§ 543.18 What are the minimum internal control standards for the cage, vault, kiosk, cash and cash equivalents? ( 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 ) *Check cashing.* ( 1 ) If checks are cashed at the cage, the controls must provide for security and integrity. 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.
( 2 ) When counter checks are issued, the following must be included on the check: ( i ) The patron's name and signature;
( ii ) The dollar amount of the counter check;
( iii ) Patron's bank name, bank routing, and account numbers;
( iv ) Date of issuance; and
( v ) Signature of the agent approving the counter check transaction.
( 3 ) Checks that are not deposited in the normal course of business, as established by management, (held checks) are subject to § 543.15 lines of credit standards.
( 4 ) When traveler's checks or other guaranteed drafts, such as cashier's checks, are presented, the cashier must comply with the examination and documentation procedures as required by the issuer.
( 5 ) 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.
( c ) *Cage and vault accountability.* ( 1 ) All transactions that flow through the cage must be summarized for each work shift of the cage and must 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 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 (including coin rooms) must 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.
( 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.
( d ) *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 TGRA or the gaming operation, subject to the approval of the TGRA, must develop and implement physical security controls over the kiosks. Controls should address the following: forced entry, evidence of any entry, and protection of circuit boards containing programs.
( 5 ) With regard to cashless systems, the TGRA or the gaming operation, subject to the approval of the TGRA, 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 redeemed;
( 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 dollar amount per financial instrument; and
( xii ) Ending balance number of items per financial instrument.
( e ) *Patron deposited funds.* If a gaming operation permits a patron to deposit funds with the gaming operation at the cage, and when transfers of patron deposited funds are transferred to a gaming area for wagering purposes, the following standards apply: ( 1 ) The receipt or withdrawal of a patron deposit must be documented, with a copy given to the patron and a copy remaining in the cage.
( 2 ) Both copies of the document of receipt or withdrawal must contain the following information: ( i ) Same receipt number on each copy;
( ii ) Patron's name and signature;
( iii ) Date of receipt and withdrawal;
( iv ) Dollar amount of deposit/withdrawal (for foreign currency transactions include the US dollar equivalent, the name of the foreign country, and the amount of the foreign currency by denomination);
( v ) Nature of deposit/withdrawal; and
( vi ) Name and signature of the agent who conducted the transaction.
( 3 ) Procedures must be established and complied with for front money deposits to: ( i ) Maintain a detailed record by patron name and date of all funds on deposit;
( ii ) Maintain a current balance of all patron deposits that are in the cage/vault inventory or accountability; and
( iii ) Reconcile the current balance with the deposits and withdrawals at least daily.
( f ) *Promotional payments, drawings, and giveaway programs.* The following procedures must apply to any payment resulting from a promotional payment, drawing, or giveaway program disbursed by the cage department or any other department. This section does not apply to payouts for card game promotional pots and/or pools. ( 1 ) All payments must be documented to support the cage accountability.
( 2 ) Payments above $600 (or lesser amount as approved by TGRA) must be documented at the time of the payment, and documentation must include the following: ( i ) Date and time;
( ii ) Dollar amount of payment or description of personal property;
( iii ) Reason for payment; and
( iv ) Patron's name and confirmation that identity was verified (drawings only).
( v ) Signature(s) of at least two agents verifying, authorizing, and completing the promotional payment with the patron. For computerized systems that validate and print the dollar amount of the payment on a computer generated form, only one signature is required.
( g ) *Chip(s) and token(s).* Controls must be established and procedures implemented 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.
( h ) *Vouchers.* ( 1 ) Controls must be established and procedures implemented to: ( i ) Verify the authenticity of each voucher redeemed.
( ii ) If the voucher is valid, verify that the patron is paid the appropriate amount.
( iii ) Document the payment of a claim on a voucher that is not physically available or a voucher that cannot be validated such as a mutilated, expired, lost, or stolen voucher.
( iv ) Retain payment documentation for reconciliation purposes.
( v ) For manual payment of a voucher of $500 or more, require a supervisory employee to verify the validity of the voucher prior to payment.
( 2 ) Vouchers paid during a period while the voucher system is temporarily out of operation must be marked “paid” by the cashier.
( 3 ) Vouchers redeemed while the voucher system was temporarily out of operation must be validated as expeditiously as possible upon restored operation of the voucher system.
( 4 ) Paid vouchers must be maintained in the cashier's accountability for reconciliation purposes.
( 5 ) Unredeemed vouchers can only be voided in the voucher system by supervisory employees. The accounting department will maintain the voided voucher, if available.
( i ) *Cage and vault access.* Controls must be established and procedures implemented to: ( 1 ) Restrict physical access to the cage to cage agents, 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.
( j ) *Variances.* The operation must establish, as approved by the TGRA, the threshold level at which a variance must be reviewed to determine the cause. Any such review must be documented.
[77 FR 58712, Sept. 21, 2012, as amended at 83 FR 65509, Dec. 21, 2018]