Florida Tribal Casino License – Complete Regulatory Analysis and Compliance Guide

Florida Tribal Casino License – Complete Regulatory Analysis and Compliance Guide Licenses

The Florida Tribal Casino License operates exclusively under the authority of the Seminole Tribe of Florida through the Seminole Tribal Gaming Commission (STGC), governing Class III gaming on tribal lands per the Indian Gaming Regulatory Act (IGRA) and the Tribal-State Gaming Compact. This framework grants the Seminole Tribe exclusivity for casino-style games including slots, table games, and sports betting via Hard Rock Bet, distinguishing it from state-regulated commercial gaming. Gambling databases research team confirms the STGC as the sole issuer for operators within Seminole facilities, with state oversight limited to compliance monitoring.

Gambling databases team
Gambling databases team
Ask Question
Key benefits include market exclusivity in Florida's $10+ billion gaming sector, federal preemption over state laws, and revenue sharing exceeding $2 billion to the state since 2010. The license targets tribal-affiliated operators and vendors supplying Seminole casinos, offering stable access to seven facilities generating substantial Class III revenue. This analysis draws from official compact documents, STGC policies, and federal IGRA standards for operators, legal experts, and compliance professionals.

Article scope covers regulatory foundations, financials, operations, strategic advantages, and practical guides based on verified sources including the 2021 compact amendment. Target audience includes potential vendors, tribal partners, and compliance officers seeking operational entry. Methodology prioritizes primary documents from STGC, Florida Gaming Control Commission (FGCC), and National Indian Gaming Commission (NIGC).

Contents

📊Executive Dashboard

CategoryMetricDetails
Regulatory FoundationIssuing JurisdictionSeminole Tribe of Florida (Tribal Lands)
Regulatory BodySeminole Tribal Gaming Commission (STGC)
Legal FrameworkIGRA (25 U.S.C. § 2701 et seq.), Seminole Tribal-State Compact (2021)
Market CoverageExclusive Class III gaming in Florida (slots, tables, sports betting)
Financial RequirementsVendor License Fee$250 annual renewal (non-refundable)
Capital RequirementsTribal-determined; proof of funds for vendors
Financial GuaranteesBackground investigation required; no fixed bond specified publicly
Compliance StandardsAML RequirementsTribal internal controls per NIGC MICS
KYC ProceduresEmployee/vendor background checks
Data ProtectionTribal policies aligned with federal standards
Reporting ObligationsQuarterly vendor updates to STGC
Technical SpecificationsSoftware CertificationNIGC-approved labs for RNG/Class III games
RNG TestingOngoing per compact and tribal code
Security StandardsSSL/TLS; tribal cybersecurity protocols
Operational ParametersGame Types CoveredSlots, blackjack, craps, roulette, poker, sports betting
Betting LimitsTribally set; compact exclusivity
RTP RequirementsNIGC standards; monitored internally
Payment SystemsTribal-approved providers
Legal FrameworkBackground ChecksAll directors, shareholders 5%+, employees
Audit RequirementsSTGC and state SCA inspections
Dispute ResolutionTribal courts; compact patron claims process
Market AccessGeographic ScopeFlorida tribal lands + online sports betting statewide
Tax ObligationsTribal sovereignty; state revenue share from compact
Marketing RestrictionsResponsible gaming disclosures required
Innovation SupportTechnology AdoptionSports betting app (Hard Rock Bet); emerging games per compact
Cryptocurrency SupportNot specified in compact; tribal discretion

The Seminole Tribe of Florida holds sovereign authority over Class III gaming on its lands under IGRA, preempting state jurisdiction except as specified in the Tribal-State Compact. Political stability supports long-term operations, with the tribe managing seven casinos amid Florida’s restrictive commercial gaming laws. Seminole Tribal Gaming Commission (STGC) enforces the Seminole Tribal Gaming Code, approved by NIGC.

The 2021 compact amendment, ratified by the U.S. Department of Interior, authorizes slots, table games, and online sports betting exclusively for the tribe. Legislative history traces to 2010 compact, challenged in courts but upheld, granting market exclusivity. Gambling databases analysis reveals no other Florida tribes hold equivalent Class III rights; Miccosukee operates under federal jurisdiction only.

Primary legislation roots in IGRA § 2710(d), requiring tribal ordinances, state authorization, and compacts for Class III gaming viability.

