IntroductionAlthough there are currently no commercial casinos in the state, two Native American tribes in Wyoming (Eastern Shoshone Tribe and The Northern Arapahoe Tribe) operate 4 tribal casinos—the Eastern Shoshone through a compact agreement with the state government and the Northern Arapaho Tribe through authority granted by the National Indian Gaming Commission (“NIGC”).
As the Eastern Shoshone compact was negotiated with the state and the Northern Arapahoe Gaming Procedures were approved by the NIGC, it is important to check with each individual tribe when conducting business with a tribe in order to ensure that all tribal policies and procedures are followed, in addition to any tribal law or regulations beyond the tribal-state compact and Gaming Procedures.
The supplier licensing process, however, is handled solely by the tribal gaming control board (“Board”) that oversees the tribal casino or gaming facility. As such, those interested in supplying goods or services to a tribal gaming facility should contact the tribe directly. As each tribe regulates its tribal gaming facilities independently, it is important to remember that licensing requirements will vary between each tribe. The analysis below is provided as a general overview of the licensing requirements typical of tribal gaming facilities in Wyoming and uses the tribal ordinances and regulations of the Northern Arapaho Tribe (“Tribe”) as the basis for the analysis.
Gaming Device and EquipmentAny person or entity proposing to sell, lease or otherwise provide electronic games of chance, other gaming devices, or gaming services to the Tribe (including, without limitation, gaming device sales personnel and technicians) must be licensed by the Board.
1DurationNo license issued by the Board shall be for more than 24 months from the date of issuance. The Board may issue temporary licenses with a duration up to 90 days.
2FeesLicensing fees will vary depending on the license sought and are set by the Board. In addition to application and/or licensing fees, the applicant must also submit a deposit to cover the cost of the necessary background investigations.
ApplicationThe following information must be submitted in connection with applying for a license to provide gambling devices or equipment to the Tribe, including that if the applicant is a corporation, trust or partnership, applications must be made by any person or entity holding ten percent (10%) or more of any beneficial or legal interest in such entity and, if publicly held, all officers and directors:
1. Basic identification information;
2. Business ownership information;
3. Description of business relationships with other tribal casinos or agencies;
4. Listing of all relatives who work in the gaming or liquor industry;
5. Description of past/current business dealings in the gaming industry;
6. Educational and job history background
7. List of gaming regulatory bodies that have jurisdiction over the applicant;
8. Criminal history; and
9. Three character references.
3Non-Gaming Work PermitsAny employee who works at any facility where authorized gaming occurs or is supervised or administered must obtain a non-gaming work permit.
4 No license issued by the Board shall be for more than 24 months from the date of issuance. The Board may issue temporary licenses with a duration up to 90 days. No permit may be issued to an applicant who has been convicted of a gaming offense or a felony.
5Licensing ProcessOnce a complete licensing application is received by the Board, the Board will conduct a background check on the applicant.
6 Once the background check has been completed, the Board will make a suitability determination regarding the applicant. The identity of each person consulted during the background investigation is kept confidential.
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1See Northern Arapaho Code Title 3, §706
2Id, § 701
3See Northern Arapaho Gaming Agency Employment Application For Gaming and Non-Gaming Licenses
4Northern Arapaho Code Title 3, §705
5Id, § 705(b)
6Id, §606
7Id, §605(a).
