An Insiders Review Of

"WAMPUM - HOW INDIAN TRIBES, THE MAFIA, AND AN INATTENTIVE CONGRESS INVENTED INDIAN GAMING AND CREATED A $28 BILLION GAMBLING EMPIRE"

BY

DENNIS J. NELSON

With Insights and Major Commentaries by Attorney George Forman and Attorney Alan Fedman and Other Authorities

I was outraged by the assertions made by Donald Craig Mitchell in his 2016 book titled "Wampum". My perception of the creation and success of Indian Gaming is very different than the sinister portrayal set forth in his book. I offer now my observations along with invited critique from very credible authorities with diverse views from the early days to present.

I witnessed and participated in working with tribes in the early days of Indian Gaming. I worked with Menominee, Ho-Chunk, Oneida and many others, in the creation of gaming commissions, cultivating regulatory capabilities, and engaging in due diligence and licensing processes, from the ground up. Tribes started their gaming operations on the foundation of their inherent rights. At their direction we like others helped weed out the bad guys from isolated pockets of these new ventures. As president and "Private Regulator" of API Consulting and Investigations, we worked with dozens of tribes in building gaming regulatory procedures and guaranteeing their operations met a high standard. We have many war stories as hired guns for Indian tribes in the early days, but they are war stories and not the true picture.

First off, the word Wampum is disrespected and culturally misappropriated. It does not refer to money and it is insensitive to be used for this purpose. According to Debbie Thundercloud, former Oneida Chairwoman and now National Indian Gaming Association Chief of Staff, the word Wampum is an Iroquois term for "Belts of Authority", representing a persons' credentials, or verifying the authority to carry a message, or to signify the truth."

Mitchell has no authority to carry an Indian Country message, and his message lacks truth. Out of respect for this special cultural word and its message, we will avoid use of the title of the book and it will be referred to as Mitchell's book.

MITCHELL'S BOOK ALLEGES THE MAFIA STARTED INDIAN GAMING

Oh, yes, we met Gambino-influenced bad guys, both non-Indians and some Indians, but INDIAN GAMING WAS NOT STARTED BY THE MAFIA. Tribes started gaming through the inherent rights they possessed on a parity with state rights. This industry may have had its' share of organized and (unorganized) crime that tried to take advantage of tribes. The overwhelming majority of tribes for whom we worked for were diligent and vigilant in protecting assets and in managing and regulating their gaming opportunities. The majority of Indian Leaders with whom I worked led with integrity and distinction. They are heroes, not villains. We will portray a much different history in the following critique.

MITCHELL'S BOOK CLAIMS THAT INDIAN TRIBAL SOVEREIGNTY DOES NOT EXIST

In researching the early days and the landmark legal cases involving Sovereignty, I reached out to those legal pioneers referenced in Mitchell's book. Indian law icon Attorney George Forman is one of those, and with whom I had the pleasure of working. He too takes great exception to Mitchell's assertions, especially on Sovereignty and the overblown dramatization of unsavory influences.

Mr. Forman states: "Mitchell's book reveals interesting material in some isolated pockets of the emerging gaming economies of several tribes. The research, while seemingly thorough and meticulous, tends to focus more on a couple of infected trees rather than the forest. Mitchell ignores the dire economic straits of most of Indian country, the lack of employment on or near the reservations, the lack of capital and access to capital from traditional lending sources, and the relatively small up-front investment needed to yield a significant and almost immediate return (as well as employment opportunities otherwise lacking).

Mitchell exaggerates the isolated pockets of corruption that may occur when an economically depressed area is presented with an opportunity for rapid growth and prosperity, whether in gaming or other endeavors, and whether in Indian Country, Mexico, Russia, or Latin America. He tries to paint these limited instances of corruption as endemic throughout Indian country. The real story is not that a few tribes suffered from short-term corruption in some cases, but how quickly tribes identified it and sent it packing as a footnote in history.

In comparison with the evolution of Nevada and New Jersey gaming and its long and storied involvement with organized crime that, in Nevada, took more than 50 years to eradicate, those isolated pockets of Indian Country where it was a problem did so in only a few years. In fact, organized crime never established significant footholds anywhere for very long."