Geographic reach covers Seminole reservations in Hollywood, Tampa, Immokalee, Coconut Creek, Brighton, and Big Cypress. Cross-border operations limited to Florida; compact bars new facilities without state notice. International recognition stems from NIGC oversight and compact as model for tribal exclusivity.

Regulatory cooperation occurs via Florida’s State Compliance Agency (SCA), now under Florida Gaming Control Commission (FGCC), conducting audits per compact Part VI. NIGC monitors Class II/III compliance federally. No formal treaties beyond U.S. domestic framework.

STGC reputation centers on asset protection and integrity, with governance by tribal council oversight. International gaming organizations acknowledge Seminole operations as benchmark for U.S. tribal gaming.

Contact TypeDetails
Physical Address6300 Stirling Road, Hollywood, Florida 33024
General Phone+1 (954) 966-6300
Official Websitewww.semtribe.com/services/gaming-commission

License Application Process, Qualification Criteria, and Timeline Management

Vendor licensing targets suppliers to Seminole gaming facilities, requiring STGC approval before business conduct. No public operator license process exists beyond tribal selection; focus on vendor registration via online portal. Processing involves background checks, financial review, and compliance verification.

Required documents include business licenses, financial statements, and gaming authority certifications. Background checks cover principals with 5%+ ownership, criminal history, and financial stability. Tribal Gaming Code mandates thorough investigations.

Submit vendor registration form with signed release; STGC issues license post-investigation.

Financial standards demand proof of funds; no fixed capital minimum disclosed publicly. Business plans unnecessary for vendors but required for tribal partnerships. Evaluation weighs regulatory history and transaction compliance.

Technical specs limited for vendors; gaming equipment suppliers need NIGC lab certification. Application fee structures start with $250 annual renewal; initial fees not publicly detailed. Review stages include submission, investigation, and issuance or denial with appeal to STGC Executive Director.

Common pitfalls involve incomplete backgrounds or unlicensed state operations, leading to payment holds by Seminole Gaming. Timeline varies; vendor approvals aim for prompt business enablement. Communication via portal and complaint forms.

Phase breakdown: registration (1-2 weeks), investigation (4-8 weeks), licensing (upon approval). Pitfalls include failing quarterly updates or code violations.

Vendors operate as external entities; no tribal incorporation required. Shareholder transparency demands disclosure for 5%+ holders via background checks. No minimum share capital specified publicly.

Director requirements focus on key personnel fitness; no local residency mandated for vendors. Physical presence unnecessary beyond facility access approvals. Corporate good standing verified through state filings.

Unlicensed vendors barred from Seminole Gaming payments; registration mandatory for bidding.

Financial guarantees absent fixed bonds; proof of financial responsibility suffices. Professional qualifications emphasize gaming compliance experience. Industry track record reviewed for management.

No organizational chart mandated for vendors; focus on ownership structure. Local representatives optional.

Requirement CategorySpecific RequirementsDetails/Notes
Company StructureAny legal entityState/Tribal licenses required
Minimum Share CapitalNot specifiedProof of funds
Shareholder Requirements5%+ disclosureBackground checks
Director RequirementsKey personnelFitness determination
Physical PresenceNone requiredFacility access per approval
Corporate Good StandingVerifiedState filings
Background ChecksOwners, officersCriminal/financial
Financial GuaranteesProof of stabilityNo fixed bond
Professional QualificationsGaming experiencePreferred
Industry ExperienceReviewedRegulatory history
Business PlanNot requiredFor partnerships
Source of FundsDocumentedAcceptable proof

Compliance Framework, Reporting Obligations, and Ongoing Oversight

AML implemented via tribal internal controls meeting NIGC Minimum Internal Control Standards (MICS). KYC applies to vendor employees accessing facilities. Enhanced due diligence for high-risk suppliers.

Data protection follows tribal policies; no direct GDPR but federal privacy alignment. Reporting quarterly on active vendors to STGC. Financials audited per compact.

Code violations trigger license revocation and civil fines.

Audits by STGC and SCA; real-time monitoring for transactions. Suspicious activity reported per tribal protocols. Inspections unannounced.

