Auditing Revenue 

25 CFR 543.24 Toolkit

Version 1.0

NIGC Training Program
NIGC Auditing Revenue–25 CFR 543.24 Toolkit

Over thirty years ago, Congress adopted the Indian Gaming Regulatory Act (IGRA) to provide a statutory 

basis for gaming by Indian tribes. The National Indian Gaming Commission (NIGC) was created by IGRA to 

regulate gaming activities conducted by sovereign Indian tribes on Indian lands. The mission of the NIGC is 

to: (1) promoting tribal economic development, self-sufficiency and strong tribal governments; (2) 

maintaining the integrity of the Indian gaming industry; and (3) ensuring that tribes are the primary 

beneficiaries of their gaming activities. One of the primary ways the NIGC does this is by providing training 

and technical assistance to Indian tribes and their gaming regulators.

The National Indian Gaming Commission (NIGC) is pleased to present this Toolkit to all Compliance and 

Auditing staff. This reference guide is intended to assist Auditors, Gaming Commissioners and Operations 

personnel in the performance of measuring compliance of their operation(s) with 25 CFR 543.24. The 

Toolkit lists each standard of 543.24, the intent of the standard, and a recommended testing step, which

will ensure minimum regulatory compliance. 

This Toolkit is designed to meet the minimum requirements of the NIGC MICS and does not take into 

account Operations’ Tribal Internal Control Standards (TICS) and/or System of Internal Control Standards 

(SICS), which may require further testing. The NIGC encourages operations to develop standards that 

exceed the Minimum Internal Control Standards. The uniqueness of each operation warrants a robust set 

of controls tailored to its individual needs. 

If you have questions or comments about this guide, please contact the NIGC Division of Public Affairs at 

traininginfo@nigc.gov . For more information, visit the NIGC website at http://www.nigc.gov.
The Training Program has designed this Toolkit as a resource for understanding the Auditing Revenue 543.24

Minimum Internal Control Standards (MICS) and to use as a tool in conducting an audit of the revenue standards 

in determining compliance with 543.24. This Toolkit was developed in a table fashion. You can use the Toolkit 

to help:

1) Clarify the meaning of terms used in this Toolkit (Definitions);

2) See the regulation for Auditing Revenue 543.24. (The regulation is listed in the first column in the table 

verbatim);

3) Understand the intent of the regulation and why the control was created. (The intent is listed in the 

second column in the table); 

4) Determine testing steps to utilize to determine compliance with the regulation. (The testing step is listed in 

the second column in the table under the Intent information);

5) Identify best practices. (These have been included in either the intent or the testing steps to provide the 

user with current industry procedures);

6) Additional information is provided as a note. This information provides practical advice to consider when 

performing the testing step, such as the step being completed in another section.

The toolkit provides many practical and concrete suggestions for understanding and evaluating compliance with 

Auditing Revenue MICS 543.24. This toolkit can be used by either the new or experienced auditor during the 

various stages of the audit.
GLOSSARY

Accountability

DEFINITION

All financial instruments, receivables, and patron deposits constituting the total amount for which the 

bankroll custodian is responsible at a given time.

Agent A person authorized by the gaming operation, as approved by the TGRA, to make decisions or perform 

assigned tasks or actions on behalf of the gaming operation.

Automated 

payout

Payment issued by a gaming machine, commonly referred to as payout slips, vouchers or tickets.

Cage A secure work area within the gaming operation for cashiers, which may include a storage area for the 

gaming operation bankroll.
Cash 

equivalents

Documents, financial instruments other than cash, or anything else of representative value to which 

the gaming operation has assigned a monetary value. A cash equivalent includes, but is not limited to, 

tokens, chips, coupons, vouchers, payout slips and tickets, and other items to which a gaming 

operation has assigned an exchange value.

Class II 

gaming

Games of chance such as bingo (whether or not electronic, computer, or other technological aids are 

used in connection therewith in), pull tabs, and non-banked card games (poker).

Class II 

gaming 

system

All components, whether or not technologic aids in electronic, computer, mechanical, or other 

technologic form, that function together to aid the play of one or more Class II games, including 

accounting functions mandated by these regulations or part 547 of this chapter.

Independent The separation of functions to ensure that the agent or process monitoring, reviewing, or authorizing 

the controlled activity, function, or transaction is separate from the agents or process performing the 

controlled activity, function, or transaction.
Manual

payout

Any non-automated payout.

MICS Minimum internal control standards in this part.

Patron A person who is a customer or guest of the gaming operation and may interact with a Class II game. 

Also may be referred to as a “player".

Player 

interface

Any component(s) of a Class II gaming system, including an electronic or technologic aid (not limited to 

terminals, player stations, handhelds, fixed units, etc.), that directly enables player interaction in a 

Class II game.
Prize payout Payment to a player associated with a winning or qualifying event.

Sample A set of records, data or elements drawn from a larger population and analyzed to estimate the 

characteristics of that population.

Shift A time period, unless otherwise approved by the tribal gaming regulatory authority, not to exceed 24 

hours.

SICS (System 

of Internal 

Control 

Standards)

An overall operational framework for a gaming operation that incorporates principles of independence 

and segregation of function, and is comprised of written policies, procedures, and standard practices 

based on overarching regulatory standards specifically designed to create a system of checks and 

balances to safeguard the integrity of a gaming operation and protect its assets from unauthorized 

access, misappropriation, forgery, theft, or fraud.
Tier A Gaming operations with annual gross gaming revenues of more than $3 million but not more than $8 

million.

Tier B Gaming operations with annual gross gaming revenues of more than $8 million but not more than $15 

million.

Tier C Gaming operations with annual gross gaming revenues of more than $15 million.

TGRA Tribal gaming regulatory authority, which is the entity authorized by tribal law to regulate gaming 

conducted pursuant to the Indian Gaming Regulatory Act.
TICS Tribal Internal Control Standards established by the TGRA that are at least as stringent as the 

standards set forth in this part.
Citation Language Intent and Testing

§ 543.24 (a)

543.24(a)

Supervision. Supervision must be provided 

as needed for revenue audit by an agent(s) 

with authority equal to or greater than 

those being supervised. 

Intent: To provide for the proper supervision of revenue audit 

procedures, to help prevent, identify, and correct actions by those 

being supervised that could impair the integrity of gaming or lead 

to the loss of gaming assets 

Testing: 

1. Review organizational chart, department schedules, and/or

job descriptions for personnel who perform and supervise 

revenue audit procedures to determine the structure of 

supervision for revenue audit. 

2. Observe how supervision of the performance of revenue audit

procedures is provided to determine adequacy and to verify

proper supervision is provided. 

3. Inquire with supervisory personnel to determine what types of 

tasks are performed as part of the supervision of revenue 

audit, such as: monitoring staff, scheduling, communicating 

findings, etc. Further inquiries may be needed based on what 

is verified by reviews and observations from testing #1 and #2.

Best Practice: Effective supervision should be by someone of 

greater authority than those being supervised. If supervision is of 

equal authority, consider additional controls for sensitive reviews, 

such as those, which may detect possible incidents of collusion. If 

one person performs all revenue audit procedures, supervision 

can be provided by a supervisor from an external department, as 
long as the supervisor is independent of the transactions being 

reviewed.

§ 543.24 (b)

 

 543.24(b)

Independence. Audits must be performed by 

agent(s) independent of the transactions being 

audited.

Intent: To require revenue audit procedures be performed 

(including supervision) by personnel whom are not directly or 

indirectly involved in the transactions, processes, or areas 

reviewed to prevent potential conflicts of interest and 

opportunities for collusion and to ensure reviews are unbiased.

Testing: 

1. Review employee lists and/or organizational chart to verify 

documented independence of revenue audit personnel by 

whom they report under and the area they work (as 

applicable). 