I witnessed and experienced this as a gaming regulator for Ho-Chunk, Menominee, Oneida, Forest County Potawatomi and elsewhere throughout Indian Country. I witnessed and participated in establishing rigorous Indian Gaming regulatory structures that emerged immediately upon adoption of IGRA and Class III Indian Gaming.

Mr. Forman notes: "No doubt there were people involved early on that might not be able to pass today's suitability standards, but the book relies more on innuendo and allegations than convictions. Being named in an FBI agent's report is not proof of anything other than suspicion, founded or unfounded. If there were shady characters involved in facilitating early development of tribal gaming, the tribes clearly shed those characters much more quickly and completely than did the non-tribal gaming industry, particularly in Nevada. Missing from the book are the success stories of the many tribes that operated without outside management companies, and have transformed not only their own reservations, but also their surrounding communities".

Former Chief of Enforcement for the National Indian Gaming Commission Attorney Alan Fedman states: "When the NIGC initiated its enforcement efforts, a primary concern was to identify situations where there was evidence of organized crime involvement. The infiltration of tribal gaming operations by organized crime had been a significant part of the discussions surrounding the passage of IGRA and was considered as serious threat to the long- term success of Indian gaming. What we found, however, was that ORGANIZED CRIME CONCERNS WERE GREATLY EXAGGERATED. It turned out that tribal gaming operations were not attractive targets for organized crime. In my opinion, this was primarily due to the fact that tribal gaming operations were owned and operated by tribal governments and the governing process made it very difficult to infiltrate tribal operations. For one thing, the leadership of the tribes was changing constantly due to election cycles. In addition, the presence of competing political groups within a tribe meant that there was a very high level of scrutiny surrounding the financial activities of the tribe. In addition, you have multi-layered regulatory oversight involving tribal, state, and federal regulators. The NIGC played a very important role in limiting organized crime infiltration. The NIGC management contract approval process involved a rigorous background investigation process which effectively screened out individuals with criminal records and criminal associations. The NIGC also quickly made it an enforcement priority to identify contracts which attempted to circumvent federal oversight. As result of this combination of factors, organized crime basically was not able penetrate tribal operations, and except in a couple of isolated incidents, there was little evidence of organized criminal activity.

I think an important step in protecting tribal operations was the formation of a Federal Indian Gaming Working Group which was a coalition of all of the agencies with regulatory and law enforcement authority over tribal gaming. On a regular basis, the NIGC, the FBI, the DOI Office of Inspector General, the Internal Revenue Service, FINCEN and the BIA law enforcement met to discuss Indian gaming related developments, to review situations where criminal activity was suspected and to share information related to such activities. This information sharing made it possible to identify suspected criminal activities quickly and helped ensure that the agency with best investigative tools took the lead on a particular matter".

From 2000 to 2006, the Federal Indian Gaming Working Group was coordinated by the FBI's Michael LeMieux. Now a private consultant, Mr. LeMieux adds: "While there will always be much work to do and room for improvement, crime related to tribal gaming generally mirrors non-tribal enterprises engaged in cash-intensive enterprises. Internal and external theft remains a primary concern, much like non-tribal gaming enterprises, but the belief that Indian gaming is commonly influenced or infiltrated by organized crime is not really supported by the types and numbers of investigations and prosecutions related to tribal gaming over the last decade. However, continued regulatory vigilance will remain key to maintaining the integrity of tribal gaming".

Indian Country in the 1990's quickly organized and united under the National Indian Gaming Association (NIGA) led by Wisconsin Oneida member and former Oneida Chairman Rick Hill. Rick Hill has been succeeded by current Chairman Ernie Stevens, Jr., providing over 25 years of stable and vigilant leadership. Ernie was a protege of Rick Hill on the Oneida council.

Mr. Stevens comes from a family of Indian leaders including his mother and father. His mother was a strong proponent of making change in Indian Country and helped lead the fight against alcohol and drugs. His Father served under the Nixon Administration and headed the historic Indian Policy Review Commission in the 70's and was the first Staff Director of the Senate Select Committee on Indian Affairs.

The stability in Tribal leadership and good government through lobbying, education, and unity is unprecedented. Indian Gaming is heavily regulated (a fact ignored by Mitchell) by multiple layers of regulation and oversight. Tribes are the primary regulators with established gaming commissions, compliance, and security staff. Tribes today are also likely to have police powers and court systems.

