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Bingo – Audit

25 CFR 543.8 Toolkit

Version	
  1.0	
  

NIGC Compliance Division

National Indian Gaming Commission
NIGC Bingo Audit–25 CFR 543.8 Toolkit

Over twenty-five 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 and provide 

oversight for gaming activities conducted by sovereign Indian tribes on Indian lands. The mission of the NIGC is to fully 

realize IGRA’s goals of: (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 means by which the NIGC accomplishes this is by providing training and technical 

assistance to Indian tribes, their operations and their gaming regulators.

The NIGC is pleased to present this Toolkit to all stakeholders of Indian Gaming. This reference guide is intended to assist 

Auditors, Regulators and Operations personnel in the performance of measuring compliance of their operation(s) with 

25 CFR 543.8. The toolkit is designed to provide each standard of 543.8, 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 TGRAs and Operations to develop standards that exceed the MICS, because each operation is 

unique and a robust set of controls is warranted. 

If you have questions or comments about this guide, please contact the NIGC Compliance Division at training@nigc.gov . 

For more information, visit the NIGC website at http://www.nigc.gov.
How to use this Toolkit

The NIGC Compliance Division has designed this toolkit as a resource for understanding the Bingo 543.8 Minimum Internal 

Control Standards (MICS) and as a tool for conducting an audit of the bingo department in determining compliance with 

543.8. This toolkit was developed in a table fashion. The Toolkit includes: 

1) Definitions of key terms to provide the user with a clear understanding of how the term is used in this toolkit.

2) The Bingo 543.8 regulation listed in the first column in the table, verbatim.

3) An explanation of the intent of the regulation and why the control was created is listed in the second column 

in the table. 

4) Testing steps to utilize to determine compliance with the regulation is listed in the second column in the table 

under the Intent information.

5) Best Practices have been included in either the Intent or Testing steps to provide the user with examples of current 

procedures used in the industry.

6) Notes have been included to provide practical advice to consider when performing the testing step, common 

examples or alerting the user the step/test needed may have been completed in another section.

7) Where controls must be established in the standard TICS should be developed by the TGRA’s requiring that 

Operations develop SICS for process implementation of the control. 

The toolkit provides many practical suggestions for understanding and evaluating compliance with Bingo MICS 543.8. This 

toolkit can be used by either the new auditor or the experience auditor during the various stages of the audit.
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OVERVIEW 

GLOSSARY

GLOSSARY DEFINITION

 Accountability 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 machine.

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

gaming operation bankroll.
GLOSSARY DEFINITION

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 As defined in the Indian Gaming Regulatory Act (IGRA) §2703

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.
GLOSSARY DEFINITION

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.
GLOSSARY DEFINITION

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.
GLOSSARY DEFINITION

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.
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Citation Language Intent and Testing

§ 543.8 (a-b)

543.8(a) Supervision. Supervision must be provided as 

needed for bingo operations by an agent(s) 

with authority equal to or greater than those 

being supervised. 

Intent: To ensure that appropriate supervision is provided during 

manual and electronic bingo operations. (Best practices would 

dictate that supervision should be by someone with authority 

greater than those being supervised).

Testing: 1. Interview appropriate personnel to determine who has 

supervision responsibility for both manual and Class II electronic 

bingo machines (e.g., Bingo Management, Bingo Supervisor, 

Bingo Floor Clerk, etc.). 2. Review TICS and or SICS to determine 

procedures implemented (e.g. designation of supervisory and 

non-supervisory agents, reporting responsibilities, etc.) Identify 

and document titles of supervisory personnel (e.g., Bingo Manager, 

Bingo Floor Supervisor, etc.). 3. Observe live bingo operations to 

ensure that supervision requirement are being met. 5. Review Bingo 

organizational chart for both manual and Class II electronic bingo 

machines to determine or verify supervision responsibility. 

543.8(b)(1)

(i)-(ii)

Bingo cards. (1) Physical bingo card inventory 

controls must address the placement of 

orders, receipt, storage, issuance, removal, and 

cancellation of bingo card inventory to ensure 

that: 

(i) The bingo card inventory can be accounted 

for at all times; and

(ii) Bingo cards have not been marked, altered, 

or otherwise manipulated.

Intent: To ensure proper accounting of the manual bingo card 

inventory at all times and that bingo cards have not been marked, 

altered, or otherwise manipulated. 

Testing: 1. Interview appropriate personnel (e.g., Inventory Clerk, 

Security and Shipping/ Receiving Clerk, etc.) to determine who is 

responsible for bingo card inventory (e.g.in the receipt, storage, 

issuance, removal and cancellation of manual bingo card inventory). 

2. Review TICS and or SICS to determine if purchasing, receipt, 

storage, issuance, removal, cancellation, inspection and inventory 

procedures have been implemented. (Best practice would include 

the requirement in the SICS at the end of each month, a person or 

persons independent of bingo sales and inventory control verify the 

accuracy of the ending balance of the bingo paper. By reconciling 

the paper on-hand to the physical inventory count, compared to the 

perpetual records).

543.20(i) 

§ 543.8 (a-b)
Citation Language Intent and Testing

§ 543.8 (b)

543.8(b)(1)

(i)-(ii)

Bingo cards. (1) Physical bingo card 

inventory controls must address the 

placement of orders, receipt, storage, 

issuance, removal, and cancellation of 

bingo card inventory to ensure that: 

(i) The bingo card inventory can be 

accounted for at all times; and 

(ii) Bingo cards have not been marked, 

altered, or otherwise manipulated. 

Intent: To ensure proper accounting of the manual bingo card inventory at 

all times and that bingo cards have not been marked, altered, or otherwise 

manipulated. 

Testing: 1. Interview appropriate personnel (e.g., Inventory Clerk, Security 

and Shipping/ Receiving Clerk, etc.) to determine who is responsible for bingo 

card inventory (e.g.in the receipt, storage, issuance, removal and cancellation 

of manual bingo card inventory). 2. Review TICS and or SICS to determine if 

purchasing, receipt, storage, issuance, removal, cancellation, inspection and 

inventory procedures have been implemented. (Best practice would include 

the requirement in the SICS at the end of each month, a person or persons 

independent of bingo sales and inventory control verify the accuracy of the 

ending balance of the bingo paper. By reconciling the paper on-hand to the 

physical inventory count, compared to the perpetual records).

