2 Features ........................................................................................................................... 16
5.3 Non-Volatile Backup Memory Required ........................................................................ 16
5.4 On/Off Switch ................................................................................................................. 17
5.5 Static Discharge/Interference .......................................................................................... 17
5.6 Accounting Meters .......................................................................................................... 17
5.7 No Automatic Clearing of Accounting Meters; Reading and Resetting Meters ............. 17
5.8 Display of Information .................................................................................................... 18
5.9 Protection of Displayed Information ............................................................................... 18

T
5.10 Hardware Switches Prohibited ........................................................................................ 18
5.11 Networking Requirements ............................................................................................... 18
5.12 Prohibited Software Functions ........................................................................................ 19
5.13 Quick-Pick Function........................................................................................................ 19
5.14 Wagers; Displaying Electronic Scratch Ticket Outcomes .............................................. 19

AF
5.15 Cash Standards ................................................................................................................ 19
5.16 Door Access Logging ...................................................................................................... 20
SECTION 6. STANDARDS FOR RANDOM NUMBER GENERATORS USED WITHIN THE
TRIBAL LOTTERY SYSTEM.............................................................................. 20
6.1 Chi-Square Analysis ........................................................................................................ 20
6.2 Runs Test ......................................................................................................................... 21
6.3 Correlation Analysis ........................................................................................................ 21
6.4 Serial Correlation Analysis ............................................................................................. 21
SECTION 7. ELECTRONIC ACCOUNTING SYSTEM ........................................................... 21

D 7.1 Revenue Reporting Requirements ................................................................................... 21
SECTION 8. CASHLESS TRANSACTION SYSTEM SECURITY, REPORTING AND

R STORAGE REQUIREMENTS .............................................................................. 24
8.1 Player Information ........................................................................................................... 24
8.2 Smart Cards ..................................................................................................................... 26
8.3 Other Functions ............................................................................................................... 26
8.4 Kiosks .............................................................................................................................. 26
SECTION 9. GENERAL SECURITY REQUIREMENTS ......................................................... 27
9.1 Separation ........................................................................................................................ 27
9.2 Security ............................................................................................................................ 27
9.3 Secure Connections; DES or Equivalent Data Encryption ............................................. 28
9.4 Surge Protection; Uninterrupted Power System (“UPS”) ............................................... 28
9.5 Identification Plates ......................................................................................................... 28
9.6 Locked Areas ................................................................................................................... 28
9.7 Access Control Standards ................................................................................................ 28
9.8 MEAL Cards ................................................................................................................... 29
9.9 Access Control ................................................................................................................ 29

ii
9.10 Cameras ........................................................................................................................... 30
9.11 Verification Data and Functions...................................................................................... 30
SECTION 10. TESTING OF TRIBAL LOTTERY SYSTEMS TO ENSURE INTEGRITY . 30
10.1 Designation of Independent Gaming Test Laboratory .................................................... 30
10.2 Testing and Certification of Tribal Lottery Systems ....................................................... 30
10.3 Approval by the State Gaming Agency ........................................................................... 32
10.4 Modifications of Approved Lottery Systems; Emergency Certifications ....................... 32
10.5 Manufacturer's Conformity to Technical Standards ........................................................ 32
10.6 Payment of Gaming Test Laboratory Fees ...................................................................... 33
10.7 Gaming Test Laboratory Duty of Loyalty ....................................................................... 33
10.8 Random Inspections ........................................................................................................ 33
10.9 State Gaming Agency to be Supplied Model of Player Terminal and System ............... 33
SECTION 11. ALTERNATIVE STANDARDS PERMITTED .............................................. 33
SECTION 12. TRIBAL LOTTERY SYSTEM PLAYER TERMINAL ACQUISITION AND

T
OPERATION ......................................................................................................... 33
Appendix E Section 6 governs Player Terminal Allocations and operation, and such provisions
are incorporated herein. .......................................................................................... 33
SECTION 13. STATE REGULATORY FEES ........................................................................ 34

AF
SECTION 14. COMMUNITY INVESTMENTS AND PUBLIC HEALTH ........................... 34
13.1 Community Impact .......................................................................................................... 34
13.2 Charitable Contributions. ................................................................................................ 34
13.3 Problem and Responsible Gambling ............................................................................... 34
13.4 Smoking Cessation and Prevention ................................................................................. 34
SECTION 15. HOURS OF OPERATION ............................................................................... 34

DR
iii
SECTION 1. OVERVIEW

This Appendix describes, authorizes and sets forth provisions applicable to the operation of a
tribal lottery system conducted pursuant to the Indian Gaming Regulatory Act for playing
electronic scratch ticket and on-line lottery games. The system utilizes player terminals with
video displays which allow players to purchase chances and obtain game result information, a
manufacturing computer which securely creates the finite set of chances used in the scratch ticket
portion of the system, a central computer which stores and transmits game information and
makes draws for the on-line lottery game, and an electronic central security and accounting
system. In the scratch ticket game, preexisting scratch tickets are dispensed in an electronic
format to players through the player terminals on an on-demand basis. In the on-line lottery
game, drawings are conducted on a central computer independently of any activity at player
terminals. The drawing results are then matched to player selections previously made on the

T
player terminals. The system and games described and authorized herein are subject to the
technical provisions set forth herein. Notwithstanding anything to the contrary herein, tribal
lottery systems and player terminals approved pursuant to Appendix X prior to the effective date
of this Appendix X2 may continue to be operated consistent with the requirements of Appendix

AF
X as they existed on the date this Appendix X2 became effective. Further, nothing herein shall
restrict the Tribe from exercising any provision in its Compact not covered by this Appendix X2.

This Appendix X2, as originally added to the Compact by the Third Amendment in 2007,
contained interdependent conditions and consequences that were accepted as a whole in order to
operate or participate in the Tribal Lottery System. In 2025, the Tribe amended and restated its
Compact, and as part of that effort, portions of this Appendix X2 were updated to better align
with the Compact. This Appendix X2 was bargained for and in exchange for all the terms

D
contained herein, as well as Compact Sections III.D.(2), D.(4), F., and K., Section XII, and
Appendix E Section 4, 6, and 7 in the amended Compact.

R SECTION 2. DEFINITIONS

All capitalized terms not defined herein, to the extent they do not conflict, shall have the same
definitions as in the Tribe’s Compact, as amended.

0.1 Cashless Transaction System. The means by which a player obtains, transfers and
redeems Game Play Credits. The Cashless Transaction system permits a player to play
the Tribal Lottery System without inserting cash (coins, tokens or paper currency) into,
and to win prizes without receiving cash from, the Player Terminal. The Cashless
Transaction System includes the following components:

0.1.1 The Electronic Accounting System;

Squaxin Island Tribe –State of Washington Gaming Compact
Appendix X2 - Rules Governing Tribal Lottery Systems (Amended and Restated)
1
0.1.2 One or more of the following: plastic, cardboard, magnetic, or "smart" cards;
paper; personal identification ("PIN") numbers; Game Play Credits obtained from
the exchange of cash or cash equivalents; Game Play Credits displayed on the
Player Terminal which were earned as prizes from prior play and not redeemed;
and other means for effectuating play and awarding prizes without inserting or
dispensing cash into or from the Terminal, provided that all Game Play Credits
(other than credits earned from prior play and remaining displayed on a Player
Terminal) must have been paid for by cash or cash equivalent;

0.1.3 A means of accounting for player deposits of cash or cash equivalents and
exchanges for and redemption of Game Play Credits which is independent of the
Player Terminal, through a player's account, a voucher system, or a "smart" card
or similar device for recording individual player data; and

0.1.4
T
A means by which players can redeem unused Game Play Credits for cash or cash
equivalents. All redemptions for cash must be through a cashier or redemption
system separate from the Player Terminal.

2.1.5

AF
The Cashless Transaction System may include a means of obtaining Game Play
Credits through the exchange of non-gambling promotions as allowed in Section
8.1.8 delivered from a Promotion Tracking System. Players may use credits
obtained in this manner to purchase additional electronic scratch tickets or redeem
them for cash or cash equivalents. Non-cashable Game Play Credits obtained
from promotions may be returned to a player’s account in the Promotion Tracking
System

D
0.2

R
0.3
Central Computer. A computer which conducts drawings for On-line Lottery Games and,
for Electronic Scratch Ticket games, stores and dispenses Electronic Scratch Tickets from
Scratch Ticket Subsets which have been loaded into it from a Manufacturing Computer
and are maintained in a secure manner.

Electronic Accounting System. A computer system that provides a secure means to
receive, store and access data and record critical functions and activities, as set forth in
Section 7.

0.4 Electronic Scratch Ticket. A predetermined winning or losing outcome in electronic
form. Each Scratch Ticket represents a chance from among the finite set of chances that
comprise an Electronic Scratch Ticket Game Set. Electronic Scratch Ticket may also be
known as Scratch Ticket.

0.5 Electronic Scratch Ticket Game. A scratch ticket lottery game that is played in an
electronic environment. A game has a specific set of rules including: The theme and

Squaxin Island Tribe –State of Washington Gaming Compact
Appendix X2 - Rules Governing Tribal Lottery Systems (Amended and Restated)
2
types of symbols used; the total number of tickets in the game; the ratio or mix of
winning and losing tickets; the prize structure, including number and dollar value of each
prize; and price of a single ticket. The game is played by use of computer hardware and
software to manufacture, store, distribute, sell, and display scratch tickets to players.
Electronic Scratch Ticket Game may also be known as Game.

0.6 Electronic Scratch Ticket Game Set. A finite set of Electronic Scratch Tickets that is
based on a Template that has been designed in accordance with a specific set of rules,
including the basic requirements of Section 3.2, governing the structure of an Electronic
Scratch Ticket Game. Based on that Template, an Electronic Scratch Ticket Game Set is
created in a Manufacturing Computer in a secure and verifiable electronic form prior to
the play of an Electronic Scratch Ticket Game. Each Electronic Scratch Ticket Game Set
is uniquely identifiable, by serial number or otherwise, so that it can be distinguished

0.7
T
from other Game Sets manufactured from the same Template. Electronic Scratch Ticket
Game Set may also be known as Game Set.

Electronic Scratch Ticket Game Subset. A defined group of Electronic Scratch Tickets

0.8
AF
that has been randomly selected from an Electronic Scratch Ticket Game Set and
transmitted to a Central Computer in a fixed order for play. Each Electronic Scratch
Ticket Game Subset is uniquely identifiable from all other Subsets selected from the
same Game Set. Electronic Scratch Ticket Game Subset may also be known as Electronic
Scratch Ticket Subset, Game Subset, or Subset.

Game Play Credits. A means of representing value obtained from the exchange of cash or
cash equivalents, or earned as a prize, which is used as a means to effectuate play. Game

DR
0.9

2.10
Play Credits may be redeemed for cash or a cash equivalent. Game Play Credits obtained
from promotions may be returned to a player’s account in the Promotion Tracking
System.

Kiosks. Cash exchange or redemption terminals, which allow for cash to cashless
transactions or cashless to cash transactions with or without a cashier. A Player Terminal
is not a Kiosk.

Manufacturing Computer. A computer which creates Electronic Scratch Ticket Game
Sets, randomly allocates tickets into Scratch Ticket Subsets, and delivers them to a
Central Computer.