Linda Minash is the former Director of Indian Gaming for the State of Wisconsin, former president of the North American Gaming Regulators, and currently a Senior Consultant at API. In her role as Director in the 1990's Ms. Minash recalls her days as state regulator and observes: "As a new industry, many tribes turned to management companies to assist them in developing and managing their gambling enterprise. Management companies were back-grounded and cleared to work with tribes. The initial problems with tribal gaming were often due to corrupt management. Many tribes turned to their state and federal regulators when inconsistencies were noted.

Class III Gaming was a new industry for tribes and it took some time for staff to be trained in the complex areas of money laundering, internal controls, and organization structure. In the beginning, Gaming Commissions were often established with members being from the Tribal leadership. The tribes quickly learned the need for separation of duties and many formed separate Gaming Commissions.

Tribal gaming is one of the most regulated industries that exist. Wampum fails to identify the state and federal regulators that played a big part in the regulation of class III gaming on reservations. In many states, the state receives money for their regulation of class III gaming and the tribes are afforded the privilege of having exclusive rights to gaming. When irregularities were identified, tribes often turned to their state and federal regulators for assistance in the investigation.

For some unknown reason, tribal gaming has been singled out as the poorly run industry that invites this activity. It is obvious that the author failed to research the amount of money that tribes spend in their back-grounding of vendors to ensure suitability to work in the industry. Some vendor applications are over 140 pages long that include areas for in-depth personal information on individuals that will be working with the Class III facility" concludes Ms. Minash.

David Vialpando, a thirty-six-year State of California law enforcement veteran and current Chairman of the Santa Ysabel Gaming Commission, shares his perspective on organized crime (OC) in gaming:

"The passage of the Indian Gaming Regulatory Act (IGRA) by Congress in 1988 certainly provided an attractive prospect for traditional organized crime's involvement in tribal gaming in the United States. There were certainly isolated incidents across the country of OC's success in this area, but much like the Mafia's experience in Las Vegas during the 1940s and 1950s, regulations and legal constraints were implemented at the federal and tribal government level which prevented organized crime from realizing the control they desired. Tribal gaming quickly became a well-regulated corporate-driven industry. The impetus for the initiation of tribal gaming was, as it remains today, to provide self-sufficiency for and to strengthen tribal communities.

Based on my experience in the gaming industry, tribal gaming regulation in the U.S., with its federal government oversight through the National Indian Gaming Commission, state compact compliance, and above all else, tribal regulatory enforcement of the tribe's gaming ordinance and gaming regulations, is among the most well-regulated and honest industries in U.S. commerce today.

Unlike non-tribal commercial gaming, any corruption of tribal gaming places the tribe's assets at risk and directly harms the tribal community, including tribal government service delivery, youth programs, senior citizen resources, and the myriad components of government people come to rely on to deal with the challenges of life.

The first line of defense in keeping corruption and crime at bay is the tribal gaming regulator. I have not met a more disciplined, professional, and dedicated group of people in the gaming industry during my adult career. The wide variety of professional organizations, such as the National Indian Gaming Association and the National Tribal Gaming Commissioner and Regulator Association, are dedicated to sharing knowledge and industry best practices with the practitioners responsible for ensuring the integrity and accountability of gaming. The number of tribal gaming regulators in the U.S. outnumber many times over the combined total number of state and federal gaming regulators. By way of example, there are more tribal gaming regulators working for a single California Tribe, the San Manuel Band of Mission Indians, than the total number of California state gaming regulators. When it comes to protecting tribal gaming interests, no one does this better than those who depend on gaming revenues for the very livelihood and success of their community.

Tribal gaming regulators have historically set the standard for gaming industry best practices; from cutting-edge security and surveillance technology, to suitability backgrounds, to Internet gaming protocols, to digital employee onboarding and online compliance training", concludes Mr. Vialpando.

Through the National Indian Gaming Commission, Indian gaming is the only segment of gaming in America that has a significant federal oversight component. No other State-sponsored gaming, including Nevada and New Jersey, has this multi-layering of regulation.