543.8(b)(2)

(i)-(ii)

Receipt from supplier. 

(i) When bingo card inventory is initially 

received from the supplier, it must be 

inspected (without breaking the factory 

seals, if any), counted, inventoried, and 

secured by an authorized agent. 

(ii) Bingo card inventory records must 

include the date received, quantities 

received, and the name of the individual 

conducting the inspection. 

Intent: To ensure manual bingo card inventory is inspected (e.g. factory seals, 

unopened, etc.), counted, inventoried, and secured by an authorized agent upon 

initial receipt and that proper documentation of bingo card inventory records 

exists. 

Testing: 1. Interview appropriate personnel to determine who is responsible 

for receiving, inspecting, counting, inventorying and securing bingo card 

inventory(e.g., Inventory Clerk, Security, Shipping/ Receiving Clerk, etc.). 2.

Review TICS and or SICS to determine if procedures have been implemented 

for inspecting, counting, inventory, documenting receipt, and updating the 

perpetual bingo inventory records. (Best practice would include requiring at 

the end of each month, a person or persons independent of bingo sales and 

inventory control verify the accuracy of the ending balance in the bingo paper 

control by reconciling the paper on-hand (physical inventory count and compare 

to perpetual records). 3. Review (most recent) bingo card inventory records 

for the date received, quantities received, and the name(s) of the individual(s) 

conducting the inspection. (Best practice would also include conducting physical 

inventory of manual bingo cards and comparing to inventory records). 
Citation Language Intent and Testing

§ 543.8 (b)

543.8(b)(3)

(i)-(ii)

(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. 

(ii) For Tier A operations, bingo card 

inventory may be stored in a cabinet, 

closet, or other similar area; however, 

such area must be secured and separate 

from the working inventory. 

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. In addition, to create a separate requirement for Tier A 

facilities that is more suited to the operation.

Testing: 1. Interview appropriate personnel to determine location of bingo cards 

and who can access the storage area (e.g., Inventory Clerk, Security, Shipping/ 

Receiving Clerk, and Surveillance). 2. Review TICS and or SICS to determine if 

procedures have been implemented that specify who the authorized agents are 

and identification of secure location (e.g., authorized agents listing, surveillance 

coverage, etc.). 3. For Tier B and C, review surveillance recordings of storage 

area to verify adequate coverage. 4. For Tier A, observe alternate storage area 

and verify separate working bingo paper inventory storage.

543.8(b)(4)

(i)(A)-(D)

(4) Issuance and returns of inventory. 

(i) Controls must be established for 

the issuance and return of bingo card 

inventory. Records signed by the issuer 

and recipient must be created under the 

following events: 

(A) Issuance of inventory from storage to 

a staging area; 

(B) Issuance of inventory from a staging 

area to the cage or sellers; 

(C) Return of inventory from a staging 

area to storage; and 

(D) Return of inventory from cage or 

seller to staging area or storage. 

Intent: To reduce potential misappropriation of assets or compromise to the 

bingo game by providing for documented accountability of bingo card inventory 

as it is issued from storage to staging to the selling area(s) and as it is returned 

from the selling area(s) to staging to storage.

Testing: 1. Interview appropriate personnel to determine who is responsible for 

issuance and return of inventory (e.g., Inventory Clerk, Bingo Supervisor, Bingo 

Floor Clerk, etc.) 2. Review TICS to ensure controls have been established and 

review SICS to determine if procedures have been implemented for issuance, 

returns, record requirements, signature requirements, storage area, staging 

area, etc. 3. Observe the issuance of bingo card inventory to be used in the 

bingo session(s) and the subsequent return of unsold bingo card inventory, if 

any, 4. Review the most recent bingo card inventory records regarding issuance 

and, if applicable, subsequent return transaction records to verify signatures and 

accountability.
Citation Language Intent and Testing

§ 543.8 (b)

543.8(b)(5)

(i)-(ii)

(5) Cancellation and removal. 

(i) Bingo cards removed from inventory 

that are deemed out of sequence, 

flawed, or misprinted and not returned 

to the supplier must be cancelled to 

ensure that they are not utilized in 

the play of a bingo game. Bingo cards 

that are removed from inventory and 

returned to the supplier or cancelled 

must be logged as removed from 

inventory. 

(ii) Bingo cards associated with an 

investigation must be retained intact 

outside of the established removal and 

cancellation policy. 

Intent: To reduce potential misappropriation of assets or compromise to the 

bingo game by providing for proper cancellation and removal from inventory 

of bingo cards which are out of sequence, flawed, misprinted or returned to 

the supplier to ensure such cards are not introduced into a live bingo game. In 

addition, to ensure bingo cards part of any investigation are properly retained 

until such investigation has been completed or further retained as supporting 

documentation. 

Testing: 1. Interview appropriate personnel to determine the procedure for 

cancellation and removal of bingo cards (e.g., Inventory Clerk, Bingo Supervisor, 

Bingo Floor Clerk, Security, Surveillance, etc.). 2. Review TICS and or SICS to 

determine if procedures have been implemented to identify bingo cards that 

are out of sequence, flawed, misprinted or have other errors. To include, 

cancellation procedures, returns to suppliers, and maintenance of bingo 

cards associated with investigation, etc. 3. Observe bingo card cancellation 

procedures. 4. Review the most recent bingo card cancellation records to verify 

compliance with procedures. 5. Review investigation records, if any, related to 

bingo cards.
Citation Language Intent and Testing

§ 543.8 (b)

543.8(b)(6)

(i)-(ii)(A)-(J)

(6) Logs. 

(i) The inventory of bingo cards must 

be tracked and logged from receipt 

until use or permanent removal from 

inventory. 

(ii) The bingo card inventory record(s) 

must include: 

(A) Date; 

(B) Shift or session; 

(C) Time; 

(D) Location; 

(E) Inventory received, issued, removed, 

and returned; 

(F) Signature of agent performing 

transaction; 

(G) Signature of agent performing the 

reconciliation; 

(H) Any variance; 

(I) Beginning and ending inventory; and 

(J) Description of inventory transaction 

being performed. 

Intent: To reduce potential misappropriation of assets or compromise to the 

bingo game by accounting for bingo card inventory at all times and providing for 

accountability of the bingo card inventory confirming bingo cards have not been 

manipulated (e.g. Marking, altering or by other means meant to identify card 

value).