0.11. On-line Lottery Game. A lottery game by which players, through the use of Player
Terminals, select numbers, symbols or other possible outcomes to be matched to
outcomes that are subsequently and randomly selected in drawings which are
electronically conducted on a Central Computer.

Squaxin Island Tribe –State of Washington Gaming Compact
Appendix X2 - Rules Governing Tribal Lottery Systems (Amended and Restated)
3
0.12 On-line Lottery Game Ticket. A paper, cardboard or electronically encoded medium
onto which information is legibly printed, or is recorded electronically, in a manner
which can cause a Player Terminal to display, the outcome(s) and prize(s) won, if any,
and other information associated with, an On-line Lottery Game drawing in which the
player is enrolled.

0.13 Player Terminals. Electronic computer terminals housed in cabinets with input devices
and video screens and with which players play the On-line Lottery and Electronic Scratch
Ticket games. Player Terminals are not capable of playing gambling games as
stand-alone devices. Player Terminal may also be known as a Terminal.

0.14 Template. A software file containing all possible prize values for a Game Set to be
created, indicating the number of prizes for each prize value that will appear in the Game

0.15
Set.

T
Tribal Lottery System. Any lottery system operated pursuant to this Appendix. All
computers and terminals and the combination and components thereof in each system

2.16

AF
operated by the Tribe shall conform to the provisions of this Appendix.

Virtual Environment. A Virtual Environment is comprised of a host computer or server
and virtualization software. Virtualization refers to the abstraction of computer resources
from the underlying hardware. A layer of virtualization software called the hypervisor is
added between the hardware and operating system on a physical server. This
virtualization layer allows multiple operating system instances to run concurrently within
Virtual Machines on a single computer. It dynamically partitions and shares the available
physical resources such as CPU, storage, memory, and I/O devices among multiple

DR
2.17
Virtual Machines.

The hypervisor enables the operating system within the Virtual Machine, called the guest
operating system, to run unmodified and to behave as if it is running on physical
hardware. Virtual devices are implemented in software and function in exactly the same
way as their physical counterparts. The guest operating system interacts with the
hypervisor's abstraction layer of virtual hardware and not the physical hardware.

Virtual Machine. A Virtual Machine is a software implementation of a computing
environment that is operated using a Virtual Environment. Virtual Machines shall operate
separately and be securely isolated from other Virtual Machines within the Virtual
Environment, thereby emulating single physical computers.

2.18 Promotion Tracking System. A computer system or program designed to promote play of
the Tribal Lottery System and to provide an account for each player’s promotions.
Portions of the Promotion Tracking System may reside within the Tribal Lottery System,

Squaxin Island Tribe –State of Washington Gaming Compact
Appendix X2 - Rules Governing Tribal Lottery Systems (Amended and Restated)
4
which distributes and displays bonuses and promotions to patrons. The Promotion
Tracking System will not serve any gambling functions. Those portions and functions of
the Promotion Tracking System that reside within or directly interact with or impact the
Tribal Lottery System are subject to the requirements of this Appendix.

SECTION 3. TRIBAL ELECTRONIC SCRATCH TICKET LOTTERY GAME
SYSTEM

0.1 Description of System Operation

0.1.1 The Tribal Lottery System game known as the Electronic Scratch Ticket Game
consists of a finite number of Electronic Scratch Tickets, a certain number of
which, if drawn, entitle a player to prize awards at various levels. The scratch

T
tickets are designed from a Template in conformity with this Appendix and are
created in Game Sets on a Manufacturing Computer from which Scratch Tickets
are randomly selected and placed into Scratch Ticket Subsets. Each Game Set has
a predetermined number of winners and values and is designed so as to assure

0.1.2
AF
players of an at least seventy-five percent (75%) payback of the amounts paid in
the aggregate for all tickets in the Set. As a Game Set’s tickets are placed into
Subsets, the pool of tickets available from that Game Set for placement into
Subsets diminishes, until each ticket in the Game Set has been placed into a
Subset.

Scratch Ticket Subsets are transmitted to the Central Computer, where they are
stored until dispensed electronically on demand to Player Terminals. Scratch
Tickets are electronically dispensed from the Central Computer in the order

DR 0.1.3
within each Subset in which the tickets were received. Players compete against
each other to draw winning tickets. As Subsets are used they are replaced by
additional Subsets which have been created and delivered to the Central
Computer in the same manner, until the Game Set has been depleted, or pulled
from play, ending that particular game. Different Games based on different Game
Sets may be offered simultaneously through the Central Computer.

A player initiates participation in an Electronic Scratch Ticket game at a Player
Terminal, using Game Play Credits purchased on the Player Terminal through the
insertion of cash, through the Cashless Transaction System, or by accessing and
downloading any promotion. The monitor displays one or more of the Electronic
Scratch Ticket Games that are offered by the system, as well as other information
such as graphics, game play and outcome information, and entertainment effects,
subject to the limitations in Sections 5.2.2 and 5.2.3. The player may choose a

Squaxin Island Tribe –State of Washington Gaming Compact
Appendix X2 - Rules Governing Tribal Lottery Systems (Amended and Restated)
5
particular game and reveal the outcome, by touching the screen, pressing a button
once or performing some other form of interaction with the Player Terminal.

0.1.4 Following or as part of the player’s selection of a game or games, the player uses
Game Play Credits displayed on the Player Terminal to purchase one or more
Electronic Scratch Tickets. The pricing of tickets is governed by the provisions of
Section 3.2.1. Wagers are deducted from the Game Play Credits displayed on the
Player Terminal.

0.1.5 Prize structure, ticket purchase and selection, and wager information is displayed
or available on the Player Terminal with respect to any game which is being
played through that Terminal.

0.1.6

T
After the player purchases an Electronic Scratch Ticket the outcome associated
with that ticket is shown on the Player Terminal. Any prizes won are displayed on
the Player Terminal and may be in the form of Game Play Credits, the right to
receive merchandise, or other valuable property.

0.1.7

AF
Game Play Credits earned as prizes or offered through a promotion remain
displayed and available for use in further play from that Terminal. Game Play
Credits also may be electronically transferred to a) a player’s account in the
Cashless Transaction System, b) a ticket or receipt printed by the Player Terminal,
or c) a "smart" card or similar instrument. Once transferred, Game Play Credits
may be a) used for further play on another Terminal or b) redeemed for cash or
cash equivalents through a cashier or other separate redemption system.
Merchandise or other property won is collected in accordance with the rules of the

DR
0.2
game.

Game Set and Subset Requirements

0.2.1 Game Set Requirements. Each Game Set Template shall meet the following
minimum requirements:

(a) Each Game Set shall be made up of a finite number of Electronic Scratch
Tickets;

(b) All Scratch Tickets in a particular Game Set Template shall be of the same
purchase price. Appendix E Section 4.1 governs wagering limits, and such
provisions are incorporated herein. A single Ticket may offer an
opportunity to enter another Game Set;

Squaxin Island Tribe –State of Washington Gaming Compact
Appendix X2 - Rules Governing Tribal Lottery Systems (Amended and Restated)
6
(c) The payout percentage for the entire Game Set shall be no less than
seventy-five percent (75%) of the total purchase price of all tickets in the
set combined;

(d) Each Game Set shall be assigned a unique serial number; and

(e) Each ticket shall have a specific outcome and prize level associated with
it.

0.2.2 Game Set Verification Process. Prior to commencement of play, the initial Game
Set shall be verified as to the total number of tickets in the set and the number of
winners at each prize level, including the amounts of such prizes, and the number
of non-winners. The verification standards which the Game Set must meet are

0.2.3
those set forth in Section 3.3.

T
Transmission of Subsets to Central Computer. Following verification of the Game
Set, the Manufacturing Computer shall create ordered Scratch Ticket Subsets on

0.2.4

AF
demand from the Central Computer and transmit the ordered Subsets to it.

Subset Requirements. Each Electronic Scratch Ticket Game Subset shall meet the
following minimum requirements:

(a) Within a given Game Set, each Subset shall be the same size and
comprised of no less than 5,000, and no more than 10,000 Electronic
Scratch Tickets, provided that in order to complete the distribution of all
tickets in a Game Set, the final Subset derived from the Set may have less

DR 0.2.5
than the number of tickets in any other Subset and be less than 5,000;

(b) Each Subset shall be individually and uniquely identified by the Game Set
serial number and a unique serial number for each Subset assigned in the
order in which the Subsets are created;

(c) Once an Electronic Scratch Ticket has been dispensed to a Player
Terminal from a Subset, it cannot be dispensed again.

Completion of Game. A Scratch Ticket Game is deemed to be completed only
when all of the Electronic Scratch Tickets in a Game Set have been dispensed, or
the Game Set has been taken out of play. If any Game Set is withdrawn from play
before completion of the Game, the Tribe shall ensure that at least seventy-five
percent (75%) of the revenues received from sales of Electronic Scratch Tickets in
that Game have been, or in future Electronic Scratch Ticket Games will be,
awarded to players.

Squaxin Island Tribe –State of Washington Gaming Compact
Appendix X2 - Rules Governing Tribal Lottery Systems (Amended and Restated)
7
0.3 Data Required to be Available Prior to Commencement of an Electronic Scratch Ticket
Game.
The following data shall be available to the Tribal Gaming Agency and State Gaming
Agency prior to the commencement of an Electronic Scratch Ticket Game and shall be
maintained and be viewable both electronically and if requested, by printed report, upon
demand:

0.3.1 A unique identifying Game Set serial number;

0.3.2 A description of the Game Set theme sufficient to categorize the Game Set
relative to other Game Sets;

0.3.3 The number of total Scratch Tickets in the Game Set;

0.3.4

0.3.5
T
The number of Scratch Ticket Subsets to be created from the Game Set, and the
number of tickets in each Set;

The payout percentage of the entire Game Set;

0.3.6

0.3.7

0.3.8
AF
The payout table for the Game Set and the number of Scratch Tickets at each
level of the payout table;

The purchase price per ticket assigned to the Game Set;

Such further information as the State Gaming Agency may reasonably require to
assure the integrity and accuracy of the foregoing information.

D
0.4

R
Data Required to be Available Following the Completion of a Scratch Ticket Game.
Following the completion of an Electronic Scratch Ticket Game (i.e., upon the sale of all
tickets in a Game Set or the withdrawal of the Set from play), the following data shall be
available to the Tribal Gaming Agency and State Gaming Agency and shall be
maintained and viewable both electronically and if requested, by printed report, upon
demand:
0.4.1 The Game Set and Game Subsets serial numbers;

0.4.2 The total number of Electronic Scratch Tickets unsold, if the Game is removed
from play;

0.4.3 The total number of Electronic Scratch Tickets purchased;

0.4.4 The time and date that each Subset was transmitted to the Central Computer;

0.4.5 The time and date that the game was completed or removed from play;

Squaxin Island Tribe –State of Washington Gaming Compact
Appendix X2 - Rules Governing Tribal Lottery Systems (Amended and Restated)
8
0.4.6 The final payout percentage of the game; and

0.4.7 Price per Ticket.

0.5 Software Auditing Tool to be Made Available.
For auditing Game Sets and Subsets that have been archived, any Tribal Lottery System
shall include and have available for the State Gaming Agency and the Tribal Gaming
Agency a secure software tool which provides the same data as set forth in Section 3.3
and 3.4, provided that such tool shall be used only during authorized audits of Tribal
Lottery System games and operations, or in cases of player disputes, and shall not be
used for any other purpose without the consent of the Tribal Gaming Agency and the
State Gaming Agency.