2. Observe the overall performance of revenue audit procedures, 

to ensure that other tasks these persons may perform do not 

present conflicts in independence (e.g., as a key custodian 

being the person whom performs quarterly reviews of key 

system reports). 

3. Inquire with revenue audit personnel to learn how they ensure 

independence from the areas they review (e.g., do they 

disclose family/personal relationships with personnel who 

work in the areas they may be required to review? What is the 

procedure to mitigate risk if such relationships are present?). 

Best Practice: Independence should prevent any appearance of 

impropriety to ensure the integrity of revenue audit procedures.

Personnel who perform revenue audit procedures should not 
report to management of departments they are charged with 

reviewing. This helps to remove possible conflicts of interest. 

Revenue audit may want to establish an outside reporting 

channel, such as TGRA, Audit Committee, Internal Auditor(s), etc. 

which may be used by revenue audit personnel for rare instances 

where they may not be comfortable reporting a detected finding 

within their department.

§ 543.24 (c)

543.24(c)

Documentation. The performance of revenue audit 

procedures, the exceptions noted, and the followup of all revenue audit exceptions must be 

documented and maintained.

Intent: To require the documentation, and its maintenance, of the 

revenue audit workflow from start to follow-up. To provide 

documented evidence that revenue audit procedures are 

performed correctly, exceptions are appropriately reported, and 

follow-up is conducted to avoid recurrence of exceptions. 

Testing:

1. For selected test period, examine all documentation prepared 

to evidence the performance of revenue audit procedures. 

This should include documented exceptions and follow-up of 

those exceptions to verify revenue audit work is properly 

documented. Examinations should include testing to verify the 

following is performed and clearly documented: (1) what work 

is performed and by whom, (2) any exceptions are noted and 

properly communicated to personnel and/or departments for 

response and corrective action, and (3) follow-up is performed 

to review responses and re-perform testing, if needed.

2. Inquiries and/or observations may be needed to determine 

how revenue audit documents its procedures when the 

documentation is unclear. If no exceptions were noted for the 
selected test period, the audit sample should be expanded to 

include periods where documented exceptions and follow-up

were completed. 

3. If any findings are noted related to the failure to perform 

revenue audit procedures as required under this section, this 

standard should be re-visited to determine if a finding under 

this standard (due to a lack of documented performance) 

would be appropriate.

Best Practice: The industry relies on many standardized forms to 

document the performance of revenue audit procedures. Such 

forms help clarify when, how, and for whom the procedures are

performed and can be an essential tool for monitoring and 

verifying the performance and effectiveness of the revenue audit 

workflow. Standardized forms for revenue audit include revenue 

audit checklists, testing narratives, exception notices, and 

exception/follow-up logs.

Note: For § 543.24 (d), ensure each process is properly documented in the Operation’s TICS and/or SICS.

§ 543.24 (d)(1)

543.24(d)(1)(i)

Controls must be established and procedures 

implemented to audit of each of the following 

operational areas:

(1) Bingo.

(i) At the end of each month, verify the accuracy of 

the ending balance in the bingo control log by 

Intent: To provide for the protection of assets and verify bingo 

transactions are properly recorded by performing a reconciliation 

between the recorded bingo inventory and the physical inventory 

of bingo paper at the end of the month.

Testing: 
reconciling it with the bingo paper inventory. 

Investigate and document any variance noted.

1. Review TICS and/or SICS to confirm controls and revenue audit

procedures for the end of the month bingo inventory

reconciliation are established and implemented.

2. For selected test period, examine revenue audit’s

documentation to determine whether the end of the month

bingo paper inventory reconciliations were completed.

3. Test documentation to verify the physical inventory of bingo 

paper was reconciled to the inventory recorded in the bingo 

control log, which may be a manual or computerized record. If 

any variances in the reconciliation were noted, verify that they 

were investigated and documented with the determined 

cause and proposed corrective action to avoid recurrence of 

variances, as applicable. If no variances were noted, inquire to 

verify what procedures would be performed had there been a 

variance.

 

543.24(d)(1)(ii)

Controls must be established and procedures 

implemented to audit of each of the following 

operational areas:

(1) Bingo.

(ii) Daily, reconcile supporting records and 

documents to summarized paperwork or 

electronic records (e.g. total sales and payouts per 

shift and/or day).

Intent: To provide for the protection of assets and verify bingo 

transactions are properly recorded and supported by performing a 

reconciliation between supporting documentation and 

summarized records (paper or electronic) on a daily basis.

Testing: 

1. Review TICS and/or SICS to confirm controls and revenue audit 

procedures for the daily records reconciliation are established 

and implemented.

2. For selected test period, examine revenue audit’s 

documentation to determine whether the daily bingo records 

reconciliation was completed. 

3. Test documentation to verify supporting records and 

documents for bingo were reconciled to summarized 
paperwork or electronic records. Reconciled records should 

include activity such as bingo sales and payouts and may 

include records for bingo banks (if applicable) or other bingo 

activity. If any summarized records were unable to be 

reconciled to documentation, verify whether revenue audit 

noted an exception and communicated with the bingo

department to determine and/or correct the cause of missing 

or inaccurate documentation or records.

543.24(d)(1)(iii) Controls must be established and procedures 

implemented to audit of each of the following 

operational areas:

(1) Bingo.

(iii) At least monthly, review variances related to 

bingo accounting data in accordance with an 

established threshold, which must include, at a 

minimum, variance(s) noted by the Class II gaming 

system for cashless transactions in and out, 

electronic funds transfer in and out, external 

bonus payouts, vouchers out and coupon 

promotion out. Investigate and document any 

variance noted.

Intent: To provide for the protection of assets and verify bingo 

revenue is properly recorded by Class II systems and in the 

accounting, records by reviewing meter data on system reports 

and recorded accounting data.

Testing: 

1. Review TICS and/or SICS to confirm controls and revenue audit 

procedures exist requiring that at least monthly a review of 

variances related to bingo accounting data are established and 

implemented. Verify that the established threshold includes 

the minimum types of variances required under this standard, 

as applicable, and determine whether additional types of 

variances are included in the controls.

2. For selected test period, examine revenue audit’s 

documentation to determine whether reviews of variances 

related to bingo accounting data were completed at least 

monthly.

3. Test documentation to verify review of variances related to 

bingo accounting data, in accordance with the established 

threshold. Variances may be identified by the Class II system, 

such as for meter failures, variances between meter data and 
recorded accounting journal entries or records, such as clerical 

errors. For variances noted, verify that they were investigated 

and documented. Including, the determined cause and 

proposed corrective action. If no variances were noted in test 

sample, inquire with revenue audit, what procedures would 

be performed for variances to verify procedures are known.

543.24(d)(1)(iv) Controls must be established and procedures 

implemented to audit of each of the following 

operational areas:

(1) Bingo.

(iv) At least monthly, review statistical reports for 

any deviations from the mathematical 

expectations exceeding a threshold established by 

the TGRA. Investigate and document any 

deviations compared to the mathematical 

expectations required to be submitted per §547.4.

Intent: To provide for the protection of assets and verify Class II 

gaming equipment is performing in accordance with the 

specifications set by the manufacturer and as certified by the 

laboratory.

Testing: 

1. Review TICS and/or SICS to confirm controls and revenue audit 

procedures are established for the review of statistical reports 

on at least a monthly basis and implemented. Determine the 

threshold level between actual and theoretical hold that has 

been established by the TGRA requiring investigation. 

2. For selected test period, examine revenue audit’s 

documentation to determine whether the review of statistical 

reports for Class II gaming equipment was completed at least 

monthly.

3. Test documentation to verify statistical reports for Class II 

gaming equipment were reviewed. Identify any deviations 

from the actual to theoretical hold percentage that exceeded

the TGRA established threshold and confirm whether they

were investigated and documented. 

