(a) Supervision. Supervision must be provided as needed for cage, vault, kiosk, and other operations using cash or cash equivalents by an agent(s) with authority equal to or greater than those being supervised.
(b) Personal checks, cashier's checks, and payroll checks.
(1) The gaming operation shall comply with appropriate controls for purposes of security and integrity, as approved by SMTGC. For each check cashing transaction, the agent(s) conducting the transaction must:
(i) Verify the patron's identity;
(ii) Examine the check to ensure it includes the patron's name, current address, and signature;
(iii) For personal checks, verify the patron's check cashing authority and record the source and results in accordance with management policy; however
(iv) If a check guarantee service is used to guarantee the transaction and the
procedures required by the check guarantee service are followed, then the above requirements do not apply.
(v) Checks shall be deposited in the normal course of business, as established by management.
(2) The gaming operation as approved by SMTGC, shall establish and the gaming operation shall comply with procedures for the acceptance of personal checks (i.e., locations, fees, restrictions) collecting and recording checks returned to the gaming operation after deposit, re-deposit, and write-off authorization.
(3) If a third party check cashing or guarantee service is used, the examination and documentation procedures required by the service provider apply, unless otherwise provided by tribal law or regulation.
(4) When traveler's checks or other guaranteed drafts such as cashier's checks are presented, the cashier shall comply with the examination and documentation procedures as required by the issuer.
(c) The gaming operation shall not permit customers to deposit funds with the gaming operation.
(d) Cage and vault accountability.
(1) All transactions that flow through the cage shall be summarized on a cage accountability form on a per shift basis and shall be supported by documentation.
(2) Increases and decreases to the total cage inventory must be verified, supported by
documentation, and recorded. Documentation must include the date and shift, the purpose
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of the increase/decrease, the agent(s) completing the transaction, and the person or department receiving the cage funds (for decreases only).
(3) The cage and vault inventories shall be counted independently by at least two agents, attested to by signature, and recorded in ink or other permanent form at the end of each shift during which the activity took place. These agents must make individual counts to compare for accuracy and maintain individual accountability. All variances must be documented and investigated. Unverified transfers of cash and/or cash equivalents are prohibited.
(4) The gaming operation must establish and comply with a minimum bankroll formula to ensure the gaming operation maintains cash or cash equivalents (on hand and in the bank, if readily accessible) in an amount sufficient to satisfy obligations to the gaming
operation's patrons as they are incurred. Such formula must be approved by SMTGC.
(e) Chip(s) and token(s). Controls must be established and procedures implemented, as approved by SMTGC, to ensure accountability of chip and token inventory. Such controls must include, but are not limited to, the following:
(1) Purchase;
(2) Receipt;
(3) Inventory;
(4) Storage; and (5) Destruction
(f) Coupon standards. Any program for the exchange of coupons for cash or cash equivalents shall be approved by SMTGC prior to implementation. If approved, the gaming operation shall establish and comply with procedures that account for and control such programs.
(g) [Reserved]
(h) Extraneous items. The gaming operation as approved by SMTGC, shall establish and the gaming operation shall comply with procedures to address the transporting of extraneous items, such as coats, purses, and/or boxes, into and out of the cage, coin room, count room, and/or vault.
(i) Kiosks
(1) Kiosks must be maintained on the cage accountability and must be counted independently by at least two agents, documented, and reconciled for each increase or decrease to the kiosk inventory.
(2) Currency cassettes must be counted and filled by an agent and verified independently by at least one agent, all of whom must sign each cassette.
(3) Currency cassettes must be secured with a lock or tamper resistant seal and, if not placed inside a kiosk, must be stored in a secured area of the cage/vault.
(4) The gaming operation, subject to the approval of SMTGC, must develop and implement physical security controls over the kiosks. Controls should address the following: forced
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entry, evidence of any entry, and protection of circuit boards containing programs.
(5) With regard to cashless systems, the gaming operation, subject to the approval of SMTGC, must develop and implement procedures to ensure that communications between the kiosk and system are secure and functioning.