0.6

T
No Auditing of Game Sets While in Play; Dispute Process

0.6.1 No Audit of Set While in Play. In order to provide maximum game integrity, no
audit or other determination of the status of any Game Set or any Subset,

0.6.2
AF
including but not limited to a determination of the prizes won or prizes remaining
to be won, shall be conducted by anyone, including Tribal Gaming Agency and
State Gaming Agency personnel, while a Subset is in play without causing
termination of the entire Game Set from which the Subset was derived as
provided in Section 3.6.3.

Dispute Resolution: Impact on Game Set Play. In the event of a dispute by a
player that cannot be resolved by ordinary means by Gaming Facility personnel as
to the outcome, prize, wager made, or any other aspect of the player's

DR
participation in a Game Set being played, all relevant data shall be immediately
collected, including but not limited to all meter readings, memory records,
surveillance recordings, and any other reports or information regarding play at the
Terminal for the play in dispute. Following the collection of all relevant data, the
Tribal Gaming Agency shall be notified and requested to make an evaluation of
whether or not the dispute involves the integrity of the hardware or software being
used and to try and resolve the dispute. A report of all disputes shall be
maintained by the Tribal Gaming Agency. If the dispute is not resolved within
seventy-two (72) hours from the time of the complaint, the Tribal Gaming
Agency shall immediately forward a report to the State Gaming Agency detailing
the nature of the dispute. In the event the dispute is resolved, the Tribal Gaming
Agency is not obligated to report to the State Gaming Agency, but shall make
Tribal Gaming Agency reports available for review.

Squaxin Island Tribe –State of Washington Gaming Compact
Appendix X2 - Rules Governing Tribal Lottery Systems (Amended and Restated)
9
0.6.3 Termination of Game Set. Protection of game integrity, even if it requires the
early withdrawal of a Game Set from play, shall be the primary goal of this
Appendix. If resolution of a patron dispute requires access to data or records
stored on any part of a system other than the Player Terminal involved in the
dispute, and such access can only be accomplished through a means by which
data would be revealed that could materially assist anyone in determining the
likelihood of a particular ticket being drawn, other than information available to
all patrons, the Game Set shall be terminated prior to accessing such data or
records.

0.6.4 Tribal Gaming Agency /State Gaming Agency Disputes. In the event there is a
dispute between the Tribal Gaming Agency and State Gaming Agency at any
point in the above process, it shall be resolved in accordance with the dispute

0.7
T
resolution process for such issues set forth in the Compact.

Manufacturing Computer

0.7.1

AF
Security from Alteration, Tampering, or Unauthorized Access. The
Manufacturing Computer shall provide a physical and electronic means, by use of
a password or other method approved by the Tribal Gaming Agency and State
Gaming Agency, for securing the Game Set against alteration, tampering, or
unauthorized access. The Manufacturing Computer shall provide a means for
terminating the Game Set if unopened ticket information from an operating Game
Set or Subset has been accessed except as permitted in this Appendix. The
Gaming Test Laboratory shall certify that such security system, and a means for

DR 0.7.2
monitoring its use in accordance with this Appendix, is included in the system
before it may be authorized for use. Security systems and monitoring may be
required for any component that has electronic access to this system that may
violate the integrity and security of the manufacturing computer.

Primary Purpose; Separation. The Manufacturing Computer shall be dedicated
primarily to those Tribal Electronic Scratch Ticket gaming system functions
related to the creation of Scratch Ticket Game Sets and the creation,
randomization, and transmittal to the Central Computer of Scratch Ticket Subsets.
Notwithstanding the foregoing, the Manufacturing Computer may also be used for
other computer functions in the Tribal Lottery System or Electronic Accounting
System if such use will not affect the integrity or outcome of any game.

0.7.3 Storage Medium; Backup. The Manufacturing Computer shall have a medium for
securely storing Electronic Scratch Ticket Game Sets and Subsets on the
Manufacturing Computer which shall be mirrored on line by a backup medium

Squaxin Island Tribe –State of Washington Gaming Compact
Appendix X2 - Rules Governing Tribal Lottery Systems (Amended and Restated)
10
within the same cabinet or enclosure. In addition, duplicates of the Sets and
Subsets, as created and stored on the Manufacturing Computer, shall be stored in
a secure enclosure in the Gaming Facility separate from the Manufacturing
Computer. All storage shall be through an error checking, nonvolatile physical
medium, so that should the primary storage medium fail, there will be no critical
data loss.

0.7.4 Randomization. The Manufacturing Computer shall utilize randomizing
procedures in the creation of the Subsets. The randomizing procedures shall be in
accordance with Section 6 of this Appendix.

0.8 Central Computer Used in Connection With Electronic Scratch Ticket Game.
The following requirements apply to any Central Computer used in connection with an
Electronic Scratch Ticket Game.

0.8.1 T
Dispensing of Tickets. The Central Computer shall dispense, upon request from a
Player Terminal, Electronic Scratch Tickets.

0.8.2

AF
Order of Scratch Tickets. The Central Computer shall maintain Electronic Scratch
Ticket Subsets in the order received from the Manufacturing Computer, and
transmit them in that order to Player Terminals on demand, provided that not less
than two (2) nor more than five (5) Subsets per Game Set shall be dispensed in
accordance with a predetermined order for rotating the Subsets. Subsets from
more than one Game Set may be stored on the Central Computer and made
available for play at the same time.

DR
0.8.3

0.8.4
Storage Medium; Backup. The Central Computer shall have a medium for storing
Electronic Scratch Ticket Game Subsets and reflecting their current status of play,
which shall be mirrored on line by a backup medium within the same cabinet or
enclosure. All storage shall be through an error checking, nonvolatile physical
medium, so that should the primary storage medium fail, there will be no critical
data loss.

No Randomization Capability. The Central Computer shall have no
randomization capability associated with its use in an Electronic Scratch Ticket
game.

0.9 Player Terminals Used in Electronic Scratch Ticket Games.
Player Terminals used in connection with Electronic Scratch Ticket Games shall conform
to the requirements of Section 5.

Squaxin Island Tribe –State of Washington Gaming Compact
Appendix X2 - Rules Governing Tribal Lottery Systems (Amended and Restated)
11
3.10 Data Available for Inspection.
The following data is required to be available for inspection in compliance with Section
7.1.9 for any Player Terminal or Game Set:

3.10.1 All Game Set serial numbers, indicating the date and time the Game Set was put
in play, pulled from play, or completed.

3.10.2 By Game Set serial numbers, the Player Terminal numbers assigned, and the dates
and times of assignment to the Player Terminals.

SECTION 4. TRIBAL ON-LINE LOTTERY GAME SYSTEM

0.1 Description of System Operation. Tribal On-line Lottery Games shall be played in
accordance with the following provisions:

0.1.1 T
A player initiates participation in On-line Lottery Games at a Player Terminal,
using Game Play Credits through the insertion of cash or from the Cashless
Transaction System which are displayed on the Terminal video monitor. Play may

0.1.2
AF
also be initiated through a Player Terminal dedicated to On-line Lottery Games,
or a clerk-operated Player Terminal. References herein to player activity and
interaction with a Player Terminal in connection with an On-line Lottery Game
shall also mean activity and interaction by a clerk on behalf of a player.

The Player Terminal video monitor displays one or more of the On-line Lottery
games that are offered by the system, as well as other information such as
graphics, game play, and outcome information, and entertainment effects, subject

DR 0.1.3
to the limitation in Sections 5.2.2 and 5.2.3. The player chooses a particular game
by touching the screen, pressing a button, or performing some other form of
interaction with the Player Terminal.

Following or as part of the player’s choice of a game or games, the player selects
numbers, symbols or other data to be matched in the game by pressing buttons or
touching the video screen. The player may also make such selections through the
"quick pick" method. The player then uses Game Play Credits displayed on the
Terminal monitor to purchase one or more On-line Lottery Game Tickets
representing such selections, for drawings to be held in the future.

0.1.4 Each On-line Lottery Game may offer more than one method of winning a prize,
and each method may be represented by a separate wager. Appendix E Section
4.2 governs wagering limits, and such provisions are incorporated herein. Wagers
are deducted from the Game Play Credits displayed on the Player Terminal.

Squaxin Island Tribe –State of Washington Gaming Compact
Appendix X2 - Rules Governing Tribal Lottery Systems (Amended and Restated)
12
0.1.5 The player’s wager and selected numbers, symbols or other data to be matched in
the game, along with information identifying the drawing(s) to which they apply,
are provided to the player in some tangible means, such as by electronic encoding
or printing on a paper, card or other medium. In addition, the numbers, symbols or
other data selected may be displayed on the Player Terminal.

0.1.6 The player is then entered into one or more future On-line Lottery Games, which
are conducted through drawings held on the Central Computer.

0.1.7 All drawings for any game are conducted within a period of 5 minutes or less, and
all drawings for all games offered are held within that period. Drawings are held
on a regularly scheduled basis and regardless of whether any player is enrolled in
a particular On-line Lottery Game. Games take place no more frequently than

T
thirty minutes apart, determined by when the first drawing in a game occurs. No
more than five different On-line Lottery Games are offered at a time, unless the
State increases the number of On-line Lottery Games it is now playing, thereby
entitling the Tribe to increase the number of games it offers in accordance with

0.1.8
AF
the rules for doing so.

A Player Terminal may display a player’s entry into an On-line Lottery Game and
the commencement of that game. The form of displaying information may be
entertaining and at the discretion of the Tribe, except as limited in Sections 5.2.2
and 5.2.3. For example, the Terminal may alert the player through means of a
count-down that the drawing in which the player is entered is about to occur.
Information regarding prizes that may be awarded for each game are made

DR
0.1.9
available to the player prior to commencement of the game.

Following each drawing, the results are displayed and made available in
accordance with the rules set forth in Section 4.4. Players win if their selections
match a required number of drawn numbers or symbols, in accordance with the
predetermined and published rules for that particular game. Results and prizes are
verified in accordance with the rules set forth in Section 4.4, and are paid in Game
Play Credits except where, due to the size of the prize, the rules specify some
other method of payment. Prizes may also be awarded in the form of merchandise
or other valuable property.

0.1.10 Game Play Credits earned as prizes remain displayed and available for use in
further play from that Terminal. Game Play Credits also may be electronically
transferred through the Cashless Transaction System, such as to a) a player’s
account in the Cashless Transaction System, b) a ticket or receipt printed by the
Player Terminal, or c) a "smart" card or similar instrument. Once transferred,

Squaxin Island Tribe –State of Washington Gaming Compact
Appendix X2 - Rules Governing Tribal Lottery Systems (Amended and Restated)
13
Game Play Credits may be a) used for further play on another Terminal or b)
redeemed for cash or cash equivalents through a cashier or other separate
redemption system. Merchandise or other property won is collected in accordance
with the rules of the game.

0.2 Central Computer Used for On-line Lottery Game. The following requirements apply to
any Central Computer used in connection with an On-line Lottery Game.

0.2.1 Introduction. A Central Computer may, in addition to being available for use in
connection with Electronic Scratch Ticket Games, be utilized in the On-line
Lottery Game. The rules in this Section 4.2 govern that activity.