Typically, reports will compare month-to-date and year-todate data. For any deviations identified, verify they were 

investigated and documented with the determined cause
(e.g., high or low amount of payouts on equipment, high 

amount of recent wagering, machine recently entered service, 

etc.). Some causes should be continually monitored if 

equipment has a history of frequent deviations to determine 

whether fraudulent payouts or equipment compromise has

occurred. If a cause cannot be determined, the manufacturer 

may need to be contacted to determine if equipment was 

installed correctly and/or if it has the correct software 

activated/installed. Confirm if any continual monitoring takes 

or would take place if equipment has continuous deviations.

543.24(d)(1)(v) Controls must be established and procedures 

implemented to audit of each of the following 

operational areas:

(1) Bingo.

(v) At least monthly, take a random sample, foot 

the vouchers redeemed and trace the totals to the 

totals recorded in the voucher system and to the 

amount recorded in the applicable cashier's 

accountability document.

Intent: To provide for the protection of assets and verify vouchers 

are properly redeemed.

Testing:

1. Review TICS and/or SICS to confirm controls and revenue audit 

procedures are established and implemented for the (at least 

monthly) footing and tracing of a random sample of vouchers.

Controls and procedures should indicate the minimum sample 

size. 

2. For selected test period, examine revenue audit’s 

documentation to determine whether the footing and tracing 

of a random sample of vouchers has been completed at least 

monthly. 

3. Test documentation to verify that a random sample of 

redeemed vouchers were footed (usually documented by 

adding machine tape or a spreadsheet) and traced to the 

totals recorded by the voucher redemption system and the 

cage cashier’s accountability documentation. If the footed 

total does not agree to the system and/or accountability

totals, confirm whether the cause was determined and 
whether management and/or the department was notified, if 

applicable.

§ 543.24 (d)(2)

543.24(d)(2)(i) Controls must be established and procedures 

implemented to audit of each of the following 

operational areas:

(2) Pull tabs.

(i) Daily, verify the total amount of winning pull 

tabs redeemed each day.

Intent: To provide for the protection of assets and verify 

redeemed pull tabs are properly recorded. 

Testing: 

1. Review TICS and/or SICS to confirm controls and revenue audit 

procedures for the daily verification of redeemed winning pull 

tabs are established and implemented. 

2. For selected test period, examine revenue audit’s 

documentation to determine if the daily verification of 

winning pull tabs has been completed. 

3. Test documentation to verify that redeemed winning pull tabs 

were physically verified and the total amount was traced to 

system records and/or payout documentation to confirm 

proper recording of pull tab payouts. 

543.24(d)(2)(ii)

Controls must be established and procedures 

implemented to audit of each of the following 

operational areas:

(2) Pull tabs.

(ii) At the end of each month, verify the accuracy 

of the ending balance in the pull tab control log by 

Intent: To provide for the protection of assets and verify pull tab 

transactions are properly recorded by performing a reconciliation 

between the recorded pull tab inventory and the physical 

inventory of pull tabs on hand at the end of the month.

Testing: 

1. Review TICS and/or SICS to confirm that there are controls and 

revenue audit procedures for the end of the month pull tabs 

inventory reconciliation are established and implemented.
reconciling the pull tabs on hand. Investigate and 

document any variance noted.

2. For selected test period, examine revenue audit’s 

documentation to determine whether the end of the month 

pull tab reconciliation(s) were completed.

3. Test documentation to verify that the physical inventory of 

pull tabs on hand was reconciled to the inventory recorded in 

the pull tab control log. This information may be a manual or 

computerized record. If any variances in the reconciliation 

were noted, verify that they were investigated and 

documented, including the determined cause and proposed 

corrective action to avoid recurrence of variances, as 

applicable. If no variances were noted, inquire to verify what 

procedures would be performed.

543.24(d)(2)(iii) Controls must be established and procedures 

implemented to audit of each of the following 

operational areas:

(2) Pull tabs.

(iii) At least monthly, compare for reasonableness 

the amount of pull tabs sold from the pull tab 

control log to the amount of pull-tab sales.

Intent: To provide for the protection of assets and verify pull tab 

transactions are properly recorded.

Testing: 

1. Review TICS and/or SICS to confirm controls and revenue audit 

procedures for the at least monthly comparison of pull tab 

sales are established and implemented.

2. For selected test period, examine revenue audit’s 

documentation to determine if the at least monthly 

comparison of pull tab sales was completed.

3. Test documentation to verify that the amount of pull tabs sold 

from the pull tab control log was compared to the amount of 

recorded pull tab sales to confirm proper recording of sales.
543.24(d)(2)(iv) Controls must be established and procedures 

implemented to audit of each of the following 

operational areas:

(2) Pull tabs.

(iv) At least monthly, review statistical reports for 

any deviations exceeding a specified threshold, as 

defined by the TGRA. Investigate and document 

any large and unusual fluctuations noted.

Intent: To provide for the protection of assets and verify pull tab 

games are performed in accordance with vendor specifications by 

review of significant deviations in actual to theoretical hold as 

recorded in statistical reports.

Testing: 

1. Review TICS and/or SICS to confirm controls and revenue audit 

procedures for the at least monthly review of statistical 

reports are established and implemented. Determine the 

TGRA established variance threshold level, between actual 

and theoretical hold, which requires investigation. 

2. For selected test period, examine revenue audit’s 

documentation to determine whether the review of statistical 

reports for pull tabs was completed at least monthly. 

3. Test documentation to verify statistical reports for pull tabs 

were reviewed to identify deviations exceeding the threshold 

set by TGRA of the actual to theoretical hold percentage. For 

any large and unusual fluctuations identified, verify that they 

were investigated and documented with the determined 

cause. For example, game ending early, low sales of game, 

etc. Note: Proper recording of transactions for game should be 

reviewed when a large or unusual fluctuation is identified to 

determine whether the game may have been compromised or 

fraudulent activity may have occurred (e.g., use of inside 

knowledge about the payout activity for the game).

§ 543.24 (d)(3)
543.24(d)(3)(i) Controls must be established and procedures 

implemented to audit of each of the following 

operational areas:

(3) Card games.

(i) Daily, reconcile the amount indicated on the 

progressive sign/meter to the cash counted or 

received by the cage and the payouts made for 

each promotional progressive pot and pool. This 

reconciliation must be sufficiently documented, 

including substantiation of differences and 

adjustments.

Intent: To provide for the protection of funds contributed by 

patrons and the operation (if applicable) for progressive pots and 

pools and verify the correct amount(s) are communicated to 

patrons and card games staff by reconciliation of posted amounts 

to progressive activity and transactions.

Testing:

1. Review TICS and/or SICS to confirm controls and revenue audit 

procedures for the daily reconciliation of progressive pot(s) 

and pool(s) are established and implemented. 

2. For selected test period, examine revenue audit’s 

documentation to determine whether the daily reconciliation 

of card game progressive pot(s) and pool(s) was completed.

3. Test documentation to verify that the posted amount(s) of the 

card game progressive pot(s) and pool(s) are reconciled by the 

amount of contributions received from patrons, by drop or 

transfer, and payouts (if any occurred). If there are, any 

differences or adjustments verify that they were adequately 

documented with a valid explanation. The reconciliation 

document(s) should include the prior day’s posted amount, 

the amount of contributions and payouts, and the new 

amount posted. Differences should be reviewed to ensure 

they are in accordance with progressive rules and Card Games 

MICS. Payouts for card game progressives are infrequent and

therefore may require expanding test period.

Best Practice: General industry practice includes updating the

posted progressive sign(s) or meter(s) displayed in the card games 

area immediately following the daily reconciliation.
543.24(d)(3)(ii) Controls must be established and procedures 

implemented to audit of each of the following 

operational areas:

(3) Card games.

