Surveillance – Audit

25 CFR 543.21 Toolkit

Version 1.0

Division of Public Affairs 

 
NIGC Surveillance Toolkit–25 CFR 543.21

Over thirty years ago, Congress adopted the Indian Gaming Regulatory Act (IGRA) to provide a statutory basis for gaming by Indian tribes. IGRA 

establishes the National Indian Gaming Commission (NIGC) to regulate and provide oversight for gaming activities conducted by sovereign Indian 

tribes on Indian lands. The mission of the NIGC is to realize IGRA’s goals: (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. As a primary means to accomplish these goals, NIGC provides training and technical assistance to Indian tribes, specifically for 

Gaming Operations and Regulators. 

The NIGC is pleased to present this Toolkit to all stakeholders of Indian Gaming. This reference guide assists Auditors, Regulators, and Operations 

personnel in the performance of measuring compliance of their operation(s) with 25 CFR 543.21 and additional 25 CFR 543 standards relevant to 

Surveillance Operations. The Toolkit design provides each 543.21 standard, intent of each standard, and a recommended testing step to ensure 

minimum regulatory compliance. 

Additionally, this Toolkit design meets the minimum requirements of the NIGC Minimum Internal Control Standards (MICS). The Tribal Internal 

Control Standards (TICS) and/or System of Internal Control Standards (SICS) may require further testing which is not included in this Toolkit. The 

uniqueness of each gaming 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 https://www.nigc.gov. 
The Training Department has designed this toolkit as a resource for understanding the Surveillance 543.21 Minimum Internal Control Standards 

(MICS) and as a tool for conducting an audit of the Surveillance department in determining compliance with 543.21. 

This Toolkit table can help: 

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

2. Learn the regulation for Surveillance 543.21. (The regulation is listed in the second column of the table verbatim) 

3. Understand the intent of the regulation and importance of the control. (The intent is listed in the third column in the table) 

4. Determine testing steps to determine compliance with the regulation. (The testing step is listed in the third column of the table under the 

intent information) 

5. Identify best practices. (These have been included for some regulations in either the intent or testing steps to provide the user with current 

industry procedures) and 

6. Consider practical advice when performing testing step. (Example: step completed in another section. Additional information is provided as 

a Note) 

The Toolkit provides many practical and concrete suggestions for understanding and evaluating 543.21compliance. Either the new or the 

experienced auditor will find this Toolkit helpful during various stages of the audit. 
GLOSSARY DEFINITION 

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. 

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 Class II gaming has the same meaning as defined in 25 U.S.C. 2703(7)(A). 

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. 

Count The act of counting and recording the drop and/or other funds. In addition, the total funds counted for a particular 

game, player interface, shift, or other period. 
GLOSSARY DEFINITION 

Count room A secured room where the count is performed in which the cash and cash equivalents are counted. 

Dedicated camera A video camera that continuously records a specific activity. 

Kiosk A device capable of redeeming vouchers and/or wagering credits or initiating electronic transfers of money to or 

from a patron deposit account. 

MICS Minimum internal control standards. 

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". 

Promotional progressive 

pots and/or pools 

Funds contributed to a game by and for the benefit of players that are distributed to players based on a 

predetermined event. 

Sufficient clarity The capacity of a surveillance system to record images at a minimum of 20 frames per second or equivalent 

recording speed and at a resolution sufficient to clearly identify the intended activity, person, object, or location.

Surveillance operation 

room(s) 

The secured area(s) where surveillance takes place and/or where active surveillance equipment is located. 

Surveillance system A system of video cameras, monitors, recorders, video printers, switches, selectors, and other equipment used for 

surveillance. 
 GLOSSARY DEFINITION 

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 

the MICS. 

Vault A secure area where cash and cash equivalents are stored. 

Voucher A financial instrument of fixed wagering value, usually paper, that can be used only to acquire an equivalent value of 

cashable credits or cash through interaction with a voucher system. 
 Surveillance Minimum Internal Control Standards 

§ 543.21 

Citation Language Intent and Testing

 

543.21(a) 

(a) Supervision. Supervision must be 

provided as needed for surveillance by an 

agent(s) with authority equal to or 

greater than those being supervised. 

Intent: To provide for the proper supervision of surveillance staff by 

someone with authority equal to or greater than those being supervised. 

Testing: 

1. Review Surveillance organizational chart, department schedules 

and/or job descriptions to determine supervisory responsibility and 

availability. 

2. Review TICS and or SICS to determine supervisory procedures 

implemented (e.g., designation of supervisory and non-supervisory 

agents, reporting responsibilities, etc.). 

3. Identify and document titles of supervisory personnel. 

4. Interview appropriate personnel (e.g., Surveillance 

Manager/Director, Surveillance Shift Manager/Lead, Surveillance 

Agent) to determine who has supervision responsibility for the 

Surveillance Department. 

5. Observe shift(s) to ensure that supervision requirements are being 

met. 

Best Practices: 

1. Effective supervision should be by someone of greater authority 

than those being supervised. If supervision is of equal authority, 

consider additional controls that clearly distinguish the line of 

authority.

 

543.21(b)(1) 

(b) Surveillance equipment and control 

room(s). Controls must be established and 

procedures implemented that include the 

following: (1) For Tier A, the surveillance system 

must be maintained and operated from a secured 

location, such as a locked cabinet. For Tiers B and 

C, the surveillance system must be maintained 

Intent: To prevent tampering with surveillance equipment and/or 

recordings, and to ensure no unauthorized access. Additionally, it is to 

actively deter, detect, and/or document potential threats to tribal assets 

and the integrity of gaming. This is accomplished by identifying individuals 

and activity, confirming the amounts of transactions, and documenting 

compliance with applicable internal control standards. 
Citation Language Intent and Testing

and operated from a staffed surveillance 

operation room(s). 

Note: Tier A (as defined in Glossary) surveillance systems are not required 

to be staffed. 

Testing: 

1. Review the gaming operation’s annual gross gaming revenue to 

determine which Tier requirements apply (See Definitions for Tier 

thresholds). 

2. Review TICS and/or SICS to determine whether controls for 

gaming operation surveillance equipment and control room(s) 

which meet the requirements for the appropriate Tier are 

established and implemented. 

3. For Tier A gaming operations, (1) observe the surveillance 

equipment and note its surroundings (e.g., within a locked room, 

a cabinet, etc.), (2) interview appropriate personnel (e.g.,

Surveillance Manager/Director, Surveillance Shift Manager/Lead, 

Surveillance Agent, Security Officer) to identify security features, 

and (3) determine whether the surveillance system is operated 

from a secured location. 

4. For Tier B or C, observe the surveillance room(s) for assigned 

staff. If no staff are present at the time of observation, inquire 

with appropriate surveillance personnel and department 

management to determine how the room is being staffed. 

5. Review Surveillance department schedules to ensure appropriate 

staffing levels are maintained for Tier B and C operations. 

Best Practices: 

1. For Tier A operations— 

a. Appropriate personnel (Surveillance Employees, Security 

Officers, or TGRA staff) should check the system at least 

once per day to verify the system is functioning properly 

and ensure the date and time are accurate. 

b. Use a surveillance system access log to document system 

checks, camera and recording device checks, and general 

system access. 
Citation Language Intent and Testing

c. Install a dedicated camera to continuously record the 

physical access point of the surveillance system. 

d. Use hardened doors and tamper resistant locks on 

cabinets and closets housing surveillance equipment. 

