Tribal Casinos, Have You Registered Your Machines?

shutterstock_760722913By: Gabriela Rios | Associate | gabriela.rios@procopio.com
Theodore J. Griswold | Partner | ted.griswold@procopio.com

In the midst of the year-end rush, and planning for holidays, it is easy for tribal gaming enterprises to overlook another annual rite for the month of December—compliance with the Johnson Act.

The Johnson Act, 15 U.S.C. §§ 1171-1178, prohibits the manufacture, possession, use, sale, or transportation of any “gambling device” in the District of Columbia, and any possession in the United States and in Indian Country. The Indian Gaming Regulatory Act (IGRA) created an exemption to this prohibition for tribes with a tribal-state gaming compact in effect.

The exemption does not apply to the registration requirements. Therefore tribes that want to manufacture, repair, recondition, buy, sell, lease, use or make gambling devices available for use by others, must register the gambling devices with the U.S. Department of Justice every year. The Request for Registration must be submitted between December 1st and December 31st each year. It can be submitted via email to oracle.grs@usdoj.gov.

The Johnson Act also requires certain records to be maintained for five years containing the gambling devices owned, repaired, leased, used, etc. including the serial number associated with the gambling device, manufacturer, and date of manufacture.

The annual registration is a simple, but important process to remember every year.

Now back to your holiday preparations!

Gabriela Rios -LJR_2938

Gabriela is an associate with the Native American Law Practice Group and citizen of the Cahuilla Band of Indians. She graduated from the James E. Rogers College of Law at the University of Arizona in 2015 and is a member of the State Bar of California.

Ted GriswoldTed is head of the Native American Law practice group and primary editor for the Blogging Circle. Connect with Ted at ted.griswold@procopio.com and 619.515.3277.