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ARIZONA
DEPARTMENT
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ANNUAL
REPORT

table of
contents

02
03
04
05
06
07
08
09
10

Director’s Message

Mission & Values

Audit Unit

Tribal Contributions

Vendor Certification

Employee Certification

Games & Systems Compliance

Investigations & Inspections

Intelligence

11
12
14
15
16
17
18
19
20

Gaming Device Compliance

Administration

Agency Expenditures

Agency Outreach

Tribes with Gaming
Compacts

Office of Problem
Gambling
SEAS

Internship Program

History of Gaming

Director’s
Message
Gaming never rests.

It is an around-theclock proposition; a
highly
competitive,
technologically driven
and cash intensive
industry.
While it
provides Tribes with
opportunities
for
economic development, excitement for patrons
and funding for valuable State programs – gaming
also demands a robust regulatory structure that
can keep pace with its dynamic growth.
In 2013, our former agency director, Mark
Brnovich continued his commitment to
improving efficiencies at the Department. Every
unit was challenged to review its procedures,
evaluate its performance and proactively make
recommendations for improvement. While we
are proud to hear Arizona often cited as a model
jurisdiction for the regulation of Indian Gaming,
the Department cannot simply do things the
way it always has. It is essential to recognize
the active nature of the gaming industry and
ensure that our regulatory practices evolve to
remain meaningful and effective. The following
unit reports highlight our advancements in 2013,
including the breakthrough State Electronic
System Access (SEAS) program!
This year we also saw the opening of two new
gaming facilities. The first was the Navajo Nation’s
Twin Arrows Casino in northern Arizona and the
second was Gila River Indian Community’s new
Vee Quiva Casino located just west of Phoenix.
The checklist of things to be accomplished in
launching a new casino in compliance with
our Compact is quite extensive. Opening two
gaming facilities within several months required
exceptional organization, detailed scheduling as
well as clear communication and cooperation
with our Tribal counterparts. I am very proud of
the energy and professionalism that our team
members displayed in getting the job done.

Beyond our team and the casino patrons, there
are many other people involved and affected
by gaming and the Department works to serve
them all. For those seeking employment at
the casinos -- and vendors hoping to provide
goods and services to the gaming facilities -ADG is making the process for state certification
as convenient as possible. The Department
has also expanded its internship program. For
college students interested in learning more
about gaming and careers available after
graduation, we are helping to train the leaders
of tomorrow. For those who have compulsive
gaming concerns, ADG continues to oversee the
Office of Problem Gambling. It provides an array
of services to address social concerns associated
with gaming and it recently won a national award
for outstanding public service billboards.
Finally, I would like to express the Department’s
gratitude to its outgoing director, Mark Brnovich.
Thanks to his leadership and vision over the past
4 years, this agency has made great progress
in our operations and it is well-poised to meet
the future challenges of regulating the gaming
industry. The Department is doing more than ever
and accomplishing our mission with enhanced
efficiency.
					

Dan Bergin
Director

Executive staff honors Director Brnovich
ARIZONA DEPARTMENT OF GAMING | 2

Mission&

Values

Mission

Protect the public, ensure compliance with the
gaming compacts, and regulate the gaming industry

Values

DE

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We act with integrity.
We support diversity.
We work with the Tribes on a
government-to-government basis.
We are transparent, consistent, and predictable.
We are professional, accountable, and
responsible in all of our activities.
We respect and support each other.

U

LA

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ENF

ARIZONA DEPARTMENT OF GAMING OFFICE LOCATIONS
Phoenix
1110 W. Washington St.
Suite 450
Phoenix, AZ 85007
(P) 602.771.4263
(F) 602.255.3883
ARIZONA DEPARTMENT OF GAMING |3

Tucson
400 W. Congress
Suite 156
Tucson, AZ 85701
(P) 520.628.6468
(F) 502.628.6470

Flagstaff
311 N. Caden Ct.
Suite 200
Flagstaff, AZ 86004
(P) 602.771.4263
(F) 602.255.3883

AuditUnit
T

he Audit Unit is responsible for evaluating compliance with the Arizona
Tribal-State Gaming Compact. The team conducts annual on-site audits of
all casinos and a Compact Compliance Review (CCR) team reviews hundreds
of items ranging from cash handling to video surveillance, and audits casino
accounting records, monitoring systems and minimum internal control
standards. The Unit also verifies the amounts of all gaming revenues and ensures
a timely payment of Tribal contributions to the State, totaling over $97 million.

accomplishments
•

audit unit responsibilities

•
•
•
•

Completed an annual CCR for all 23 Class III
Casinos in the State
Verified gaming revenues and payment of over
$97 million of Tribal contributions to the State
Increased auditor visibility by providing training
and education resources to the Tribes
Promoted performance and accountability by
implementing the State’s new MAP process
Ensured that the new Twin Arrows and Vee
Quiva casinos opened in compliance

A CCR team conducting an audit of a
Tribal gaming facility operation

Our accomplishments enhance ADG’s ability to promptly identify potential
compliance issues so that they may be resolved in the most-timely manner.
ARIZONA DEPARTMENT OF GAMING | 4

Tribal
Contributions
W

ith the passage of Proposition 202 in November 2002, and the subsequent new
Tribal-State Gaming Compact, participating Tribes in Arizona make quarterly
contributions to the State. In fiscal year 2013, the gaming Tribes filed all Class
III Net Win reports and quarterly Tribal Contribution payments as required.
Contributions are based on each Tribe’s Class III Net Win. In 2013, the
aggregate amount reached $97,581,815. Of that, 88% ($86,527,607)
of the Tribes’ total annual contribution was paid to the Arizona
Benefits Fund. The remaining 12% ($11,054,208) of gaming contributions
are distributed by the Tribes directly to cities, towns and counties.