Testing: 1. Interview appropriate personnel to determine how inventory is 

accounted for and procedure for discrepancies (e.g., Inventory Clerk, Bingo 

Supervisor, Bingo Floor Clerk, Security, etc.). 2. Review TICS and or SICS to 

determine if procedures have been implemented addressing the following; 

record requirements of receipt, issuance, sales, returns, dates, shift/ session, 

time, location, signatures, reconciliations, perpetual inventories, description 

of transactions, etc. Best practice would also include SICS requiring at the end 

of each month, a person or persons independent of bingo sales and inventory 

control verify the accuracy of the ending balance in the bingo paper control by 

reconciling the paper on-hand (e.g. physical inventory count and compare to 

perpetual records). 3. Review the most recent bingo card inventory records for 

the required information. (Best practice would also include conducting physical 

inventory of manual bingo cards and comparing to inventory records). 
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Citation Language Intent and Testing

§ 543.8 (c)

543.8(c)(1) Bingo card sales. 

(1) Agents who sell bingo cards must not be the sole 

verifier of bingo cards for prize payouts. 

Intent: To ensure that documentation accompanying new or 

used hardware is retained describing said system in use and it’s 

proper operation, to include hardware systems.

Testing: 1. Interview appropriate personnel to determine 

who is responsible for verifying the bingo card. (E.g. Bingo 

Management, Bingo Supervisor, Bingo Floor Clerk, etc.). 2. 

Review TICS and or SICS to determine if procedures have 

been implemented addressing the selling of bingo cards and 

subsequent verification of winning bingo events, delineation 

of sole verifier, prohibition of selling and sole verifier, etc. 3.

Observe live bingo games for the verification of bingo wins and 

prize payouts. 

543.8(c)(2)

(i)-(iv)

(2) Manual bingo card sales: In order to adequately 

record, track, and reconcile sales of bingo cards, the 

following information must be documented: 

(i) Date; 

(ii) Shift or session; 

(iii) Number of bingo cards issued, sold, and returned; 

(iv) Dollar amount of bingo card sales; 

(v) Signature, initials, or identification number of the 

agent preparing the record; and 

(vi) Signature, initials, or identification number of 

an independent agent who verified the bingo cards 

returned to inventory and dollar amount of bingo 

card sales. 

Intent: To reduce potential misappropriation of assets 

and properly support bingo revenue data by recording 

accurate documentation for bingo card sales for tracking and 

reconciliation purposes and to ensure revenue from bingo card 

sales is supported by documentation.

Testing: 1. Interview appropriate personnel to determine who 

is responsible for manual bingo card sales and verification of 

bingo cards returned to inventory (e.g. Bingo Management, 

Bingo Supervisor, Bingo Floor Clerk, etc.). 2. Review TICS and 

or SICS to determine if procedures have been implemented 

addressing; manual bingo card sales records including date, 

shift/ session, quantity, dollar amount, signature requirements, 

and independent agent verification, etc. 3. Review a sample 

(as described in Glossary) of bingo card sales records from the 

selected test dates to determine if all required information is 

documented.

DEFINITIONS 

§ 543.8 (c)
Citation Language Intent and Testing

§ 543.8 (c)

543.8(c)(3)

(i)-(iv)

(3) Bingo card sale voids must be processed 

in accordance with the rules of the game and 

established controls that must include the 

following: 

(i) Patron refunds; 

(ii) Adjustments to bingo card sales to reflect 

voids; 

(iii) Adjustment to bingo card inventory; 

(iv) Documentation of the reason for the void; 

and 

(v) Authorization for all voids. 

Intent: To reduce potential misappropriation of assets or 

compromise to the bingo game by ensuring voids for bingo card 

sales are performed in accordance with the rules of the game and 

controls, which must be established, to ensure voids are properly 

documented, with an adjustment to sales and inventory, and are 

properly authorized.

Testing: 1. Interview appropriate personnel to determine how 

bingo card sale voids are processed. (E.g. Bingo Management, Bingo 

Supervisor, Bingo Floor Clerk, etc.). 2. Review TICS and or SICS to 

determine procedures implemented for bingo card sale void (e.g. 

manual bingo card sale void records including patron refunds, 

adjustments to bingo card sales and inventory, documentation and 

authorization of the voids, etc.) 3. Review a sample (as described 

in Glossary) of bingo card sale void records from the selected test 

dates to determine if all required information is documented.

543.8(c)(4)

(i)-(v)

(4) Class II gaming system bingo card sales. In 

order to adequately record, track and reconcile 

sales of bingo cards, the following information 

must be documented from the server (this is 

not required if the system does not track the 

information, but system limitation(s) must be 

noted): 

(i) Date; 

(ii) Time; 

(iii) Number of bingo cards sold; 

(iv) Dollar amount of bingo card sales; and 

(v) Amount in, amount out and other associated 

meter information. 

Intent: To reduce potential misappropriation of assets and properly 

support bingo revenue data for Class II gaming system(s) by 

recording accurate documentation for bingo card sales for tracking 

and reconciliation purposes and to ensure revenue from bingo card 

sales is supported by documentation.

Testing: 1. Review sample (as described in Glossary) of electronic 

bingo card sales records for the selected test dates to determine if 

all required information is maintained. If the Class II system does 

not track certain information, system limitations must be noted and 

documented. 
DEFINITIONS 

Citation Language Intent and Testing

§ 543.8 (d)

543.8(d)(1) (d) Draw. 

(1) Controls must be established and procedures 

implemented to ensure that all eligible objects used 

in the conduct of the bingo game are available to 

be drawn and have not been damaged or altered. 

Verification of physical objects must be performed by 

two agents before the start of the first bingo game/

session. At least one of the verifying agents must be a 

supervisory agent or independent of the bingo games 

department. 

Intent: To reduce potential misappropriation of assets or 

compromise to the bingo game by ensuring game outcomes 

are properly drawn by examination of gaming equipment to 

confirm all outcomes are possible for the draw and equipment 

is not damaged or altered.