Mr. Fedman notes: "Multi-layered regulation proved to be especially effective at identifying and screening out criminal activities. Tribes understandably placed a very high priority on knowing the individuals and organization present in their gaming operations. They quickly established tribal gaming commissions which were able to identify suspicious activities and take measures to ensure that tribes were the beneficiaries of their own gaming facilities. Where Class III gaming was involved, state regulators provided additional regulatory oversight and tribal and state regulators, for the most part, were able to effectively work together. On the federal side you had NIGC investigators, which served as liaison to all of the other federal law enforcement agencies with jurisdiction over Indian gaming such as the FBI and the DOI Inspector General's Office. In addition, tribes had to comply with the Bank Secrecy Act regulations which made it difficult to launder money at tribal casinos. Overall, there was just too much oversight coming from too many different directions for tribal gaming operations to be successfully targeted".

We would be remiss not to mention the creation of the National Tribal Gaming Commission and Regulators Organization, "NTGCR", which is currently led by Jamie Hummingbird. NTGCR includes regulatory and compliance staff from Tribes, and educates and facilitates information sharing within the Tribal regulatory culture.

Adds Mr. LeMieux; "As tribal gaming continues to evolve, gaming operations benefit from a growing sophistication of oversight efforts from within the tribes themselves. Having also been involved in tribal gaming in the early to mid-2000's, in my return I've noticed an improvement in compliance efforts within the tribal enterprises, along with a consistently growing number of specialized professionals dedicated to risk management and compliance efforts".

All of these positive things go grossly unmentioned by Mitchell. So what do we believe of his statements? Very little. We believe Mitchell's book is not an accurate history of Indian Gaming and it starts with the misuse of the title. The racially insensitive title, especially for a book on Indian gaming is an out of context hype against one of the most regulated and successful US Industries.

Mitchell either does not mention the highly regulated aspects of Indian Gaming or glosses over them. Instead he positions his conclusions in the book as the norm in Indian gaming operations, it covers the very early days, and in isolated instances sensationalizes the islands of lawlessness as representative of all of Indian Country in the 1980's. The result is a titillating stroke of the sensational paint brush which is substantially out of context. What concerns us is that it pretends to be the Inside Story of Indian Gaming. These provocative views into corruption pockets are used to make us believe that everything Mitchell says therefore is credible, but it is not. It is difficult to understand why Mitchell deceives us, except that he is perhaps jealous of Indian Tribes successes. He now wants to capitalize commercially himself.

One of his shallow, attention-getting passages may illustrate it best: he mentions the death of Anna Nicole Smith at Seminole Hard Rock. Mr. Forman questions; "What did that troubled woman's death have to do with Indian gaming?". Mitchell's book is much the same, offering interesting and sensationalized tidbits demonstrating exactly nothing.

Surely in the area of intellectual credibility, Anna Nicole Smith and Mitchell's book are equals. It has no relevance, nor contextual place in anything purporting to be an historical expose. What that has to do with Indian Gaming History is, quite frankly, beyond me.

This is not the true story of Indian Gaming. Mitchell begins by attacking the foundation of Indian existence.

TRIBAL SOVEREIGNTY

Mitchell claims that SOVEREIGNTY is a fictitious and artificial creation of Felix Cohen an Indian law practitioner. We went to the legal authorities who are quoted in the book and who advocated the early Indian legal victories.

Mr. Forman notes: "The notion that Felix Cohen "invented" the doctrine of inherent tribal sovereignty is nonsense. The Constitution's Indian Commerce Clause recognizes tribes as governments, and the Supreme Court recognized tribal sovereignty in numerous cases both before and after Cohen published his book. Morongo's and Cabazon's lawyers undoubtedly outlawyered the State's lawyers in the Cabazon case, but there was no trickery involved in putting together the record; we simply had better facts and did a better job of marshalling the law. The Supreme Court was persuaded to follow its precedents in determining that a State that has a lottery, profits from horse racing, and allows for-profit card rooms and a broad spectrum of charity bingo has a policy to regulate, rather than prohibit, gaming. There was nothing nefarious about what Pat Zell, Paul Alexander and Frank Duchenaux were doing on the legislative and administration fronts. The State's lawyer, Rod Walston, had a long history of being the State's chief Indian-fighter, having started with using inflammatory misrepresentations of the facts in Klamath River fishing rights cases (Mattz v. Arnett, Arnett v. 5 Gill Nets, People v. McCovey), and generally signing on to oppose and oppress tribal rights generally (Santa Rosa Band v. Kings County)."