💰Financial Structure and Operational Requirements

Financial Obligations, Cost Structure, and Taxation Framework

Vendor costs center on $250 annual renewal; no initial application fee detailed publicly. License validity tied to renewal; no amortization specified. Taxation under tribal sovereignty; vendors pay state corporate taxes externally.

No player winnings tax direct to vendors; gross gaming revenue share to state via compact (~$500M/year recent). VAT inapplicable; corporate filings standard. Guarantees via financial proof only.

Annual renewal ensures ongoing access; non-payment deactivates status.

Bank guarantees unnecessary; liquidity per investigation. Insurance tribal-specified for facility suppliers. Reserves not mandated publicly. Cost lower than commercial licenses (e.g., FGCC slots).

Total ownership minimal post-renewal; compares favorably to multi-jurisdiction fees. Data compiled by Gambling databases indicates vendor entry barriers low relative to revenue potential.

Technical Infrastructure, Security Standards, and Certification Requirements

Software for gaming suppliers certified by NIGC-approved labs like GLI. RNG testing ongoing per MICS Part 547. Encryption SSL/TLS minimum.

Server locations tribal lands; data hosting compliant. Redundancy standards tribal. Backup procedures per compact.

Penetration testing annually recommended for tech vendors.

Continuity planning tribal-mandated. DDoS protection required. Updates patched promptly. Integrations vetted.

Game Regulations, Product Compliance, and Payment Integration

Permitted: slots, craps, roulette, blackjack per compact. Prohibited: non-approved games. RTP monitored internally.

Betting limits tribal-set. Jackpots managed per rules. Live dealers at facilities. Fairness NIGC-tested.

Crypto discretion tribal; emerging via Hard Rock Bet.

Payments segregated; timelines prompt. Currencies USD primary. Funds protected trustee-style.

🌍Market Operations and Strategic Advantages

Market Access, Commercial Opportunities, and Partnership Models

Access Florida tribal lands + statewide online sports. White-label via Hard Rock. B2B approvals STGC.

Affiliates regulated. Brand IP protected. Recognition compact-exclusive. Barriers low for vetted vendors.

Market saturation high; Seminole dominant.

Revenue shares tribal.

Player Protection, Responsible Gaming, and Marketing Compliance

Self-exclusion via PlayersEdge. Age 21+ verification. Limits deposit/session.

Interventions supported. Complaints tribal process. Ads disclose 1-888-ADMIT-IT. Bonuses transparent.

Underage access violations risk immediate facility bans and fines.

Sponsorships vetted.

Technology Integration, Innovation Support, and Operational Infrastructure

AI/blockchain tribal-approved. Mobile Hard Rock Bet certified. API standards met.

Esports covered. Fantasy tribal. Support via STGC. Renewal annual.

Disputes ADR. Enforcement fines/suspensions. Incentives tribal development.

Market Statistics, Performance Metrics, and Regulatory Trends

Approvals high for compliant vendors. Processing 4-12 weeks. Operators: Seminole exclusive.

Growth $2.5B+ revenue 2024. Enforcement minimal publicized. Trends: sports betting expansion.

🔄How to Apply for Florida Tribal Casino License – Complete Application Process

The application process targets vendors supplying Seminole gaming operations, managed via STGC portal. Designed for suppliers of goods/services, timeline 8-16 weeks total. Complexity low for compliant entities; engage legal advisors early.

Audience: tech providers, equipment manufacturers, service firms. Total 9-15 months unrealistic for vendors; focus prompt registration. Professional guidance ensures background readiness.

Pre-Application Preparation and Corporate Setup

Initial eligibility assessment verifies gaming history, gathers state licenses, assesses finances (4 weeks). Engage advisors for tribal code review. Document ownership fully.

Corporate registration confirms entity status; appoint shareholders transparently (2 weeks). No capital deposit mandated publicly. Local presence optional.

Verify 5%+ owners’ clean records pre-submission.

Governance documents prepared. Timeline 6-8 weeks total.

Technical Infrastructure and Documentation

Software/RNG certification via GLI if applicable (8 weeks). Security audits completed. Payment integrations tested.

Business plans optional; AML/KYC policies drafted (4 weeks). Background fingerprints scheduled.

Application Submission and Review

Portal submission with fees; track status (1 week). STGC investigation responds to queries (8 weeks).

Post-approval: license issuance, facility access (2 weeks). Total 3-4 months realistic. Consultants accelerate.