2. For Tier B or C operations— 

a. Ensure adequate personnel are present in the room to 

monitor drop and count activities as well as other gaming 

activities occurring at the same time (Size and scope of 

the operation may dictate that one person is enough to 

monitor some shifts, but two or more persons may be 

needed during count and drop activities). 

b. Allow limited personal breaks during times when only one 

surveillance staff member is on duty but require those 

breaks to be in areas separate from other casino 

personnel so that it is not known the surveillance room is 

unoccupied. Ensure that surveillance agents are able to 

answer radio or phone transmissions from the break 

area(s). Generally, it is best to not reveal surveillance 

staffing levels to casino personnel. 

543.21(b)(2)

(2) The surveillance operation room(s) must be 

secured to prevent unauthorized entry. 

Intent: To ensure the surveillance operation room(s) are secured to prevent 

unauthorized persons from entering and or accessing sensitive equipment. 

Testing: 

1. Review TICS and/or SICS to determine whether controls are 

established and implemented for surveillance operation room(s) 

being secured to prevent unauthorized entry . (Note: The 

regulations define surveillance operation room(s) as “The secured 

area(s) where surveillance takes place and/or where active 

surveillance equipment is located.” This control therefore includes 

surveillance server rooms, IDF closets, electrical rooms and closets, 

and communication rooms and closets in the facility—anywhere 

active surveillance equipment is located.)
Citation Language Intent and Testing

2. Note the location of the surveillance operation room(s) and 

accessibility from public or private areas of the gaming operation. 

3. Interview appropriate personnel (e.g., Surveillance 

Manager/Director, Surveillance Shift Manager/Lead, Surveillance 

Agent) to determine the location of all active surveillance equipment 

and how each area is secured. 

4. Physically attempt to open the surveillance operation door(s) before 

disabling any locks. 

Best Practices: 

1. Locate the surveillance operation room so that the entrance is not 

readily accessible or viewable. 

2. In addition to securing the equipment against unauthorized entry, 

surveillance operations should consider requiring measures at 

installation to prevent surveillance equipment (e.g., monitors, 

recording devices, selectors, switches, servers, cabling, patch panels, 

etc.) from being obstructed, tampered with or disabled. 

543.21(b)(3)

(3) Access to the surveillance operation room(s) 

must be limited to surveillance agents and other 

authorized persons. 

Intent: To ensure access to the surveillance operation room(s) is limited to 

surveillance agents and other authorized persons to prevent unauthorized 

personnel from entering. 

Testing: 

1. Review TICS and/or SICS to determine whether controls to limit 

surveillance room access to surveillance agents and other 

authorized persons are established and implemented. (Note: The 

regulations define surveillance operation room(s) as “The secured 

area(s) where surveillance takes place and/or where active 

surveillance equipment is located.” This control therefore includes 

surveillance server rooms, IDF closets, electrical rooms and closets, 

and communication rooms and closets in the facility—anywhere 

surveillance equipment is located.) 
Citation Language Intent and Testing

2. Interview appropriate personnel (e.g., Surveillance 

Manager/Director, Surveillance Shift Manager/Lead, Surveillance 

Agent) to determine who (e.g., General Manager, TGRA staff, 

Security staff, gaming management, law enforcement, tribal officials) 

is authorized to enter the surveillance room, and the conditions 

upon which they may enter. 

3. Review TICS and or SICS to determine whether there is an 

authorized access list. 

4. Verify the Authorized Access List has been approved by either TGRA 

or Operations 

5. Review surveillance access logs and compare them to the authorized 

access list. 

6. If Surveillance Room key(s) are located within a computerized key 

tracking system, review who has authority to remove Surveillance 

Access Keys and compare to the approved access list. 

7. Ask appropriate personnel who has keys/access to the surveillance 

room (e.g., emergency keys, etc.). 

Best Practices: 

1. Set up a separate room where appropriate Department Managers 

may review surveillance video without giving them access to the 

entire surveillance room. 

2. Together with TGRA, establish a list of personnel who can access the 

room or surveillance system under specific conditions (e.g., building 

maintenance, IT, janitorial, etc.). It is also recommended that the 

authorized access list be posted where agents can quickly reference.

543.21(b)(4)

(4) Surveillance operation room(s) access logs 

must be maintained. 

Intent: To ensure that access to the surveillance equipment and control 

room(s) is restricted to authorized persons and that a list of all nonsurveillance personnel entering the surveillance operation room(s). 
Citation Language Intent and Testing

Testing: 

1. Review TICS and/or SICS to determine whether controls which 

require surveillance operation room(s) access logs to be maintained 

are established and implemented. (Note: The regulations define 

surveillance operation room(s) as “The secured area(s) where 

surveillance takes place and/or where active surveillance equipment 

is located.” This control therefore includes surveillance server 

rooms, IDF closets, electrical rooms and closets, and communication 

rooms and closets in the facility—anywhere surveillance equipment 

is located.) 

2. Interview appropriate personnel (e.g., Surveillance 

Manager/Director, Surveillance Shift Manager/Lead, Surveillance 

Agent) to determine whether access logs are maintained and stored 

as required. 

3. Review access logs to confirm that logs are maintained as required, 

that all required information is entered into the log, and that logs 

are current. Verify that the logs are being retained for at least five 

years (see part 571.7(c)). 

Best Practice: 

1. The access log should include the date and time of entry and exit, 

reason for access, name (printed), position/title, and the agent 

authorizing access. 

543.21(b)(5) 

(5) Surveillance operation room equipment must 

have total override capability over all other 

satellite surveillance equipment. 

Intent: To ensure that surveillance agents maintain complete and 

continuous access and control over all surveillance equipment. 

Testing: 

1. Review TICS and/or SICS to determine whether controls which 

require the surveillance operation room equipment have total 

override capability over all other satellite surveillance equipment are 

established and implemented. 

2. Interview appropriate personnel (e.g., Surveillance 

Manager/Director, Surveillance Shift Manager/Lead, Surveillance 
Citation Language Intent and Testing

Agent) to determine whether satellite viewing stations exist and if 

the surveillance room has override capability. Determine total 

number of viewing stations in operation throughout the gaming 

operation. Determine whether any person has access to the 

surveillance system through server access or other means. 

3. Observe override capability of satellite surveillance equipment by 

the surveillance operation room. 

Best Practice: 

1. Consider establishing a MOU with non-surveillance departments, 

which have viewing access to non-sensitive or sensitive cameras. 

Similar to a code of standards for surveillance staff, identify the use 

and conduct of surveillance cameras are for official use and 

monitored by the Surveillance staff, i.e., observations for personal 

use are prohibited. Have training provided for override capabilities 

and that the surveillance operations has priority and secondary 

viewer will relinquish control. 

2. Recommend inquiry whether there is use of any other surveillance 

cameras or systems, such as remote viewing, which are not part of 

casino surveillance system. 

Note: 

1. Some operations choose to allow non-surveillance departments (i.e., 

TGRA, security, table games management, or gaming management) 

access to specific cameras or recording devices. This control was 

created to ensure that Surveillance agent(s) could take control of all 

cameras and recording devices as needed. 

543.21(b)(6) 

(i)-(ii) 

(6) Power loss to the surveillance system: 

(i) For Tier A, in the event of power loss to the 

surveillance system, alternative security 

procedures, such as additional supervisory or 

Intent: To ensure that procedures are in place in the event a power outage 

or catastrophic failure of the surveillance system occurs to reduce potential 

risk to assets. 
Citation Language Intent and Testing

security agents, must be implemented 

immediately. 

