As a regulatory agency of the Tribes, the Gaming Commission (Commission) was established pursuant to the Indian Gaming Regulatory Act of 1988. Chapter 5-2 (Gaming Code) was adopted in Tribal Ordnance #30B dated 8 December 2003 and approved by the National Indian Gaming Commission (NIGC) on 4 January 2004, established the Gaming Commission regulatory agency for the Tribe on that date. The Commission was comprised of a Chairman and two Commissioners.
On 27 April 2016, Tribal Council adopted revisions to Chapter 5-2 by passing Tribal Ordinance #30E, these revisions are considered approved by NIGC and became effective as of 10 August 2016. Under the revised Gaming Code, the Commission shall consist of a five (5) member Commission and an Executive Director, all appointed by a majority vote of Tribal Council. The Executive Director is responsible for the oversight and hiring and firing of Commission staff. The Commission and Commission staff regulate Class II and Class III Gaming on CTCLUSI Indian Lands and are responsible for the regulatory oversight of the Gaming Operations, to ensure compliance with the Compact, and with Tribal, Federal, and if applicable, State law and regulations. The Commission also serves as the licensing authority for individuals employed by the Gaming Operation.
CTGC Surveillance Section staff work with Gaming Commission, Tribal Gaming, Tribal Police, Outside Police agencies, and the Three Rivers Casino Resort staff, to monitor compliance with the Compact, CTGC Regulations, Minimum Internal Controls Standards (MICS), Tribal Internal Control Standards (TICS) and Casino policies and procedures, thereby ensuring the fairness, integrity, security, and honesty of the Gaming Operation. The Surveillance Section is managed by the Director of Surveillance, Keaty Lane, who reports directly to the Executive Director of the Gaming Commission, Rusty Bossley.
The essential duties of the Surveillance Section are to:
- Ensure the integrity of gaming and protecting the assets of the casino.
- Protect the safety of the employees and guests at Three Rivers Casino Resort (TRCR) through clandestine observation of the casino operation and the activities associated with TRCR.
- Enforce Regulations, Minimum Internal Control Standards (MICS), Tribal Internal Control Standards (TICS), and Casino Policy & Procedures.
- Conduct audits on all departments to ensure compliance with Policy and Procedures, Compact, MICS, and TICS.
- Actively observe casino activities, money handling functions, back-of-the-house and outside areas.
- Conduct investigations on reported Casino Guest Gaming disputes.
- Assist Law Enforcement as needed in the investigation of criminal activities.
- Actively observe, record and report all daily casino activities.
- Maintain an operational Surveillance system.
- Maintain detailed activity logs.
In order to fulfill the responsibilities under the Tribal Gaming Code, NIGC regulations and the Tribal/State Compact, the Licensing Section was created within the Confederated Tribes Gaming Commission. The Licensing Section reports directly to the Executive Director, Rusty Bossley. All required Licensing functions are accomplished by the Licensing Agents. Final licensing decisions are made by the Commissioners.
The essential duties of the Licensing Section are to:
Licensing TRCR Team Members
- Conduct, review, and analyze background and financial investigations of applicants seeking a gaming license at Three Rivers Casino Resort.
- Make temporary licensing decisions of applicants seeking a gaming license and take disciplinary action, as needed.
- Maintain and update licensing databases for casino personnel.
- Prepare and issue all licenses and identification cards to employees of the Casino, CTGC, Tribal Police, and other qualified individuals whose job requires them to work in the Casino.
- Track conditional licensing requirements, including any Notice of Violations.
- Schedule, issue, and track the necessary forms for license renewals for all individuals working at the casino.
Gaming Commission Reporting
- Prepare reports for the Gaming Commission and Oregon State Police containing results of the investigations and any recommended terms and conditions for licensing.
- Compile and organize complete investigative files for applicants and licensees, and make them available to the Gaming Commission.
- Testify before the Gaming Commission as required.
- Responsible to ensure that appropriate files, fingerprints, photographs, and documents are forwarded to the NIGC, Oregon State Police-Tribal Gaming Sections (OSP-TGS), and FBI.
- Perform background investigations of gaming vendor companies and their technicians that will be providing services to the gaming facility.
- Maintain and update databases for vendor companies and their technicians.
- Compile, organize, and complete investigative files for gaming vendor companies and their technicians, and make them available to the Gaming Commission.
CTGC Compliance Section staff work with Tribal Gaming, Surveillance, Tribal Police and the Three Rivers Casino Resort staff, to monitor compliance with the Compact, CTGC Regulations, Minimum Internal Controls Standards (MICS), Tribal Internal Control Standards (TICS) and Casino policies and procedures, thereby ensuring the fairness, integrity, security, and honesty of the Gaming Operation. The Compliance Section is made up of the Audit Unit and the Gaming Inspector Unit and is supervised by the Director of Internal Audit, Cheryl Hoile, who reports directly to Rusty Bossley, the Executive Director of the Gaming Commission.
The essential duties of Compliance Section are to:
- Approve the Casino's Policy & Procedures related to the Gaming Operation.
- Approve all Casino rules dealing with promotional giveaways where chance is an element of the giveaway.
- Approve all Casino rules related Gaming play, including tournament rules.