Testing: 1. Interview appropriate personnel to determine who 

is responsible for verifying physical objects prior to start of the 

first bingo game (e.g. Bingo Management, Bingo Supervisor, 

Bingo Caller, Bingo Floor Clerk, etc.). 2. Review TICS to 

determine if controls have been established and review SICS to 

determine procedures implemented for periodic inspection of 

bingo balls, identification of damage/ altered balls, verification 

of all eligible objects prior to start of game and supervisory/ 

independent verification (Note: common practice is to utilize 

patron for verification), etc. 3. Observe live bingo game and/or 

recorded surveillance footage to determine all eligible objects 

are available to be drawn and verified before start of the first 

bingo game by 2 agents Note: common practice is to utilize 

independent patron as 1 of the agents.

543.8(d)(2) (2) Where the selection is made through an electronic 

aid, certification in accordance with 25 CFR 547.14 is 

acceptable for verifying the randomness of the draw 

and satisfies the requirements of paragraph (d)(1) of 

this section. 

Intent: To reduce potential misappropriation of assets or 

compromise to the bingo game by ensuring game outcomes are 

properly drawn by verification of documented lab certification 

in accordance with 547.14 Technical Standards.

Testing: 1. Observation of the bingo caller stand to determine if 

an electronic aid is utilized. 2. Interview appropriate personnel 

to determine if certification was received for the electronic 

aid (e.g. IT, Bingo Management, Bingo Supervisor, Bingo Caller, 

etc.). 3. Review of certification in accordance with 547 in the 

event the draw is made through electronic aid.

§ 543.8 (d)

FLOWCHART 
Citation Language Intent and Testing

§ 543.8 (d)

543.8(d)(3) (3) Controls must be established and procedures 

implemented to provide a method of recall of the 

draw, which includes the order and identity of the 

objects drawn, for dispute resolution purposes. 

Intent: To reduce potential misappropriation of assets or 

compromise to the bingo game by providing controls for the 

purpose of responding to patron disputes by ensuring a method 

is in place to recall the draw of past games played. 

Testing: 1. Interview appropriate personnel to determine when 

the last time a dispute occurred (e.g. Bingo Management, Bingo 

Supervisor, Bingo Caller, Bingo Floor Clerk, etc.). 2. Review 

TICS to ensure controls have been established andreview SICS 

to determine procedures implemented for recall of the draw, 

order and identity of objects drawn, dispute resolution and 

surveillance review, etc. 

543.8(d)(4) (4) Verification and display of draw. Controls must be 

established and procedures implemented to ensure 

that: 

(i) The identity of each object drawn is accurately 

recorded and transmitted to the participants. The 

procedures must identify the method used to ensure 

the identity of each object drawn. 

(ii) For all games offering a prize payout of $1,200 or 

more, as the objects are drawn, the identity of the 

objects are immediately recorded and maintained for 

a minimum of 24 hours.

Intent: To reduce potential misappropriation of assets or 

compromise to the bingo game by providing controls for the 

purpose of recording and transmitting to the patrons the 

identity of each object drawn. In addition, for machines with 

potential payouts of $1,200 or more, an additional recording 

retention control of at least 24 hours is required.

Testing: 1. Interview appropriate personnel to determine how 

the draw is recorded and who maintains the record. (E.g. Bingo 

Management, Bingo Supervisor, Bingo Caller, Bingo Floor Clerk, 

etc.). 2. Review TICS to ensure controls have been established 

and review SICS to determine if procedures are implemented 

addressing the method used to identify draw, accurately 

recorded and transmitted to patrons, games $1,200 or more 

are recorded and maintained for 24 hours accurately recorded, 

etc. 3. Observe live bingo game to verify that bingo games with 

jackpots of $1,200 or more that the numbers are immediately 

recorded by the caller and maintained for at least 24 hours. 

4. Review the most recent card caller log for bingo game $1,200 

or more.
Citation Language Intent and Testing

§ 543.8 (e)

543.8(e)(1)

(i)-(iii)

(e) Prize payout. 

(1) Controls must be established and procedures 

implemented for cash or cash equivalents that 

address the following: 

(i) Identification of the agent authorized (by 

position) to make a payout; 

(ii) Predetermined payout authorization levels; 

and 

(iii) Documentation procedures ensuring separate 

control of the cash accountability functions.

Intent: To reduce potential misappropriation of assets by providing 

controls for the purpose of establishing which personnel are 

authorized to perform payouts, separate authorized levels of payouts 

and documentation to record accountability for the funds used for 

payouts.

Testing: 1. Interview appropriate personnel to determine what the 

authorization levels are and who is authorized to make payouts (e.g. 

Bingo Management, Bingo Supervisor, Bingo Paymaster, Bingo Floor 

Clerk, etc.). 2. Review TICS to ensure controls have been established 

and review SICS to determine procedures implemented for prize 

payouts (e.g. agents authorized by position to verify bingo wins 

and make payouts, payout authorization levels, documentation to 

record accountability of the funds used for payouts, etc.). 3. Review 

sample (as described in Glossary) of payout and accountability 

documentation for selected test dates to determine appropriate 

authorizations levels and accountability of the payout funds. 

543.8(e)(2)

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

(2) Verification of validity. 

(i) Controls must be established and procedures 

implemented to verify that the following is 

valid for the game in play prior to payment of a 

winning prize: 

(A) Winning card(s); 

(B) Objects drawn; and 

(C) The previously designated arrangement 

of numbers or designations on such cards, as 

described in 25 U.S.C. 2703(7) (A). 

(ii) At least two agents must verify that the 

card, objects drawn, and previously designated 

arrangement were valid for the game in play. 

(iii) Where an automated verification method 

is available, verification by such method is 

acceptable

Intent: To reduce potential misappropriation of assets by providing 

controls for the purpose of verifying the validity of the game 

components and outcome prior to payment to the patron.

Testing: 1. Interview appropriate personnel to determine method 

used for verification of validity and who is responsible for verifying 

card, object drawn and designated arrangement of numbers ore 

designations on cards (e.g. Bingo Management, Bingo Supervisor, 

Bingo Paymaster, Bingo Floor Clerk, etc.). 2. Review TICS to ensure 

controls have been established and review SICS to determine 

procedures implemented for verifying validity (e.g. verifying winning 

bingo card to include, objects drawn, bingo pattern, authorized 

agents, use of automated system, etc.). 3. Review sample (as 

described in Glossary) of payout documentation for the selected test 

dates to determine if agent(s)/ automated system verified winning 

events by comparing bingo cards to the predetermined pattern (e.g. 

