State Certifications

The product and type of goods or services the vendor intends to provide to the tribe determines the scope of ADG’s investigative process. Companies classified as “A” or “B” vendors, as described in this website, undergo in-depth background investigations to determine their suitability for State Certification. Such vendors include, but are not limited to:

• Manufacturers of Gaming Devices
• Financiers
• Distributors of Gaming Device Component Parts
• Surveillance Equipment, and
• Other products that are closely associated with the operation and management of a gaming facility.

Companies classified as “D” vendors, as described in this website, undergo less scrutiny because their goods or services are generally not directly involved with the operation or management of the gaming facility.

However, as with all investigations “…the State Gaming Agency shall retain the right to conduct additional background investigations of any Person required to be licensed or certified at any time while the license or certification remains valid.” Section 5(b)(3)*

*References the Tribal-State Gaming Compact and Appendices

To apply for State Certification, vendors need to take the following initial steps:

1. Sponsorship Letter

   The Gaming Facility Operator (“GFO”) notifies the Tribal Gaming Office (“TGO”) of its intent to purchase supplies/services that would require certification of a Vendor. The TGO forwards a letter of sponsorship to ADG.

2. Inquiry Letter Sent to Vendor
   Upon receiving the sponsorship letter from the TGO, ADG sends an inquiry letter to the vendor’s contact person requesting information to determine the classification of the vendor. Classification (Class A, B, or D) determines the type of application to be completed for the certification process.

3. Application Forms
   Based on the information provided by the vendor in response to the inquiry letter, such as the structure of the business (corporation, limited liability company, partnership) and the type of goods or services being provided, ADG sends the vendor the appropriate application packet, which includes the following forms,* or directs the vendor to the on-line forms:

*This list is for information only. Based on a vendor’s classification, ADG will email appropriate applications, including a request for additional information, to a prospective vendor once Steps 1 and 2 are completed.

1. Case Assignment
   The ADG Vendor Intake Officer routes the file internally for review and assignment.
   • If the vendor Applicant is Class A or B, the file is assigned to an Investigative Team comprised of a Special Agent and a Financial Investigator.
   • If the Applicant is a Class D vendor, the case is assigned to a Investigator/Special Agent.
2. Temporary Certification
   Temporary Certification allows a vendor to conduct business with the sponsoring tribe(s) during the time necessary for ADG to conduct an in-depth background investigation. ADG has 20 days from receipt of a complete Application to issue a Temporary Certification “…unless the background investigation undertaken by the State Gaming Agency discloses that the Applicant has a criminal history, or unless other grounds sufficient to disqualify the Applicant pursuant to subsection (f) of Section 5 are apparent on the face of the Application.” Section 5(n)*:
   • ADG notifies applicant and sponsoring tribe that Temporary Certification has been granted.

   Any tribe, other than the sponsoring tribe, desiring to use a vendor who has received a Temporary Certification may request from ADG an extension of the temporary certification to their tribe. Also, the vendor may submit a written request to ADG to transact business with a tribe(s) other than the sponsoring tribe.

3. State Certification

   After issuance of the Temporary Certification, the Investigator/Investigative Team conducts the necessary in-depth investigation to ensure suitability of the Applicant. This will include a review of the finances of the vendor and key management personnel (cursory or in-depth depending on the vendor’s class) and may entail visits to the headquarters and manufacturing facilities of Class A or B vendors and in-person interviews of key management personnel, including but not limited to CEO’s, CFO’s, COO’s, etc. Upon completion of all necessary steps, the Investigator(s) document the findings and make a recommendation to management. After review and discussion, a final determination is made regarding State Certification.

   • ADG notifies applicant and sponsoring tribe that State Certification has been granted or denied.
4. Certification is for Two Years

   State Certification expires on the last day of the month two years from the date it is initially issued or subsequently renewed. If the vendor intends to continue providing services exceeding $10,000 per month, it must renew its certification. However, if a vendor provides services to the tribe at less than $10,000 per month, vendor may be eligible for short form application.
   
   It should be noted that the $10,000 per month amount does not apply to Class A vendors who must be certified irrespective of the dollar amount of services being provided.
   
   A vendor that has applied for renewal may continue to provide a product or service under the expired certification until ADG takes action on the renewal.

5. Certification of Vendor Employees

   With respect to Vendor Certification, there are two types of individuals who are required to obtain State Certification:

   1. Employees of Management Contractors. Section 4(c)*
   2. Those vendors who employ individuals in gaming facilities who have unescorted access to secure areas, for example, check cashing, cleaning contractors, food and beverage contractors. Section 4(b)*
      The background investigation of these individuals is conducted by ADG’s gaming Employee Certification Unit.
   3. Vendors who employ individuals in gaming facilities who require or are authorized access to restricted areas of a gaming facility not otherwise open to the public must be licensed by the Tribal Gaming Office.