0.2.2 Randomization Capability. The Central Computer shall have randomization

T
capability associated with its use in an On-line Lottery Game only. All drawings
shall be on a random basis, using the randomization requirements set forth in
Section 6.

0.2.3

0.2.4
AF
Independent Drawings; Schedule of Drawings. Drawings on the Central
Computer shall occur independently of any Player Terminal activity and
regardless of whether or not players are enrolled in a game. On-line Lottery Game
drawings shall be held on a regularly scheduled basis in intervals of no less than
30 minutes. Once a drawing period begins, all drawings during that period must
be drawn within 5 minutes. Each drawing shall have its own identifying serial
number.

Limit on Number of On-line Lottery Games. The Tribe may have no more than

DR
0.3
five (5) On-line Lottery Games in play at one time. Such games may be offered
on more than one system within the facility. The number of games offered may be
increased if, and by the same number, the State Lottery increases the number of
On-line Lottery Games it offers.

Player Terminals Used for On-line Games. Player Terminals used in connection with On-
line Lottery Games shall conform to the requirements of Section 5. The following
provisions shall also be applicable:

0.3.1 A Player Terminal may, in addition to being available for use in connection with
Electronic Scratch Ticket Games, be used to play On-line Lottery Games. The
On-line Lottery Game may also be played from a Player Terminal dedicated to
selling On-line lottery tickets or by a clerk operating a Player Terminal for such
purposes. References to Player Terminals herein shall include such dedicated and
clerk-operated Terminals.

Squaxin Island Tribe –State of Washington Gaming Compact
Appendix X2 - Rules Governing Tribal Lottery Systems (Amended and Restated)
14
0.3.2 The Player Terminal shall enable a player to select numbers, symbols or other
data, through touching the screen or pressing one or more buttons on the
Terminal. The player may also ask for a "quick pick" selection via the use of a
random number generator located in the Player Terminal and used solely for the
On-line Lottery Games, provided that such random number generator shall meet
the criteria set forth in Section 6.

0.3.3 The player's wager and selected numbers, symbols or other data, along with
information identifying the drawing(s) to which they apply, shall be provided to
the player through the Player Terminal in some tangible means using electronic
encoding or printing on paper, card or other medium. Such information may also
be displayed on the screen for review by the player.

0.4

T
Verification and Viewing Requirements for On-line Game Results. The results of each
On-line drawing on a Central Computer shall be available for display on a Player
Terminal on demand by players enrolled in such games, and may be made available on
one or more scoreboards, video screens or other electronic display devices sufficiently

0.5
AF
visible to enable players and other observers, including those not at Player Terminals, to
view the outcome of the game. Printed result reports shall be made available in
accordance with Section 4.5.

On-line Lottery Game Records. The following records with respect to each On-line
Lottery Game shall be maintained and be viewable both electronically and, if requested,
by printed report, upon demand: The outcome of each drawing including all numbers
drawn, the sequence of drawing, prizes available, prizes won (whether or not redeemed),

DR
0.6

0.7
and related information. Such reports shall be made available in the casino for player
reference for up to 30 days following the close of any drawing period.

Redemption Period. Prizes may be redeemed by players for a period of no less than 48
hours following the drawing in any On-line Lottery Game.

Other Game Rules. The specific rules and prize structures for each On-line Lottery Game
may vary, and shall be made available to players prior to making any wagers on that
game. The rules shall indicate when, in relation to the commencement of the first drawing
in a game, no further wagers on that game may be made. Each On-line Lottery Game
may offer more than one method of winning a prize, and each method may be represented
by a separate wager, but each wager may not exceed the amounts set forth in Section
4.1.4.

0.8 Prizes; Jackpots. Every On-line Lottery Game must have at least one "jackpot" level prize
paid, when won, from a lottery prize pool into which a percentage of each player’s

Squaxin Island Tribe –State of Washington Gaming Compact
Appendix X2 - Rules Governing Tribal Lottery Systems (Amended and Restated)
15
wagers, as set forth in the rules for that game, is placed and in which the Tribe shall have
no interest. The prize pool may be seeded from time to time by promotional payments or
interest-free loans from the Tribe. Jackpot prizes not won in a particular game shall be
rolled forward into a future game in accordance with rules for disposing of such prizes.
Rollover funds may replace the need for seeding a pool if the amount of such rollover
funds exceeds the minimum prize available under the rules of that game. The player pool
fund may not be used for any purpose other than payment of the jackpot prize.

SECTION 5. PLAYER TERMINALS

All Player Terminals shall conform at a minimum to the requirements of this Section 5.

0.1 Use as a Stand-Alone Gambling Device Prohibited. No Player Terminal shall be capable

T
of being used as a stand-alone unit for the purposes of engaging in any gambling game,
including but not limited to the lottery games described in this Compact, or in any other
way prohibited in this Appendix.

0.2

AF
Features. Player Terminals shall include the following features:

0.2.1

0.2.2
Operation either through the Cashless Transaction System, or through means for
accepting cash (coins, tokens or paper currency) for conversion into Game Play
Credits, which can then activate participation in the game, provided the insertion
of cash will not alone activate the game and such use of cash is in accordance
with section 5.15;

One or more of the following: A video monitor, electro-mechanical display,

DR
0.3
0.2.3
printer, graphics and signage, provided that slot machine-type spinning reel
mechanisms are prohibited in mechanical form; and

One or more of the following: electronic buttons, touch screen capability, and a
mechanical, electro-mechanical or electronic means of activating the game and
providing player input, including a means for making player selections and
choices in games, provided that slot machine-type handles are prohibited.

Non-Volatile Backup Memory Required. A non-volatile backup memory or its equivalent
shall be maintained in a secure compartment on each Player Terminal for the purpose of
storing and preserving a redundant set of critical data which has been error checked in
accordance with this Appendix, and which data shall include, at a minimum, the
following Player Terminal information:

0.3.1 Electronic Meters required by this Appendix;

Squaxin Island Tribe –State of Washington Gaming Compact
Appendix X2 - Rules Governing Tribal Lottery Systems (Amended and Restated)
16
0.3.2 Recall of all wagers and other information associated with the last ten (10)
Electronic Scratch Ticket plays and the last ten (10) On-line Lottery Games
played;

0.3.3 Error conditions that may have occurred on the Player Terminal; and

5.3.4 Recall of the last twenty (20) cash or cash equivalent deposits, with metering in
the game of all funds deposits.

0.4 On/Off Switch. An on/off switch that controls the electrical current that supplies power to
the Player Terminal must be located in a secure place that is readily accessible within the
interior of the Player Terminal.

0.5

0.6
T
Static Discharge/Interference. The operation of each Player Terminal must not be
adversely compromised or affected by static discharge, liquid spills, or electromagnetic
interference.

Accounting Meters. A Player Terminal must have electronic accounting meters which

AF
have tally totals to a minimum of eight (8) digits and be capable of rolling over when the
maximum value of at least 99,999,999 is reached. The Player Terminal must provide a
means for on-demand display of the electronic meters via a key switch or other secure
method on the exterior of the machine. Electronic meters on each Player Terminal for
each of the following data categories for Electronic Scratch Ticket games and On-line
Lottery Games are required in compliance with Section 7.1.9:

0.6.1 Credits, promotions, or equivalent monetary units, wagered on a cumulative basis

DR
0.6.2

0.6.3

0.6.4
on that Terminal;

Credits, or equivalent monetary units, won for the Player Terminal;

For Scratch Ticket games, the number of Scratch Tickets purchased on the
Terminal; and

For On-line Lottery games, the number of On-line Lottery wagers made on that
Terminal.

5.6.5 Promotions downloaded to the Player Terminal will be shown separately on meter
reports, including any promotions balance returned to a player’s account in the
Promotion Tracking System.

5.7 No Automatic Clearing of Accounting Meters; Reading and Resetting Meters. Under no
circumstances shall the Player Terminal electronic accounting meters be capable of being
automatically reset or cleared, whether due to an error in any aspect of its or a game's
Squaxin Island Tribe –State of Washington Gaming Compact
Appendix X2 - Rules Governing Tribal Lottery Systems (Amended and Restated)
17
operation or otherwise. All meter readings must be recorded and dated in the presence of
a Tribal Gaming Agency inspector both before and after an electronic accounting meter is
cleared.

0.8 Display of Information. At a minimum, each Player Terminal shall have the following
game information available for display on the video screen and/or displayed on the Player
Terminal itself, in a location conspicuous to the player:

0.8.1 The rules of the game being played;

0.8.2 The maximum and minimum wagers and the amount of credits, cash equivalents,
or additional game play opportunities, which may be won for each Electronic
Scratch Ticket and On-line Lottery Game offered through that Terminal,

0.8.3

0.8.4
T
including the current values of any progressive prizes available;

The player's credit balance;

The outcome of the Electronic Scratch Ticket(s) then being played; and

0.9
0.8.5

AF
Any prize won on the Electronic Scratch Ticket(s) then being played.

Protection of Displayed Information. The video screen or other means for displaying
game rules, outcomes and other game information shall be kept under a glass or other
transparent substance which places a barrier between the player and the actual surface of
the display. At no time may stickers or other removable media be placed on the Player
Terminal's face for purposes of displaying rules or payouts.

D
0.10

R
0.11
Hardware Switches Prohibited. No hardware switches may be installed on a Player
Terminal or any associated equipment which may affect the outcome or pay out of any
game for which the Player Terminal is used. Switches may be installed to control the
ergonomics of the Player Terminal.

Networking Requirements. The use of firewalls and other system protections as approved
by Tribal Gaming Agency and State Gaming Agency are required to protect the integrity
of the Tribal Lottery System and player accounts and:

5.11.1 Where the Tribe’s Tribal Lottery System or components are linked with one
another in a local network for progressive jackpot, function sharing, aggregate
prizes or other purposes, communication protocols must be used which ensure
that erroneous data or signals will not adversely affect the operations of any such
system or components. No class III game or gaming system in which any part or
component is located outside the Tribe’s gaming facilities shall be deemed

Squaxin Island Tribe –State of Washington Gaming Compact
Appendix X2 - Rules Governing Tribal Lottery Systems (Amended and Restated)
18
approved as part of the approval of this Appendix. Any proposal for such game or
gaming system, including the proposed rules, manner of regulation, and manner
of play, monitoring and/or maintenance of the system, shall require submission to,
and approval by, the Tribal Gaming Agency and State Gaming Agency.

5.11.2 Dedicated and protected network connections prohibiting unauthorized access,
approved by State Gaming Agency and Tribal Gaming Agency, may allow two or
more of the Tribe’s Tribal Lottery Systems to share player information. Game
tickets and other information prohibited from being viewed, as outlined in other
sections of this Appendix, shall not be available or transmitted between the
Tribe’s connected Tribal Lottery Systems or facilities. Communications between
the Tribe’s facilities will require the use of approved firewalls that are configured
and operated to protect the Tribal Lottery System and player information.

0.12
T
Computer systems linked between the Tribe’s facilities may not be used to link
progressive jackpots, except in Joined Facilities.