4 corners, small X, etc.) prior to payment. (Note: Complete with 

543.8(e) (6)). 4. Observe winning bingo verification process. 

SEVERITY

MATRIX § 543.8 (e)
Citation Language Intent and Testing

§ 543.8 (e)

543.8(e)(3)

(i)-(ii)

(3) Validation. 

(i) For manual payouts, at least two agents must 

determine the validity of the claim prior to the 

payment of a prize. The system may serve as one 

of the validators. 

(ii) For automated payouts, the system may serve 

as the sole validator of the claim. 

Intent: To reduce potential misappropriation of assets by establishing 

validation requirements for manual payouts resulting from bingo wins 

involving either two persons or one person when the Class II system is 

used as validation of the claim.

Testing: 1. Interview appropriate personnel to determine process for 

manual payouts and if an automated process is used for payouts (e.g. 

Bingo Management, Bingo Supervisor, Bingo Paymaster, Bingo Floor 

Clerk, etc.). 2. Review SICS to determine procedures implemented 

for validating winning bingo cards (e.g. objects drawn, bingo pattern, 

authorized agents, use of automated system, etc.). 3. Review sample 

(as described in Glossary) of payout documentation for the selected 

test dates to determine if agent(s)/ automated system verified 

winning events by comparing bingo cards to the predetermined 

pattern (e.g. 4 corners, small X, etc.) prior to payment. (Note: 

Complete with 543.8(e) (6)). 4. Observe winning bingo validation 

process. 

543.8(e)(4)

(i)-(ii)

(4) Verification. 

(i) For manual payouts, at least two agents 

must verify that the winning pattern has been 

achieved on the winning card prior to the 

payment of a prize. The system may serve as one 

of the verifiers. 

(ii) For automated payouts, the system may serve 

as the sole verifier that the pattern has been 

achieved on the winning card. 

Intent: To reduce potential misappropriation of assets by establishing 

validation requirements for manual payouts resulting from bingo wins 

involving either two persons or one person when the Class II system is 

used as validation of the claim.

Testing: 1. Interview appropriate personnel to determine who is 

responsible for verifying bingo payouts (e.g. Bingo Management, 

Bingo Supervisor, Bingo Paymaster, Bingo Floor Clerk, etc.). 2. Review 

TICS and or SICS to determine procedures implemented for verifying 

winning bingo card (e.g. objects drawn, bingo pattern, authorized 

agents, use of automated system, etc.). 3. Review sample (as 

described in Glossary) of payout documentation for the selected test 

dates to determine if agent(s)/ automated system verified winning 

events by comparing bingo cards to the predetermined pattern (e.g. 

4 corners, small X, etc.) prior to payment. Complete with 543.8(e) (6). 

4. Observe winning bingo verification process. 
Citation Language Intent and Testing

§ 543.8 (e)

543.8(e)(5)

(i), (ii)(A)-(D), 

(iii)-(iv)

(5) Authorization and signatures. 

(i) At least two agents must authorize, sign, 

and witness all manual prize payouts above 

$1,200, or a lower threshold as authorized by 

management and approved by the TGRA. 

(ii) Manual prize payouts above the following 

threshold (or a lower threshold, as authorized 

by management and approved by TGRA) 

must require one of the two signatures and 

verifications to be a supervisory or management 

employee independent of the operation of Class 

II Gaming System bingo: 

(A) $5,000 for a Tier A facility; 

(B) $10,000 at a Tier B facility; 

(C) $20,000 for a Tier C facility; or 

(D) $50,000 for a Tier C facility with over 

$100,000,000 in gross gaming revenues. 

(iii) The predetermined thresholds, whether set 

at the MICS level or lower, must be authorized 

by management, approved by the TGRA, 

documented, and maintained. 

(iv) A Class II gaming system may substitute for 

one authorization/signature verifying, validating 

or authorizing a winning card, but may not 

substitute for a supervisory or management 

authorization/signature. 

Intent: To reduce potential misappropriation of assets by establishing 

authorization and accountability requirements involving either two 

persons or one person and the system for payments over $1,200 (or 

lower threshold as authorized and approved). In addition, establishes 

requirement for payouts above specified thresholds to have 

supervisory/ independent authorization.

Testing: 1. Interview appropriate personnel to determine threshold 

wherein two agents are required to authorize, sign and witness 

manual prize payout and who qualifies as the authorized agents. 

(E.g. Bingo Management, Bingo Supervisor, Bingo Paymaster, Bingo 

Floor Clerk, etc.). 2. Review TICS and or SICS to determine procedures 

implemented for ; authorization, and approved thresholds and 

signature requirements,(e.g. verifying winning bingo card to include, 

objects drawn, bingo pattern, authorized agents, use of automated 

system, etc.). 3. Review sample (as described in Glossary) of payout 

documentation for the selected test dates to determine if agent(s)/ 

automated system verified winning events by comparing bingo cards 

to the predetermined pattern (e.g. 4 corners, small X, etc.) prior 

to payment. Complete with 543.8(e) (6). 4. Observe winning bingo 

verification process for manual prize payouts.
Citation Language Intent and Testing

§ 543.8 (e)

543.8(e)(6)

(i)-(iv)(A)-(E)

(6) Payout records, including manual payout 

records, must include the following information: 

(i) Date and time; 

(ii) Amount of the payout (alpha & numeric for 

player interface payouts); and 

(iii) Bingo card identifier or player interface 

identifier. 

(iv) Manual payout records must also include the 

following: 

(A) Game name or number; 

(B) Description of pattern covered, such as coverall or four corners; 

(C) Signature of all, but not less than two, agents 

involved in the transaction; 

(D) For override transactions, verification by a 

supervisory or management agent independent 

of the transaction; and 

(E) Any other information necessary to 

substantiate the payout. 

Intent: To reduce potential misappropriation of assets by requiring 

detailed documentation to support all non-automated payouts 

which include detailed information about the payouts, signatures for 

accountability and verifications for overrides. 