(ii) For Tier B and C, in the event of power loss to 

the surveillance system, an auxiliary or backup 

power source must be available and capable of 

providing immediate restoration of power to the 

surveillance system to ensure that surveillance 

agents can observe all areas covered by dedicated 

cameras. 

Testing: 

1. Review TICS and/or SICS to determine whether controls for the 

immediate implementation of alternative security procedures or an 

auxiliary or backup power source (depending on the Tier level of the 

gaming operation), in the event of a power loss to the surveillance 

system are established and implemented. 

2. Interview appropriate personnel (e.g., Surveillance 

Manager/Director, Security Manager/Director, Surveillance Shift 

Manager/Lead, Surveillance Agent) to determine the procedure for 

power outage(s) or other catastrophic failure of the surveillance 

system. For Tier B and C operations, interview appropriate 

personnel (e.g. Surveillance Manager/Director, Surveillance Shift 

Manager, Facility Manager, etc.) to determine whether the operation 

has an auxiliary or backup power source capable of immediate 

restoration of power to the surveillance system. 

3. For Tier B and C gaming operations, review auxiliary or backup 

power source procedures to verify they provide for an immediate 

restoration of power to the surveillance system so that surveillance 

agents can observe all areas of the gaming operation covered by 

dedicated cameras. 

4. TICS and/or SICS should also require periodic testing of the backup 

power source to ensure that it is “available and capable” to provide 

immediate restoration of power. Testing for this control should 

include reviewing backup generator weekly exercise logs and 

transfer switch periodic testing logs. 

Note: 

1. A “backup power source” is typically a backup power generator or 

individual Uninterruptable Power Supply or Source (UPS). An 

“auxiliary power source” is typically an alternative power supplier, 

such as another electricity utility provider, a natural gas utility 

provider, or even alternative power supplies such as solar, wind, 

biofuels, or similar. 
Citation Language Intent and Testing

Best Practices: 

1. If UPS units are utilized solely (without a backup power generator) to 

provide backup power to the surveillance equipment, testing should 

be performed to determine how long the surveillance system can 

safely operate before requiring to be powered down properly 

without damaging the surveillance system components. 

2. Because UPS units provide limited functionality during a power loss 

to the surveillance system, operations should implement alternative 

security procedures along with the use of UPS units. 

3. For Tier A gaming operations, verify that the alternative security 

procedures provide immediate additional security measures for 

areas deemed most vulnerable to theft. (e.g., requirements for 

security and/or supervisory personnel to report to cash handling 

areas such as the Cage and Count Room (if count is active) and table 

games pits.) 

4. Operations should have procedures for events where the power 

goes out to more than just the surveillance system. These 

procedures should include evacuation of the facility and securing of 

assets such as banks, tills, floats, etc. Controls should include 

additional areas that are deemed cash sensitive areas. 

5. Surveillance management should request copies of these logs from 

Facilities Maintenance personnel for documentation purposes. 

Surveillance agents may also log system testing in daily activity 

reports. 

6. Although emergency lighting systems are not necessarily included in 

the language of this control, Surveillance Management should test 

this system along with the backup power source and document 

results. 
Citation Language Intent and Testing

543.21(b)(7) 

(7) The surveillance system must record an 

accurate date and time stamp on recorded 

events. The displayed date and time must not 

significantly obstruct the recorded view. 

Intent: To ensure that video footage is usable and reliable evidence in legal 

proceedings and other formal inquiries (e.g., criminal prosecutions, 

insurance claims, human resources cases, and compliance documentation). 

The date and time stamp is also useful in searching for a particular date or 

time in reviewing footage. 

 

Testing: 

1. Review TICS and/or SICS to determine whether controls for the 

surveillance system to record an accurate date/time stamp on 

recorded events. 

2. Verify the date/time stamp does not significantly obstruct the 

recorded view are established and implemented. 

3. Interview appropriate personnel (e.g., Surveillance 

Manager/Director, Surveillance Shift Manager/Lead, Surveillance 

Agent) to determine the procedure for establishing what date and 

time source is used for the surveillance system settings. 

Best Practices: 

1. Synchronize all gaming operation devices and systems that utilize a 

date/time stamp to one uniform source. 

2. A common date and time source (e.g., atomic clock, phone system 

date/time, etc.) should be used for setting the time on the 

surveillance system. 

3. Surveillance agent(s) should review the date/time stamp as part of 

the periodic camera checks, and document the results. 

543.21(b)(8) 

(8) All surveillance agents must be trained in the 

use of the equipment, games, and house rules. 

Intent: To ensure that the agents are familiar with all surveillance 

equipment, its purpose and use. The activities they are observing and able 

to identify non-compliance with established controls and deviations from 

normal procedures. 
Citation Language Intent and Testing

Testing: 

1. Review TICS and/or SICS to determine whether controls for all 

surveillance agents to receive training in the use of equipment, 

games, and house rules are established and implemented. 

2. Interview appropriate personnel (e.g., Surveillance 

Manager/Director, Surveillance Shift Manager/Lead, Surveillance 

Agent) to determine what training is provided, who receives it, how 

often training is provided, and the types of training programs in 

place. 

3. Review training logs and training documentation in Surveillance 

personnel files to verify what training has been provided, who 

received it, how often training is provided, and the types of training 

programs in place. 

4. Confirm that training programs and the training received includes 

“use of equipment, games, and house rules.” 

Best Practices: 

1. TGRA’s and gaming operations should establish a minimum level of 

training for all surveillance agents in the TICS/SICS that is sufficient 

to equip employees with a complete understanding of the activities 

they are required to observe. 

2. Agents should also receive training in common cheating techniques, 

effective surveillance techniques and methods, typical 

fraud/theft/scam schemes, and a familiarity with the MICS, TICS, 

and SICS. 

543.21(b)(9) 

(9) Each camera required by the standards in this 

section must be installed in a manner that will 

prevent it from being readily obstructed, 

tampered with, or disabled. 

Intent: To protect the camera views being observed and recorded and the 

integrity of the surveillance system in general. Cameras, cabling, 

connections are installed out of reach and in such a manner as the view 

cannot be disabled, altered or obstructed. 
Citation Language Intent and Testing

Testing: 

1. Review TICS and/or SICS to determine whether controls which 

ensure cameras are installed in a manner that prevents them from 

being readily obstructed, tampered with, or disabled are established 

and implemented. 

2. Interview appropriate personnel (e.g., Surveillance 

Manager/Director, Surveillance Shift Manager/Lead, Surveillance 

Technician) to determine what types of cameras are installed and 

how cameras and surveillance equipment are installed in order to 

prevent them from being readily obstructed, tampered with, or 

disabled. 

3. Observe the gaming operation, paying particular attention to areas 

with low ceilings where cameras could be within reach. Observe the 

types of cameras installed in each area and note cameras that may 

be susceptible to being obstructed, tampered with, or disabled. 

(Best practices include installing cameras with tamper-resistant 

domes or so that they are out of reach and the direction that the 

camera is facing or moving is unknown.) 

Best Practices: 

1. SICS should be developed in other departments (e.g., Bingo, Card 

Games, Gaming Promotions) that require Surveillance management 

to be notified of and approve changes to the gaming operation floor 

or installation of promotional signs and items placed on the gaming 

floor. This ensures that those changes and installations do not 

interfere or significantly obstruct required camera coverage. 