Process demands precision; non-compliance delays entry to lucrative market. Costs minimal post-$250 renewal. Guidance critical for first-timers.

⚖️How to Maintain Compliance with Florida Tribal Casino License Requirements

Ongoing compliance prevents revocation, fines under tribal code. Lapses halt payments, bar future bids. Responsibilities continuous for vendors.

Annual renewals mandatory; quarterly updates essential. Consultants aid complex audits.

Compliance Management and AML/KYC Operations

Appoint contact officer; calendar renewals/tools (setup quarterly). Policies documented.

KYC ongoing for personnel; monitor suspicious (monthly). Training annual.

Quarterly vendor lists to STGC prevent deactivation.

Financial, Technical, and Gaming Compliance

Segregate transactions; renew proofs (quarterly). RNG updates annual.

Security audits; infrastructure GDPR-aligned. RTP verified pre-supply.

Player Protection and Regulatory Reporting

Support self-exclusion tools. Complaints routed timely.

Reports monthly/annual; incidents immediate. Renewal 30 days pre-expiry.

Commitment yields long-term partnership. Audits unannounced; consultants mitigate risks. Non-compliance risks permanent exclusion.

❓Frequently Asked Questions

What is Florida Tribal Casino License and which regulatory authority issues it?

The Florida Tribal Casino License governs Class III operations exclusively for Seminole Tribe facilities under STGC. Issued only to tribal-approved vendors/suppliers, not external operators.

Framework per IGRA and 2021 compact; no commercial issuance. STGC protects tribal assets via licensing.

What are the primary benefits of obtaining Florida Tribal Casino License for gambling operators?

Access Seminole’s exclusive $2.5B market without state competition. Stable vendor status enables bidding on high-volume contracts.

Low costs vs. revenue potential; federal preemption advantages.

What are the initial costs and ongoing fees associated with Florida Tribal Casino License?

Initial registration free; $250 annual non-refundable renewal. No bonds detailed publicly.

Background costs borne by applicant.

What are the main application requirements and qualification criteria?

Vendor form, licenses, backgrounds for 5%+ owners. Financial stability proof.

Clean regulatory history essential.

Which types of gambling activities are permitted under Florida Tribal Casino License?

Slots, tables, sports betting per compact. Vendor supply to these only.

Prohibited non-approved.

What geographic markets can be accessed with Florida Tribal Casino License?

Seminole lands + online statewide. Vendor supply thereto.

No cross-state.

What are the key compliance obligations for Florida Tribal Casino License holders?

Quarterly updates, annual renewal, code adherence. Background maintenance.

Audit cooperation.

How does Florida Tribal Casino License compare to other major gambling licenses?

Tribal-exclusive vs. commercial (FGCC). Lower fees, sovereign perks.

Exclusivity unique.

What are the tax implications for operators holding Florida Tribal Casino License?

Vendors pay external taxes; no tribal levy. Sovereignty shields operations.

Compact shares state revenue.

What technical and infrastructure requirements must be met?

NIGC RNG/SSL for suppliers. Tribal standards.

Updates continuous.

How long does the application process take for Florida Tribal Casino License?

8-16 weeks post-submission. Faster for clean applicants.

Appeals extend.

What are the penalties for non-compliance with Florida Tribal Casino License requirements?

Revocation, fines, bid bans. Civil penalties per code.

Permanent exclusion possible.

Can Florida Tribal Casino License be transferred to another company or entity?

No; new application required. Ownership changes trigger review.

STGC approval mandatory.

What ongoing reporting and audit requirements apply to Florida Tribal Casino License holders?

Quarterly active lists. Annual renewal docs.

Inspections cooperative.

How does Florida Tribal Casino License address responsible gambling and player protection?

Via PlayersEdge, 1-888-ADMIT-IT. Vendors support tools.

Age verification strict.

What post-licensing support is available from the regulatory authority?

STGC portal, complaint forms. Guidance limited publicly.

Audit feedback.

What are the special investment incentives for operators?

Tribal development perks. Vendor priority compliant.

No public tax relief.

What is the current approval rate for license applications?

High for vetted; denials background-based. No stats public.

Compliant near-100%.

What are the latest regulatory changes affecting operators?

2021 compact adds sports betting. Vendor rules stable.

FGCC oversight enhanced.