Testing: 1. Interview appropriate personnel to determine who 

is responsible for completing override transactions (e.g. Bingo 

Management, Bingo Supervisor, Bingo Paymaster, Bingo Floor 

Clerk, etc.). 2. Review TICS and or SICS to determine procedures 

implemented for payout records (e.g. requiring: date and time, 

amount of payout, bingo/ player interface identifier, game name/ 

number, pattern, signatures, overrides, authorized and approved 

thresholds, signature requirements, verifying winning bingo card(s) 

to include, objects drawn, bingo pattern, authorized agents, use of 

automated system, etc.). 3. Review sample (as described in Glossary) 

of payout documentation for the selected test dates to determine 

if all required information is included on payout forms. (Note: 

Complete with 543.8(e) (2), (3), (4) and (5)). 4. Observe winning bingo 

verification and payout process including manual payout process if 

possible.
Citation Language Intent and Testing

§ 543.8 (f)

543.8(f)(1) (f) Cash and cash equivalent controls. 

(1) Cash or cash equivalents exchanged between 

two persons must be counted independently 

by at least two agents and reconciled to the 

recorded amounts at the end of each shift 

or session. Unexplained variances must be 

documented and maintained. Unverified 

transfers of cash or cash equivalents are 

prohibited. 

Intent: To reduce potential misappropriation of assets by requiring 

at least two independent counts for all exchanges of cash and cash 

equivalents and a reconciliation of the exchanges at the end of the 

shift or session. In addition, variances between counts which cannot 

be explained must be documented and unverified transfers are not 

allowed.

Testing: 1. Interview appropriate personnel to determine cash 

control procedures (e.g. Bingo Management, Bingo Supervisor, Bingo 

Paymaster, Bingo Floor Clerk, etc.). 2. Review TICS and or SICS to 

determine if procedures have been implemented addressing cash 

or cash equivalents (e.g. exchanges, independent counts, signature 

requirements, variances, prohibition of unverified transfers, etc.). 

3. Review sample (as described in Glossary) of accountability 

documentation for the selected test dates to determine if effective 

transfer of accountability of the funds. 4. Observe shift change to 

verify funds are being independently counted and that unverified 

transfers are not occurring.

543.8(f)(2)

(i)-(iv)

(2) Procedures must be implemented to control 

cash or cash equivalents based on the amount 

of the transaction. These procedures must 

include documentation by shift, session, or other 

relevant time period of the following: 

(i) Inventory, including any increases or 

decreases; 

(ii) Transfers; 

(iii) Exchanges, including acknowledging 

signatures or initials; and 

(iv) Resulting variances. 

Intent: To reduce potential misappropriation of assets by requiring 

procedures to create documentation for cash and/or cash equivalents 

to record changes of inventory, transfers, exchanges and any 

variances in counts to physical funds and supporting documentation.

Testing: 1. Interview appropriate personnel to determine signature 

requirements (e.g. Bingo Management, Bingo Supervisor, Bingo 

Paymaster, Bingo Floor Clerk, etc.). 2. Review TICS and or SICS 

to determine if procedures have been developed addressing 

documentation requirements based on transaction types (e.g. 

Inventory of cash equivalents, documentation, shift, session, 

transfers, exchanges, signatures, variances, etc.). 3. Review a sample 

(as described in Glossary) of cash or cash equivalent records for Bingo 

from the selected test dates to determine if increases, decreases, 

transfers, exchanges, signatures, and variances are properly 

documented.

OVERVIEW 

§ 543.8 (f)
Citation Language Intent and Testing

§ 543.8 (f)

543.8(f)(3) (3) Any change to control of accountability, 

exchange, or transfer requires that the cash 

or cash equivalents be counted and recorded 

independently by at least two agents and 

reconciled to the recorded amount. 

Intent: To reduce potential misappropriation of assets and provide 

for accountability by requiring a documented independent count and 

reconciliation of cash and/or cash equivalents whenever there is a 

change in the control of accountability of the funds.

Testing: 1. Interview appropriate personnel to determine who is 

responsible for counting and recording cash or cash equivalent 

when there is a change to control of accountability (e.g. Bingo 

Management, Bingo Supervisor, Bingo Paymaster, Bingo Floor 

Clerk, etc.). 2. Review TICS and or SICS to determine procedures 

implemented for cash and cash equivalents when there is change of 

accountability (e.g., inventory of cash equivalents, documentation, 

independent counts, shift, session, transfers, exchanges, signatures, 

variances, etc.). 3. Review a sample (as described in Glossary) of cash 

or cash equivalent accountability records for Bingo from the selected 

test dates to determine if independent counts are performed, 

recorded and reconciled by at least 2 agents and are properly 

documented. 4. Observe change in accountability (Note: Typically 

shift change, etc.).
Citation Language Intent and Testing

§ 543.8 (g)

543.8(g)(1)

(i)-(iv)

Class II gaming systems’ logical and physical controls. 

Controls must be established and procedures 

implemented to ensure adequate:

(1) Shipping and receiving. 

(i) A communication procedure must be established 

between the supplier, the gaming operation, and the 

TGRA to properly control the shipping and receiving 

of all software and hardware components. Such 

procedures must include: 

(A) Notification of pending shipments must be 

provided to the TGRA by the gaming operation; 

(B) Certification in accordance with 25 CFR part 547; 

(C) Notification from the supplier to the TGRA, or 

the gaming operation as approved by the TGRA, of 

the shipping date and expected date of delivery. The 

shipping notification must include: 

(1) Name and address of the supplier; 

(2) Description of shipment; 

(3) For player interfaces: a serial number; 

(4) For software: software version and description of 

software; 

(5) Method of shipment; and 

(6) Expected date of delivery. 

(ii) Procedures must be implemented for the 

exchange of Class II gaming system components for 

maintenance and replacement. 

(iii) Class II gaming system components must be 

shipped in a secure manner to deter unauthorized 

access. 

(iv) The TGRA, or its designee, must receive all Class II 

gaming system components and game play software 

packages, and verify the contents against the shipping 

notification. 

Intent: To reduce potential misappropriation of assets and 

compromise to the bingo game by providing detailed shipping 

procedures for gaming software and hardware which include 

specific communications between the vendor, TGRA and gaming 

operation, verification shipped items are properly lab certified, 

shipping in a secured manner to prevent unauthorized access 

and accountability of received system components and software 

by physical verification to shipping documents. In addition, 

providing procedures specific to exchanges of equipment for 

maintenance and replacement.