2. Surveillance agents should also conduct periodic inspections (at 

least once per shift) of the surveillance system to identify any 

cameras that may have been obstructed, tampered with, or 

disabled. 
Citation Language Intent and Testing

543.21(B)(10)(i)-

(iv) 

(10) The surveillance system must: 

(i) Have the capability to display all camera views 

on a monitor; 

(ii) Include sufficient numbers of recording 

devices to record the views of all cameras 

required by this section; 

(iii) Record all camera views 

(iv) For Tier B and C only, include sufficient 

numbers of monitors to simultaneously display 

gaming and count room activities. 

Intent: The intent of this control is to ensure that Surveillance Agents have 

the technical capabilities (sufficient monitors and recording) to observe all 

activities (such as drops, payouts, transfers, accessing bill acceptors, and 

count room activities) that may occur simultaneously. 

Testing: 

1. Review TICS and/or SICS to determine whether controls ensure the 

surveillance system has the capability to display all camera views on 

a monitor; includes a sufficient number of recording devices to 

record all camera views; records all camera views; and for Tier B and 

C gaming operations, includes sufficient numbers of monitors to 

display gaming and count room activities simultaneously are 

established and implemented. 

2. Interview appropriate personnel (e.g., Surveillance 

Manager/Director, Surveillance Shift Manager/Lead, Surveillance 

Agent) to determine whether (1) the surveillance system has the 

capability to display all camera views on a monitor, (2) includes a 

sufficient number of recording devices to record all camera views, 

(3) records all camera views, and for Tier B and C gaming operations, 

and (4) includes sufficient numbers of monitors to display gaming 

and count room activities simultaneously. 

3. Observe the location of installed cameras on the gaming floor and 

make note of any camera views that do not appear to be displayed 

on surveillance monitors. Review recordings to determine whether 

any camera views are not being recorded as required. For Tier B and 

C only, observe the surveillance system to verify that there are 

sufficient numbers of monitors to display both gaming and count 

room activities simultaneously. 

Notes: 

1. Cameras installed in the surveillance operation room itself that are 

designed solely to monitor surveillance room activities are not 

considered to be non-compliant with this control as they are 

recorded and can be displayed by Surveillance Management. 
Citation Language Intent and Testing

2. The requirement that the surveillance system include “sufficient 

numbers of recording devices to record the views of all cameras” is 

important as it may affect the ability of the system to remain 

compliant with the storage, identification, and retention standards 

referenced in 543.21(f)(1). If insufficient recording devices are 

available, some camera views may not be recorded (stored) as they 

normally would be. Some camera views may not be recorded at the 

required “sufficient clarity” (identification) setting of a minimum of 

20 frames/images per second, as the recording system may 

automatically step down the recording frame rate to adjust to the 

reduced amount of storage media available. Also, if insufficient 

recording devices are available, the recorded video may not be 

retained for the minimum 7 days required due to the reduced 

amount of storage media. 

Best Practices: 

1. “Dummy cameras” or fake cameras in order to give the 

appearance of increased camera coverage are not 

recommended, as these “cameras” cannot be recorded or 

displayed as required. Additionally, the use of these types of 

“cameras” may actually put the tribe at increased liability risk 

due to patrons or employees being given the impression that 

video surveillance of an incident is available when it is not. 

2. One way to test whether there is a sufficient number of 

recording devices for all camera views would be to note the 

number of total cameras and the total number of recording 

devices/servers, then note how many cameras are assigned per 

recording device. 

3. Refer to the SICS/TICS for the required retention requirements 

and then sample a number of cameras to see if the cameras are 

being retained for the required length. All digital storage 

devices should be checked routinely to ensure the standards are 

met, and more frequently when changes are made to the 

storage devices.
Citation Language Intent and Testing

543.21(b)(11)(i) 

–(ii) 

(11) A periodic inspection of the 

surveillance systems must be conducted. 

When a malfunction of the surveillance 

system is discovered, the malfunction 

and necessary repairs must be 

documented and repairs initiated within 

seventy-two (72) hours. 

(i) If a dedicated camera malfunctions, 

alternative security procedures, such as 

additional supervisory or security agents, 

must be implemented immediately. 

(ii) The TGRA must be notified of any 

surveillance system and/or camera(s) 

that have malfunctioned for more than 

twenty-four (24) hours and the 

alternative security measures being 

implemented. 

Intent: The control reduces potential risks to assets by discovering, 

documenting, reporting and addressing malfunctions of the surveillance 

system in a timely manner, and providing additional personnel and/or 

equipment to safeguard the assets in the event a dedicated camera 

malfunctions. 

Testing: 

1. Review TICS and/or SICS to determine whether controls ensure 

the surveillance system is inspected periodically; malfunctions 

and repairs are documented and the TGRA is notified of 

malfunctions lasting more than 24 hours in duration are 

established and implemented. 

2. Determine whether “alternative security procedures” in the case 

of a dedicated camera malfunction are included in the TICS or 

SICS for other gaming operation departments such as Security or 

Gaming. 

3. Interview appropriate personnel (e.g., Surveillance 

Manager/Director, Surveillance Shift Manager/Lead, Surveillance 

Agent) to— 

a. Determine how often surveillance system checks are 

completed and how those checks are logged. 

b. Determine who is responsible for conducting periodic 

inspections, and what the inspection includes. 

c. Discuss what “alternative security procedures” occur if 

there is a dedicated camera malfunction. 

d. Determine if alternative security procedures are included 

in the SICS for other gaming operation departments such 

as Security or Gaming. 

e. Determine how the TGRA is notified, and who at the 

TGRA is notified in the event of a malfunction that lasts 

more than 24 hours. 

4. Review supporting documentation (e.g., Daily Activity Reports, 

Camera Check reports, and Malfunction/Repair Logs) to verify 

that malfunctions and necessary repairs have been documented 
Citation Language Intent and Testing

(see 543.21(f)(2)). Confirm that the repairs are initiated within 

72 hours of being discovered. 

5. Review documentation of notification being made to the TGRA 

of malfunctions lasting more than 24 hours in duration, and 

confirm that alternative security procedures that were taken. 

Note: 

1. While dedicated camera malfunctions are specifically addressed 

in this control, note that the intent is to address “surveillance 

system” malfunctions generally. The surveillance system 

includes all equipment used for surveillance (e.g., monitors, 

recording devices, selectors, switches, servers, cabling, patch 

panels, etc.). The requirements of this control therefore extends 

to periodic inspections, documentation of malfunctions, and 

notifications to the TGRA for all surveillance system equipment. 

Best Practice: 

1. Require checks of all cameras at least once per shift and 

documenting the results. These results can be logged on the 

daily activity report log, or included with the storage, 

identification, and retention compliance log (see 543.21(f)(1)). 

Document any malfunction notifications to the TGRA, along with 

the date/time of the malfunction, date/time of notification, who 

was notified, how they were notified, and what alternative 

security measures were implemented. (“Alternative security 

measures” may involve the repositioning of a PTZ camera, the 

installation of a backup replacement camera, or the positioning 

of additional supervisory or security agents on the gaming floor 

to observe the activity being monitored by the dedicated 

camera.) 
Citation Language Intent and Testing

 

543.21(c)(1) 

(i)-(ii)

(c) Additional surveillance requirements. With 

regard to the following functions, controls must 

also include: (1) Surveillance of the progressive 

prize meters for Class II gaming systems at the 

following thresholds: 

(i) Wide area progressives with a reset amount of 

$1 million; and 

(ii) In-house progressives with a reset amount of 

$250,000. 