Fiscal Year 2013 Tribal Contributions Disbursement
Tribal
Contributions
FY 2013
$97,581,815

12% goes directly to cities,
towns & counties
FY 2013
$11,054,208

88% goes to the Arizona
Benefits Fund
9% or $8 million, whichever
is greater, is for ADG’s expenses
FY 2013
8,000,000

8% is transferred to the
Wildlife Conservation Fund
FY 2013
$6,143,764
2% is for the Office of
Problem Gambling
FY 2013
$1,730,552

8% is transferred to
the Tourism Fund
FY 2013
$6,143,764
28% is transferred to the
Trauma & Emergency
Services Fund
FY 2013
$21,503,176
ARIZONA DEPARTMENT OF GAMING |5

56% is transferred
to the Instructional
Improvement Fund
FY 2013
$43,006,351

Vendor
Certification
T

he Gaming Vendor Certification Unit, comprised of special agents, financial
investigators, compliance auditors and intake officers, determine the
suitability of companies and principals doing business with casinos in Arizona.
The unit certifies gaming facility financiers, contractors involved in casino
management and operations, manufacturers and distributors of gaming devices,
and companies offering services to casinos in excess of $10,000 in any one month.
The applicant company, principals and key personnel undergo in-depth background
investigations to determine suitability for the issuance of State certification.

accomplishments
•
•
•
•
•

Issued a total of 349 Vendor Certifications; 87 new, 262 renewals
Facilitated 60 waivers and 2 denials of certification as appropriate
Conducted 69 vendor compliance reviews with Tribal Gaming Offices
Developed a standard application for use by the Tribe and ADG
Streamlined the application making it easier for qualified companies to
do business with casinos

Connie Gross assists
vendors through the
certification process

The unit worked to remove obstacles to the application process and provide Casinos
with a larger pool of certified vendors. With the new Tribal/State application,
Vendors can submit one set of applications to the State and the Tribal Gaming Office.
It greatly reduces time and effort for the Vendor, Tribe and the State of Arizona.
ARIZONA DEPARTMENT OF GAMING | 6

Employee
Certification
T

he Unit conducts extensive background checks on current and prospective
employees to ensure that only suitable individuals are employed within the
industry. The background process includes criminal history checks, fingerprints,
credit history reports, financial background screening and review of past
employment. Two special agents were recruited and trained in time to accommodate
the hiring demands of the recently opened Twin Arrows Navajo Casino Resort.

accomplishments
•
•
•
•
•

Processed 539 new applications for Class III gaming and processed 515 criminal history checks for
Twin Arrows Casino Resort employees
Processed 1,608 new applications and 7,028 renewal applications
Prepared Negative Recommendations/Revocation of Tribal licenses as necessary
Created case management forms to ensure that investigations are completed within 90 days
Special Agents trained in enforcing the State gambling laws played a major role in assisting fellow law
enforcement agencies to combat illegal, off-reservation gambling

Agents conduct a Background
Investigation Training Class for
Tribal regulators

In recent years the Department has witnessed the growth of Indian Gaming. With
the addition of each newer and larger gaming facility, ADG works to ensure that
only the most qualified individuals are employed in the casinos. To meet the growing
needs of the industry, the Department maintains a qualified staff of employees to
ensure the well being of the public and maintain the integrity of Indian Gaming.
ARIZONA DEPARTMENT OF GAMING |7

Games
&
Systems
Compliance
T

he unit reviewed all new poker and table games, revisions to existing games,
drawings, promotions and tournaments. It works hand-in-hand with tribal
regulators, operators, manufacturers, game and technology developers
to ensure the integrity of gaming and compliance with the Compact and its
appendices.
The Unit pursues continuing education and monitors
emerging trends in gaming and regulation.
The Unit develops and
provides training on a myriad of topics including game play, compact
compliance, regulatory enhancement and gaming trends and technology.

accomplishments
•
•
•
•

Performed on-site observations of tournaments, drawings and game implementation
Held internal training classes for ADG employees
Participated in Arizona Tribal Gaming Regulators Alliance training
Attended industry conferences and met with leading gaming manufacturers and
distributors to review new technology and products