(ii) At least monthly, review all payouts for the 

promotional progressive pots, pools, or other 

promotions to verify payout accuracy and proper 

accounting treatment and that they are conducted 

in accordance with conditions provided to the 

patrons.

Intent: To provide for the protection of funds contributed by 

patrons and the operation (if applicable) for progressive pots, 

pools, and/or other promotions and to verify payouts are 

conducted and recorded properly.

Testing:

1. Review TICS and/or SICS to confirm controls and revenue audit 

procedures for the at least monthly review of all card games 

promotional payouts are established and implemented. 

2. For selected test period, examine revenue audit’s 

documentation to determine whether the review of all card 

games promotional payouts was completed at least monthly. 

3. Test documentation to verify all card games payouts for 

promotional pot(s) and pool(s) and/or other promotions are 

reviewed. Verify through documentation that payouts are 

accurately recorded and given proper accounting treatment. 

Verify proper accounting treatment should be verified by 

comparing payouts to accounting records (such as general 

ledger activity) for progressive liability and/or promotional 

expense. Also, verify that payouts are in accordance with the 

conditions provided to patrons in the rules for the 

progressive(s) and/or promotion by comparing payout 

documentation to the applicable rules and/or conditions.
543.24(d)(3)(iii) Controls must be established and procedures 

implemented to audit of each of the following 

operational areas:

(3) Card games.

(iii) At the conclusion of each contest/tournament, 

reconcile all contest/tournament entry and payout 

forms to the dollar amounts recorded in the 

appropriate accountability document.

Intent: To provide for the protection of funds from patrons and 

the operation (if applicable) for contests and tournaments and 

verify that entries and payouts are recorded properly by 

reconciling contest/tournament forms to accountability 

documentation.

Testing: 

1. Review TICS and/or SICS to confirm controls and revenue audit 

procedures for the reconciliation of contests and/or 

tournaments are established and implemented. 

2. For selected test period, examine revenue audit’s 

documentation for the reconciliation of each contest(s) and/or 

tournament(s) prepared at the conclusion of the event.

3. Test documentation to verify that the entry and payout forms 

for each contest(s) and/or tournament(s) are reconciled to the 

dollar amounts recorded in the accountability documentation

and to confirm the amount of funds received and paid out for 

the contest and/or tournament were recorded accurately.

§ 543.24 (d)(4)

543.24(d)(4)(i) Controls must be established and procedures 

implemented to audit of each of the following 

operational areas:

(4) Gaming promotions and player tracking.

(i) At least monthly, review promotional payments, 

drawings, and giveaway programs to verify payout 

accuracy and proper accounting treatment in 

accordance with the rules provided to patrons.

Intent: To provide for the protection of assets and operational 

integrity for promotions and verify payouts are conducted and 

recorded properly. 

Testing: 

1. Review TICS and/or SICS to confirm controls and revenue audit 

procedures for the at least monthly review of promotional 

payouts are established and implemented. 
2. For selected test period, examine revenue audit’s 

documentation to determine whether the review of 

promotional payouts was completed at least monthly.

3. Test documentation to verify that payouts for promotional 

payments, drawings, and/or giveaway programs are reviewed. 

Verify that the payouts are accurately recorded and given

proper accounting treatment. Verify proper accounting 

treatment by comparing payouts to accounting records (such 

as general ledger activity) for promotional expense. Also,

verify that payouts are in accordance with the rules provided 

to patrons for the promotional program by comparing payout 

documentation to the applicable rules.

543.24(d)(4)(ii)(AC)Controls must be established and procedures 

implemented to audit of each of the following 

operational areas:

(4) Gaming promotions and player tracking.

(ii) At least monthly, for computerized player 

tracking systems, perform the following 

procedures:

(A) Review authorization documentation for all 

manual point additions/deletions for propriety;

(B) Review exception reports, including transfers 

between accounts; and

Intent: To provide for the protection of assets and detect 

potentially fraudulent transactions related to player tracking 

systems and transactions.

Testing:

1. Review TICS and/or SICS to confirm controls and revenue audit 

procedures for the at least monthly reviews for player tracking 

systems are established and implemented.

2. For selected test period, examine revenue audit’s 

documentation to determine whether player tracking systems 

and transactions were reviewed at least monthly.

3. Test documentation to verify that player tracking system 

transactions and access to accounts are reviewed. Review 

documentation verifying that all manual point adjustments, 

additions and deletions, were reviewed for proper 

authorization and appropriateness. This review should also 
(C) Review documentation related to access to 

inactive and closed accounts.

confirm such adjustments are not prohibited by the gaming 

operation’s controls.

Exception reports, including transfers between accounts, should 

be reviewed to determine the cause of the exception and whether

such activity is legitimate, authorized, and allowed. Depending on 

the player tracking system, a specific exception report may not be 

available. Reports which include any unusual transactions, such as 

manual changes to activity, account transfers, and voided activity

would be appropriate for this review.

Documentation for access to inactive and/or closed accounts 

should be reviewed to determine the reason and authorization for 

access and the activity performed. (The risk for this type of activity 

may be mitigated if such accounts have their point/activity 

balances zeroed.) If any accounts are inactive or closed due to the 

patron’s request for self-exclusion, reviews should ensure they 

were not contacted in violation of their exclusion request. 

**Dormant accounts with point balances are an attractive target 

for fraudulent activity and access to such accounts should be 

closely monitored.**

543.24(d)(4)(iii) Controls must be established and procedures 

implemented to audit of each of the following 

operational areas:

(4) Gaming promotions and player tracking.

Intent: To provide for the protection of assets and detection of 

potentially fraudulent transactions related to player tracking 

systems and transactions.

Testing: 
(iii) At least annually, all computerized player 

tracking systems must be reviewed by agent(s)

independent of the individuals that set up or make 

changes to the system parameters. The review 

must be performed to determine that the 

configuration parameters are accurate and have 

not been altered without appropriate 

management authorization Document and 

maintain the test results.

1. Review TICS and/or SICS to confirm that controls and revenue 

audit procedures for the at least annual review of player 

tracking system parameters are established and implemented. 

2. For selected test period, examine revenue audit’s 

documentation to determine whether the player tracking 

system parameters review was completed at least annually. 

3. Test documentation to verify that player tracking system 

parameters are reviewed. The review should include: (1) 

identification of system parameters in the player tracking 

system which can be altered and may present a risk of 

fraudulent activity; (2) documentation of the currently 

authorized configuration/system parameters; (3) 

documentation with authorization of any changes to 

parameters for the period under review; (4) comparison of the 

authorized parameters to the currently active parameters; and

(5) the results of the review. 

Parameters vary depending on the type and age of the player 

tracking system. The most common parameter with the greatest 

potential risk is the points awarded structure based on play. Other 

parameters may include, but not be limited to settings for 

promotional events run through the system (such as hot seat 

drawings), bonus point award periods (2X point events), and 

system access settings.

Best Practice: Reviews should focus on potential risk and the 

player tracking system vendor may be a helpful resource in 

identifying parameters, which should be included in this review.

§ 543.24 (d)(5)
543.24(d)(5) Controls must be established and procedures 

implemented to audit of each of the following 

operational areas:

(5) Complimentary services or items. At least 

monthly, review the reports required in 

§543.13(c). These reports must be made available 

to those entities authorized by the TGRA or by 

tribal law or ordinance.

Intent: To provide for the protection of assets and detection of 

potentially fraudulent transactions related to complimentary 

services or items.

Testing: 

1. Review TICS and/or SICS to confirm controls and revenue audit 

procedures for the at least monthly review of reports for 

complimentary services or items are established and 

implemented. 