(6) The following reconciliation reports must be available upon demand for each day, shift, and drop cycle (this is not required if the system does not track the information, but system limitation(s) must be noted):
(i) Starting balance dollar amount per financial instrument;
(ii) Starting balance number of items per financial instrument;
(iii) Dollar amount per financial instrument issued;
(iv) Number of items per financial instrument issued;
(v) Dollar amount per financial instrument issued;
(vi) Number of items per financial instrument redeemed;
(vii) Dollar amount per financial instrument increases;
(viii) Number of items per financial instrument increases;
(ix) Dollar amount per financial instrument decreases;
(x) Number of items per financial instrument decreases;
(xi) Ending balance number of items per financial instrument.
(j) Cage and vault access. Controls must be established and procedures implemented to:
(1) Restrict physical access to the cage to cage employees, designated staff, and other authorized persons; and
(2) Limit transportation of extraneous items such as personal belongings, tool boxes, beverage containers, etc., into and out of the cage.
(k) Variances. The operation must establish, as approved by SMTGC, the threshold level at which a variance must be reviewed to determine the cause. Any such review must be documented.
(l) The gaming operation shall not transact in foreign currency.
(m) Controls over cash and cash equivalents.
(1) All gaming operation funds used to operate games, food and beverage outlets, and retail outlets shall be recorded on an accountability form.
(2) All gaming operation funds used to operate games, food and beverage outlets, and retail outlets shall be counted independently by at least two persons and reconciled to the recorded amounts at the end of each shift or session.
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(3) Procedures must be established and implemented with the intent to prevent unauthorized access to or fraudulent transactions involving cash or cash equivalents.
(4) Procedures must be implemented to control cash or cash equivalents based on the amount of the transaction. These procedures include, but are not limited to, counting and
recording on an accountability form by shift, session or relevant time period the following:
(i) Inventory or imprest including any increases or decreases;
(ii) Transfers;
(iii) Exchanges, including acknowledging signatures or initials; and (iv) Resulting variances.
(5) Any change to control of accountability, exchange, or transfer requires that the cash or cash equivalents be counted and recorded independently by at least two agents and reconciled to the recorded amount.
(6) The gaming operation shall establish internal control systems sufficient to ensure that currency (other than tips or gratuities) received from a patron is promptly placed in a locked box in the table, or, in the case of a cashier, in the appropriate place in the cashier's cage, or on those games which do not have a locked drop box, or on card game tables, in an appropriate place on the table, in the cash register or in another approved repository.
(7) The physical transport of cash or cash equivalents shall be subject to the following:
(i) Movement of cash or cash equivalents over $10,000 outside of secured cage or vault areas shall require an armed escort.
(ii) Movement of cash or cash equivalents outside of secured cage or vault areas in excess of $1 million and all movement from the count room shall require additional security procedures to be established and implemented by the gaming operation, subject to SMTGC approval.
(n) Controls over point-of-sale transactions.
(1) A separate cash drawer or bank must be maintained for each point-of-sale operator on duty
(2) Point-of-sale transaction records shall be reconciled with cash receipts on a per shift basis to balance operator drawers and determine any variances.
(i) The operation must establish, as approved by SMTGC, the threshold level at which a variance must be reviewed to determine the cause. Any such review must be documented.
(3) Cash receipts shall be transferred to the cage for accountability on a per-shift basis.
(4) The gaming operation must establish, as approved by SMTGC procedures for reviewing no sale, void, and refund transactions for reasonableness and irregularities. Any such review must be documented.
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(5) Cash or cash equivalent exchanges for cash shall not be permitted at point-of-sale terminals. All cash or cash equivalent exchange transactions must be conducted at the cage or kiosks.
(6) Management staff should routinely inspect debit and credit transaction equipment for signs of tampering, such as the addition of unusual objects on data cable lines.
(7) Employees shall not process transactions for their own purchases.
(8) The gaming operation must establish, as approved by SMTGC procedures for providing discounts to patrons and employees, including an independent review of discount transactions for reasonableness. Any such review must be documented.
XV. TRIBAL INTERNAL CONTROL STANDARDS FOR CREDIT