Testing: 1. Interview appropriate personnel to determine who 

is responsible for Class II gaming systems’ logical and physical 

controls (e.g. TGRA, Electronic Bingo Management, Bingo Floor 

personnel, Security, Shipping Receiving personnel, IT personnel, 

etc.). 2. Review TICS to ensure controls are established and 

review SICS to determine process and what documentation 

is required to be maintained for the shipping and receiving 

of bingo technological aids including; supplier notification 

of shipments, testing lab certifications, TGRA verification of 

receipt, etc. Also to determine document retention period and 

auditing procedures for auditing the records. 3. Review sample 

of shipping and receiving documentation to determine all 

required information is included. (Look at sample as defined in 

the Glossary).

543.20(i) 

§ 543.8 (g)
Citation Language Intent and Testing

§ 543.8 (g)

543.8(g)(2)(i) (2) Access credential control methods. 

(i) Controls must be established to restrict 

access to the Class II gaming system 

components, as set forth in § 543.20, 

Information and Technology. 

Intent: To reduce potential misappropriation of assets and compromise to 

the bingo game by ensuring access to Class II gaming system components 

are restricted in accordance with 25 CFR Part 543.20, Information 

Technology.

Testing: 1. Interview appropriate personnel to determine who has access to 

the Class II gaming system components (e.g., electronic bingo management, 

electronic bingo floor personnel, and person in charge of securing server 

room). 2. Review TICS to ensure controls have been established and review 

SICS to determine if procedures have been implemented to restrict access 

to the Class II gaming system components 3. Observe and document how 

access is controlled.

Note: This step may have been conducted during the audit of the IT section. 

543.8(g)(3)

(i)(A)-(I), (ii)

(3) Recordkeeping and audit processes. 

(i) The gaming operation must maintain the 

following records, as applicable, related to 

installed game servers and player interfaces: 

 (A) Date placed into service; 

(B) Date made available for play; 

(C) Supplier; 

(D) Software version; 

(E) Serial number; 

(F) Game title; 

(G) Asset and/or location number; 

(H) Seal number; and 

(I) Initial meter reading. 

(ii) Procedures must be implemented for 

auditing such records in accordance with § 

543.23, Audit and Accounting. 

Intent: To reduce potential misappropriation of assets and compromise 

to the bingo game by ensuring documentation is maintained recording 

the installation and related installation testing performed when Class II 

gaming system servers and player interfaces are installed. And to provide 

accountability by ensuring that records are reviewed in accordance with 

established auditing procedures. 

Testing: 1. Interview appropriate personnel to determine who is 

responsible for completing procedure (e.g. TGRA, Electronic Bingo 

Management, Bingo Floor personnel). 2. Review TICS and or SICS to 

determine process and what documentation is required to be maintained. 

Also to determine document retention period and auditing procedures 

for auditing the records. (Best Practice recommends until servers and 

interfaces are permanently removed from the operation) 

3. Review sample of install records for game servers and player interfaces. 

Also, review sample to ensure the documents were audited according to 

the auditing procedures (Look at sample as defined in the Glossary) 

Note: The industry is moving away from seals (due to the increasing number of 

ways a seal can be compromised) locks is more frequently used by operations. 

If locks are used confirm and document the board or cabinet is locked with a 

restricted access key, instead of ‘N/A’ for seal number.
Citation Language Intent and Testing

§ 543.8 (g)

543.8(g)(4)

(i)-(iv)

(4) System software signature verification.

(i) Procedures must be implemented for system

software verifications. These procedures must include

comparing signatures generated by the verification

programs required by 25 CFR 547.8, to the signatures

provided in the independent test laboratory letter for

that software version.

(ii) An agent independent of the bingo operation must

perform system software signature verification(s) to

verify that only approved software is installed.

(iii) Procedures must be implemented for investigating

and resolving any software verification variances.

(iv) Internal audits must be conducted as set forth in

§ 543.23, Audit and Accounting. Such audits must be

documented.

Intent: To reduce compromise to the bingo game by testing software 

signatures to ensure that the software signature verification matches 

the signature provided by the independent testing lab. (Best practice 

recommends that verification is performed by personnel independent 

of bingo and that any variances identified during the verification are 

investigated and resolved prior to installation of the software or device.)

Testing: 1. Interview appropriate personnel to determine who is 

responsible for system software signature verification procedure (e.g. 

TGRA, Electronic Bingo Management, Bingo Floor personnel). 2. Review 

TICS and or SICS to determine procedures implemented for system 

software verifications. 3. Review sample of system software verifications 

documents (e.g. test lab reports, investigation documentation) game 

servers and player interfaces. (Look at sample as defined in the Glossary) 

543.8(g)(5)

(i)(A)-(K)

(5) Installation testing.

(i) Testing must be completed during the installation

process to verify that the player interface has been

properly installed. This must include testing of the

following, as applicable:

(A) Communication with the Class II gaming system;

(B) Communication with the accounting system;

(C) Communication with the player tracking system;

(D) Currency and vouchers to bill acceptor;

(E) Voucher printing;

(F) Meter incrementation;

(G) Pay table, for verification;

(H) Player interface denomination, for verification;

(I) All buttons, to ensure that all are operational and

programmed appropriately;

(J) System components, to ensure that they are safely

installed at location; and

(K) Locks, to ensure that they are secure and functioning.

Intent: To ensure that the electronic bingo game is accurately recording 

data and communicating that data to the Class II gaming system, 

accounting system and the player tracking system. Accurate recording 

of data helps to identify and reduce compromise to the bingo game 

by verifying proper communication with applicable systems. Proper 

installation of the player interface (e.g. metering, printing of tickets, pay 

table(s), denomination, physical buttons, components for safe installation 

and locks) reduces the risk of misappropriation of assets.

Testing: 1. Interview appropriate personnel to determine who is 

responsible for the installation process (procedure (e.g. Electronic 

Bingo Management, Bingo Floor personnel). 2. Review TICS and or SICS 

to determine the procedures involved in the installation testing and 

documents required being maintained 3. Review sample of documents 

completed during the installation testing 

(Note: Typically an installation testing checklist is created to document 

these procedures)
Citation Language Intent and Testing

§ 543.8 (g)

543.8(g)(6) (6) Display of rules and necessary 

disclaimers. The TGRA or the operation must 

verify that all game rules and disclaimers 

are displayed at all times or made readily 

available to the player upon request, as 

required by 25 CFR part 547.

Intent: To reduce compromise to the bingo game by ensuring that all patrons 

are aware of and participate in games under the same set of rules. 