2. For selected test period, examine revenue audit’s 

documentation to determine whether the reports for 

complimentary services or items transactions were reviewed 

at least monthly. Inquire with revenue audit personnel about 

process for reviewing reports and clarification (if needed) 

regarding documentation examined.

3. Test documentation to verify that the reports for 

complimentary services or items, required under 543.13(c) are 

reviewed and reports are made available to authorized 

entities. The reports under review should summarize the 

complimentary services and items records. Revenue audit 

should ensure that reported transactions were properly 

reviewed for proper authorization and compliance with 

thresholds. In addition, any transactions, which were not 

properly authorized must be investigated to determine the 

cause and reported to management (as applicable). Proper 

authorization requirements should be documented in the 

procedures for complimentary services or items. Review 

should also include review of situational restrictions covered 

by the procedures (e.g., procedures often prohibit issuances to 

family members).
Best Practice: It is a recommended practice to examine multiple 

transactions issued to the same person within a close timeframe, 

which are just below or at the issuer’s authorization limit, to 

determine whether the issuer is subverting their limit by the 

issuance of multiple complimentary services or items.

§ 543.24 (d)(6)

543.24(d)(6)(i) Controls must be established and procedures 

implemented to audit of each of the following 

operational areas:

(6) Patron deposit accounts.

(i) At least weekly, reconcile patron deposit 

account liability (deposits ± adjustments −

withdrawals = total account balance) to the system 

record.

Intent: To provide for the protection of funds deposited by 

patrons and verify account transactions are properly recorded. 

Testing:

1. Review TICS and/or SICS to confirm controls and revenue audit 

procedures for the at least weekly reconciliation of patron 

deposit account liability are established and implemented. 

2. For selected test period, examine revenue audit’s 

documentation to determine whether the patron deposit 

accounts were reconciled at least weekly. 

3. Test documentation to verify that the patron deposit account 

liability was reconciled to the system records. The 

reconciliation should include examination of accounting 

records for the patron deposit account liability and 

comparison to system records for all patron accounts with an 

account balance. If the balances do not reconcile, an 

investigation should be performed to determine the cause.
543.24(d)(6)(ii) Controls must be established and procedures 

implemented to audit of each of the following 

operational areas:

(6) Patron deposit accounts.

(ii) At least weekly, review manual increases and 

decreases to/from player deposit accounts to

ensure proper adjustments were authorized.

Intent: To provide for the protection of assets and verify manual 

transactions for patron deposit accounts are properly authorized 

Testing:

1. Review TICS and/or SICS to confirm controls and revenue audit 

procedures for the at least weekly review of manual increases 

and decreases for patron deposit accounts are established and

implemented. 

2. For selected test period, examine revenue audit’s 

documentation to determine whether the manual increases 

and decreases for patron deposit accounts were reviewed at 

least weekly. 

3. Test documentation to verify that manual increases and 

decreases for player deposit accounts were reviewed. The 

review should include examination of all manual increases and 

decreases for accounts. Including, testing to verify that the 

adjustments are in accordance with procedures and were 

performed with proper authorization. The procedures for 

patron deposit accounts should identify whom may authorize 

the adjustments.

§ 543.24 (d)(7)

543.24(d)(7)(i)(AE)Controls must be established and procedures 

implemented to audit of each of the following 

operational areas:

(7) Lines of credit.

Intent: To provide for the protection of assets and minimize the 

exposure to credit risk by review, reconciliations, and

examinations of credit accounts, credit activity, and collection 

activity.

Testing:
(i) At least three (3) times per year, an agent 

independent of the cage, credit, and collection 

functions must perform the following review:

(A) Select a sample of line of credit accounts;

(B) Ascertain compliance with credit limits and 

other established credit issuance procedures;

(C) Reconcile outstanding balances of both active 

and inactive (includes write-offs and settlements) 

accounts on the accounts receivable listing to 

individual credit records and physical instruments. 

This procedure need only be performed once per 

year for inactive accounts; and

(D) Examine line of credit records to determine 

that appropriate collection efforts are being made 

and payments are being properly recorded.

(E) For at least five (5) days during the review 

period, subsequently reconcile partial payment 

receipts to the total payments recorded by the 

cage for the day and account for the receipts 

numerically.

1. Review TICS and/or SICS to confirm controls and revenue audit 

procedures for the at least three times per year review of 

credit accounts and credit and collection activities are

established and implemented.

2. For selected test period, examine revenue audit’s

documentation to determine whether the credit accounts and 

credit and collection activities were reviewed at least three 

times per year. Inquire with revenue audit personnel about 

their process for review of credit and for clarification (if 

needed) regarding documentation examined.

3. Test documentation to verify proper reviews were performed 

for credit accounts and credit and collections activity. Confirm 

an adequate sample of line of credit accounts were selected 

(sample should include active, inactive, and closed accounts 

and a range of authorized credit limits if possible). The review 

should include testing whether account activity complied with 

authorized credit limits and all other established credit 

issuance procedures for the selected sample. As part of the 

review, the outstanding balances of accounts on the accounts 

receivable listing should be reconciled to individual accounts 

and physical instruments (reconciliation only needs to be 

performed once per year for inactive accounts). The 

reconciliation should verify the A/R listing was updated to 

reflect any write-offs and/or settlements authorized during the 

period under review. The reconciliation should be limited to 

the selected sample, but also include examples of write-offs 

and/or settlements if any occurred. The review should also 

include verification that appropriate collection efforts are 

performed and payments are properly recorded for the 

sample of credit accounts tested. If the selected sample does 

not include accounts in a collections or patron payment 
agreement status, the sample should be expanded to include a 

sample of such accounts if any are present. Finally, the review 

should include a reconciliation of all partial payment receipts 

to the payments recorded by the cage for the day for a 

minimum of five days during each review period with the 

receipts numerically accounted for.

Best Practice: The sample size selected for review varies 

depending on the level of credit activity for the Gaming 

Operation. However, a 5-15% sample of credit accounts for each 

of the three reviews within the year is the average. As suggested 

above, the sample should include accounts in a variety of statuses 

for an effective review.

543.24(d)(7)(ii) Controls must be established and procedures 

implemented to audit of each of the following 

operational areas:

(7) Lines of credit.

(ii) At least monthly, perform an evaluation of the 

collection percentage of credit issued to identify 

unusual trends.

Intent: To provide for the protection of assets and minimize the 

exposure to credit risk by evaluation of collection percentage of 

issued credit.

Testing:

1. Review TICS and/or SICS to confirm controls and revenue audit 

procedures for the at least monthly evaluation of credit 

collection are established and implemented. 

2. For selected test period, examine revenue audit’s 

documentation to determine whether the credit collection

percentage was evaluated at least monthly.

3. Test documentation to verify that an evaluation of the 

collection percentage of credit issued to identify unusual 

trends was performed. The monthly collection percentage 

should be calculated by:

• The total of collections in areas other than the pit
• Divided by the sum of:

• Pit marker credit issues and Cage credit issues. 

The collection percentage for the month should be reviewed and 

compared to previous monthly percentages to identify unusual 

trends. Any unusual trends detected should be brought to the 

attention of management, as applicable, to determine the cause 

and whether any changes need to be made in credit authorization 

and issuance processes.

Best practice: If available, year-to-date, life-to-date, and rolling 12 

month-to-date percentages may be used for additional analysis in 

the monthly evaluation. 

§ 543.24 (d)(8)

543.24(d)(8)(i) Controls must be established and procedures 

implemented to audit of each of the following 

operational areas:

(8) Drop and count.

(i) At least quarterly, unannounced currency 

counter and currency counter interface (if 

applicable) tests must be performed, and the test 

results documented and maintained. All 

denominations of currency and all types of cash 

out tickets counted by the currency counter must 

be tested. This test may be performed by internal 

audit or the TGRA. The result of these tests must 

Intent: To provide for the protection of assets and verify count 

equipment is functioning properly. 