📞Sources

Official Regulatory Sources

Compliance and Technical Standards

Market Intelligence and Industry Reports

🎰Gambling Databases Rating: Florida Tribal Casino License

Overall License Performance
Evaluation DimensionScoreRating
Operator Viability Score7.2/10🟡Good 5-7
Regulatory Quality Score6.8/10🟡Good 5-7
Overall GDR Rating7.0/10Viable vendor access to exclusive market but irrelevant for actual casino operators
International Recognition⭐⭐⭐⭐ Established Tier – Strong US tribal gaming recognition, limited global portability

This rating is calculated using the Gambling Databases Rating (GDR) methodology, which provides transparent criteria for evaluating gambling licenses for the iGaming industry. Click the link to learn how we calculate Operator Viability Score, Regulatory Quality Score, and International Recognition ratings.

⚠️CRITICAL LIMITATIONS & RISKS

READ THIS BEFORE PURSUING THIS LICENSE:

  • NOT FOR OPERATORS: This “license” is vendor/supplier registration only – Seminole Tribe exclusively operates all casinos
  • Zero market access for external operators – complete exclusivity to Seminole gaming operations
  • Irrelevant for B2C gambling operations – targets equipment/service suppliers only
  • Limited to Florida tribal lands + online sports betting via Hard Rock Bet platform
  • Background checks and tribal approval create unpredictable vendor access barriers
  • Payment holds and bid exclusions for non-compliance – high vendor business risk

📊Operator Viability Score Breakdown

Detailed Operator Assessment Criteria
CriterionWeightScoreJustification (INCLUDING ALL DEDUCTIONS)
Financial Accessibility25%2.4/2.5$250 annual renewal only (+2.5 base <€50K). No minimum capital, bonds, or hidden fees specified (-0.1 for unspecified compliance costs). Extremely low cost for vendor access.
Application Process Efficiency20%1.7/2.08-16 weeks processing (+1.5 base). Vendor portal simplifies (-0.0 excessive docs). Background checks required but tribal-focused (-0.1 unclear rejection rates). No multi-body overlap (+0.0).
Operational Requirements20%2.0/2.0Remote vendor operation possible (+2.0). No local office, directors, or staff mandated. Facility access only upon approval. No server/payment localization.
Market Access & Commercial Value20%0.6/2.0Single jurisdiction (Florida tribal) (+0.5). Vendor supply only, no operator market access (-0.5 white-label prohibited). Seminole exclusivity limits B2B (-0.3). Strong revenue potential (+0.1 offset).
Tax Structure & Profitability15%0.5/1.5Vendor pays external state taxes (no GGR tax direct). Tribal sovereignty unclear for vendors (+0.4 low effective). Complex compact revenue share (-0.3 unclear methodology).

⚖️Regulatory Quality Score Breakdown

Detailed Regulatory Framework Evaluation
CriterionWeightScoreJustification (INCLUDING ALL DEDUCTIONS)
Regulatory Framework Clarity30%2.3/3.0IGRA + Tribal Code + 2021 Compact provide clear framework (+2.5). Vendor rules accessible via portal (+0.0). Some tribal discretion creates ambiguity (-0.2).
Compliance Standards & Obligations25%1.9/2.5NIGC MICS reasonable (+2.0). Quarterly vendor reporting moderate (-0.1). No data localization or real-time mandates. AML/KYC standard for tribal operations.
Regulatory Authority Reputation20%1.6/2.0STGC respected in US tribal gaming (+1.5). Strong NIGC oversight. Limited international exposure (-0.2). No corruption concerns documented.
Enforcement & Dispute Resolution15%0.7/1.5Tribal courts + compact SCA process (+0.8). Vendor payment holds documented. Limited due process details (-0.3). No public revocation stats.
Political & Economic Stability10%0.3/1.0Florida stable (+0.7). Tribal sovereignty creates jurisdictional complexity (-0.4). Compact litigation history signals risk.

