Class III games are defined as all games which are not class I or class II and includes house banked baccarat, chemin de fer, and blackjack (21). NIGC regulations define class II card games as nonbanking card games. See, John Scarne, Scarne's New Complete Guide to Gambling, 342, 459-460 (1986) Albert H.

Baccarat and blackjack (21) are card games banked by the gaming operation, whereas chemin de fer is a player banked version of baccarat. Those specifically enumerated card games are baccarat, chemin de fer, and blackjack (21). Apparently, some tribes are of the view that if the gaming operation does not bank the game, the game is a nonbanking card game and thus falls within class II gaming.Īll banking card games, including three which are specifically enumerated, are excluded from class II gaming in the IGRA. In blackjack (21), as traditionally played, the gaming operation acts as the bank or banker. A player takes on the role of banker, collecting all losses and paying all winnings. The gaming operation makes money by collecting an ante from each player per hand. The tribal gaming operation does not participate in, or have any interest in, the outcome of the game. The banker/player has a mathematical percentage advantage over the other players similar to the advantage the gaming operation has in traditional blackjack.

In player banked blackjack (21), players are playing against a player bank. Because many tribes are conducting player banked card games, including player banked blackjack, as part of their class II gaming operations, the NIGC is issuing this bulletin. After a thorough legal review, the NIGC has concluded that all banking card games, including card games banked by the gaming operation or by a player, fall within class III gaming. The National Indian Gaming Commission (NIGC) was asked recently whether a player banked version of blackjack (21) falls within class II or class III gaming under the Indian Gaming Regulatory Act (IGRA). Subject: All Banking Card Games Fall Within Class III Gaming

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