Testing: 

1. Review TICS and/or SICS to confirm controls and revenue audit 

procedures for the at least quarterly unannounced currency 

counter and currency counter interface (if applicable) are

established and implemented. 

2. For selected test period, examine revenue audit’s 

documentation to determine whether the currency counter 

and currency counter interface (if applicable) were tested 

(unannounced) at least quarterly.

3. Test documentation to verify unannounced tests of currency 

counter(s) and the currency counter interface (if applicable) 

were performed. Confirm documentation verifies testing was 
be documented and signed by the agent(s) 

performing the test.

performed to include all currency counters used to count the 

drop and the communication of the test count to the 

accounting system through the currency counter interface (if 

applicable) and is signed by the agent(s) who performed the 

test. The test(s) should include all denominations of currency 

and all types of cash out tickets counted by the equipment. 

Testing for tickets should be based on the capability of the 

counter(s), either by number of tickets or by amount of each 

ticket. Document the testing of the interface, confirm the 

amount tested by the counter(s), traced to the casino 

accounting system and verified for accuracy. Note: an interface 

can be through direct wire, wireless, or storage media data 

transmission.

Best Practice: Typically, the physical performance of tests for 

count equipment are performed by count team staff with revenue 

audit functioning as an observer. The standard allows this test to 

be performed by internal audit or the TGRA, but consider

independence standards when testing compliance of this standard 

for internal audit.

543.24(d)(8)(ii) Controls must be established and procedures 

implemented to audit of each of the following 

operational areas:

(8) Drop and count.

(ii) At least quarterly, unannounced weigh scale 

and weigh scale interface (if applicable) tests 

must be performed, and the test results 

Intent: To provide for the protection of assets and verify count 

equipment is functioning properly by unannounced testing of 

weigh scale(s) and the weigh scale interface (if applicable).

Testing: 

1. Review TICS and/or SICS to confirm controls and revenue audit 

procedures for the at least quarterly unannounced weigh scale 

and weigh scale interface (if applicable) are established and 

implemented. 
documented and maintained. This test may be 

performed by internal audit or the TGRA. The 

result of these tests must be documented and 

signed by the agent(s) performing the test.

2. For selected test period, examine revenue audit’s 

documentation to determine whether unannounced weigh 

scale and weigh scale interface (if applicable), tests were 

completed at least quarterly.

3. Test documentation to verify unannounced tests of weigh 

scale(s) and the weigh scale interface (if applicable) were 

performed. Confirm documentation is adequate to verify 

testing was performed to include all weigh scales used to 

count the drop and the communication of the test count to 

the accounting system through the weigh scale interface (if 

applicable) and is signed by the agent(s) who performed the 

test. The test(s) should include all denominations of coin and

tokens counted by the equipment. Documented testing for the 

interface should be performed by confirming the amount 

tested by the weigh scale(s) was traced to the casino 

accounting system and verified for accuracy. Note: an interface 

can be through direct wire, wireless, or storage media data 

transmission.

Best Practice: Typically, the physical performance of tests for 

count equipment are performed by count team staff with revenue 

audit functioning as an observer. The standard allows this test to 

be performed by internal audit or the TGRA, but consider 

independence standards when testing compliance of this standard 

for internal audit.
543.24(d)(8)(iii)(AC)

Controls must be established and procedures 

implemented to audit of each of the following 

operational areas:

(8) Drop and count.

(iii) For computerized key security systems 

controlling access to drop and count keys, 

perform the following procedures:

(A) At least quarterly, review the report 

generated by the computerized key security 

system indicating the transactions performed by 

the individual(s) that adds, deletes, and changes 

users' access within the system (i.e., system 

administrator). Determine whether the 

transactions completed by the system 

administrator provide adequate control over the 

access to the drop and count keys. Also, 

determine whether any drop and count key(s) 

removed or returned to the key cabinet by the 

system administrator was properly authorized;

(B) At least quarterly, review the report generated 

by the computerized key security system 

indicating all transactions performed to 

determine whether any unusual drop and count 

key removals or key returns occurred; and

(C) At least quarterly, review a sample of users 

that are assigned access to the drop and count 

Intent: To provide for the protection of assets and verify sensitive

drop and count keys are properly secured by review of reports, 

transactions, and access to drop and count keys from the

computerized key security system(s).

Testing:

1. Review TICS and/or SICS to confirm controls and revenue audit 

procedures for the at least quarterly review of reports, 

transactions, and access for the computerized key security 

system(s) controlling access to drop and count keys are 

established and implemented. 

2. For selected test period, examine revenue audit’s 

documentation to determine whether the reports, 

transactions, and access to the computerized key security 

system(s) that controls access to drop and count keys were 

reviewed at least quarterly.

3. Test documentation to verify computerized key security 

system’s reports, transactions, and access to drop and count 

keys are reviewed. 

Activity and/or transaction reports for agent(s) with administrative 

rights (system administrator(s)) to the computerized key security 

system should be reviewed to verify whether their transactions 

provide adequate control over access to the drop and count keys, 

such as: ensuring access is restricted to appropriate personnel, 

establishing accountability for drop and count keys, setting system 

parameters to require presence of appropriate number of 

personnel to check-out/check-in keys, etc. In addition, the reports 

and supporting documents should be reviewed to verify proper 

authorization for any drop and count key(s) removed and/or 
keys to determine that their access to the 

assigned keys is appropriate relative to their job 

position.

returned by system administrator(s), such as transactions for: 

replacing broken keys, retagging key rings, replacing key fobs, etc.

Report(s) including all drop and count key transactions performed 

for the computerized key security system should be reviewed to 

identify any unusual removals and/or returns of drop and count 

keys to determine the cause, such as: emergency drops, early or 

late start of drop and/or count, drop due to equipment removal, 

etc., and if such access was appropriate and authorized.

A key access listing report should be examined to select a sample 

of users who are assigned access to the drop and count keys and 

with an active employee listing, a review should be performed to 

verify access is appropriate to their job position. In addition, 

assigned access to drop and count keys by terminated and/or 

transferred employees should be tested to confirm access to drop 

and count keys is properly maintained.

543.24(d)(8)(iv) Controls must be established and procedures 

implemented to audit of each of the following 

operational areas:

(8) Drop and count.

(iv) At least quarterly, an inventory of all 

controlled keys must be performed and 

reconciled to records of keys made, issued, and 

destroyed. Investigations must be performed for 

all keys unaccounted for, and the investigation 

documented.

Intent: To provide for the protection of assets and verify accurate 

accounting for sensitive drop and count keys.

Testing:

1. Review TICS and/or SICS to confirm controls and revenue audit

procedures for the at least quarterly inventory of controlled 

keys, reconciliation to records, and documentation of 

investigations are established and implemented. 

2. For selected test period, examine revenue audit’s 

documentation to determine if the at least quarterly inventory 

of controlled keys, reconciliation to records, and 

documentation of investigations (if applicable) was completed.
3. Test documentation to verify a physical inventory of all 

controlled keys was performed and reconciled to records of 

keys made (or ordered from a vendor), issued, and destroyed. 

If any keys were unaccounted for, verify an investigation was 

performed and documented. After the initial key inventory is 

performed at the gaming operation, a perpetual inventory for 

controlled keys should be maintained with adjustments for 

keys made/ordered (additions), keys removed/destroyed 

(subtractions), and keys issued (usually reflected as a change of 

location) using key records for the quarter. On a quarterly 

basis, a physical inventory count should be performed to 

confirm the updated perpetual key inventory based on the key 

records. If any keys are physically unaccounted for, an 

investigation must be performed and documented to 

determine the cause and the level of increased risk due to the 

unaccounted for key(s). If the risk is substantial, the Gaming 

Operation may want to consider a re-keying process for the 

locks of the key(s) that were unaccounted for. 