The Unit works closely with tribal gaming officials to ensure the casinos are
conducting lotteries, promotions, and tournaments fairly and that poker and
table games are operated within the rules and regulations of the Compact
and its appendices. The Unit stays abreast of the latest technology and
innovations in the gaming industry to maintain an effective regulatory structure.
ARIZONA DEPARTMENT OF GAMING | 8

Investigations &
Inspections

T

he
Investigations
and
Inspections
(I&I)
Unit
monitors
Compact
compliance by conducting onsite inspections of casino operations
and investigating suspected compact violations and criminal activity.
The unit is comprised of AZPOST certified Special Agents, experienced
in law enforcement.
These agents provide valuable expertise to Tribal
authorities in identifying potential problems and correcting deficiencies.

accomplishments
•
•
•
•
•

Held weekly meetings with Navajo representatives and spent three weeks on site for the preopening inspection of the new Twin Arrows casino
Agents spent three weeks on the pre-opening inspection of the new Gila River Vee Quiva Casino
A new ADG Flagstaff Office was opened and a new agent was added along with the assignment
of a machine compliance agent to enhance coverage to Northern Arizona Tribes
Significantly expanded the pilot Tribal Incident Reporting (TIR) program to streamline the
tracking of reports submitted by the TGOs from 3 to 13 Tribes which has increased the accuracy
of statistical information for the Intelligence Unit
Assisted the Arizona Tribal Gaming Regulatory Alliance (ATGRA) in the planning of the 6th
annual New Agents Training Academy sponsored by the Pascua Yaqui Tribe

Deputy Director Rudy Casillas meets with
managers Gary Applegate, Ron Clark and
Dave VanBoxtaele

Agents qualify for annual AZ
POST Certification

Our work with the Navajo Nation helped to increase their understanding
of complex compact requirements and insure non-compliance issues
were held to a minimum at the start of operations. The joint pre-opening
inspections of both Twin Arrows and Vee Quiva enabled ADG and Tribal
regulators
to
maintain
strong
regulatory
partnerships,
resolve
issues in a timely fashion and avoid unforeseen delays with opening.
ARIZONA DEPARTMENT OF GAMING |9

Intelligence
Unit

T

he Intel Unit continued to receive and track inquiries involving suspected
off-reservation gambling operations and investigation of reported
criminal incident information outside of Indian Country. It worked to track
suspicious currency, persons excluded for criminal conduct and suspected
gambling cheats. The Unit assisted Tribal Authorities by providing investigative
assistance and intelligence on suspected criminal activities in their jurisdictions.

accomplishments
•
•
•
•
•

Tracked over 450 criminal gambling complaints; 355 gambling
inquiries; 875 suspicious currency reports; and 8,322 restricted persons
removed from casinos
Provided over 30 training sessions to casino officials and Tribal law
enforcement within and  outside of Arizona
Investigated and shut down a criminal organization that operated illegal
devices and laundered over $40,000 weekly, seizing over 60 devices
from more than 40 locations in the Phoenix area
Investigated a vendor illegally operating redemption devices in the  
State and shut down over 30 locations
Agents conduct training in New Mexico
The Unit shut down 5 illegally operating poker rooms in the Phoenix
area using a newly developed Gambling Inspection Form

Agents seized
illegal gambling
devices

With each successful investigation and prosecution, ADG continues to impact
illegal gambling operations. The tracking of criminal conduct and Intel
by the Unit allows the Department of Gaming to be a central repository of
information for Tribal, Local, State and Federal Law Enforcement authorities.
ARIZONA DEPARTMENT OF GAMING | 10

GamingCompliance
Device
T

he Gaming Device Compliance Unit inspects machine software, electronic
monitoring systems and casino records to ensure correct operation and
disbursement of required payout percentages. Before reaching the casino
floor, all gaming software and electronic slot monitoring systems are
reviewed by an independent testing lab to confirm their compliance with Arizona’s
strict regulatory standards.
Once the machines are in play, the Unit
regularly inspects gaming devices at each of Arizona’s Tribal casinos.
The Machine Compliance Technicians randomly select and test machines
during unannounced visits at 8 to 10 casinos each month and review
casino records to confirm continued compliance with the Compact.

•
•
•
•
•

accomplishments

Inspected and certified 13,407 gaming devices, including 5,517 at random
Discovered 66 gaming devices with deficiencies and provided notification to the TGO in order
to take corrective action
Helped with the opening of Navajo Twin Arrows casino from March 25th to April 30th
certifying over 1,000 gaming devices, systems and kiosks.
Assisted with the opening of the new Vee Quiva casino and worked to certify over 900 games,
devices, systems and kiosks.
Supported the Intelligence Unit with the inspection of seized illegal gambling devices.

