Auditing Player s Club and Promotions

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1 Auditing Player s Club and Promotions

2 Contact Information Doug Parker Compliance Division Office: (405)

3 Warm Up Which of the following would be considered a promotional payout? A. Giving a player $10 of Birthday Bucks B. Awarding a patron a new four wheeler because they entered a random drawing C. A player earning a $30 gas voucher as a result of their play at your casino D. All of the above

4 Definitions Promotional Payout merchandise or awards given to players by the gaming operation based on wagering activity Player Tracking System - system or component of a computerized casino accounting system used to record the gaming play of individual customers Points - representative of value awarded to a customer based upon specific criteria established by the gaming operation Complimentary Services and Items - Services and items provided to a patron at the discretion of an agent on behalf of the gaming operation or by a third party on behalf of the gaming operation. Services and items may include, but are not limited to, travel, lodging, food, beverages, or entertainment expenses

5 Player Tracking Standards Player s Club Vulnerabilities Player Point Fraud Names Changes Combining Accounts Point Adjustments Comp Fraud Free Bonus Play Fraud Hot Seat Promotion Fraud Player Gift Fraud

6 Case Example Former Casino Employee and Wife Sentenced to Probation for Scheme to Embezzle Money from Casino Marketing Department $74, Access to active and inactive player s club accounts Added money and credits to the cards Gave loaded cards to wife She passed them out to others Split percentage of their winnings 2 years probation + $74, in restitution

7 MICS Checklist

8 Case Example Arizona Pair Indicted in $25,000 Casino Scam Table Games $27,000 Access to enter player rating value Prepared falsified player-rating cards in the name of his girlfriend Altered handwriting Used other employees numbers Ratings ranged from $220 to $ instances added up to more than $20,000

9 MICS Checklist

10 Case Example Former Tribal Casino Employee Charged in Federal Court with Embezzlement Players Club Manager $13,326 Access to create counterfeit players club cards Had others use the pre-loaded cards in the slot machines Approximately $17,400 fraudulently won If convicted, 5 years in federal prison and a fine up to $250,000

11 MICS Checklist

12 Case Example Three Charged in Casino Fraud Case Vice President of Player Development Cocktail Server Gambler $478,100 in free slot play $418,793 in winnings Access to accounts and free bonus play Cocktail server collected player s card numbers and PIN numbers Created duplicate cards Added free bonus play Split the winnings

13 MICS Checklist

14 Case Example Former Casino Employee Sentenced to 57 Months in Prison for Stealing Players Card Information Database Manager $863,895 Access to unused free play points Transferred the points to counterfeit players club cards Recruited people to play slots with the cards 57 months in prison & pay $863,895 in restitution

15 MICS Checklist

16 Case Example Former Casino Worker Charged with Theft Player s Club Host Supervisor $20,000 Access to accounts and to issue cash vouchers Converted points into cash vouchers Cashed the vouchers

17 Promotion Standards

18 Case Example Indictment Over Alleged Casino Scam on Tribal Grounds $64,000 Pre-selected a winner for the drawing Told the winner when to expect their name to be called they had 3 minutes to claim the prize. Told the winner what number to pick on the prize board. Numbers were from 1 to 13 and had prize amounts ranging from $250 to $2,500.

19 MICS Checklist

20 Case Example Former Employee of Newcastle Gaming Facility Pleads Guilty to Embezzlement $17,500 Helped security guards, family and friends win promotional games that were intended for random drawing.

21 MICS Checklist

22 Case Example Former Biloxi Casino Employee Charged with Embezzlement $18,000 Had access to promotional offers

23 Revenue Audit/Accounting Standards

24 MICS Checklist

25 Risk Considerations Purpose of an Audit Protect the assets of the tribe Remain proactive against threats in the industry Meet established requirements Maintaining Control Points and promotions = Cash Involving other departments Marketing Accounting Planning and executing

26 Risk Management TICS and SICS Communication and Research Staff Interviews System Research Training Management training Staff training Audit training

27 Completing the Checklist Implementation Checklist vs. Analysis Make it meaningful Frequency Requirements Necessities Escalation Management considerations Follow up Retention

28 Where there is value, there is fraud, always! Gaming auditors who are aware of industry-specific risks can help head off fraud by ensuring both preventive and detective controls are in place.

29 Questions and Comments us at for copy of materials Visit us at booth # 1222

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