Intent: To deter, detect, and/or document potential misappropriation of 

assets or compromise to the integrity of Class II gaming systems, by 

requiring surveillance of high value prize meters. Additionally, recording of 

the meters protects the operation from potential liability and or fraud and 

abuse. 

Testing:

1. Review TICS to determine the controls for display and recording of 

required camera views are established and implemented. 

2. Interview appropriate personnel (e.g., Bingo Management, 

Surveillance Management, etc.) to determine which Class II gaming 

systems, if any, meet the threshold for wide area progressives with a 

reset amount of $1 million and in-house progressives with a reset 

amount of $250,000. 

3. Observe the camera views of those Class II gaming systems meeting 

the progressive thresholds to verify that the camera can view the 

progressive prize meter and can be displayed on a monitor. 

4. Observe the camera view recordings of those Class II gaming 

systems meeting the progressive thresholds to verify that the 

camera views are being recorded and retained for at least 7 days. 

Note: 

1. Wide Area gaming machine contracts and or agreements should be 

reviewed for potential additional requirements that could be more 

stringent than the MICS. 

 

543.21(c)(2) 

(i)-(ii)

(2) Manual bingo: 

(i) For manual draws, the surveillance system 

must monitor the bingo ball drawing device or 

mechanical random number generator, which 

must be recorded during the course of the draw 

Intent: To protect the integrity of manual bingo games and to deter, detect, 

and/or document potential fraud or cheating in Class II manual bingo by 

requiring surveillance to monitor the ball drawing/number selection device 

and bingo activities. 
Citation Language Intent and Testing

by a dedicated camera to identify the numbers or 

other designations drawn; and 

(ii) The surveillance system must monitor and 

record the activities of the bingo game, including 

drawing, and entering the balls, numbers or other 

designations drawn. 

Testing:

1. Review TICS to determine whether controls for display and recording 

of required camera views are established and implemented. 

2. Interview appropriate personnel (e.g., Bingo Management, 

Surveillance Management, etc.) to determine all locations where 

Bingo games are played, where Bingo equipment is located, and 

what Bingo games are played. 

3. Observe the camera views of the manual bingo ball drawing device 

or mechanical random number generator to verify that the camera 

views can be displayed on a monitor and that a dedicated camera is 

used. Observe the camera view recordings to verify that they are 

being recorded during the course of the draw, and the recordings 

are retained for at least 7 days. 

4. Observe the camera views of the activities of the bingo game, 

including drawing and entering the balls, numbers, or other 

designations drawn to verify that the camera views can be displayed 

on a monitor. Observe the camera view recordings to verify that 

they are retained for at least 7 days. 

Notes: 

1. If other bingo games (e.g., Bonanza, U-pick-em games, etc.) are 

played, verify that the required camera views are available for these 

game components (e.g., bingo board, blower/hopper, U-pick-em 

boxes, etc.). 

2. Additional MICS requirements include establishing TICS and 

implementing SICS for surveillance camera coverage with sufficient 

clarity to “identify persons accessing” the Bingo card inventory 

storage area, destruction of Class II gaming system components, 

and, while not specifically included in this control, coverage with 

sufficient clarity to “identify persons accessing” the pull tabs 

inventory storage area (see 543.8(b)(3)(i), 543.8(h)(2)(v)(B), and 

543.9(b)(5)). For a definition of Class II gaming see 25 U.S.C. 

2703(7)(A). 

3. The coverage should be of sufficient clarity to identify the ball 

numbers drawn. 
Citation Language Intent and Testing

 

543.21(c)(3) 

(i) (A)-(C), (ii)

(3) Card games: 

(i) Except for card game tournaments, a dedicated 

camera(s) with sufficient clarity must be used to 

provide: 

(A) An overview of the activities on each card 

table surface, including card faces and cash 

and/or cash equivalents; 

(B) An overview of card game activities, including 

patrons and dealers; and 

(C) An unobstructed view of all posted 

progressive pool amounts. 

(ii) For card game tournaments, a dedicated 

camera(s) must be used to provide an overview of 

tournament activities, and any area where cash or 

cash equivalents are exchanged. 

Intent: To protect the integrity of the card games and tournaments and to 

deter, detect, and/or document potential theft, cheating, or 

misappropriation of assets within them by requiring surveillance to record 

individuals and activities. 

Testing:

1. Review TICS to determine whether controls, which provide for 

display and recording of required camera views are established and 

implemented. 

2. Interview appropriate personnel (e.g., Surveillance 

Manager/Director, Surveillance Shift Manager/Lead, Surveillance 

Agent) to determine how often card game tournaments occur, 

where they occur, and how long they occur. 

3. For card games— 

a. Observe the required camera views of (1) the activities on 

each card table surface (card faces and/or cash equivalents), 

(2) an overview of card game activities (patrons and dealers), 

and (3) all posted progressive pool amounts. 

b. Verify that the card game camera views can be displayed on 

a monitor, and that a dedicated camera is utilized. 

c. Observe the recordings for card game activities to verify that 

they are being recorded and retained for at least 7 days, and 

that they are recorded with sufficient clarity (20 fps and with 

resolution sufficient to clearly identify the intended person, 

activity, object, or location). 

4. For card game tournaments-- 

a. Observe the required views of an overview of tournament 

activities and any area where cash or cash equivalents are 

exchanged. 

b. Verify that the camera views can be displayed on a monitor, 

and that a dedicated camera is used. 

c. Observe the required camera view recordings to verify that 

they are being recorded and retained for at least 7 days. 
Citation Language Intent and Testing

Best Practices: 

1. The MICS only designate certain camera views as requiring 

“sufficient clarity.” Therefore, the TICS and SICS should identify 

whether additional camera views (as determined by the Tribe/TGRA) 

that are important to the effective regulation and protection of the 

Tribe’s gaming activities. These additional camera views should also 

be designated in the SICS and TICS as requiring “sufficient clarity.” 

Notes: 

1. Additional MICS requirements include establishing TICS and 

implementing SICS for surveillance camera coverage of the secure 

location where new and used playing cards are maintained and 

destruction of Class II gaming system components (see 543.10(c)(1) 

and 543.8(h)(2)(v)(B)). For a definition of Class II gaming see 25 

U.S.C. 2703(7)(A)). 

2. Sufficient clarity and dedicated camera are terms with specific 

meanings, which may be found in the Glossary and in 25 C.F.R. 

§543.2 

543.21(c)(4)(i)-

(iii)

(4) Cage and vault: 

(i) The surveillance system must monitor and 

record a general overview of activities occurring 

in each cage and vault area with sufficient clarity 

to identify individuals within the cage and patrons 

and staff members at the counter areas and to 

confirm the amount of each cash transaction; 

(ii) Each cashier station must be equipped with 

one (1) dedicated overhead camera covering the 

transaction area; and 

(iii) The cage or vault area in which exchange and 

transfer transactions occur must be monitored 

and recorded by a dedicated camera or motion 

activated dedicated camera that provides 

Intent: To deter, detect, and/or document potential misappropriation of 

assets, by identifying individuals and activity, confirm the amount of 

transactions, and to document compliance with applicable internal control 

standards. 

Testing:

1. Review TICS to determine whether controls, which provide for 

display and recording of required camera views are established and 

implemented. 