The Unit will continue to protect the public by thoroughly inspecting
gaming machines and verifying that the software is up to date.
ARIZONA DEPARTMENT OF GAMING |11

Administration
Procurement & General Services

T

he Procurement and General Services Unit is responsible for providing
ADG with procurement, facility management, administrative support, website
assistance, graphic design, communications, and project management. The
mission of this unit is to support the agency by providing quality administrative
and technical services that promote operational efficacy and efficiency.

accomplishments

•
•
•
•

Improved work space efficiency through floor plan improvements and furniture
adjustments, including the addition of a new meeting room to support collaboration
and training of staff and the public
Planned and completed the opening of the new Flagstaff office
Enhanced system for securing and storing evidence
Created and published digital forms for vendor applications

Human Resources

T

he HR Unit serves the public and helps ensure the integrity of gaming regulation
by recruiting the most qualified candidates and providing new employees
with the tools and training to promote good health and professional growth.

accomplishments
•
•
•
•
•
•

Conducted 14 recruitments, requiring reviews of 653 resumes and applications
Coordinated 103 interviews and provided 13 new employee orientations
Served as the Department’s primary liaison with the Arizona Department of Administration on all
personnel related actions
Held nine Employee Wellness Events, conducted four Open Enrollment Meetings and three sponsored
employee training events
The HR Section has been actively engaged in the State’s Personnel Reform efforts including assisting in the
implementation of the Managing Accountability and Performance (MAP) training and review process
Served as primary resource to Department employees for inquiries
concerning benefits and retirement
HR Administrator
Paula Daniels
attends the 2013
Employee State
Education Fair

ARIZONA DEPARTMENT OF GAMING |12

Accounting/Finance

T

he
Financial
Services
Unit’s
responsibilities
include
budgeting,
planning, accounting for and managing ADG’s revenues, including
disbursement through the accounts payable system. The Unit handles all
payroll and ensures compliance with good accounting practices and the
State’s guidelines.
In addition, the Unit facilitates all necessary travel.

Fiscal Services team members Margaret
Sefton, Lori Anderson & Barbara Wulbrecht

Fiscal Services Specialist
Chris Loring

Information Technology

T

he Unit provides and performs all of ADG’s information technology
requirements, including computer and technology functions, as
well as maintaining the certification database system.
The computer
systems and programs have enabled ADG to perform its responsibilities
under the Compact by streamlining work and tracking performance.

accomplishments
•
•
•
•
•

Continued implementation of the State Electronic Access System (SEAS)
improving efficiency in the Audit, Gaming Device Compliance and I&I Units.
Implemented the Integrated Regulator’s Information System (IRIS) that
supports machine compliance activities in the field
Installed all voice, data and technology services for new Flagstaff office
including an enhanced, secure data network
Developed a Content Management System website allowing updates to
be performed by multiple functional areas across ADG
Provided technical expertise to the audit unit while participating in
Tribal Compact Compliance Reviews

Network Specialists
Enrique Rivera and
Linda Smith

ARIZONA DEPARTMENT OF GAMING |13

Agency
Expenditures
Department of Gaming Expenditures

ARIZONA DEPARTMENT OF GAMING | 14

Agency
Outreach
St. Mary’s Food Bank

A

DG employees participated in a food
drive
benefitting
St.
Mary’s
Food
Bank,
a
non-sectarian,
nonprofit
organization
that
alleviates
hunger
by
efficiently gathering and distributing food across Arizona. More than 180
pounds of food was donated, which brought over 180 meals to the needy.

T

Christmas Wish Program

he Christmas Wish Program with
Wilson Primary School, located in one
of the poverty-stricken neighborhoods
in Phoenix, has been in place since 1995. For
many of these children, Santa never comes.
In FY 2013, over 50 ADG employees donated
gifts and money, and an enthusiastic team
provided the Wilson School
party for the Kindergarten Class.
Employees donated 23 “Santa”
gifts for the students and raised
monetary donations, which provided
food and refreshments for the party,
supplies for the classroom and gifts
for the teacher and her aide.

SECC

T

he State Employees Charitable Campaign is conducted under Executive
Order in partnership with the state fiscal agent, a 501 (c) (3) charitable
organization. More than 45,000 state employees donate funds to help
support over 500 charities. In the past 20 years, State Employees have raised over
$24 million to support charities in Arizona, across the nation and throughout
the world. ADG has participated in the campaign since 1997 and our long-term
commitment to the campaign is reflected in the numerous awards won for such
things as dollars raised, participation, Supergivers and Leadershipgivers.
ARIZONA DEPARTMENT OF GAMING |15

Tribes With

Gaming Compacts
COMPACTED TRIBES WITH CASINOS
Kaibab Band of Paiute Indians

Ak-Chin Indian Community
Harrah’s Ak-Chin Casino
Cocopah Indian Tribe
Cocopah Casino

San Juan Southern Paiute Tribe
Havasupai Indian Tribe

Colorado River Indian Tribes
Blue Water Casino

Navajo Nation
Hualapai Indian Tribe

Fort McDowell Yavapai Nation
Fort McDowell Gaming Center

Twin Arrows Casino

Fort Mojave Indian Tribe
Spirit Mountain Casino

Spirit Mountain Casino

Gila River Indian Community
Wild Horse Pass, Vee Quiva,
& Lone Butte Casinos

Cliff Castle Casino
Bucky’s Casino &
Yavapai Gaming Center
Hon Dah Casino
Mazatzal Casino
Blue Water Casino

