Hafa Adai and Tirow!

On behalf of the Commissioners of the Commonwealth Casino Commission (CCC), it gives me great pleasure to present the CCC’s official website. This site covers our operations for the fiscal years beginning October 24, 2014 through September 30, 2018. The CCC has come a long way since it was first established, in name only, on April 1, 2014 through the signing of House Bill No. 18-182 that became Public Law (PL) 18-43—subsequently repealed and reenacted by Public Law 18-56. Later that year, Commissioner Alvaro A. Santos, Commissioner Joseph C. Reyes and I were appointed and confirmed by the 18th Saipan and Northern Islands Legislative Delegation. After our confirmation and since we met quorum requirements, the CCC was officially established. We hit the ground running and conducted our first CCC meeting in November of 2014, adopted Bylaws in December of 2014, hired the CCC’s first employee in January of 2015, and further continued our growth and development.

Given our non-gaming backgrounds, but with strong fundamentals in finance, administration and business management, the Commissioners and I made it a high priority to quickly seek gaming education and reached out to the University of Nevada, Las Vegas’ International Gaming Institute for a crash course in the gaming industry tailored to new gaming regulators in April of 2015. From there, we began laying the foundation of the CCC’s regulatory framework for our casino gaming industry.

In retrospect, the CCC has made significant progress these past years of operations. Today, the CCC has succeeded in establishing its Casino Rules and Regulations, Title 175 of the CNMI Administrative Code, and adopted a robust Minimum Internal Control Standards (MICS) that our exclusive casino gaming licensee, Imperial Pacific International (CNMI), LLC (IPI), must adhere to. In addition to the federal and CNMI statutes, these CCC policies provide the governance over the powers and duties of the CCC and the guidance over operations and procedures for the casino gaming industry.

The CCC has grown into an agency of forty (40) professionals across its various divisions—Executive Division of Permit & Licensing, Division of Enforcement & Investigations, Division of Compliance, and Division of Audit. It has built a professional network of resources including casino gaming regulators from other jurisdictions, casino industry professionals, and casino academics. The CCC will continue to develop both its staff and regulatory policies that will further enhance the CCC’s capabilities to effectively oversee and regulate the casino gaming industry on Saipan.

IPI began its operations with the opening of Temporary Live Training Facility at the Duty Free T-Galleria Shopping Mall on July 26, 2015 and subsequently relocated to its permanent Initial Gaming Facility at the Imperial Pacific Resort Hotel (Imperial Palace) in Garapan on July 6, 2017. Since the beginning of its operations to September 30, 2018, IPI has generated a total of $165.8 million in Gross Gaming Revenue Taxes owed to the CNMI Government. Additionally, IPI disbursed $953.7 million in payments of goods and services to vendors, suppliers and for wages and salaries. The CNMI Government has also received $75 million from IPI for payment of the exclusive annual casino license fee as well as $9 million in Casino Regulatory fees for the CCC up September 30, 2018. IPI has also contributed $10 million to CUC residential customers for their respective utility charges.

In July 31, 2017, the Casino License Agreement (CLA) Amendment No. 5 was executed which required IPI to begin making the payments of $20 million in Community Benefit Fund; the first $10 million was due no later than January 1, 2018 and the remaining $10 million was due no later than June 1, 2018. Pursuant to the amended CLA, the casino operator or Licensee is required to make an annual Community Contribution payment of $20 million on or before October 1st of each year which shall begin in 2019 until the expiration of the CLA. The $20 million is to be used to fund various community programs which include education, scholarships, infrastructure, health care, employee retirement benefits, and others as determined by IPI in consultation with the Governor.

A substantial amount of government revenues are being generated through taxes and fees from IPI, the casino operator. As a result, the CNMI government is now able to pay for the retirees’ pension, outstanding land compensation, infrastructure, increase funding for public education, healthcare, CUC and other vital public services.

The casino gaming industry is not a perfect industry and while it brings economic prosperity to the CNMI it could potentially bring with it unwanted activities such as money laundering, theft, collusion and problem gambling.

The CCC exercises great diligence in supervising, monitoring, and investigating activities of the casino operator. It implemented measures and performs within its power to prevent and eliminate illegal activities in all areas including within the casino floor. In this effort, and as part of the licensing requirements, the CCC mandated all employees, major shareholders, directors and anyone dealing with the casino to undergo training and certification in Anti-Money Laundering (AML) from a recognized service provider or from an accredited institution. AML training and certification is compulsory and a requisite for licensure by CCC. The CCC cannot overemphasize the importance of compliance with the U.S. Bank Secrecy Act (BSA) and AML Sections of Title 31 of the U.S. Code. The success of the casino industry in the Third Senatorial District is contingent upon its compliance with CNMI and federal regulations and laws.

On October 1-5, 2017, Commissioners, staff, and management level representatives from IPI, attended the National Council on Problem Gambling conference, sponsored by the National Center For Responsible Gaming. The CCC took the opportunity to network with service providers in the area of problem gambling. Given the CNMI’s problem gambling history with Poker and Pachinko parlors, the CCC recognizes the need to develop similar “problem gambling” programs currently in existence in other jurisdictions. This initiative should be a joint effort between the CNMI government and the casino operator (IPI) to support and fund the program. Problem gambling is a significant community concern and must be dealt with effective collaborative efforts.

The CCC has made proposed changes to Public Laws 18-56 and 19-24. This effort is currently undergoing Senate review and action. The House of Representatives unanimously approved House Bill 20-82 HD1 entitled “To further clarify the powers of the Commonwealth Casino Commission and to make needed changes to the Commonwealth Code given the unique regulatory oversight of the Casino Industry in the Commonwealth; and for other purposes” in May of 2018. The proposed changes seek to provide additional regulatory authority to CCC thus reflecting new gaming industry standards, regulations and specific autonomous functions of the agency.

On August 24, 2017, one of IPI’s Service Provider, Gold Mantis Construction Decoration (CNMI), LLC, was issued a stipulated order by the CCC to pay a fine in the amount of $192,000 for not complying with licensing application requirements.

On October 26, 2017, IPI was assessed a penalty in the amount of $115,000 for not complying with the Commission’s Minimum Internal Control Standards (MICS) . The MICS is a set of detailed policies and procedures established and comprising of Key Control, Rules of the Game, Table Games, Electronic Gaming Devices, Poker Rooms, Drops and Counts, Casino Cashiering and Credit, Casino Accounting, Admissions and Ticketing, Currency Transaction Reporting, Internal Audit, Surveillance, Security, Purchasing and Contract Administration, Excluded Persons, Self-Exclusion, Forms, Management Information Systems, Tips, Cashless, Promotional, and Bonusing Systems, and Server-Supported Game Systems.

In closing, the CCC continues to invest in training for CCC members, management and staff to enhance knowledge of new standards, industry best practices and evolving technologies in casino gaming that includes the latest software, hardware, equipment, games, and other facets of the industry such as activities that involve criminal elements. The CCC wants the casino gaming industry to succeed in the Third Senatorial District of Saipan within the parameters of federal and CNMI laws. In the spirit of cooperation, collaboration and transparency, the CCC wishes to see continued support of the casino gaming industry to the CNMI economy through job creation, increased tourist arrivals, government/private partnership, increased investments into the islands, and improved quality of life for the people of the CNMI.

I encourage you to take the time to review this website and to give us a call at 670-233-1857/8 or visit us at our office at the Springs Plaza in Gualo Rai, should you need more information or require further clarification.

On behalf of the Commissioners, thank you for taking the time to visit our new site.

Best Regards,


Juan M . Sablan