2. Interview appropriate personnel (e.g., Surveillance 

Manager/Director, Surveillance Shift Manager/Lead, Surveillance 

Agent) to determine where all cage and vault areas are located. 

Determine whether there are any satellite cage areas. Determine 
Citation Language Intent and Testing

coverage with sufficient clarity to identify the chip 

values and the amounts on the exchange and 

transfer documentation. Controls provided by a 

computerized exchange and transfer system 

constitute an adequate alternative to viewing the 

amounts on the exchange and transfer 

documentation. 

the process for monitoring exchanges and transfers occurring in the 

cage or vault areas. 

3. Observe the required camera views of the general overview of 

activities occurring in each cage and vault area. Verify that the 

camera views can be displayed on a monitor, that they are being 

recorded and retained for at least 7 days. Verify the camera views 

are recorded with sufficient clarity, i.e., 20 fps and with resolution 

sufficient to clearly identify individuals within the cage, patrons and 

staff members at the counter areas, and the amount of each cash 

transaction). 

4. Observe the required camera views of each cashier station in each 

cage and vault area (subsection (ii)). Verify that the camera views 

can be displayed on a monitor, that they are being recorded and 

retained for at least 7 days, and that a dedicated camera is utilized. 

5. Observe the required camera views of the cage and vault area in 

which exchange and transfer transactions occur. Verify that the 

camera views can be displayed on a monitor and that a dedicated 

camera or motion-activated camera is utilized. Also, verify that 

camera views are being recorded and retained for at least 7 days, 

and that they are recorded with sufficient clarity, i.e., 20 fps and 

with resolution sufficient to clearly identify chip values and the 

amounts on the exchange and transfer documentation (if not 

computerized). 

Notes: 

1. Sufficient clarity and dedicated camera are terms with specific 

meanings, which may be found in the Glossary and in 25 C.F.R. § 

543.2.

2. The requirement to “confirm the amount of each cash transaction” 

implies that the camera view should be sufficiently clear to observe 

the denominations of any cash and cash equivalents exchanged, and 

the observer be able to determine the details of the transaction. 

3. Multiple cameras may be required in order to obtain adequate 

camera views to identify individuals within the cage, patrons and 
Citation Language Intent and Testing

staff members at the counter areas, and to confirm the amount of 

each cash transaction as required. 

4. An alternative procedure offered in the minimum internal control 

states: “Controls provided by a computerized exchange and transfer 

system constitute an adequate alternative to viewing the amounts 

on the exchange and transfer documentation.” However, if this 

alternative control is used, the chip values must still be visually 

observed and compared to the amounts on the computerized 

exchange and transfer system documentation. In addition, TGRA 

approved SICS must be established and implemented. 

 

543.21(c)(5) 

(i)-(ii)

(5) Count rooms: 

(i) The surveillance system must monitor and 

record with sufficient clarity a general overview of 

all areas where cash or cash equivalents may be 

stored or counted; and 

(ii) The surveillance system must provide 

coverage of count equipment with sufficient 

clarity to view any attempted manipulation of the 

recorded data. 

Intent: To deter, detect, and/or document potential misappropriation of 

assets, by creating an additional independent record of the amount of 

transactions. 

Testing:

1. Review TICS to determine whether controls, which provide for 

display and recording of required camera views are established and 

implemented. 

2. Interview appropriate personnel (e.g., Surveillance 

Manager/Director, Surveillance Shift Manager/Lead, Surveillance 

Agent) to determine all areas where “cash or cash equivalents may 

be stored or counted.” Determine by inquiry a general description 

of the count process, and any count procedures that require the 

involvement of Surveillance (e.g., showing empty drop boxes to 

Surveillance). 

3. Observe the required camera views of the count rooms, a general 

overview of all areas where cash or cash equivalents may be stored 

or counted, and the count equipment. Verify that the camera views 

can be displayed on a monitor, that they are being recorded and 

retained for at least 7 days, and that they are recorded with 

sufficient clarity to view any attempted manipulation of the data. 
Citation Language Intent and Testing

Notes: 

1. Sufficient clarity is a term with specific meaning, which may be 

found in the Glossary and in 25 C.F.R. § 543.2. 

2. Additional MICS requirements include the notification to 

Surveillance agents whenever count room agents exit or enter the 

count room during the count (see 543.17(b)(2)). Notification when 

the drop begins so Surveillance agents can monitor the activities 

(see 543.17(d)(1) and 543.17(e)(1)). Notification when emergency 

drops are required (see 543.17(d)(5) and 543.17(e)(3)). These 

notifications are typically documented on the Surveillance 

Department daily activity log or call log. 

 

 

543.21(c)(6) 

(6) Kiosks: The surveillance system must monitor 

and record a general overview of activities 

occurring at each kiosk with sufficient clarity to 

identify the activity and the individuals 

performing it, including maintenance, drops or 

fills, and redemption of wagering vouchers or 

credits. 

Intent: To deter, detect, and/or document potential misappropriation of 

assets by monitoring activity and the individuals performing maintenance, 

drops or fills, and redemption of wagering vouchers and credits. 

Testing:

1. Review TICS to determine whether controls for display and recording 

of required camera views are established and implemented. 

2. Observe the required camera views of the general overview of 

activities occurring at each kiosk. Verify that the camera views can 

be displayed on a monitor, and that they are being recorded and 

retained for at least 7 days. Verify the camera views are recorded 

with sufficient clarity to identify the activity and the individuals 

performing it (including maintenance, drops and fills, and 

redemption of wagering vouchers or credits). 

Notes: 

1. Sufficient clarity is a term with specific meaning, which may be 

found in the Glossary and in 25 C.F.R. § 543.2. 

It may require more than one camera per kiosk to obtain both a 

general overview of activities at each kiosk and a view sufficient to 

“identify the activity and the individuals performing it.” 
Citation Language Intent and Testing

543.21(d)

(d) Reporting requirements. TGRA-approved 

procedures must be implemented for reporting 

suspected crimes and suspicious activity. 

Intent: To protect the integrity, assets, and safety of the gaming operation, 

its patrons and employees by reporting suspected crimes and suspicious 

activity consistent with methods approved by the TGRA. 

Testing: 

1. Review SICS to determine whether controls for reporting suspected 

crimes and suspicious activity are established and implemented. 

2. Interview appropriate personnel (e.g., Surveillance 

Manager/Director, Surveillance Shift Manager/Lead, Surveillance 

Agent) to determine the procedure for reporting suspected crimes 

and suspicious activity. 

3. Locate written documentation of TGRA approval for reporting 

suspected crimes and suspicious activity. 

4. Review documentation of a recent example of reporting suspected 

crime and suspicious activity. Verify that the document describes 

who the activity was reported to, how it was reported, and in what 

timeframe it was reported. 

Best Practices: 

1. Surveillance should have procedures describing what constitutes a 

“suspected crime or suspicious activity” and detail specifically 

a. Who the activity is reported to, 

b. How it is reported (e.g., phone, email, text, etc.), and in what 

timeframe notification is to be made. 

 

543.21(e)(1) 

(e) Recording retention. Controls must be 

established and procedures implemented that 

include the following: 

(1) All recordings required by this section must be 

retained for a minimum of seven days; and 

Intent: To allow a reasonable amount of time for concerns to be raised and 

initiate a review of the recordings without requiring overly burdensome 

storage capacity. 