Navajo Nation
Twin Arrows Casino
Pascua Yaqui Tribe of Arizona
Casino of the Sun & Casino del
Sol

Fort McDowell Gaming Center
Vee Quiva, Wild Horse Pass
& Lone Butte Casinos

Quechan Indian Tribe
Paradise Casino
Salt River Pima-Maricopa Indian
Community
Casino Arizona & Talking Stick
Resort

Zuni Tribe

Casino Arizona at Salt River
Casino Arizona at Talking Stick
Apache Gold Casino

Harrah’s Ak-Chin Casino
Paradise Casino
Cocopah Casino

San Carlos Apache Tribe
Apache Gold Casino

Golden Ha:sañ Casino

Casino del Sol &
Casino of the Sun

Desert Diamond Casino I
Desert Diamond Casino II

Tohono O’odham Nation
Desert Diamond, Desert
Diamond I & Desert Diamond II
Tonto Apache Tribe
Mazatzal Casino

COMPACTED TRIBES WITHOUT CASINOS

White Mountain Apache Tribe
Hon Dah Casino

Havasupai Indian Tribe

Yavapai-Apache Nation
Cliff Castle Casino

Hualapai Indian Tribe

Yavapai-Prescott Indian Tribe
Yavapai Gaming Center & Bucky’s Casino

Kaibab Band of Paiute Indians
San Juan Southern Paiute Indian Tribe
Zuni Tribe
ARIZONA DEPARTMENT OF GAMING | 16

Office

of Problem Gambling

T

he mission of the Office of Problem Gambling (OPG) is to provide
and support problem gambling prevention, treatment and education
programs throughout Arizona. OPG reaches out to the public to increase
awareness and promote prevention of problem gambling.
It coordinates
the training of licensed counselors throughout the State who work under
contract to treat those with gambling related issues. OPG continues to
expand awareness that compulsive gambling exists and is treatable. OPG
also administers the Patron Self-Exclusion Process, maintaining and
disseminating a self-exclusion list of over 2.800 compulsive gamblers who
have agreed to not enter an Arizona casino for 1, 5 or 10 years. In FY 2013,
more than 550 people voluntarily banned themselves from the Casinos.

accomplishments
•
•
•
•

Created a DVD collection available to the public for problem gambling education and it may act as
an alternative to in-person training for behavioral health professionals
Planned and hosted a symposium during Arizona’s Problem Gambling Awareness week with keynote
presentations by national problem gambling experts
Created and published a needs assessment survey targeting stakeholders, community service
organizations and behavioral health providers
Created award winning media and advertisements for problem gambling education and prevention

Office of Problem Gambling Team

ADG Director Brnovich addresses the audience at
the 2013 OPG Symposium
ARIZONA DEPARTMENT OF GAMING |17

SEASState Electronic
Access System

In 2012, Arizona became the very first
jurisdiction to establish an electronic monitoring
system between sovereign Indian nations
and a state agency.
The State Electronic
Access System
(SEAS) provides ADG with
real-time read-only access to casino financial
and gaming device event information.

expressed concern on the Tribal side, and rightly so.
Security is one of the pivotal issues to be considered
in any type of agreement when introducing a
new procedure and/or technology. And due to its
importance, this is where the beauty of this system lies.

The access point to the SAS thus to the SEAS system,
is the same gateway which the vendors use for
Since its implementation, all of the urban Tribes
maintenance and repairs. One simple and efficient,
have partnered with ADG in order to establish
yet powerfully secure access point. Additional
the monitoring procedures, as mandated in
passwords with a strong encryption each
the Compact. SEAS is accurate, as it
side (the Tribal system and the
monitors and records the realADG system) obviates the
time information.
need for additional
It is secure since it
“doorways and
Casino
Encrypted
Network
State
of
AZ
requires
double
passages.” Fewer
encryption
on
doorways
each side of the
mean less
entry, and the
vulnerability.
total cost is
significantly
Information
SEAS Overview
below the cost
must pass
of monitoring
through
systems in other
encryptions
jurisdictions.
on each end,
allowing for
Slot Accounting System
SEAS uses the Slot
the smooth and
Access System (SAS)
secure flow of
hardware as its main
information.
platform - the base from which
information is accessed, and realSo in addition to the strong
time monitoring, recording and report production
encryption which is used on both sides when
occurs. When there is a need for a report,
information is traveling through the internet, it has
an ADG employee contacts the Tribal IT office to
encryptions in order to pass through both firewalls.
access SEAS. The ADG employee is able to logThat is the two-way verification module.
in from a secure platform from which the SEAS
report can be accessed and printed.
The agreements have been signed and ADG has
begun using SEAS in support of its regulatory
During the SEAS negotiations, the main
work including Compact Compliance Reviews.
issue was security. This has been the most
This edited information was originally
produced by Intern Maya Fangiullos