§ 543.24 (d)(9)

543.24(d)(9)(i) Controls must be established and procedures 

implemented to audit of each of the following 

operational areas:

(9) Cage, vault, cash, and cash equivalents.

(i) At least monthly, the cage accountability must 

be reconciled to the general ledger.

Intent: To ensure accurate accounting of assets held at the cage 

and verify accuracy of financial records

Testing: 

1. Review TICS and/or SICS to confirm controls and revenue audit 

procedures for the at least monthly reconciliation of the cage 

accountability to the general ledger are established and 

implemented. 
2. For selected test period, examine revenue audit’s 

documentation to determine whether the cage accountability

was reconciled to the general ledger at least monthly. 

3. Test documentation to verify that a reconciliation of the cage 

accountability to the general ledger was performed. Confirm 

documentation verifies the amount(s) from the cage 

accountability records were traced to the general ledger 

account(s). If any amounts do not reconcile, confirm Auditing 

Revenue inquired with accounting personnel to determine the 

cause.

543.24(d)(9)(ii) Controls must be established and procedures 

implemented to audit of each of the following 

operational areas:

(9) Cage, vault, cash, and cash equivalents.

(ii) At least monthly, trace the amount of cage 

deposits to the amounts indicated in the bank 

statements.

Intent: To provide for the protection of assets and verify cage 

deposits are accurately recorded by the Gaming Operation and 

financial institution.

Testing:

1. Review TICS and/or SICS to confirm controls and revenue audit 

procedures for the at least monthly tracing of the amount of 

cage deposits to the bank statement(s) are established and 

implemented. 

2. For selected test period, examine revenue audit’s 

documentation to determine whether the cage deposits were 

traced to the bank statement(s) at least monthly.

3. Test documentation to verify a tracing of cage deposits to the 

bank statement(s) was performed. Confirm documentation 

verifies the amount(s) from the cage deposits were traced to 

the amount of deposits indicated in the bank statements. If 

any amounts do not trace, confirm inquiry was made with 

accounting personnel to determine the cause.
543.24(d)(9)(iii)(AB)

Controls must be established and procedures 

implemented to audit of each of the following 

operational areas:

(9) Cage, vault, cash, and cash equivalents.

(iii) Twice annually, a count must be performed of 

all funds in all gaming areas (i.e. cages, vaults, and 

booths (including reserve areas), kiosks, cash-out 

ticket redemption machines, and change 

machines). Count all chips and tokens by 

denomination and type. Count individual straps, 

bags, and imprest banks on a sample basis. 

Reconcile all amounts counted to the amounts 

recorded on the corresponding accountability 

forms to ensure that the proper amounts are 

recorded. Maintain documentation evidencing 

the amount counted for each area and the 

subsequent comparison to the corresponding 

accountability form. The count must be 

completed within the same gaming day for all 

areas.

(A) Counts must be observed by an individual 

independent of the department being counted. It 

is permissible for the individual responsible for 

the funds to perform the actual count while being 

observed.

(B) Internal audit may perform and/or observe 

the two counts.

Intent: To provide for the protection of assets and verify gaming 

area accountabilities are properly accounted for and accurately 

recorded.

Testing:

1. Review TICS and/or SICS to confirm controls and revenue audit 

procedures for the twice annual count of all gaming areas and 

reconciliations to corresponding accountability forms, with 

evidencing documentation maintained, are established and 

implemented. 

2. For selected test period, examine revenue audit’s 

documentation to determine whether the count of all gaming 

areas and reconciliations to corresponding accountability 

forms was completed at least twice per year. 

3. Verify that physical counts were performed for all gaming 

areas and all amounts counted are traced to the amount 

recorded on the appropriate accountability form. Counts 

should be performed by counting all chips and tokens by 

denomination and type and count of individual straps, bags, 

and imprest banks on a sample basis. The sample size should 

be weighted by value and risk, where higher denominations or 

amount are counted more frequently than lower 

denominations or amount. The maintained documentation for 

the counts should reflect the amount counted for each area 

and that it was compared to the corresponding accountability

form. The count is to be completed within the same gaming 

day for all areas. Observation of counts must be by personnel 

independent of the area/department being counted and it is 

preferred that the individual responsible for the funds perform 

the actual count. An independent accountant may be used to 

perform (observe) the counts.
Best practice: The standard allows the counts to be performed 

and/or observed by internal audit, but consider independence

standards when testing compliance of this standard for internal 

audit.

543.24(d)(9)(iv) Controls must be established and procedures 

implemented to audit of each of the following 

operational areas:

(9) Cage, vault, cash, and cash equivalents.

(iv) At least annually, select a sample of invoices 

for chips and tokens purchased, and trace the 

dollar amount from the purchase invoice to the 

accountability document that indicates the 

increase to the chip or token inventory to ensure 

that the proper dollar amount has been recorded.

Intent: To provide for the protection of assets and verify the chip 

and token accountability is accurately updated to reflect 

purchases.

Testing: 

1. Review TICS and/or SICS to confirm controls and revenue audit 

procedures for the at least annual tracing of a sample of 

invoices, for chips and tokens purchased, to the accountability 

document(s) are established and implemented.

2. For selected test period, examine revenue audit’s 

documentation to determine whether a sample of invoices,

for chips and tokens purchased are traced to the 

accountability document(s) at least annually.

3. Test documentation to verify that a sample of invoices for chip 

and token purchases are traced to the accountability 

document(s). The documentation should reflect that the dollar 

amount (total face value of the chips or tokens) from each 

invoice selected is traced to the accountability document 

indicating the increase to the chip or token inventory to 

ensure accurate recording.

Best Practice: If chip and token purchases do not occur often, it is 

suggested to trace all purchase invoices.
543.24(d)(9)(v) Controls must be established and procedures 

implemented to audit of each of the following 

operational areas:

(9) Cage, vault, cash, and cash equivalents.

(v) At each business year end, create and 

maintain documentation evidencing the amount 

of the chip/token liability, the change in the 

liability from the previous year, and explanations 

for adjustments to the liability account including 

any adjustments for chip/token float.

Intent: To ensure accurate accounting of the chip/token liability 

and verify accuracy of financial records by creating documentation 

for the liability, change from the prior year and explanations for 

increases/decreases to the liability account.

Testing:

1. Review TICS and/or SICS to confirm controls and revenue audit 

procedures for the business year-end creating documentation 

for the chip/token liability, change from the prior year, and 

explanations for increases/decreases to the liability account

are established and implemented. 

2. For selected test period, examine revenue audit’s 

documentation to determine if documentation for the 

chip/token liability change from the prior year and 

explanations for increases/decreases to the liability account

was created at business year-end and maintained.

3. Test documentation to verify documentation is created and 

maintained to evidence the business year-end amount of the 

chip/token liability, the change from the prior year, and the 

explanations for increases/decreases to the liability account 

including any adjustments for chip/token float. The chip/token 

liability should reflect the amount of outstanding chips and 

tokens, at business year-end, held by patrons, which would 

need to be honored by the Gaming Operation when 

redeemed. The change in liability would be the difference 

from the current year-end’s and previous year-end’s liability. 

Adjustments may be made if it is known that a patron will not 

redeem the chips or tokens, such as for 

discontinuation/retirement of a chip/token series. A 

chip/token float may be utilized to reflect a percentage of 

chips and tokens being kept as souvenirs, which will never be 
redeemed. When a chip/token float is used, an adjustment is 

made to the Annual Float for the difference between the 

current and prior year’s Adjusted Float.

Best Practice: Most gaming operations that utilize a chip/token 

float use the Eldorado Method to calculate the Adjusted Float, 

which is calculated as follows:

1. Determine the total value of chips and tokens in active 

circulation.