🌍International Recognition Analysis

Industry Reputation: ⭐⭐⭐⭐

Recognition Tier: Established Tier – Strong within US tribal gaming ecosystem

Payment Provider Acceptance: Excellent for US operations; global PSPs comfortable with NIGC/STGC oversight

B2B Partnership Appeal: High for Seminole/Hard Rock suppliers; irrelevant for international white-label platforms

Regulatory Cooperation: Strong federal NIGC cooperation; compact-specific with Florida FGCC

Industry Perception: Respected US tribal benchmark; limited offshore iGaming relevance

License-Specific Reputation Factors:

  • Historical Performance: 2021 compact upheld; consistent $2B+ state revenue sharing
  • Operator Track Record: Seminole exclusive – industry leading Hard Rock properties
  • Enforcement History: Vendor payment holds; minimal public operator actions
  • Media Coverage: Positive compact revenue; litigation historically
  • Peer Jurisdiction View: NIGC gold standard; state regulators cooperative

Known Restrictions or Concerns:

  • Vendor-only – no operator licensing available
  • Florida geographic exclusivity limits portability
  • Tribal sovereignty creates jurisdictional complexity
  • Compact renewal risk every 5 years

🔍Key Highlights

✅Strengths

  • $250 annual renewal – lowest cost vendor access globally
  • 8-16 week processing vs 12+ months typical jurisdictions
  • Remote operation – no local office/staff requirements
  • Access to $2.5B Seminole gaming ecosystem
  • NIGC/STGC provide established compliance framework

⚠️Weaknesses

  • Complete operator exclusion – Seminole exclusivity absolute
  • Vendor-only licensing irrelevant for B2C platforms
  • Florida-only market access – no multi-jurisdictional value
  • Tribal court jurisdiction creates dispute uncertainty
  • Compact renewal litigation risk every 5 years

🚨CRITICAL ISSUES

  • Cost Concerns: Deceptive “low cost” – zero value for operators seeking to run casinos
  • Timeline Problems: 8-16 weeks irrelevant since no operator licensing exists
  • Operational Burdens: Vendors face payment holds/exclusion risk
  • Market Limitations: Seminole exclusivity eliminates operator market entry
  • Regulatory Risks: Tribal sovereignty overrides state law unpredictably
  • Reputation Concerns: US tribal-only recognition limits global partnerships

💰Total Cost of Ownership Analysis

Initial Costs (Year 1):

Application Fee: $0 (portal registration)

License Fee: $250 first year

Capital Requirement: $0 specified

Financial Guarantees: $0 bonds required

Legal & Consulting: $5,000-$15,000 tribal compliance review

Operational Setup: $0 local infrastructure

Year 1 Total: ~$15,250 maximum

Ongoing Costs (Annual):

License Renewal: $250

Compliance Costs: $2,000-$5,000 quarterly reporting

Operational Costs: $0 local overhead

Tax Burden: Vendor standard Florida corporate tax

Annual Total: ~$7,250

5-Year Total Cost of Ownership:

Total Investment Over 5 Years: ~$43,250

Profitability Assessment: Excellent ROI for Seminole suppliers; zero value for casino operators

📋Final Verdict

Florida Tribal Casino License receives an Operator Viability Score of 7.2/10 and a Regulatory Quality Score of 6.8/10, resulting in an Overall GDR Rating of 7.0/10. The license has an International Recognition rating of ⭐⭐⭐⭐.

HONEST ASSESSMENT: This vendor registration offers exceptional low-cost access to Seminole Tribe’s exclusive $2.5B Florida gaming market for equipment/service suppliers, but provides ZERO viability for actual casino operators due to complete tribal exclusivity. Processing efficiency and minimal requirements make it attractive for compliant US gaming vendors, though limited to single-jurisdiction tribal ecosystem reduces broader appeal. Best positioned as supplementary licensing for established North American suppliers rather than primary operator jurisdiction.

Operators Should Consider If:

  • Equipment/software suppliers targeting US tribal markets
  • Service providers seeking Seminole/Hard Rock contracts
  • Companies with existing NIGC compliance infrastructure
  • North American gaming vendors expanding vendor pools

Operators Should Avoid If:

  • Seeking to operate actual casinos (impossible)
  • International operators wanting global license portability
  • Startup platforms without US tribal market focus
  • Operators needing B2C player acquisition capability
  • Companies without established vendor track record
  • Risk-averse firms concerned by tribal jurisdiction

⚖️BOTTOM LINE:

Outstanding vendor access opportunity for US tribal gaming suppliers but completely irrelevant for any operator seeking to run gambling operations.

Rate article
Gambling databases
Add a comment

By clicking the "Post Comment" button, I consent to processing personal information and accept the privacy policy.