ARIZONA DEPARTMENT OF GAMING | 18

Internship

Program

Internships provide students with practical learning and on-thejob training to enhance their academic experience and prepare
for a professional career. ADG is proud to offer internship and job
shadow opportunities in a variety of departments throughout
our agency. We provide internships in the fields of finance,
communications, legislative affairs, law, information technology,
problem gambling and law enforcement.
For the last several years we have been grateful to partner
with ASU and take part in their Legislative and Government
Internship program. This year, our agency hosted ASU student,
Shana Berschler, for 18 weeks where she participated not only
in the legislative session, but also worked closely with our
Communications and Media Relations team. In addition we
hosted a law extern, Travis Lovett a communications intern, Maja
Fangiullos, and an intern specializing in information technology,
Aaron Knoll.
We believe that not only are internships a valuable experience
for students, but also a great asset for our agency. Internships
provide a chance for us to showcase to the next generation
workforce a career in state government and for students to make
connections with professionals in their field prior to graduating.
ADG is continuing to explore new partnerships with colleges to
offer beneficial opportunities to future students.

IT Intern Aaron Knoll

ARIZONA DEPARTMENT OF GAMING |19

ASU Student Carolina Gastewal
participates in the Job Shadow Program

Communications Intern
Maya Fangiullos

Assistant Director Rick Medina and
Legislative Intern Shana Berschler
attend the 2013 OPG Symposium

Law Extern Travis Lovett

History

of Gaming in Arizona

I

n 1988, the U.S. Congress passed the Indian Gaming Regulatory Act (IGRA) in response to the
proliferation of gambling halls on Indian reservations. IGRA recognized gaming as a way to promote
Tribal economic development, self-sufficiency, and strong Tribal government. The Act says a State
must permit Indians to run gaming on reservations if the State permits
such gaming off reservation. Under the Indian Gaming Regulatory Act, a
Tribe that wants to engage in Class III casino style gaming must first sign
a gaming Compact (or agreement) with the State where the casino would
be located. IGRA requires a State to negotiate in good faith with the Tribe
seeking a Tribal-State Gaming Compact.
In enacting IGRA, Congress was reacting to a regulatory vacuum left by
Ancient Dice
a 1987 U.S. Supreme Court ruling (California v. Cabazon Band of Mission
Indians) that States have no regulatory authority over gaming on Indian reservations. That ruling said Tribes
have the right to operate gaming on reservations if States allowed such gaming off-reservation.
The Indian Gaming Regulatory Act of 1988 expressly granted States and the Tribes the power to jointly
regulate Class III Tribal gaming. Class III gaming includes slot machines, blackjack, keno and other casino
style games. IGRA also created the federal National Indian Gaming Commission to oversee reservation
bingo games and certain aspects of Class III gaming.
By the early 1990s, several Arizona Tribes had installed slot machines in their casinos even though none of
them had a Tribal-State Gaming Compact with the State. The Arizona governor at the time, Fife Symington,
said reservations shouldn’t have casinos because Arizona didn’t allow such gambling off-reservation. Tribes
countered that Arizona did permit such gambling by allowing state lotteries, dog and horse racing, and
charity bingo games off-reservation.
In May 1992, the National Indian Gaming Commission issued rules clarifying that a Tribe must have a
gaming Compact with a State before the Tribe can operate slot machines. Immediately after the rules were
announced, the Arizona Governor called on the U.S. Attorney in Phoenix to shut down casinos with the slot
machines. FBI agents raided five Indian casinos and seized their slot machines. At Fort McDowell casino
near Scottsdale, Tribal members formed a blockade to prevent the removal of the machines, and a threeweek standoff ensued.
Against a backdrop of legal challenges by both sides that continued for more than a decade, Governor
Symington signed Arizona’s first set of Tribal-State Gaming Compacts with 16 Tribes from 1992 to 1994.
The governor’s successor, Jane Hull, signed a Compact with a 17th Tribe in 1998.
The Arizona Tribal-State Gaming Compact gave Tribes exclusive rights to operate slot machines and casino
style gaming, limited the number of slot machines and casinos, established comprehensive rules governing
gaming, and set minimum internal control standards for casino operations.
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The Compact authorized the State of Arizona to ensure compliance with the Tribal-State Gaming Compact
and to work with Tribal regulators to protect the integrity of Class III gaming on Tribal lands. This first set
of Compacts was in effect from 1993 to 2003.
In the November 2002 general election, Arizona voters approved Proposition 202, which authorized the
continuation of Indian gaming. From December 2002 to January 2003, Governor Hull signed new TribalState Gaming Compact with 16 Tribes.  In 2003, Governor Janet Napolitano signed Compacts with an
additional five Tribes. The Compact with each of the 21 Tribes is substantially identical. The Compact took
effect in 2003. They last for 10 years, and can be renewed for another decade and an additional term of three
years. The Compact is part of state law in Arizona Revised Statutes Section 5-601.02.
Currently, there are 16 Tribes operating 23 Class III casinos in the State. Another 6 Tribes do not have
casinos but have slot machine rights they may lease to other Tribes. One of Arizona’s 22 Tribes (Hopi)
doesn’t have a gaming Compact.
History of Gaming Timeline
1987 Cabazon Court Case – The legal foundation upon which Indian  
gaming is built.