    

*References the Tribal-State Gaming Compact and Appendices

Listed vendor classifications are not described in State Statute, Arizona Tribal-State Gaming Compacts (Compacts), Rule-Making Authority or ADG Regulation. ADG created and provides these classifications solely to assist vendor applicants in navigating the types of gaming vendors they provide to the gaming industry, required application forms, and ADG’s Investigative Process.

State Certification Fees
Pursuant to Section 5(l)(2), 5(l)(3) and 5(l)(4) of the Compacts, every vendor requesting certification or renewal of certification shall pay the following fees:

In addition, if the actual Investigation costs exceed the listed fees, ADG will bill the vendor Applicant for such costs during the Investigation. Payment in full to ADG shall be required prior to its issuance of State Certification. Section 5(l)*

Pay Online

*References the Tribal-State Gaming Compact and Appendices

Management Contractor

Any natural person or entity that has entered into a management contract with the Tribe or Gaming Facility Operator, which has been approved pursuant to 25 U.S.C. §§ 2710(d)(9) and 2711, shall be required to obtain State Certification prior to providing such management services. Section 2(ddd); Section 4(c).*

Financiers
Any natural person or entity that extends or guarantees any third party financing for the Gaming Operation and/or Gaming Facilities shall be required to obtain State Certification annually, unless said Person is an agency of the United States or a lending institution licensed and regulated by the State or the United States. Section 3(s); Appendix J*

Manufacturers
Any natural person or entity that manufactures, produces, or assembles a Gaming Device, component or software and who intends to furnish it to a Distributor, supplier or the Tribe must be state-certified prior to the sale or lease of such. Section 2(eee), 4(d); Appendix A, Part 1, Chapter 1(24)*

Distributors
Any natural person or entity that obtains a Gaming Device, component, or software from a Manufacturer or supplier and intends to furnish it to the Tribe must be State Certified prior to providing the product to the Tribe. “Component” means any part deemed sensitive and critical to the operation of a Gaming Device that affects the play of the game, outcome of the game, player safety or the Monitoring and Control System, and includes the parts listed below. All such parts that are shipped to the Tribe must include a copy of an independent gaming laboratory approval that meets Arizona standards and that is approved for use as a replacement for the type of Gaming Device being repaired. Section 2(cc), 4(d); Appendix A, Part 1, Chapter 1(10)*

Class A Related Products/Components
Following is a list of gaming related products/components that would require certification under either Manufacturer or Distributor Classification:

• Processor boards
• Reel strips
• Belly Glass that defines pay tables
• Any software or hardware for any Gaming Device or progressive systems, to include wide area
• EPROM chips
• Toppers/top boxes
• Any logic or interfacing boards that interact with the Gaming Device
• Online Game Management Systems that communicate and receive information directly from Gaming Devices and ticket redemption devices, including online electronic bonusing and promotional systems
• Host or incentive systems
• Bill validators and/or software
• Retro Fit Kits that convert a cash/coin device to cashless
• Kiosks, Cashless ticket acceptors, dispensers, and ticket redemption devices
• Mother boards
• Most peripherals (CCOM’s, ADSC’s and CVT’s)
• Optic Sensors
• New or upgraded software that introduces new program/technologies to the bill or ticket acceptor
• Communication boards
• New Spectrums
• Magnetic Sensors
• New or upgraded equipment for bill or ticket validation
• Credit/Debit Card Acceptors-Electronic Fund Transfer
• Coin Acceptor

Note: Any component parts not listed above, that perform the same or similar function, shall meet the same standards. The above list is not intended to be all-inclusive.

Providers of Blackjack and Poker Equipment and Gaming Supplies
Any Manufacturer, Distributor, or Supplier of Playing Cards, Shufflers, Chips, Tokens, all card tables and associated equipment, shall be state-certified. Appendix F(1), Section II (L), (M)(1), (S)(2)(a); Appendix F(2), Section II (L) and (M)(1)*

Shufflers, chips/tokens, playing cards, blackjack, and poker tables may be distributed by state-certified Class A vendors as long as the Manufacturer is also state-certified. Playing cards that have imprinted on them the name and/or logo of the gaming establishment may be distributed by state-certified Class A vendors as long as the playing card manufacturer is also state-certified as a Class A vendor. Manufacturers or distributors providing playing cards that do not have imprinted on them the name and/or logo of the gaming establishment would require State Certification only if the dollar amount exceeds $10,000 in any given month.

ADG approved Blackjack/Poker table layouts (felts) and Class III Games (intellectual property) may be distributed by state-certified Class A vendors.

Blackjack Table and Card Table Manufacturers and Distributors (without felts) would require State Certification if the dollar amount exceeds $10,000 in a given month.

Providers of Keno Equipment and Software
Manufacturers, Distributors, and suppliers of Keno equipment (including component parts of a Keno system which affect game play or outcome including Keno balls and Keno ball and number selection devices) shall be required to obtain State Certification prior to providing services.