Prohibited Software Functions. Player Terminals shall not have software or hardware that

AF
determines the outcome of any Electronic Scratch Ticket Game. Nothing herein is
intended to prohibit the Player Terminal from creating the appropriate Scratch Ticket and
On-line Game graphics and animation to correspond to, display or represent, in an
entertaining manner, the outcome. In addition, Player Terminals shall not have any
software that:

0.12.1 Determines which Scratch Ticket outcome from within the Scratch Ticket Subset
is transmitted to the Player Terminal; or

DR
0.13

0.14
0.12.2 Alters the amount of the payout of the Electronic Scratch Ticket as received from
the Central Computer.

Quick-Pick Function. Nothing herein shall prohibit the use of a quick pick function on
the Player Terminal in conjunction with the playing of the On-line Lottery Game.

Wagers; Displaying Electronic Scratch Ticket Outcomes. Players shall make wagers
using a Player Terminal to purchase Electronic Scratch Tickets. Following a purchase,
the Electronic Scratch Ticket shall be displayed on the Terminal's video screen for the
purpose of revealing the outcome of the selected ticket.

0.15 Cash Standards. When cash is used, the following procedures shall be performed by
accounting/auditing employees who are independent of the transactions being reviewed:

5.15.1 For each drop period, accounting/auditing employees shall compare the report
information required in Section 7.1.10 (a) to the total cash acceptor drop amount

Squaxin Island Tribe –State of Washington Gaming Compact
Appendix X2 - Rules Governing Tribal Lottery Systems (Amended and Restated)
19
for the period. Discrepancies shall be resolved before the generation/distribution
of any statistical reports.

5.15.2 Tribal Gaming Agency will be notified and follow-up shall be performed for any
one machine having an unresolved variance between actual cash drop and the
report information required in Section 7.1.10 (a) in excess of an amount that is
both more than twenty-five dollars ($25) and at least three percent (3%) of the
actual cash drop. The follow-up performed and results of the investigation shall
be documented and maintained for inspection.

5.15.3 At least annually, accounting/auditing and Tribal Gaming Agency personnel shall
randomly verify that EPROM or other equivalent game software media changes
are properly reflected in the analysis reports.

T
5.15.4 Accounting/auditing employees shall review exception reports on a daily basis for
propriety of transactions and unusual occurrences. Tribal Gaming Agency will be
notified in writing of any unexplained or suspicious transactions or unusual

AF
occurrences.

5.15.5 All auditing procedures and any follow-up performed shall be documented and
maintained for inspection.

5.15.6 Cash shall be removed from the Player Terminal in accordance with Appendix A
drop box and transportation standards for secure and verifiable handling of cash
receipts from electronic games.

D
0.16

R
Door Access Logging. The Player Terminal shall record the date and time of any opening
of cabinet door(s); provided, that this information need not be retained on the Player
Terminal if it is communicated to another component of the system. This information
shall be retrievable in report form.

SECTION 6. STANDARDS FOR RANDOM NUMBER GENERATORS USED WITHIN
THE TRIBAL LOTTERY SYSTEM

Any random number generation used in connection with the Tribal Lottery System must be by
use of a microprocessor and random number generation program that meets the following
random selection tests:

0.1 Chi-Square Analysis. Each card, symbol, number, or stop position which is wholly or
partially determinative of the outcome of the game satisfies the 99 percent confidence
limit using the standard chi-square analysis.

Squaxin Island Tribe –State of Washington Gaming Compact
Appendix X2 - Rules Governing Tribal Lottery Systems (Amended and Restated)
20
0.2 Runs Test. Each card, symbol, number, or stop position does not as a significant statistic
produce predictable patterns of game elements or occurrences. Each card symbol,
number, or stop position will be considered random if it meets the ninety-nine percent
(99%) confidence level with regard to the "runs test" or any generally accepted pattern
testing statistic.

0.3 Correlation Analysis. Each card, symbol, number, or stop position is independently
chosen without regard to any other card, symbol, number or stop position, drawn within
that game play. Each card, symbol, number, or stop position is considered random if it
meets the 99 percent confidence level using standard correlation analysis.

0.4 Serial Correlation Analysis. Each card, symbol, number, or stop position is independently
chosen without reference to the same card, number, or stop position in the previous game.

T
Each card, number, or stop position is considered random if it meets the ninety-nine
percent (99%) confidence level using standard serial correlation analysis.

SECTION 7. ELECTRONIC ACCOUNTING SYSTEM

AF
One or more Electronic Accounting Systems shall be required to perform reporting and other
functions in support of the Tribal Lottery Game activities described in this Appendix. These
systems may communicate with the other computers described in this document utilizing the
protocol standards set forth in Section 9.3. The Electronic Accounting System shall not interfere
with the outcome of any gaming functions.

0.1 Revenue Reporting Requirements. The following reporting capabilities must be provided
by the Electronic Accounting System:

DR
0.1.1 Player Terminal Revenue Report. A revenue report for each Player Terminal must
be made and maintained on a confidential and secure basis which, at a minimum
on a daily and monthly basis, provides:

(a) The total aggregate amount won per Player Terminal;

(b) The aggregate amount wagered per Player Terminal; and

7.1.2 Closed Game Set Reports. Immediately after a Game Set is completed or pulled
from play, a report will provide the Game Set ending information described in
Section 3.4 above.

Squaxin Island Tribe –State of Washington Gaming Compact
Appendix X2 - Rules Governing Tribal Lottery Systems (Amended and Restated)
21
7.1.3 In Play Game Set Reports. One or more reports will be available for Game Sets
still in play, containing the information described in Sections 3.3.1 through 3.3.7
above.

0.1.4 On-line Lottery Game Reports. An On-line Lottery Game report must be made
and maintained on a confidential and secure basis which, at a minimum of a daily
and monthly basis, provides as to each On-line Lottery Game, the following
information:

(a) Total sales;

(b) Total won per prize level;

T
(c) Total won per Player Terminal; and

(d) Activity per jackpot prize, for the accounting period and to-date, per Section
7.1.5.

0.1.5

AF
Progressive Jackpot Report. A progressive jackpot report must be made for the
accounting period and to-date which provides:

(a) Amount seeded;

(b) Amount in reserve fund;

DR 7.1.6
(d) Contribution total;

(e) Total paid in prizes;

(f) Itemized jackpot awards; and

(g) Amount, time of award, and the Player Terminal on which the progressive
jackpot prize was won.

Larger Prize Report. A report will be required for all prizes that exceed the
threshold that triggers additional procedures to be followed for the purposes of
compliance with federal tax reporting requirements. At a minimum, on a daily and
monthly basis, the report shall provide the following information per Player
Terminal:

(a) The date and time won; and

Squaxin Island Tribe –State of Washington Gaming Compact
Appendix X2 - Rules Governing Tribal Lottery Systems (Amended and Restated)
22
(b) Amount of all prizes.

0.1.7 Liability Reports. Liability reports will be required on a daily and monthly basis
at a minimum. They should provide a summary of the outstanding funds which
carry from business day to business day. At a minimum, they must include:

(a) Amount of prizes which were awarded, but have not yet been claimed;

(b) Detail of prizes for which redemption period expired during this reporting
period;

(d) Expired Game Play Credits; and

T
(e) Daily and cumulative contributions to progressive prize pools which have not
yet been awarded.

0.1.8

AF
Master Reconciliation Report. A master reconciliation report must be available on
a daily and monthly basis, at a minimum. This report may be provided as one
single report, or as two or more individual reports. It provides a summary of all
daily sources of funds and disposition of funds, including the following:

(a) Funds collected from cashiers, Player Terminals, and Kiosks;

(b) Funds carried forward from prior business day, including liability from prizes
awarded, but not paid out, prize pool balances, and reserve funds, etc.;

DR
(c) Payments to players;

(d) Funds available to operator; and

(e) Tickets and prizes dispensed and played to reconcile with amount won.

0.1.9. Data Retention Requirements. Data necessary to audit compliance with the
standards set forth in this Appendix shall be maintained for a minimum of two (2)
years, and in connection with determining randomness where applicable, for a
minimum of six (6) months. To the extent not inconsistent with the foregoing,
data shall be retained and backed up by the Electronic Accounting System
according to the following minimum requirements:

(a) Accounting records;

Squaxin Island Tribe –State of Washington Gaming Compact
Appendix X2 - Rules Governing Tribal Lottery Systems (Amended and Restated)
23
(b) Per Player Terminal, Cashier Terminal, or other points of cash exchange-daily
records and meters: on-line for six (6) months;

(d) Game Set Records, as to each Player Terminal and by Game Set;

(e) The amount wagered and the amount won, daily by prize level, on line: six (6)
months;

(f) The amount wagered and the amount won, daily by prize level, off line: six
(6) months;

(g) On-line prize redemptions: thirty (30) days;

T
(h) Dated cash vouchers: thirty (30) days;

(i) Cash vouchers cancelled by Player Terminal, in physical form or as retained

AF
by the Electronic Accounting System and backed up as required by this
Appendix: seven (7) days;

(j) Cash vouchers redeemed by cashiers or redeemed at Kiosks, in physical form
or as retained by the Electronic Accounting System and backed up as required
by this Appendix: thirty (30) days;

(k) Log files that track password access to sensitive components: online for ninety
(90) days, offline for twelve (12) months; and

DR
(l) Log files that track system events or errors: ninety (90) days.

7.1.10 Reports. Revenue reports for the Tribal Lottery System must be made and
maintained on a confidential and secure basis which, at a minimum on a daily and
monthly basis, provides the amount of cash removed or dropped from Player
Terminals.

SECTION 8. CASHLESS TRANSACTION SYSTEM SECURITY, REPORTING AND
STORAGE REQUIREMENTS

0.1 Player Information. The following requirements shall be met in connection with any
Cashless Transaction System:

0.1.1 All player information must be stored on at least two separate non-volatile media;

Squaxin Island Tribe –State of Washington Gaming Compact
Appendix X2 - Rules Governing Tribal Lottery Systems (Amended and Restated)
24
0.1.2 An audit file must be kept of all player financial transactions. This file must be
stored in at least two separate non-volatile media, and be accessible for purposes
of audit and dispute resolution to authorized individuals; this file must be
available on-line for a minimum of thirty (30) days, after which it must be
available off-line for a minimum of one hundred eighty (180) days;

0.1.3 Physical and operational controls must be used to protect player information from
tampering or unauthorized access;

0.1.4 Passwords or personal identification numbers (“PINs”), if used, must be protected
from unauthorized access;

0.1.5 All means for communicating information within the system shall conform to the

0.1.6 T
protocol standards set forth in Section 9.3;

All player information shall be accurately recorded and such recording protected
by the system;

0.1.7

0.1.8
AF
Any card or other tangible instrument issued to a player for the purpose of using
the Cashless Transaction System shall bear on its face a control or inventory
number unique to that instrument;

Encoded bearer instruments printed or magnetic may include coupons and other
items distributed or sold for game play, promotional, advertising or other
purposes, but may not include cash. Such coupons may be transferred
electronically. Printed or magnetic instruments must be in electronically readable

DR
form in addition to having unique identification information printed on the
instrument face. The daily and monthly reporting must include with respect to
such instruments:

(a) Cash converted to value in the cashless system;

(b) Outstanding unredeemed balance;

(d) Amount wagered; and

(e) Amount won.