  

1988 Indian Gaming Regulatory Act (“IGRA”) – Congress responds to
Cabazon by enacting IGRA, which establishes the federal legislative framework for Indian Gaming.
1992 Yavapai-Prescott Indian Tribe v. Arizona – A federal district judge in Arizona rules that the State
must negotiate with the Tribe and attempt to conclude a Compact.
The Legislature establishes the State Gaming Agency within the Department of Racing.
1993 Yavapai-Prescott Case – The federal mediator chooses the Tribe’s last, best offered Compact over the
State’s recommended Compact. Negotiations follow, resulting in the “standard form” Compact.
1994 Sixteen Tribes sign Compacts and ten casinos are in operation by December 31, 1994.
1995 The Legislature creates the Department of Gaming.
The Salt River Pima-Maricopa Indian Community files a lawsuit in federal court seeking to force
Tribal-State Compact negotiations.
1996 Seminole Court Case – The U.S. Supreme Court declares provisions in IGRA, allowing states to be
sued without their consent, are unconstitutional.
A federal court judge dismisses the Salt River Court Case based on
the Seminole decision. The Tribe appeals.
Rumsey Court Case – The 9th Circuit Court of Appeals holds that
            Class III gaming is to be examined game by game and allowed on
Indian land only if permitted by a specific state law.  Based on the
Rumsey decision, Governor Symington refuses to negotiate a standard
form Compact with the Salt River Pima-Maricopa Indian Community. The Tribe’s initiative measure,
requiring the Governor to sign a standard form Compact with any Tribe seeking a Compact with the
State, is placed on the General Election ballot.
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1996

Voters approve the measure, but the law is challenged in Superior Court. Ultimately, the Arizona
Supreme Court upholds the initiative measure.
Sears Case – The Superior Court rules that the Governor of Arizona lacks the authority to negotiate a
Compact with the Salt River Pima-Maricopa Indian Community permitting slot machines and/or
keno. The decision is appealed to the Arizona Supreme Court.

1998

The Arizona Supreme Court overturns the decision in the Sears case
on the basis that Sears did not have standing to bring suit. Governor
Hull begins Compact negotiations with the Salt River Pima-Maricopa
Indian Community and signs a Compact on August 16, 1998.

2000

The Governor begins negotiating the renewal of the Tribal-State     
Compacts. Expiration of the current Compacts begin in June 2003, if not renewed.
Arizona Greyhound Case – Arizona horse and dog track owners sue Governor Hull in federal
court seeking either an injunction prohibiting the Governor from signing new Compacts or a ruling
permitting the tracks to have slot machines.

2001

The court grants the request for an injunction in the American Greyhound Case and issues a ruling
that, among other things, the State Legislature had unconstitutionally delegated its compacting
authority to the Governor, and the Tribes were not an indispensable party. However, the ruling
provides that the Governor does have the authority to continue to negotiate Compacts with the
Tribes but may not enter into new Compacts without proper legislative approval. The State appeals.

2002

January/February -- Governor Hull and 17 Tribes successfully conclude negotiations on an
agreement for the new Tribal-State Compact.
April/May -- The Governor and the Tribes take their agreement, as a resolution, to the Legislature for
approval. The Legislature fails to pass the resolution.
June/July -- The 17 Tribes gather enough signatures to put the Tribal-State agreement on the 2002
General Election ballot as Proposition 202. Two additional gaming initiatives also appear on the
ballot: Proposition 200, sponsored by the Colorado River Indian Tribes (CRIT); and Proposition 201,
sponsored by the racetrack industry.
September -- The 9th Circuit Court of Appeals overturns the decision in the American Greyhound
Case. The court rules that the Tribes are a necessary and indispensable party, and that the district
court abused its discretion in ruling to the contrary. The Court of Appeals vacates the lower court
decision and remands it with instructions to dismiss the case. The power to sign Compact is
returned to the Governor.
November -- Proposition 202 passes. Propositions 200 and 201, the
other two gaming initiatives, fail.
December 2002 - January 2003 -- Governor Hull signs new TribalState Gaming Compact with 16 Tribes.

2003

Governor Napolitano signs Compact with an additional five Tribes.

Ben Franklin helped organize and run
the Philadelphia lottery

ARIZONA DEPARTMENT OF GAMING | 22

2004

Appendix F(1) Blackjack – Revised
The revisions to Appendix F(1) allow for the play of blackjack variation games at Tribal casinos,
while keeping blackjack as the central component of any variation game and maintaining the
wagering limitations established by the Compact.
Appendix G Lotteries and Promotions
New Appendix G establishes operational standards and regulations for the play of Class III lotteries
authorized by the Compact. This Appendix also provides clear definitions for differentiating lotteries
from promotions.

2005

Appendix C Security & Surveillance – Revised
Changes to the existing Appendix C require the Tribes to develop and have in place comprehensive
Surveillance and Security Plans which meet the obligations of the Tribe under the provisions of
the Compact and its appendices. The revisions also eliminate duplication of operational standards
between Appendix C and Appendix H -Appendix H Minimum Internal Control Standards – Revised
Modifications to the existing Appendix H eliminate duplication and inconsistencies between
Appendix C and Appendix H, consolidate Minimum Internal Control
Standards for Surveillance within Appendix H, update the Appendix H
standards for new digital technology, and provide for increased
surveillance coverage within the gaming areas.