In addition, software, including a game management system that provides logging, searching, reporting of significant events, collection of financial data, display and verification of winning cards shall be required to obtain State Certification prior to providing services.

Note: State-certified Class A vendors may distribute keno equipment and component parts as long as the Manufacturer is also state-certified as a Class A vendor.

Providers of Class III Games (Intellectual Property)
Any natural person or entity that provides new game variations, including but not limited to: blackjack and poker game variations must be state-certified. A provider may include the game developer, the holder of intellectual property rights or other legal rights to the game, and anyone who has, or will have, rights to share in the profits, proceeds, royalties, commissions or other profits generated by the sale, lease, placement, or distribution of the game to an Arizona gaming Tribe. Appendix F(1), Section II (L); Appendix F(2), Section II (L); Poker MOU, Section II(L)*

* References The Tribal-State Gaming Compact and Appendices

Providers of Ticket Redemption Kiosks
Any Manufacturer and/or Distributor of ticket redemption kiosks or any device which uses bi-directional communications to the ticket-in ticket-out system and/or slot monitoring and accounting system for cash redemption or exchange for tokens must be state-certified.

Note: State-certified Class A vendors may distribute ticket redemption kiosks or any device using bi-directional communications as long as the Manufacturer of such devices is also state-certified as a Class A vendor.

*References the Tribal-State Gaming Compact and Appendices

Providers of the following goods and services must be state-certified in accordance with Section 4(d) of the Tribal-State Gaming Compact if the dollar amount of these goods or services provided to the tribe is higher than $10,000 in a single month.

Security devices or surveillance systems
Any security device that includes a locking device and/or any component that would be associated with accessing areas in a Gaming Facility, including any type of electronic device that monitors, records data and/or provides alert warnings to areas in and outside the Gaming Facility. A surveillance system would be any combination of computer hardware and software, and any electronic device used by the gaming operation that monitors, records and/or tracks information. This would include the design, installation, and maintenance of such security devices and surveillance systems. (Appendix C, Section G)*

Currency Handling Equipment
Any cash, coin or ticket/voucher counting device; any type of cash, coin or ticket/voucher transporting device; any type of cash, coin or ticket/voucher storage device; cash register and any type of ATM and/or electronic debit or credit device providing cash withdrawals, change, or that records a transaction of the user’s bank account.

Check Cashing Services
Any check cashing, cash advance, debit or credit card advance and/or any service that advances cash or credit through the service provided. Further, any employee of the check cashing vendor who works in the Gaming Facility and has unescorted access to secure areas must be state-certified.

Gaming Data Analysis Software/Systems
Any player tracking or table games monitoring and security system. Any software or software system that interfaces with a slot or table games monitoring and accounting system or player tracking system, and which extracts data/information from these systems in a one-way, read-only methodology.

Providers of “Gaming Vendors” that do not fall into the Class A or B vendor category must obtain State Certification if the value of the gaming vendors is in excess of $10,000 in any single month. Gaming vendors are defined as “ the providing of any goods or services, except for legal services, to the Tribe in connection with the operation of Class III Gaming in a Gaming Facility, including but not limited to equipment, transportation, food, linens, janitorial supplies, maintenance, or security services for the Gaming Facility…”

Threshold Amount
The Compact establishes a threshold amount of, “each Gaming Vendor providing goods or services in excess of $10,000 to the Tribe in any single month…” Section 4(d)(1)

Thus, if a vendor exceeds the threshold in any single month, the vendor is required to be certified. The threshold amount should be calculated only for the Tribe with which the vendor intends to do business. In other words, if a vendor provides less than $10,000 per month in goods or services to a Tribe, then the vendor does not need to be certified to provide those services to that particular Tribe.

*References the Tribal-State Gaming Compact and Appendices

Gaming Facility Construction and Remodel
General Contractors/Contractors providing new construction or major remodeling of a Gaming Facility, regardless of who provides the funds.

General Contractors/Contractors/Sub-Contractors
During new construction or major remodeling of a Gaming Facility, subcontractors working for a general contractor should be disclosed to the TGO and the ADG.

Any subcontractor, except as noted, who is performing new construction or remodeling of a Gaming Facility that contracts through a general contractor, and that general contractor is certified by ADG, will not require State Certification.

Subcontractors classified as a Class A or Class B vendor will require State Certification. Those subcontractors providing security, surveillance equipment or security services will require State Certification.

Architects, that contract directly with the Tribe, or through a General Contractor or Contractor, will require State Certification.

Each Gaming Vendor providing goods or services between $1,000 and $10,000 to the Tribe in any single month, and each provider of Ancillary Services in an amount in excess of $2,500 to the Tribe in any single month, shall be certified by the State Gaming Agency using a Short Form Application. There is no fee associated with the certification of a short form applicant.