The 1980's Bingo years are not representative of the history and journey of Indian Gaming from 1990 through 2017. The story over these three decades plus is an extraordinary journey of tribal governments asserting their inherent, the same rights as states to utilize gaming to generate revenues and create employment for their communities, ultimately building an industry that employs over 612,000 people, produces $29.5 Billion in annual revenue, and provides previously-impoverished Reservation communities with schools, health facilities, housing, water and sewer systems, law enforcement, fire protection and other municipal services unavailable from other sources, as well as supporting the surrounding communities with employment, contributions to Public Safety Roads and Infrastructure, and support for charitable causes.

Where Las Vegas revenues fill the pockets of Sheldon Adelson, Kirk Kerkorian, Steve Wynn, Carl Icahn, and other self- indulgent moguls, Indian Gaming feeds, clothes, shelters, educates, and provides for the welfare of hundreds of thousands of Native Americans. Tribal gaming is not private business, they are government business whose revenue provides for the community.

With the exception of attempting to sensationalize several tribal recognitions and a scant few episodes of corruption on a far lesser scale than what has occurred - and sometimes still occurs - in Nevada, New Jersey, and Corporate America, Mitchell fails to mention the over 200 tribal successes and in so doing, ignores and slanders the real story. Clearly Mitchells work here deviates from historic credibility and is a grab at commercial sales. Mitchell is the old wolf hiding in the sheepskin of his book pretending to be an Indian legal and historical authority. For every villain Mitchell spotlights, there are far more heroes.

To minimize and omit the history and contributions of NIGA and its leadership, the National Indian Gaming Regulators, the creation of Indian Law Enforcement departments, Tribal Courts and other elements of Indian self- governance is shameful, particularly coming from an author who purports to be an Indian legal authority and historian.

Where Mitchell goes dark let Mr. Forman again shed some light: "The notion that there are "fake tribes" ignores the genocidal history of relations between the federal and state governments and tribes. It may be true that some groups recognized as tribes today differ from their antecedents, and that some people may have attempted to create tribes as fig leaves for building casinos. It's also hard for people to accept that a tribe that has only a few members nonetheless has the same rights and status as does a tribe with thousands of members, but at least in California, many of today's tribes are the survivors of America's own holocaust, and should not be punished for having survived generations of destructive and hostile federal and state policies".

Even before the Indian Gaming Regulatory Act (IGRA)was enacted in 1988, tribal governments had established effective regulatory agencies to oversee the operation of their bingo and other gaming enterprises. Since the passage of IGRA and the establishment of the NIGC and the negotiation of tribal-state Class III gaming compacts, Indian gaming has become the most highly-regulated gaming in the entire country.

Moreover, tribes, with the assistance of law firms specializing in federal Indian law, the leadership and information-sharing venues created by the National Indian Gaming Association, as well as other State and Regional Indian Gaming Associations and other private consultants, established effective Indian Gaming Tribal Gaming Commissions, Compliance personnel and Audit and Enforcement capabilities to regulate under strict Minimum Internal Controls.

Mr. LeMieux observes: "Tribal gaming benefits from regulation from an informal, yet powerful, source in the form of the general tribal membership of those gaming tribes. Unlike non-tribal enterprises, which are primarily governed by shareholders, employees, and government authorities, tribal gaming enterprises also typically exist under the scrutiny of an engaged community of tribal members who are more than willing to point out violations related to gaming or gaming revenues. This informal, public oversight remains a significant source of reporting of suspected criminal violations, and especially those that concern leadership or management of gaming enterprises".

Procedures outlined by IGRA for Licensing Management Companies, Vendors, and Key Personnel were put into practice and most often Tribal Gaming Ordinances and regulation exceeded the IGRA standards.

The tribes of Wisconsin are excellent examples of how self-regulation began to institute processes of improving integrity of operations and screening out those financiers and operators who filled the void of pre-IGRA Indian Gaming, when financing from banks and other traditional sources were non-existent or financially unfeasible.