Testing: 

1. Review TICS and/or SICS to determine whether controls for retaining 

the required recordings at least seven days are established and 

implemented. 
Citation Language Intent and Testing

2. Review video recordings or system logs that document the number 

of days required recordings are being retained. Note the length of 

time indicated for recording retention. 

3. Observe samples of recorded video to verify that required 

recordings are retained a minimum of seven days as required. 

Best Practices: 

1. Each TGRA/operation should determine its own needs for video 

recording retention. While the minimum control requirement is 

retention of recorded video for at least seven days, many operations 

prefer to require retention for at least thirty days finding that the 

additional time better meets their needs. 

2. In determining a recording retention period beyond the seven-day 

minimum, consider the time needed for the Surveillance Department 

to receive the request as well as the time needed to retrieve and 

copy the video. 

543.21(e)(2) 

(2) Suspected crimes, suspicious activity, or 

detentions by security agents discovered within 

the initial retention period must be copied and 

retained for a time period, not less than one year.

Intent: To protect the assets, integrity, and safety of the tribal gaming 

operation by requiring preservation of video documentation that may be 

used as evidence to extend beyond the initial retention period. 

Testing: 

1. Review TICS and/or SICS to determine whether controls for copying 

recordings of “suspected crimes, suspicious activity, or detentions 

by security agents” and retention for at least one year are 

established and implemented. 

2. Interview appropriate personnel (e.g., Surveillance 

Manager/Director, Surveillance Shift Manager/Lead, Surveillance 

Agent) to determine the procedure for retaining recorded video of 

suspected crimes, suspicious activity, or detentions by security 

agents. Determine by what method recorded video is maintained 

and for what length of time it is retained (minimum time period is 

one year). 
Citation Language Intent and Testing

3. Review video recordings or system logs that document how long 

required video recordings are retained. Document the length of 

time that copied video is retained. 

4. Observe samples of video to verify recordings are retained for at 

least one year. 

Best Practices: 

1. Video recordings of “suspected crimes, suspicious activity, or 

detentions by security agents” should be copied to more permanent 

recording mediums, e.g., DVD’s, CD’s, flash drives, or segregated 

digital recording space on a server. This allows for a more 

permanent preservation of video recordings that may be used as 

evidence or for training. Additionally, it is recommended recordings 

of incidents be saved and retained in proprietary format to be 

preserved as evidence to ensure against allegations of tampering.

Notes: 

1. While the minimum control requirement is retention of recorded 

video for at least one year, recording retention may need to be 

increased in order to meet the particular needs of the gaming 

operation, surveillance operation, and Tribe. 

2. Recordings of “suspected crimes, suspicious activity, or detentions 

by security agents” may be used as evidence in legal or other formal 

proceedings (e.g., criminal prosecutions, insurance cases, human 

resource matters, etc.).

 

543.21(f)(1) 

(f) Logs. Logs must be maintained and 

demonstrate the following: 

(1) Compliance with the storage, identification, 

and retention standards required in this section; 

Intent: To ensure surveillance maintains a log, which documents compliance 

with the storage (Electronic and or other medium for video recording), 

identification, and retention standards, as required. 

Testing: 

1. Interview appropriate personnel (e.g., Surveillance 

Manager/Director, Surveillance Shift Manager/Lead, Surveillance 

Agent) to confirm logs are maintained which demonstrate 
Citation Language Intent and Testing

compliance with the storage, identification, and retention standards 

required. (Best practices indicate that a log should be completed 

and maintained on a routine basis, either weekly, daily, or at the 

beginning of each shift. The log may be a paper log, a computer log, 

or a computer-generated report from the digital video recording 

system.) 

2. Review logs to verify that they document compliance with storage, 

identification, and retention standards required. Verify that the logs 

are being retained for at least five years (see part 571.7(c)). 

3. Due to many surveillance systems going to a digital format, some 

surveillance departments utilize their daily activity log to maintain 

compliance with this standard. If utilizing the daily activity log, the 

surveillance department should be diligent in recording accurate 

dates and times of activity to ensure the appropriate video can be 

accessed when necessary. Additionally, some surveillance 

departments use daily activity logs to perform camera and recorder 

checks for clarity and retention. When that is practiced, it is 

recommended the results of these checks be properly documented 

in the activity log. 

Notes: 

1. Compliance is achieved for this control by documenting that the 

storage, identification, and retention standards in Part 543.21 are 

being met. Storage refers to the required camera views being 

recorded – “Are the required camera views being recorded?” 

Identification refers to the ability to be able to clearly identify an 

activity, person, object, or location; as detailed in the Sufficient 

Clarity requirement and definition – “Are the required camera views 

being recorded at a minimum of twenty (20) frames per second (or 

equivalent), and at a resolution that is sufficient to clearly identify 

the intended activity, person, object, or location?” Retention refers 

to keeping required camera view recordings for a minimum of seven 

(7) days – “Are required camera view recordings retained for a 

minimum of at least seven days?”
Citation Language Intent and Testing

2. While documentation of compliance with the identification 

standards related to “sufficient clarity” includes the number of 

frames per second of recording rate, it is important to note that also 

included in the definition of “sufficient clarity” is the requirement 

that resolution is sufficiently clear as well to identify the intended 

activity, person, object, or location. This means that although the 

recording framerate is at least 20 frames per second, resolution 

must also be sufficient so that the video is clear enough during 

playback to identify the object of the surveillance.

 

543.21(f)(2) 

(2) Each malfunction and repair of the 

surveillance system as defined in this section; and

Intent: To ensure that surveillance malfunctions are made known and 

repaired in a timely fashion. In addition, to document a history of the 

system that can be reviewed for unusual activity. 

Testing: 

1. Interview appropriate personnel (e.g., Surveillance 

Manager/Director, Surveillance Shift Manager/Lead, Surveillance 

Agent) to confirm logs are maintained that document each 

malfunction and repair of the surveillance system. 

2. Review logs to verify that they document each malfunction and 

repair of the surveillance system. Verify that the logs are being 

retained for at least five years (see part 571.7(c)). Also, verify that 

TGRA notification is occurring and that alternative procedures are 

implemented (see 543.21(b)(11)(ii)). 

Best Practices: 

1. The log should state-- 

a. The time, date, and nature of each malfunction, 

b. The efforts expended to repair the malfunction, 

c. The date of each effort, the reasons for any delays in repairing 

the malfunction, the date the malfunction is repaired, and 

d. Any alternative security measures that were taken (if applicable).

e. When TGRA notified, how was notification made. i.e., phone, 

email.
Citation Language Intent and Testing

543.21(f)(3) 

(3) Activities performed by surveillance agents as 

required by the controls in this section. 

Intent: To ensure that TICS and SICS are established and implemented that 

provide a level of control that equals or exceeds the MICS requirement for 

the maintaining of a log (or logs) which documents the activities required by 

the controls in this section performed by surveillance agents. 

Testing: 

1. Interview appropriate personnel (e.g., Surveillance 

Manager/Director, Surveillance Shift Manager/Lead, Surveillance 

Agent) to confirm logs are maintained that document activities 

performed by surveillance agents as required by the controls in this 

section. 

2. Review logs to verify that they document activities performed by 

surveillance agents as required by the controls in this section (see 

Notes). Verify that the logs are being retained for at least five years 

(see part 571.7(c)). 

Best Practices: 

1. Establish the log requirement in writing either as a TICS or SICS. 

2. A log should be maintained that, at a minimum, records the 

following information: 

a. Date, time commenced and terminated, 

b. Activity observed or performed, and 

c. The name or license credential number of each person who 

initiates, performs, or supervises the surveillance. 