2. Subtract the value of chips and tokens in the custody or under 

the control of the house as determined in accordance with 

normal counting procedures (including tokens in the Casino’s 

slot machines).

3. Subtract the value of outstanding chips and tokens in 

denomination of $100 or more.

4. Subtract the adjustment for chips and tokens in 

denominations of less than $100 (the “Small Denomination 

Adjustment”). The Small Denomination Adjustment may be 

determined by either of the following alternative

methodologies:

The Experience Method (Alternative 1): The Small 

Denomination Adjustment shall be determined as the sum 

of items (a) and (b).

a) The value of chips and tokens of denominations 

of less than $100 in patrons’ hands determined by 

accrual or observable count as of the Computation 

Date.

b) The value of total chip returns in denominations 

of less than $100 over the one-week period 

immediately following the Computation Date and 
the value of total token returns in denominations 

of less than $100 over the two-week period

immediately following the Computation Date that 

are received by the Casino.

The Percentage Method (Alternative 2): The Small 

Denomination Adjustment shall be determined as the sum 

of items (a), (b), and (c) as applied to chips and tokens 

(other than souvenir chips and tokens):

a) 75% of the value of outstanding chips and tokens 

in denomination of $10 or greater but less than 

$100;

b) 35% of the value of outstanding chips and 

tokens in denominations of $5 or greater but less 

than $10;

c) 10% of the value of chips and tokens of 

denominations of less than $5.

543.24(d)(9)(vi) Controls must be established and procedures 

implemented to audit of each of the following 

operational areas:

(9) Cage, vault, cash, and cash equivalents.

(vi) At least monthly, review a sample of returned 

checks to determine that the required 

information was recorded by cage agent(s) when 

the check was cashed.

Intent: To provide for the protection of assets and verify that 

required information was recorded for cashed checks.

Testing:

1. Review TICS and/or SICS to confirm controls and revenue audit 

procedures are established and implemented for the at least 

monthly review of a sample of returned checks. 

2. For selected test period, examine revenue audit’s 

documentation for the at least monthly review of a sample of 

returned checks.

Test documentation to verify that a sample of returned checks 

was reviewed to confirm the cage agent(s) recorded the 

required information when the check was cashed. Consult the
cage’s check cashing procedures to determine the information 

required to be recorded. If the returned check was guaranteed 

by a 3rd party who refused to reimburse the Casino due to 

failure to follow recording procedures, compliance with the 

vendor’s procedures should be part of the review. Any 

instances where the required information was not recorded 

should be brought to the attention of cage management for

corrective actions.

543.24(d)(9)(vii) Controls must be established and procedures 

implemented to audit of each of the following 

operational areas:

(9) Cage, vault, cash, and cash equivalents.

(vii) At least monthly, review exception reports 

for all computerized cage systems for propriety of 

transactions and unusual occurrences. The review 

must include, but is not limited to, voided 

authorizations. All noted improper transactions or 

unusual occurrences identified must be 

investigated and the results documented.

Intent: To provide for the protection of assets and verify cage 

transactions are properly performed.

Testing:

1. Review TICS and/or SICS to confirm controls and revenue audit 

procedures are established and implemented for the at least 

monthly review of exceptions reports from computerized cage 

systems. 

2. For selected test period, examine revenue audit’s 

documentation to verify that exception reports from 

computerized cage systems were reviewed at least monthly.

3. Test documentation to verify that exception reports from all 

computerized cage systems were reviewed for propriety of 

transactions and unusual occurrences. The review 

documentation should include confirmation that transactions 

identified as exceptions by the cage systems were properly 

verified and authorized. The review must include, but not be 

limited to, voided transactions. All transactions determined to 

be improper or unusual occurrences should be investigated 

with the results documented, including whether management 
and/or department notification was required for corrective 

actions. 

543.24(d)(9)(viii) Controls must be established and procedures 

implemented to audit of each of the following 

operational areas:

(9) Cage, vault, cash, and cash equivalents.

(viii) Daily, reconcile all parts of forms used to 

document increases/decreases to the total cage 

inventory, investigate any variances noted, and 

document the results of such investigations.

Intent: To provide for the protection of assets and verify cage 

transactions are properly recorded. 

Testing:

1. Review TICS and/or SICS to confirm controls and revenue audit 

procedures are established and implemented for the daily 

reconciliation of all parts of forms used to document 

increases/decreases to the total cage inventory. 

2. For selected test period, examine revenue audit’s 

documentation to determine whether the daily reconciliation 

of all parts of forms used to document increases/decreases to 

the total cage inventory was completed. 

3. Test documentation to verify that all parts of forms used to 

document changes to the total cage inventory were

reconciled. The documentation should reflect that revenue 

audit agent(s) verified that all parts of forms included required

transaction information. The reconciliation should identify any 

variances between the forms and the total cage inventory. For 

any variances identified, an investigation should be performed 

with the results documented, including whether management 

and/or department was notified for corrective actions. 

§ 543.24 (d)(10)
543.24(d)(10)(i) Controls must be established and procedures 

implemented to audit of each of the following 

operational areas:

(10) Inventory.

(i) At least monthly, verify receipt, issuance, and 

use of controlled inventory, including, but not 

limited to, bingo cards, pull tabs, playing cards, 

keys, pre-numbered and/or multi-part forms.

Intent: To provide for the protection of assets and verify 

controlled inventory is properly monitored.

Testing:

1. Review TICS and/or SICS to confirm controls and revenue audit 

procedures are established and implemented for the at least 

monthly verification of receipt, issuance, and use of controlled 

inventory.

2. For selected test period, examine revenue audit’s 

documentation to determine whether receipt, issuance, and 

use of controlled inventory are verified at least monthly.

3. Test documentation to confirm receipt, issuance, and use of 

controlled inventory is verified. The verification should 

include, but not be limited to, controlled inventory, such as 

bingo cards, pull tabs, playing cards, keys, pre-numbered 

and/or multi-part forms. Verifications should be performed on

all documentation where misuse presents a risk of loss to

gaming operation assets. Controlled inventory should be 

monitored from when it is received until it is properly used or 

destroyed. If any controlled inventory is determined to be 

missing or not properly accounted for, management and/or 

the department should be notified for corrective actions and 

to determine the level of risk exposure.

Best Practice: Perpetual inventory logs are an effective tool to 

track and monitor controlled inventory. To increase their 

effectiveness, multiple logs may be maintained for the same type 

of inventory for each area it is stored from receipt until it is 

issued/used or returns to accounting as a completed document.
543.24(d)(10)(ii) Controls must be established and procedures 

implemented to audit of each of the following 

operational areas:

(10) Inventory.

(ii) Periodically perform minimum bankroll 

calculations to ensure that the gaming operation 

maintains cash in an amount sufficient to satisfy 

the gaming operation's obligations.

Intent: To provide for the protection of assets (reputation) and 

verify the Gaming Operation is able to meet their obligations to 

their patrons by calculation of minimum bankroll.

Testing:

1. Review TICS and/or SICS to confirm controls and revenue audit 

procedures are established and implemented for the periodic 

calculation of minimum bankroll. Determine how often the 

calculation is performed. 

2. For selected test period, examine revenue audit’s 

documentation to determine whether and when the minimum 

bankroll was calculated. 

3. Test documentation to confirm that minimum bankroll is 

being calculated to ensure the gaming operation maintains 

cash in an amount sufficient to satisfy their obligations to 

patrons. Determine whether (1) the calculation was performed 

correctly, (2) documentation supports the amounts used, and

(3) gaming operation has sufficient cash on hand. The gaming 

operation may establish its own minimum bankroll formula or 

use the NIGC’s.
25 CFR 543.24 Toolkit

Version 1.0

NIGC Training Division

National Indian Gaming Commission Training Manager 

Training Program

Training Manager

Training Program