The History of Ho-Chunk Gaming is a prime example of a tribe exploited by corrupt influences, but through assistance from State/Federal and Private Resources took a worst- case scenario - infiltration by Chicago-area Management Companies, i.e. Glenn Corrie and Jenna Corp, and turned it into a shining example. I played a role in this story as Acting Compliance Director.

Adversaries to Indian Gaming wanted scandals to take to Congress, adversaries at that time included New Jersey gaming mogul Donald Trump and others.

Ho-Chunk was one such tribe in the media and political spotlight.

By 1990, Jenna Corp managed Ho-Chunk Nation's casinos (then Wisconsin Winnebago). Corrie and Jenna Corp bribed tribal leaders in many instances and in the instance of Ho-Chunk, rendered the tribe dysfunctional. The Ho-Chunk were governed by a twelve-member Council, six members of which were controlled by Corrie and became known as the "6-Pack". The tribe could not function for lack of a quorum.

U.S. Federal Western District of Wisconsin Judge Shabaz determined that Tribal Chairwoman Joanne Jones was the lawful Chairwoman and issued an order conditioning that the tribe could only operate gaming facilities if steps were taken to rid the organization of corrupting influences.

As acting Director of Compliance and working alongside dedicated and tireless gaming commission staff we established regulatory framework and procedures. Many Wisconsin tribes adopted the Ho-Chunk licensing models and received training.

Political enemies of Indian Gaming wanted a scandal, but Indian Gaming in this instance and many others showed that they could regulate their own industries.

The success of the Ho-Chunk experience was culminated at the Senate Committee hearings on Indian Affairs led by Senator Innouye and Senator McCain, when Chairwoman Joanne Jones testified to the Ho-Chunk story as going from dysfunctional and failing, but with selfdetermination and the assistance of Arthur Anderson and API, Ho-Chunk was able to succeed without the help of State or Federal authorities. Tribes were self-regulating. Chairwoman Jones was one of the Indian Tribal leaders who was a hero.

Meanwhile in California, Mr. Forman points out that whatever may have happened elsewhere, the book's account of Morongo's development gave short shrift to the aggressive and proactive role the tribe played in identifying and rooting out problems so as to protect both tribal assets and the rights of its patrons, and setting standards for management contracts and gaming regulation that became national benchmarks.

Mr. Fedman adds: "The adoption of minimum internal control standards was critical to ensuring the financial integrity of tribal casinos. The standards covered every significant aspect of the casino activities and were very useful in identifying suspected misappropriations of tribal gaming revenues. Both tribes and the NIGC adopted such standards which were backed up by compliance audits conducted by CPA firms. The utilization of these standards elevated the quality of tribal regulation and placed it on par with the best regulated casinos in Nevada and New Jersey. By the time it happened, however, tribes had adopted their own Class III internal control standards which limited the damage".

At the same time other tribes in Wisconsin and around the Country like Wisconsin Oneida, Menominee, Forest County Potawatomi, and tribes throughout Indian Country like Shakopee, Sycuan, Morongo, Saginaw Chippewa, and many others were establishing competent gaming regulatory resources.

Revenues from these economic engines were invested heavily in security and surveillance systems, and trained personnel to protect tribal assets and the integrity of Indian Gaming.

Where once Las Vegas interests fought to destroy Indian Gaming, Las Vegas has come to Indian Country through Caesars, Station Casinos, and others. G2E now shines a spotlight on Indian Gaming. The University of Nevada Las Vegas and the American Gaming Association seeks engagement with Indian Country.

The likes of IGT, Aristocrat, and other major gaming technology and suppliers now count Indian Country as a vital share of the revenues.

"Mitchell's book" weaves sensational anecdotes around misinformation and out of context with the larger story of the emergence of Indian gaming. Its foundation is built on an erroneous definition of sovereignty. In a time of political correctness and inclusiveness, it is disheartening that popular culture and endless news organizations and congress can be so dismissive, and be so in the dark.

The 2015 GAO study to Congress on Indian Gaming Regulation completely omits input from the Tribal regulatory side which is very substantial. Mitchell's book is even worse because it not only omits the positive but slanders the truth. Some adversaries to Indian Gaming remain and offer proof that Indian Gaming must continue to tell its successful story of Success with Integrity and intensive oversight.