3. The log should include a summary of the results of the surveillance 

of any suspicious activity. 

Notes: 

1. The following activities are required by the controls of this section 

and should be documented in the surveillance activities log: 

a. Suspected crimes, suspicious activity, or detentions by 

security agents, 

b. Individuals accessing the surveillance operation room(s), 

c. Exchange and transfers, 
Citation Language Intent and Testing

d. Drop and count activities, and 

e. Maintenance, dropping, and filling of the kiosks.
Additional Relevant Standards Outside of §543.21

Citation Language Intent and Testing

 

543.8(b)(3)(i) 

(b) Bingo Cards. 

(3) Storage 

(i) Bingo cards must be maintained in a secure 

location, accessible only to authorized agents, 

and with surveillance coverage adequate to 

identify persons accessing the storage area. 

Intent: To reduce potential misappropriation of assets or compromise to 

the bingo game by providing for a secured location to store bingo cards 

with proper surveillance coverage. 

Testing: 

1. Interview appropriate personnel (e.g., Bingo Management, 

Surveillance Management, etc.) to determine all locations where 

Bingo cards are stored and what Bingo games are played. 

2. Review TICS and/or SICS to determine if procedures have been 

implemented that specify who the authorized agents are and 

identify the secure location. 

3. Observe the camera views of the bingo storage location to verify 

that the camera views can be displayed on a monitor and that a 

dedicated camera is used. Observe the camera view recordings to 

verify that they are being recorded and the recordings are retained 

for at least 7 days. 

4. Observe the camera views of the bingo storage access and bingo 

storage access logs to verify that only authorized agents are 

accessing the inventory. Observe the camera view recordings to 

verify that they are retained for at least 7 days.

543.8(h)(1)(ii) 

(h) Operations. 

(1) Malfunctions. Procedures must be 

implemented to investigate, document and 

resolve malfunctions. Such procedures must 

address the following: 

(ii) Review of relevant records, game recall, 

reports, logs, surveillance records; 

Intent: To ensure the integrity of the bingo game by implementing 

procedures to investigate, document and resolve malfunctions, review of 

available documentation of the malfunction, repair or replacement if 

needed and verification of the system component’s integrity prior to 

restoring to operation. 

Testing: 

1. Review TICS and or SICS to determine if procedures have been 

created addressing malfunctions investigation steps and 

documentation requirements. If surveillance is part of the 
Citation Language Intent and Testing

malfunction investigation process, then the TICS and/or SICS should 

identify the surveillance records that are authorized to be provided. 

2. Review if applicable a sample of malfunction, repair and 

replacement records. (Look at sample as defined in the Glossary) 

3. Interview appropriate personnel to verify malfunction procedures if 

no sample to test. (e.g., Bingo Management, Bingo personnel) 

543.8(h)(2)(v)(B)

(h) Operations. 

(2) Removal, retirement and/or destruction 

(v) Where the TGRA authorizes destruction of any 

Class II gaming system components, procedures 

must be developed to destroy such components. 

Such procedures must include the following: 

(B) Witness or surveillance of destruction; 

Intent: To prevent potential misappropriation of assets and ensure the 

integrity of the bingo game by implementing procedures for removal, 

retirement and destruction of Class II gaming system components to 

include witnessing destructions. 

Testing: 

1. Interview appropriate personnel (e.g., TGRA, Bingo Management, 

Surveillance Management, etc.) to determine whether destruction 

of class II components is authorized. 

2. Review TICS and/or SICS to determine if procedures have been 

implemented that specify whether destruction must be witnessed 

live or by surveillance. 

3. Observe the camera views of the location where bingo system 

components are destroyed to verify that the camera views can be 

displayed on a monitor and that a dedicated camera is used. 

Observe the camera view recordings to verify that they are being 

recorded and the recordings are retained for at least 7 days, or 

longer if required by the TICS and/or SICS. 

Note: 

1. Most class II system components are leased, so if the vendor is 

responsible for the removal, retirement, and/or destruction 

processes, then the SICS should explicitly state the vendor is 

responsible for those processes. 
Citation Language Intent and Testing

543.9(b)(5) 

(b) Pull tab inventory. Controls must be 

established and procedures implemented to 

ensure that: 

(5) Pull tabs are maintained in a secure location, 

accessible only to authorized agents, and with 

surveillance coverage adequate to identify 

persons accessing the area. 

Intent: To reduce potential misappropriation of assets or compromise to 

the pull tab games by providing for a secured location to store pull tabs 

with proper surveillance coverage. 

Testing: 

1. Interview appropriate personnel (e.g., Pull Tabs Management, 

Surveillance Management, etc.) to determine all locations where 

pull tabs are stored and what pull tab games are played. 

2. Review TICS and/or SICS to determine if procedures have been 

implemented that specify who the authorized agents are and 

identify the secure location. 

3. Observe the camera views of the pull tab storage location to verify 

that the camera views can be displayed on a monitor and that a 

dedicated camera is used. Observe the camera view recordings to 

verify that they are being recorded and the recordings are retained 

for at least 7 days. 

4. Observe the camera views of the pull tab storage access and pull tab 

storage access logs to verify that only authorized agents are 

accessing the inventory. Observe the camera view recordings to 

verify that they are retained for at least 7 days.

543.10(c)(1) 

(c) Playing cards. 

(1) New and used playing cards must be 

maintained in a secure location, with appropriate 

surveillance coverage, and accessible only to 

authorized agents. 

Intent: To reduce potential misappropriation of assets or compromise to 

the card games by providing for a secured location to store new and used 

playing cards with proper surveillance coverage. 

Testing: 

1. Interview appropriate personnel (e.g., Card Games Management, 

Surveillance Management, etc.) to determine all locations where 

playing card are stored before and after use. 

2. Review TICS and/or SICS to determine if procedures have been 

implemented that specify who the authorized agents are and 

identify the secure location. 
Citation Language Intent and Testing

3. Observe the camera views of the playing card storage location to 

verify that the camera views can be displayed on a monitor and that 

a dedicated camera is used. Observe the camera view recordings to 

verify that they are being recorded and the recordings are retained 

for at least 7 days. 

4. Observe the camera views of the playing card storage access and 

card storage access logs to verify that only authorized agents are 

accessing the inventory. Observe the camera view recordings to 

verify that they are retained for at least 7 days.

Note: 

1. If used playing cards are stored in a room prior to being marked or 

destroyed, then surveillance of that room must be included in these 

requirements. Additionally, some SICS require surveillance to 

observe the marking or destruction of used playing cards so 

surveillance operations should be mindful of those requirements. 

543.20(b) 

(b) As used in this section only, a system is any 

computerized system that is integral to the 

gaming environment. This includes, but is not 

limited to, the server and peripherals for Class II 

gaming system, accounting, surveillance, 

essential phone system, and door access and 

warning systems. 

Intent: Computerized ‘systems’ are defined as computerized systems 

integral to the operation of the gaming environment. Systems include 

electronic/electrical networked-system environments, and the surveillance 

system is defined as part of the Class II system. 

Testing: 

1. Review gaming operations architectural plans and computerized 

network system design layout and applications system inventory. 
5 CFR 543.21 Toolkit

Version 1.0

NIGC Division of Public Affairs

National Indian Gaming Commission Training Manager 

Training Program