2007

Appendix F(2) Jackpot Poker – Revised
Changes to existing Appendix F(2) allow play of promotional award
poker and house-banked poker games at Tribal casinos, while keeping
poker as the central component of any variation game and maintaining
the wagering limitations established by the Compact. The revisions
also establish regulations for house-banked poker games comparable to regulations for blackjack.

2009

Gaming Compact Amendments (effective 3-25-09)

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Amendments to the Tribal-State Gaming Compact provided for the following:
Further definition of the term “Gaming Facility” under the provisions of the Compact;
Clarification to the Compact sections addressing Transfer of Gaming Device Operating Rights, Transfer
and Acquisition of Pooled Gaming Devices, and related Agreed upon Procedures Reports from Tribes;
An increase in the maximum wager on a hand of blackjack from $500 to $1,000 at up to ten card game
tables, and from $250 to $500 for all other card game tables;
An increase for a hand of poker from $75/$150 to $500 at up to ten card game tables, and from $20/$40
to $250 for all other card game tables in a Gaming Facility;
Periodic increases in wager limitations, which are adjusted on each five-year anniversary of the effective
date of the Compact based on the Consumer Price Index adjustment rate, shall be rounded up to the
nearest $5.00 increment rather than a $1.00 increment;
A waiver of the licensing requirement for vendors by the TGO, in addition to the State Gaming Agency,
if it is determined that licensing the vendor is not necessary to protect the public interest;

ARIZONA DEPARTMENT OF GAMING |23

•

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An extended effectiveness period from one year to two years from date of issuance for Tribal licenses for
Gaming Employees who are not required to have State certification or recommendation under Section
4(b) of the Compact;
Issuance, by the State Gaming Agency, of a temporary certification to an Applicant by the close of the
next business day following receipt of a complete application, unless the State Gaming Agency has a
good-faith basis to believe that the person may not qualify for State certification;
Clarification that the State Gaming Agency shall have access to investigative files of the TGO during,
and upon completion of, any investigation of an unusual occurrence or a violation or suspected violation
of the Compact, pursuant to a memorandum of understanding on information;
Clarification and establishment of a timeline for the State Gaming Agency and the Tribal Gaming
Office for issuing, responding to, and resolving disputes regarding the annual, comprehensive, Compact
Compliance Review of the Tribe’s Gaming Operation, Gaming Facilities, and Gaming Activities
conducted by the State Gaming Agency; and
Clarification regarding the time frame that Tribal contributions pursuant to Section 12(d) of the Compact
must be made.
As set forth by Proposition 202, the Tribal-State Gaming Compact shall automatically renew for a term
of ten (10) years, except in the case of substantial non-compliance.
Revisions to Appendices F(1) and F(2) and the 		
issuance of new Appendix J occurred 			
concurrently with the 2009 Tribal-State Gaming 		
Compact Amendments.
Appendix F(1) Blackjack – Revised
Clarify that the wager limitation in any blackjack game
would be applied to each single wager, based on
the approved rules of the game, rather than the total
combined amount wagered by a player during a hand.
Appendix F(2) Jackpot Poker – Revised
Clarify that the wager limitation in any house-banked
poker game would be applied to each single wager, based on the approved rules of the game, rather
than the total combined amount wagered by a player during a hand.
Appendix J Vendor Certification
Clarifies the waiver of licensing and certification for certain Persons providing Gaming Services and
certain Financial Sources.
Poker Memorandum of Understanding – Revised
Update changes in the Gaming Compact Amendments relating to the play of Poker and wager
limitation increases.
Urban Tribes State Electronic Access System MOU
Sets forth the means and manner in which the ADG will have real-time, read-only electronic access
to the Gaming Facility’s slot monitoring and control system (MCS) through the State Electronic
Access System (SEAS).

ARIZONA DEPARTMENT OF GAMING |24

Information-Sharing MOU between the Tribe and ADG
Meets the requirements of Compact Section 6(g) to enter into a memorandum of understanding
for the sharing of investigatory files and to establish efficient procedures for the distribution of such
information.
Inter-Agency Agreement between the Tribal Police Department and ADG
Provides for a process in which the Tribal Police Department and ADG may share certain
investigative information on individuals and entities involved in Indian gaming or other gaming
operations.
2012 Gaming Compact Renewal (2012-2013)
As set forth by Proposition 202, the Tribal-State Gaming Compacts shall automatically renew for a 		
term of ten (10) years, except in the case of substantial non-compliance.
2013

Two New Casinos Open in Arizona
In May, the Navajo Nation opened its first Arizona Casino, Twin Arrows, in Flagstaff.
Gila River held the grand opening of its new Vee Quiva casino in Laveen in July.

ARIZONA DEPARTMENT OF GAMING |25