- Enforce Regulations, Minimum Internal Control Standards (MICS), Tribal Internal Control Standards (TICS) and Casino Policy & Procedures.
- Conduct audits as required by the Compact, MICS, and TICS, as well as additional audits required by the Executive Director.
- Conduct investigations of any potential violations of the Compact, applicable regulations, internal controls, policy and procedures.
- Conduct investigations on reported Casino Guest Gaming disputes.
- Assist Law Enforcement as needed in the investigation of gaming related crimes.
- Issue Notice of Violations as required.
- Review the Casino's response and corrective action to Audit Findings and Notice of Violations for adequacy.
- Submit petitions to the Commissioners for licensee assessment of fines as necessary to ensure compliance.
The Audit Unit consists of the Compliance Audit Supervisor and Compliance Auditor, that performs audits of the Three Rivers Casino Resort (TRCR).
The essential duties of the Audit Unit are to:
- Learn, comprehend, and maintain a working knowledge of Gaming Commission Regulations, Tribal/State Minimum Internal Control Standards (MICS), Tribal Internal Controls (TICS), NIGC MICS, and Casino Operations policies and procedures.
- Conduct compliance reviews to assess the effectiveness of internal controls and compliance with Compact, CTGC Regulations, MICS, TICS and Casino policies and procedures.
- Develop and update the audit check lists needed for completing all audits as required in the Audit Plan.
- Work with OSP detectives and auditors to coordinate state participation of all Class III audits required by Compact.
- Prepare written reports to document audit findings and recommendations, and report such information to CTGC and TRCR management.
- Review TRCR management responses to audit findings for sufficiency and plan follow-up audits of any implemented corrective action.
- Assist in the selection and engagement of an External Auditing Firm to perform the annual audit required by the NIGC and coordinate the external audit once a firm has been selected.
- Review all TRCR contracts with Class III vendors and Class II vendors to ensure Compact language and NIGC compliance requirements are met.
- Assist with writing, implementation and updating of CTGC Regulations, TICS, State and NIGC MICS as needed.
- Maintain master records of all CTGC Regulations, TICS, State and NIGC MICS and ensuring that all CTGC staff and TRCR staff have access to most current revisions.
- Monitor other promotional giveaways periodically or as needed and maintain archive records of all promotional giveaways as required in CTGC policy.
- Investigate any cash variance greater than $100 in a specific variance report or that the CTGC determines to be a threat to the integrity of the gaming operation.
- Investigate any potential violation of the Compact, TICS, State and NIGC MICS, and TRCR policies and procedures related to the Cage, Soft Count, Drop and Accounting/Audit areas and Issue CTGC violations as appropriate.
- Monitor each month, as required by the Compact, the VLT, EGM, Table Game Drop & Soft Count, Chip Inventory and Surveillance compliance with procedure.
Gaming Inspector Unit
The Gaming Inspector Unit consists of three (3) Gaming Inspectors for the Class III VLT’s and Class II EGM’s. These areas are highly regulated by the Confederated Tribes Gaming Commission (CTGC), the State and the National Indian Gaming Commission (NIGC). Under the Compact Minimum Internal Controls (MICS), the Tribes Internal Controls (TICS) and NIGC’s MICS, all gaming equipment and software associated with the VLT’s and EGM’s has to be tested and certified as meeting all State, Tribal and Federal technical standards by an independent laboratory, to insure the fairness and integrity of the equipment and/or gaming software. The laboratory then certifies the equipment as authorized for use in Oregon. This certification process must be completed prior to the purchase and installation of these devices at our Casino. The Gamin Inspectors also monitor the Gaming Operations in Florence and Coos Bay for compliance as appropriate with all Federal, State and Tribal laws and regulations, and investigate any guest disputes involving VLT’s or EGM’s that are not adequately dealt with by the Gaming Operations.
The essential duties of the Gaming Inspector Unit are to:
- Inspect all shipments of VLTs and EGMs onto and off of property.
- Ensure that the machines have the proper transportation approval from the State for Class III and the CTGC for Class II and that the machine has been approved for use in the State of Oregon by the independent lab.
- Maintain records of all VLTs and EGMs that are shipped to or from the Florence or Coos Bay Casino.
- Maintain records and track all Class III and Class II Gaming Software ordered by the Casino.
- Test all gaming software against the independent laboratories certification and ensure that it is the correct software approved for use in Oregon.
- Track and securely stored gaming software from the time it arrives on property until it is installed and sealed in the VLT or EGM, as well as once removed from the VLT or EGM until it is either reinstalled, destroyed or returned to the manufacturer.
- Maintain VLT and EGM gaming software integrity in the logic area of all the machines available for play by guests.
- Monthly monitoring as required by the Compact and TICS, including but not limited to, Sensitive Gaming item inventories, daily review of Security and Surveillance logs review, Gaming Department’s regulatory compliance, VLT and EGM Integrity verification, and security of the movement of cash within, into, and outside the gaming facility.
- Issue CTGC violations as appropriate.
- Monitor and verify receipt of Sensitive Gaming Item shipments.
- Inspect and cancel all used cards and dice.
- Insure required Notifications to the State are made within allotted time limits.
- Investigate unresolved customer disputes as required in the Compact and Regulations, and conduct any other gaming related investigations as required.