We call out Mitchells printed drama as insensitive "Fake News". A counterfeit historical diatribe.

End of Story.

I wish to thank George Forman, Alan Fedman, Michael Lemieux, Linda Minash, David Vialpando, Carl Artman and the staff at NIGA for their support.

I remain vigilant,

Dennis J. Nelson
June 2017

About the Author:
Dennis J. Nelson is President of All Points Intel, Inc., offering Diligence and Vigilance, and CEO of GoldenEye Identity Solutions. He is a career Gaming Regulator, Financial Compliance Consultant, Independent Investigator, and Gaming and Entertainment Entrepreneur. He is founder and creator of Veridocs whose Identity Solutions operate globally. He is the author and producer of: Indian Gaming and Its Impact on Law Enforcement in Wisconsin copyright 1996. dnelson@api-inc.com - www.api-inc.com - 1.800.236.5202

About George Forman:
Mr. Forman is a Founding Partner in Forman & Associates in San Rafael, California. He began his Indian law experience with California Indian Legal Services (CILS) in 1970, and over the ensuing 15 years served as a staff attorney, directing attorney, executive director, litigation director and director of a special untermination and recognition project. Mr. Forman taught Indian law for ten years as an Adjunct Professor at U.C.'s Hastings College of the Law in San Francisco, and has been a presenter at the annual conferences of the Environmental Law Section of the California State Bar, at several conferences of the California District Attorneys' Association, at Indian Financing Conferences, the Earl Warren Inns of Court in Oakland, meetings of various tribal organizations and trade associations, and in state and federal legislative hearings, where he has shared his knowledge of jurisdiction in Indian country, tribal government gaming and other related issues. Mr. Forman handled the first contested hearing of a Notice of Violation before the National Indian Gaming Commission, negotiated both new gaming management agreements and the termination of existing agreements in California, Washington State and Michigan, and has advised and represented tribes in all aspects of the establishment and operation of tribal gaming enterprises, gaming regulatory bodies and other transactions.

About Alan Fedman:
Mr. Fedman is a member of Dentons' Public Law practice in Washington D.C., and the former head of the Firm's Native American Law and Policy practice. He is the former director of enforcement of the National Indian Gaming Commission (NIGC). He is well versed in the legal issues involved in NIGC investigations and compliance audits and has substantial experience in handling NIGC administrative appeals. He also represents Indian tribes in matters before the US Department of the Interior. While serving at the NIGC, Mr. Fedman directed a national field staff regulating 400 Indian gaming operations responsible for protecting the financial integrity of tribal gaming operations and keeping Indian gaming free from criminal influence.

About David Vialpando
Mr. Vialpando is a thirty-six-year law enforcement veteran, with twenty-seven years as a Special Agent with the California Attorney General's Department of Justice (DOJ). For the last seven years of his career, Dave was assigned to the Bureau of Gambling Control where he served as the Special Agent-in-Charge of the Bureau's southern California offices, responsible for regulatory oversight of all tribal and commercial gambling establishments.

In 2012, he was appointed Chairman of the Santa Ysabel Tribal Gaming Commission, for the Iipay Nation of Santa Ysabel. Mr. Vialpando also serves on the Board of Directors of the National Indian Gaming Association, Tribal Gaming Protection Network. In 2017, Mr. Vialpando joined the innovative team at OnCourse Learning, an online education and compliance training provider, as Director of Gaming Programs.

About Michael LeMieux
Mr. LeMieux has over 23 years of federal experience and is recently retired from the Federal Bureau of of Investigation. He has served in management positions at the FBI Indian Country Unit and as a Supervisory Instructor at the FBI Academy. Mr. LeMieux has also served as the coordinator of the Federal Indian Gaming Working Group and a Joint Terrorism Task Force. Mr. LeMieux currently operates Whiteriver, LLC a consulting, risk management and training firm.

About Linda Minash
Ms. Minash is the Former Director of Indian Gaming for the State of Wisconsin Division of Gaming and has also served as President of Gaming Informatics. Ms. Minash is past president of The North American Gaming Regulators Association. Ms. Minash currently serves as a senior consultant for All Points Intel, Inc.