0.1.9 Redemption periods, if any, shall be posted or otherwise disclosed to all players.

Squaxin Island Tribe –State of Washington Gaming Compact
Appendix X2 - Rules Governing Tribal Lottery Systems (Amended and Restated)
25
8.1.10 Vouchers must bear on the face, in addition to the unique serial number, the
following:

a. Time/Date printed;

b. Unique identification from which it was printed; and

c. Value of voucher.

0.2 Smart Cards. Any "smart card" (i.e., a card generally made of plastic with a computer
chip imbedded in it) system which the Tribe intends to implement as part of the Cashless
Transaction System shall be tested by the Gaming Test Laboratory to ensure the integrity
of player funds, following the standards applicable to player information set forth in

T
Section 8.1. Any smart card must store on the card or on the system using the card an
audit trail of the last ten (10) transactions involving the use of the card. Each transaction
record must include, at a minimum, the type of transaction, the amount of the transaction,
the date of the transaction, the time of the transaction, and the identification of the Player

AF
Terminal or cashier terminal or other points of cash exchange where the transaction
occurred. The minimum daily and monthly reporting for smart card activity must include:

0.2.1

0.2.2

0.2.3

0.2.4
Total of cash transferred to smart cards;

Total of smart card amounts transferred to cash;

Total of smart card amounts transferred to Game Play Credits;

Total of Game Play Credits transferred to smart card amounts; and

DR
0.3
0.2.5 Total unredeemed smart card balance.

Other Functions. Systems shall be permissible that allow player tracking, maintenance
tracking, and other gaming management or marketing functions. These systems shall not
interfere with, or in any way affect, the outcome of any Tribal Lottery Game or the
cashless accounting system. Systems shall be permissible that allow progressive prize
management with the certification of the Gaming Test Laboratory and approval of the
State Gaming Agency.

8.4 Kiosks. Kiosks shall have reports that properly document all transactions, as well as
dedicated video surveillance, to protect the integrity of the cashless system used. Cash
boxes shall be designed so their contents are protected from unauthorized access, in
accordance with the sections below:

Squaxin Island Tribe –State of Washington Gaming Compact
Appendix X2 - Rules Governing Tribal Lottery Systems (Amended and Restated)
26
8.4.1 Currency Exchange Terminal (CET). Cash boxes shall be designed so their
contents are protected from unauthorized access, in accordance with Appendix A
drop box and transportation standards and shall be uniquely labeled for the
purpose of audit and security.

8.4.2 Ticket Redemption Kiosk (TRK) and Manned Kiosk. Cash boxes and cash
drawers shall be designed so their contents are protected from unauthorized
access, in accordance with Appendix A cashier cage accounting controls, and
shall be uniquely labeled for the purpose of audit and security.

SECTION 9. GENERAL SECURITY REQUIREMENTS

The following requirements apply to all components of the Tribal Lottery System, including the

T
Manufacturing Computer, the Central Computer, the Electronic Accounting System and Player
Terminals.

0.1 Separation. The Manufacturing Computer, Central Computer, and Player Terminals in

AF
each Tribal Lottery System shall be physically and operationally independent from one
another except as specified otherwise in this Appendix, such as for communications,
storage and security monitoring, including the routing of communications among system
components, provided such routing does not affect the integrity of the communications or
the outcome of any game. All Tribal Lottery System cables shall be secured against
unauthorized access.

An operationally independent Manufacturing Computer Virtual Machine and an
operationally independent Central Computer Virtual Machine are considered separate.

DR
0.2
Operationally independent Virtual Machines may be located on the same physical
hardware without physical separation of the Virtual Machines. These Manufacturing
Computer and Central Computer Virtual Machines shall not reside inside a player
terminal. Virtual Machines for this Alternative Standard only apply to the Manufacturing
Computer and Central Computer. All Virtual Machines and physical combinations shall
be clearly diagrammed and approved by the State as defined in Section 10.

Security. The Manufacturing Computer and Central Computer must be in a locked,
secure enclosure with both camera coverage and key controls in place. Routers, switches,
hubs, or other network access points, to include management terminals and terminals not
separated from the Tribal Lottery System by firewalls approved by the State Gaming
Agency and Tribal Gaming Agency, must also be in a locked, secure enclosure with both
camera coverage and key controls in place. Access to Manufacturing Computers and
Central Computers shall be logged by the system to include the date and time of access
and available to State Gaming Agency and Tribal Gaming Agency upon request.

Squaxin Island Tribe –State of Washington Gaming Compact
Appendix X2 - Rules Governing Tribal Lottery Systems (Amended and Restated)
27
0.3 Secure Connections; DES or Equivalent Data Encryption. Connections between all
components of the Tribal Lottery System shall only be through the use of secure
communication protocols which are designed to prevent unauthorized access or
tampering, employing Data Encryption Standards (“DES”) or equivalent encryption with
changeable seeds or algorithms. Communications relating to promotions that do not serve
any direct gambling function do not require encryption if they do not interfere with or in
any way affect functions of the Tribal Lottery System.

0.4 Surge Protection; Uninterrupted Power System (“UPS”). Each component of the Tribal
Lottery System shall at all times be connected to a device which provides surge
protection on any line that feeds it and, with the exception of Player Terminals, shall be
connected to a temporary power source, such as a UPS, to provide means for an orderly
shutdown of the computer in the event of a main power system failure.

0.5
T
Identification Plates. A non-removable plate shall be affixed to the exterior of each Player
Terminal which shall have written upon it the Terminal's serial number and model
number of the component and name of the manufacturer. Other audit numbers may be

0.6
AF
required to be affixed to provide a means of identifying individual Terminals for
correlation to required reports.

Locked Areas. The Manufacturing and Central Computers shall at a minimum be
enclosed in a locked and monitored cabinet. Access shall be through the use of access
controls provided in Section 9.7. The Player Terminal shall have at a minimum the
following separately locked areas, which shall be the only means of accessing any non-
public part of the Terminal: (a) a locked and monitored cabinet door; (b) a locked

DR
0.7
compartment for removable media; (c) a locked outer cash box door; and (d) a locked
drop cash box door. A player terminal shall have an enclosed microprocessor
compartment, but would not require a separate lock.

Access Control Standards. Keys which provide access to any locked compartment,
component or area of a Tribal Lottery System, as well as passwords, keycards, or PIN
numbers used to access the Tribal Lottery System, shall be maintained and used in
accordance with the access control standards enacted in the Tribe's statement of
minimum internal controls.

9.7.1 Each employee accessing the Tribal Lottery System software except for Player
Terminals and unattended Kiosks by means of a password, keycard, or PIN
number, including vendor representatives, must have a user name or user number
unique to that individual, and the Tribal Lottery System must log the date and
time of access. These access logs must be readily available for audit by Tribal
Gaming Agency and State Gaming Agency.

Squaxin Island Tribe –State of Washington Gaming Compact
Appendix X2 - Rules Governing Tribal Lottery Systems (Amended and Restated)
28
0.8 MEAL Cards. For all entries into the locked areas of the Manufacturing Computer,
Central Computer, unattended Kiosks, or any Player Terminal, a written record must be
made on a machine entry authorization log (“MEAL”) indicating at least the following:
the time, date, and purpose of entering said locked area(s), and the name and employee
number (or other personal identification specific to such person) of the person doing so.

9.8.1. Third Party System electronic MEAL Card reports may be substituted for TLS
System MEAL cards under the following conditions:

(a) TLS System MEAL Card information can only be transferred to a third-
party system through a firewall approved by the State Gaming Agency.

(b) System generated reports used to substitute for MEAL cards must clearly

T
indicate the time, date, purpose of entering locked area(s), and the name
and employee number (or other personal identification specific to such
person) of the person doing so for each instance of access.

(c)

(d) AFComputer applications that provide the system generated reports
substituting for MEAL cards must prevent alteration of the data required
by (a) above.

Data used for system generated reports allowed in this section must be
retained for a period of time consistent with Compact Appendix A
provisions on document retention and agreed to in the Tribe's approved
system of internal controls.

DR
(e)

(f)

(g)
System generated reports allowed in this section must be backed up to
allow recovery of the information should the system generated report or
data become corrupted or unavailable due to a system malfunction or
crash.

System generated report backups must be retained for six (6) months.

Written MEAL cards must be substituted for system generated reports
when there is a system crash or malfunction that prevents or delays the use
of system generated reports allowed in this section 9.8.1.

0.9 Access Control. In addition to maintenance of MEAL cards, the Manufacturing
Computer, Central Computer, and Virtual Environment as described in Section 2.16 and
Section 2.17 shall record and generate a report on any access including date, time of
access, and person (by employee number) accessing the computer.

Squaxin Island Tribe –State of Washington Gaming Compact
Appendix X2 - Rules Governing Tribal Lottery Systems (Amended and Restated)
29
0.10 Cameras. For purposes of this section, all components of the Tribal Lottery System,
except wiring, cables, and conduit in which they are located, shall have the ability to be
effectively and clandestinely monitored and recorded by means of a closed circuit
television system or digital surveillance system in accordance with Appendix A and as
authorized by Tribal Gaming Agency and State Gaming Agency, in compliance with the
requirements of the Compact.

0.11 Verification Data and Functions. In addition to its functions in operating a connection
with the Electronic Scratch Ticket and On-line Lottery Games, the Central Computer
may be used to record the data used to verify game play and to configure and perform
security checks on Player Terminals, provided such functions do not affect the security,
integrity or outcome of such games.

0.1
SECTION 10.

T
TESTING OF TRIBAL LOTTERY SYSTEMS TO ENSURE
INTEGRITY

Designation of Independent Gaming Test Laboratory. The Tribe shall select one or more

AF
gaming test laboratories (hereinafter "Gaming Test Laboratory") to perform the testing
required in this Appendix. Any Gaming Test Laboratory selected shall have demonstrated
it is competent and qualified to conduct scientific tests and evaluations of electronic
gaming systems and to otherwise perform the functions set forth in this Compact, and
shall be licensed by the State Gaming Agency. The State Gaming Agency shall maintain
a list of approved Gaming Test Laboratories. A Tribe may request additional laboratories
be placed on the State Gaming Agency 's list of Gaming Test Laboratories which request
shall not be reasonably withheld. Any laboratory that is currently licensed and approved

DR
by any state, province or country to test or evaluate electronic gaming devices or systems
shall be placed on the list if after review by the State Gaming Agency it is found to be so
qualified and otherwise meets the background and licensing requirements applicable to
such laboratories under Washington State Law. For any testing required under this
Appendix, the Tribe shall choose a laboratory from those Gaming Test Laboratories on
said State Gaming Agency list. If, at any time, any of the Gaming Test Laboratory's
licenses from any jurisdiction are suspended, terminated or subject to disciplinary
actions, the Gaming Test Laboratories may be removed from the State Gaming Agency’s
list. If removed from the State Gaming Agency list, the Tribe shall choose a new Gaming
Test Laboratory as provided herein.

0.2 Testing and Certification of Tribal Lottery Systems. No Tribal Lottery System or
component thereof may be offered for play unless:

Squaxin Island Tribe –State of Washington Gaming Compact
Appendix X2 - Rules Governing Tribal Lottery Systems (Amended and Restated)
30
0.2.1 Such Tribal Lottery System is approved by the State Gaming Agency as provided
in Section 10.3;

0.2.2 The Tribal Lottery System or component prototype thereof, has been tested and
certified by the Gaming Test Laboratory as meeting the requirements specified by
this Appendix;

0.2.3 If not already provided to the Gaming Test Laboratory, the Tribe shall provide, or
require that the manufacturer provide to the Gaming Test Laboratory and the State
Gaming Agency two (2) copies of Tribal Lottery System illustrations, schematics,
block diagrams, circuit analyses, technical and operation manuals, program object
and source codes, hexadecimal dumps (the compiled computer program
represented in base 16 format), and any other information requested by the

0.2.4 T
Gaming Test Laboratory or State Gaming Agency;

If requested by the Gaming Test Laboratory or State Gaming Agency, the Tribe
shall require the Manufacturer to transport working models of the Tribal Lottery

AF
System to a location designated by the Gaming Test Laboratory or State Gaming
Agency for testing, examination or analysis. Neither the State nor the Gaming
Test Laboratory shall be liable for any costs associated with the transportation,
testing, examination, or analysis, including any damage to the components of the
Tribal Lottery System. If requested by the Gaming Test Laboratory or State
Gaming Agency, the Tribe shall require the Manufacturer to provide specialized
equipment or the services of an independent technical expert to assist with the
testing, examination and analysis. For purpose of continued monitoring, the State

DR 0.2.5
Gaming Agency may retain working models of any Tribal Lottery System or
component after approval for as long as the equipment is in play in the state;

At the conclusion of each test, the Gaming Test Laboratory shall provide to the
State Gaming Agency and the Tribal Gaming Agency a report that contains
findings, conclusions and a certification that the Tribal Lottery System conforms
or fails to conform to the requirements contained in this Compact. If the Gaming
Test Laboratory determines that the device fails to conform to such requirements
or technical standards, and if modifications can be made which would bring the
Tribal Lottery System into compliance, the report may contain recommendations
for such modifications. The State is not bound by the findings, conclusions or
certifications of the Gaming Test Laboratory for purposes of its enforcement of
the provisions of this Compact and may perform further testing on the system or
components to verify compliance;

Squaxin Island Tribe –State of Washington Gaming Compact
Appendix X2 - Rules Governing Tribal Lottery Systems (Amended and Restated)
31
0.3 Approval by the State Gaming Agency. Upon receiving the certification from the test
laboratory, the State Gaming Agency shall either approve or disapprove the Tribal
Lottery System or component thereof based on the technical criteria contained in this
Appendix, within sixty (60) days of receipt of the certification as to any new Tribal
Lottery System or any component thereof, and within fifteen (15) days of the receipt of
the certification as to any modification of a system which has already been approved by
the State Gaming Agency. The certification shall be deemed approved if no action is
taken thereon by the State Gaming Agency within said sixty (60) day period or fifteen
(15) day period, as may be applicable. The fifteen (15) day period shall be extended for
the first nine (9) months after the effective date of this Appendix and, during that first
nine (9) month period, such certification shall only be deemed approved if no action is
taken within thirty (30) days. Any disputes arising out of the approval process in this

0.4
T
Section 10.3 shall be resolved in accordance with the binding arbitration provisions of the
Compact.

Modifications of Approved Lottery Systems; Emergency Certifications. No modification
to any Tribal Lottery System may be made after testing, certification and approval of a

AF
Tribal Lottery System without certification of the modification by the Gaming Test
Laboratory under Section 10.2 and approval thereof by the State Gaming Agency under
Section 10.3. In situations where immediate modifications are necessary to preserve the
integrity of a Tribal Lottery System which has been operating pursuant to an approval
obtained under section 10.3, the Gaming Test Laboratory may issue an emergency
certification of the modification and that it must be made immediately to preserve the
integrity of the Tribal Lottery System. Such emergency certifications shall be deemed to
be temporarily approved by the State Gaming Agency and remain in effect until the State

DR
0.5
Gaming Agency takes action on the certification, which shall be governed by Section
10.3, provided that no emergency certification shall be valid or effective until actually
approved by the State Gaming Agency if it was not received by the State Gaming Agency
within 5 days after being issued.

Manufacturer's Conformity to Technical Standards. Before any component of a Tribal
Lottery System may be placed into operation, the Tribe shall first have obtained a written
Certification from the manufacturer that upon installation, each such component: a)
conforms to the specifications of the Tribal Lottery System as certified by the Gaming
Test Laboratory; and (b) operates and plays in accordance with the requirements of this
Compact. Authorization to operate a Tribal Lottery System requires that it operate and
play in accordance with the requirements specified by this Appendix; provided that while
the failure of such Tribal Lottery System to comply with such requirements will suffice
as a grounds to enjoin or otherwise terminate said Tribal Lottery System's operation, such
non-compliance will not be deemed a violation of this Compact as long as the Tribe has

Squaxin Island Tribe –State of Washington Gaming Compact
Appendix X2 - Rules Governing Tribal Lottery Systems (Amended and Restated)
32
relied in good faith on the certification of the manufacturer and has retained a written
certification in the manner described in this section.

0.6 Payment of Gaming Test Laboratory Fees. The Tribe shall be responsible for the payment
of all Gaming Test Laboratory fees and costs in connection with the duties described in
this Compact. The Tribe shall provide copies of all Gaming Test Laboratory invoices and
payments by the Tribe to the State Gaming Agency, which shall have the right to audit
such fees. In order to assure independence of the Gaming Test Laboratory, any Gaming
Test Laboratory Payment delinquency by the Tribe of fees or costs due to the Gaming
Test Laboratory may be grounds by the State Gaming Agency for rejecting such
laboratory's reports or certification.

0.7 Gaming Test Laboratory Duty of Loyalty. The Tribe shall inform the Gaming Test

T
Laboratory in writing that, irrespective of the source of payment of its fees, the Gaming
Test Laboratory's duty of loyalty and reporting requirements run equally to the State and
the Tribe.

0.8

0.9
AF
Random Inspections. The Tribe shall allow the State Gaming Agency to inspect any
components of the Tribal Lottery System for the purposes of confirming that such
component is operating in accordance with the requirements of this Compact and that
such component is identical to that tested by an Independent Test Laboratory. Inspections
shall be pursuant to the Facility access rules set forth in the Compact.

State Gaming Agency to be Supplied Model of Player Terminal and System. If not
already provided to the State Gaming Agency, the State Gaming Agency shall, upon
request, be supplied a Player Terminal Central Computer and Manufacturing Computer to

DR
be held at the State Gaming Agency 's offices for purposes of determining compliance
with these technical requirements.

SECTION 11. ALTERNATIVE STANDARDS PERMITTED

Notwithstanding anything in this Appendix to the contrary, the State Gaming Agency and Tribe
may agree on alternative provisions to those set forth herein, provided such provisions
adequately preserve and protect the integrity and security of any game or gaming system or
component, or accounting or auditing system or component, affected thereby.

SECTION 12. TRIBAL LOTTERY SYSTEM PLAYER TERMINAL
ACQUISITION AND OPERATION

Appendix E Section 6 governs Player Terminal Allocations and operation, and such provisions
are incorporated herein.

Squaxin Island Tribe –State of Washington Gaming Compact
Appendix X2 - Rules Governing Tribal Lottery Systems (Amended and Restated)
33
SECTION 13. STATE REGULATORY FEES

Compact Section XII. provisions on Set-up Fee and Annual Regulatory Fees are incorporated
herein.

SECTION 14. COMMUNITY INVESTMENTS AND PUBLIC HEALTH

03.1 Community Impact. Compact Section III.D.(2) and Appendix E Section 7.2 provisions
are incorporated herein.

03.2 Charitable Contributions. Appendix E Section 7.1 provisions are incorporated herein.

03.3 Problem Gambling and Responsible Gaming. Compact Section F provisions are
incorporated herein.

13.4
T
Smoking Cessation and Prevention. Compact Sections III.D.(4) provisions are
incorporated herein.

AF SECTION 15. HOURS OF OPERATION

Compact Section III.K. provisions are incorporated herein.

DR
Squaxin Island Tribe –State of Washington Gaming Compact
Appendix X2 - Rules Governing Tribal Lottery Systems (Amended and Restated)
34
SQUAXIN ISLAND TRIBE – STATE OF WASHINGTON
GAMING COMPACT

APPENDIX Y
Requirements for Electronic Gambling Devices
(Amended and Restated)

Table of Contents
1 INTRODUCTION ...............................................................................................................1
1.1 Definitions................................................................................................................1
1.2
1.3
1.4
1.5
T
General .....................................................................................................................1
Intent ........................................................................................................................1
Testing......................................................................................................................1
Judicially Articulated Restrictions ...........................................................................2

2
1.6

AF
Approval Process .....................................................................................................3

TESTING AND MACHINE APPROVAL .........................................................................3
2.1
2.2
2.3
2.4
2.5
2.6
Designation of Independent Gaming Test Laboratory.............................................3
Testing and Certification of EGDs ..........................................................................4
Approval by the State Gaming Agency ...................................................................5
Modifications of Approved Systems; Emergency Certifications ............................5
Manufacturer’s Conformity to Technical Standards................................................6
Payment of Gaming Test Laboratory Fees ..............................................................6

DR
2.7
2.8
2.9
Gaming Test Laboratory Duty of Loyalty ...............................................................6
Random Inspections .................................................................................................7
State Gaming Agency to be Supplied Model of Player Terminal and System ........7

i
SECTION 1. INTRODUCTION

1.1 Definitions

All capitalized terms not defined herein, to the extent they do not conflict, shall have the
same definitions as in the Compact, as amended.

1.2 General

This Appendix is created to provide the basic "core" requirements for Electronic
Gambling Devices ("EGDs") authorized under Compact Section IV.D. and to establish
the approval and testing process for gaming machines and associated equipment that are
to be operated by the Squaxin Island Tribe ("Tribe") in the State of Washington, pursuant

T
to the Compact heretofore approved by the Secretary of the Interior. This Appendix does
not apply to EGD’s authorized under Appendix X2 to the Compact, which are governed
by the respective Appendix.

These standards take into consideration certain judicially articulated restrictions on the

1.3
AF
use and operation of EGDs. Those restrictions prohibit:

1.2.1

1.2.2

Intent
individual play against such devices or terminals; and

activation of gaming devices by the insertion of a coin or currency.

The intent of this Appendix is to ensure that gaming located on Tribal Lands occurs in a

DR
manner that is:

1.3.1

1.3.2

1.3.3

1.3.4
Fair;

Secure;

Auditable; and

Compliant with judicially articulated restrictions.

1.4 Testing

The general purpose of testing gaming equipment is to determine the suitability of such
gaming equipment for operation in the intended environment. Prior to operation, all
EGDs and associated equipment shall be tested by a licensed gaming laboratory to:

Squaxin Island Tribe – State of Washington Gaming Compact
Appendix Y - Requirements for Electronic Gambling Devices (Amended and Restated)
1
1.4.1 verify that they comply with the requirements of the Compact and this Appendix;

1.4.2 ensure that they are fair to both the players and the operators;

1.4.3 verify that they comply with currently accepted gaming test industry standards
such as GLI 11 and 12; and

1.4.4 ensure that the equipment does not constitute:

(a) electronic, mechanical or electro-mechanical devices or terminals which
allow for individual play against such devices or terminals, or

(b) gambling that is activated/initiated by the insertion of a coin or currency.

1.5 Judicially Articulated Restrictions

T
EGDs may be utilized by the Tribe under the following conditions:

AF
1.5.1 The EGD is activated by a "cashless transaction system" and not by the insertion
of coin or currency;

1.5.2 The EGD does not allow for individual play against the device or terminal. The
parties agree that this requirement can be met in the following non-exclusive
ways:

(a) Players compete for a number from a predetermined set of numbers, each
associated with a specific outcome; or

DR
(b) Players compete in a pooled wagering system whereby prizes are awarded
from a wagering pool or pools made up of the players' wagers and the house is
entitled to a set amount of the pooled wagers. Systems meeting the
requirements of this subsection may allow for an initial seeding of the
wagering pool by the house, and reseeding in circumstances of excessive
volatility.

1.5.3 Player terminals do not contain slot machine-type spinning reel mechanisms in
mechanical form, nor allow for activation by a slot machine-type handle; and

1.5.4 The Tribe and the State Gaming Agency have signed an agreement for each
specific type of EGD which confirms that that type of EGD meets the foregoing
requirements and sets technical standards and internal controls for operation of
that type of EGD.

Squaxin Island Tribe – State of Washington Gaming Compact
Appendix Y - Requirements for Electronic Gambling Devices (Amended and Restated)
2
1.6 Approval Process

1.6.1. Except for those EGDs governed by Appendix X2, the Tribe and the State
Gaming Agency shall enter into an agreement for each specific type of EGD
which the Tribe wishes to operate. Each agreement shall confirm that the
proposed type of EGD meets the requirements contained in the Compact and this
Appendix, and shall set the technical standards and internal controls for the
operation of that type of EGD. Such technical standards and internal controls shall
be uniformly applied to all Washington State gaming tribes and shall include, but
not be limited to: operation, interface and random number generator standards;
game reports; accounting system requirements and reports; cashless transaction
system requirements and reports; security system requirements; testing
requirements; and regulatory fees.

T
1.6.2. The Tribe may present to the State Gaming Agency, at any time, a machine
concept it believes satisfies the requirements of the Compact and this Appendix.
Within thirty (30) days thereafter, the State Gaming Agency shall notify the Tribe

AF
of its acceptance or rejection of said concept. If the State Gaming Agency accepts
the Tribe's concept, the Tribe and the State Gaming Agency shall have ninety (90)
additional days to execute the agreement required by subsection 1.5(a); provided,
however, said ninety (90) day period shall not commence until the Tribe has made
a full submission of its machine proposal to the State Gaming Agency; provided,
further, that the Tribe shall not commence operation of said EGD until the
laboratory testing and certification requirements referred to in subsection 1.3 of
this Appendix are met.

DR
1.6.3. A "full submission," as that term is used in subsection 1.5(b), shall include
machine hardware (a prototype EGD), base software (the software platform upon
which games are loaded), game software for one or more games, and a detailed
narrative description of said hardware, base software and game software. Failure
of the Tribe and the State Gaming Agency to agree upon a machine concept or
failure to execute an agreement required by subsection 1.5 (a) shall constitute a
dispute or disagreement between the Tribe and the State Gaming Agency, subject
to the dispute resolution provisions contained in Compact Section XIII.

SECTION 2. TESTING AND MACHINE APPROVAL

2.1 Designation of Independent Gaming Test Laboratory

The State Gaming Agency shall select one or more gaming test laboratories (hereinafter
"Gaming Test Laboratory") to perform the testing required in this Appendix. Any

Squaxin Island Tribe – State of Washington Gaming Compact
Appendix Y - Requirements for Electronic Gambling Devices (Amended and Restated)
3
Gaming Test Laboratory selected shall have demonstrated it is competent and qualified to
conduct scientific tests and evaluations of electronic gaming systems and to otherwise
perform the functions set forth in the Compact. The Tribe may request additional
laboratories be placed on the State Gaming Agency's list of Gaming Test Laboratories,
which request shall not be unreasonably denied. Any laboratory that is currently licensed
and approved by any state, province or country to test or evaluate EGDs or electronic
gaming systems shall be placed on the list if, after review by the State Gaming Agency, it
is found to be so qualified and otherwise meets the background and licensing
requirements applicable to such laboratories under Washington State law. For any testing
required under this Appendix, the Tribe shall choose a laboratory from those Gaming
Test Laboratories on said State Gaming Agency list. If, at any time, any of the Gaming
Test Laboratories' licenses from any jurisdiction are suspended, terminated or subject to

2.2
T
disciplinary actions, the Gaming Test Laboratories may be removed from the State
Gaming Agency's list. If removed from the State Gaming Agency's list, the Tribe shall
choose a new Gaming Test Laboratory as provided herein.

Testing and Certification of EGDs

AF
2.2.1. No EGD may be offered for play unless:

(a) such EGD is approved by the parties as provided in this Appendix; or

(b) the EGD prototype thereof has been tested and certified by the Gaming Test
Laboratory as meeting the requirements specified by this Appendix.

2.2.2. If not already provided to the Gaming Test Laboratory, the Tribe shall provide or

DR
require that the manufacturer provide to the Gaming Test Laboratory two (2)
copies of EGD illustrations, schematics, block diagrams, circuit analyses,
technical and operation manuals, program object and source codes, hexadecimal
dumps (the complied computer program represented in base 16 format), and any
other information requested by the Gaming Test Laboratory. The Tribe shall make
all such materials available to the State Gaming Agency upon request;

2.2.3. If requested by the Gaming Test Laboratory, the Tribe shall require the
manufacturer to transport not more than two (2) working models of the EGD to a
location designated by the laboratory for testing, examination or analysis. Neither
the State nor the Gaming Test Laboratory shall be liable for any costs associated
with the transportation, testing, examination, or analysis, including any damage to
the components of the EGD. If requested by the Gaming Test Laboratory, the
Tribe shall required the manufacturer to provide specialized equipment or the

Squaxin Island Tribe – State of Washington Gaming Compact
Appendix Y - Requirements for Electronic Gambling Devices (Amended and Restated)
4
services of an independent technical expert to assist with the testing, examination
and analysis;

2.2.4. At the conclusion of each test, the Gaming Test Laboratory shall provide to the
State Gaming Agency and the Tribal Gaming Commission a report that contains
findings, conclusions and a certification that the EGD conforms or fails to
conform to the requirements contained in the Compact. If the Gaming Test
Laboratory determines that the device fails to conform to such requirements or
technical standards, and if modifications can be made which would bring the
EGD into compliance, the report may contain recommendations for such
modifications. The parties are not bound by the findings, conclusions or
certifications of the Gaming Test Laboratory for purposes of enforcement of the
provisions of the Compact.

2.3 Approval by the State Gaming Agency
T
Upon receiving the certification from the Gaming Test Laboratory, the State Gaming

AF
Agency shall either approve or disapprove the EGD or component thereof, based on the
technical criteria contained in this Appendix and the agreement adopted under subsection
1.5, within sixty (60) days of receipt of the certification as to any new EGD or component
thereof, and within fifteen (15) days of the receipt of the certification as to any
modification to a system which has already been approved by the State Gaming Agency.
The certification shall be deemed approved if no action is taken thereon by the State
Gaming Agency within said sixty (60) or fifteen (15) day period, as may be applicable.
Any disputes arising out of the approval process in this subsection 2.3 shall be resolved in

D
2.4

R
accordance with Compact Section XIII.

Modifications of Approved Systems: Emergency Certifications

No modification to any EGD may be made after testing, certification and approval of an
EGD without certification of the modification by the Gaming Test Laboratory under
subsection 2.3 and approval thereof by the State Gaming Agency under this subsection
2.4. In situations where immediate modifications are necessary to preserve the integrity
of an EGD which has been operating pursuant to an approval obtained under subsection
2.3, the Gaming Test Laboratory may issue an emergency certification of the
modification and that it must be made immediately to preserve the integrity of the EGD.
Such emergency certifications shall be deemed to be temporarily approved by the State
Gaming Agency and remain in effect until the State Gaming Agency takes action on the
certification, which shall be governed by subsection 2.3, provided that no emergency
certification shall be valid or effective until actually approved by the State Gaming

Squaxin Island Tribe – State of Washington Gaming Compact
Appendix Y - Requirements for Electronic Gambling Devices (Amended and Restated)
5
Agency, if it was not received by the State Gaming Agency within five (5) days after
being issued.

2.5 Manufacturer's Conformity to Technical Standards

Before any component of an EGD may be placed into operation, the Tribe shall first have
obtained and submitted to the State Gaming Agency a written certification from the
manufacturer that upon installation each such component:

2.5.1. conforms to the specifications of the EGD as certified by the Gaming Test
Laboratory; and

2.5.2. operates and plays in accordance with the requirements of the Compact
Procedures.

T
Authorization to operate an EGD requires that it operate and play in accordance with the
requirements specified by this Appendix; provided that while the failure of such EGD to
comply with such requirements will suffice as grounds to enjoin or otherwise terminate

2.6
AF
said EGD's operation, such non-compliance will not be deemed a violation of the
Compact as long as the Tribe has relied in good faith on the certification of the
manufacturer.

Payment of Gaming Test Laboratory Fees

The Tribe shall be responsible for the payment of all Gaming Test Laboratory fees and
costs in connection with the duties described in the Compact. The Tribe shall provide

DR
2.7
copies of all Gaming Test Laboratory invoices and payments by the Tribe to the State
Gaming Agency, which shall have the right to audit such fees. In order to assure
independence of the Gaming Test Laboratory, any Gaming Test Laboratory payment
delinquency by the Tribe of fees or costs due to the Gaming Test Laboratory may be
grounds by the State Gaming Agency for rejecting such laboratory's reports or
certification.

Gaming Test Laboratory Duty of Loyalty

The Tribe shall inform the Gaming Test Laboratory, in writing, that, irrespective of the
source of payment of its fees, the Gaming Test Laboratory's duty of loyalty and reporting
requirements run equally to the State and the Tribe.

Squaxin Island Tribe – State of Washington Gaming Compact
Appendix Y - Requirements for Electronic Gambling Devices (Amended and Restated)
6
2.8 Random Inspections

The Tribe shall allow the State Gaming Agency to inspect any components of an EGD
for the purposes of confirming that such component is operating in accordance with the
requirements of the Compact and that such component is identical to that tested by an
independent test laboratory. Inspections shall be pursuant to the Compact.

2.9 State Gaming Agency to be Supplied Model of Player Terminal and System

If not already provided to the State Gaming Agency, the State Gaming Agency shall,
upon request, be supplied all components of each EGD to be held at the State Gaming
Agency's offices for purposes of determining compliance with these technical
requirements.

T
AF
DR
Squaxin Island Tribe – State of Washington Gaming Compact
Appendix Y - Requirements for Electronic Gambling Devices (Amended and Restated)
7

File and source

File: 2026-01-21_a33649_d291554_squaxin-island-tribe-seventh-amendment-tentative-agreement.pdf
Size: 3,181,428 bytes
SHA-256: 6568b52b534fabb4ed50a6d763515d7498505aebf7ed78d5634972c816eb7507
Our copy: 2026-01-21_a33649_d291554_squaxin-island-tribe-seventh-amendment-tentative-agreement.pdf
Original: app.leg.wa.gov

Seventh Amendment to the Tribal – State Compact for Class III Gaming Between the Squaxin Island Tribe and the State of Washington

Summary

Cite this document

Full text

File and source

Related records