Testing: 1. Observe the gaming floor to determine if the game rules are 

displayed for both electronic and manual bingo games. 2. Interview 

appropriate personnel to determine if the rules are available to players upon 

request (e.g. TGRA, Electronic Bingo Management, Bingo Floor personnel).

543.8(g)(7) (7) TGRA approval of all technologic aids 

before they are offered for play.

Intent: To reduce compromise and ensure integrity of the bingo game by 

requiring that all technological aids for bingo be approved before they are 

available to patrons of the casino.

Testing: 1. Review SICS to determine the process for acquiring TGRA approval 

for the use of technological aids. 2. Locate written documentation of TGRA 

approval for technological aids used in the play of bingo.

543.8(g)(8) (8) All Class II gaming equipment must 

comply with 25 CFR part 547, Minimum 

Technical Standards for Gaming Equipment 

Used With the Play of Class II Games.

Intent: To reduce compromise and ensure integrity of the bingo game by 

requiring that all Class II gaming equipment comply with 25 CFR Part 547, 

technical standards.

Testing: 1. Observe the gaming floor to determine what gaming equipment 

is used with the play of Class II games. Interview appropriate personnel 

to verify the gaming equipment used with the play of Class II games (e.g. 

Bingo Management, Bingo Floor personnel. 2. Review TICS and or SICS to 

determine procedures for complying with 25CFR part 547. 3. Review sample 

of test lab reports.

543.8(g)(9) (9) Dispute resolution. Intent: To ensure the integrity of the bingo game by providing and 

implementing documented procedures for patron disputes that apply to all 

patrons. 

Testing: 1. Review TICS and or SICS to determine the procedures for dispute 

resolution and documentation required to be maintained 2. Review current 

dispute resolution documentation to determine compliance with procedure
Citation Language Intent and Testing

§ 543.8 (h)

543.8(h)(1)

(i)-(iv)

(h) Operations. (1) Malfunctions. 

Procedures must be implemented to 

investigate, document and resolve 

malfunctions. Such procedures must 

address the following: 

(i) Determination of the event causing the 

malfunction; 

(ii) Review of relevant records, game recall, 

reports, logs, surveillance records; 

(iii) Repair or replacement of the Class II 

gaming component; 

(iv) Verification of the integrity of the Class 

II gaming component before restoring it to 

operation.

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

procedures to investigate, document and resolve malfunctions including 

determining the cause, 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. 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)

DEFINITIONS 
Citation Language Intent and Testing

§ 543.8 (h)

543.8(h)(2)

(i)-(v)

2) Removal, retirement and/or destruction. 

Procedures must be implemented to retire or remove any 

or all associated components of a Class II gaming system 

from operation. Procedures must include the following: 

(i) For player interfaces and components that accept cash or 

cash equivalents: 

(A) Coordinate with the drop team to perform a final drop; 

(B) Collect final accounting information such as meter 

readings, drop and payouts; 

(C) Remove and/or secure any or all associated equipment 

such as locks, card reader, or ticket printer from the retired 

or removed component; and 

(D) Document removal, retirement, and/or destruction. 

(ii) For removal of software components: 

(A) Purge and/or return the software to the license holder; 

and 

(B) Document the removal. 

(iii) For other related equipment such as blowers, cards, 

interface cards: 

(A) Remove and/or secure equipment; and 

(B) Document the removal or securing of equipment. 

(iv) For all components: 

(A) Verify that unique identifiers, and descriptions of 

removed/retired components are recorded as part of the 

retirement documentation; and 

(B) Coordinate with the accounting department to properly 

retire the component in the system records. 

(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: 

(A) Methods of destruction; 

(B) Witness or surveillance of destruction; 

(C) Documentation of all components destroyed; and 

(D) Signatures of agent(s) destroying components attesting 

to 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. Controls 

include: coordination for final drop(s), recording final meter readings, 

removal of salvageable items, purging or return of software, updating 

system records, witnessing destructions accounted for by signature and 

documentation of removals, retirements and destructions.

Testing: 1. Interview appropriate personnel to determine when the final 

accounting information is recorded. Including the procedures for removal, 

retirement and destruction. 2. Review TICS and or SICS to ensure that 

procedures have been implemented addressing the retirement and/

or removal of associated components of a Class II gaming system from 

operation. Specifically, player interfaces and components that accept cash 

or cash equivalents: requirements to coordinate with the drop team to 

perform a final drop; requirements to collect final accounting information 

(e.g. meter readings, drop and payouts); requirements to remove and/

or secure associated equipment (e.g. locks, card reader, ticket printer) 

from the retired or removed component; and requirements to document 

removal, retirement, and/or destruction, Purge and/or return the software 

to the license holder; and documentation requirements. Including 

requirements for other related equipment such as blowers, cards, and 

interface cards: Including removal and/or securing of equipment; and 

documentation of the removal or securing of equipment. Additionally, 

the requirement to verify that unique identifiers and descriptions of 

removed/retired components are recorded as part of the retirement 

documentation; and coordinating with the accounting department to 

properly retire the component in the system records. Procedures must 

be developed to destroy such components which include: methods of 

destruction; Witness or surveillance of destruction; documentation of all 

components destroyed; and signatures of agent(s) destroying components 

attesting to destruction (If the TGRA authorizes destruction of any Class II 

gaming system components). 3. Review sample of vendor return records 

(for software), removal, and retirement and destruction records. (Look at 

sample as defined in the Glossary) retirement and/or destruction records.

4. Observe a removal, retirement and destruction.
FLOWCHART 

§ 543.8 (i)

Citation Language Intent and Testing

§ 543.8 (i)

543.8(i)(1)

(i)-(v)

(i) Vouchers. 

(1) Controls must be established and procedures 

implemented to: 

(i) Verify the authenticity of each voucher redeemed. 

(ii) If the voucher is valid, verify that the patron is 

paid the appropriate amount. 

(iii) Document the payment of a claim on a voucher 

that is not physically available or a voucher that 

cannot be validated such as a mutilated, expired, 

lost, or stolen voucher. 

(iv) Retain payment documentation for reconciliation 

purposes. 

(v) For manual payment of a voucher of $500 or 

more, require a supervisory employee to verify the 

validity of the voucher prior to payment.

Intent: To prevent potential misappropriation of assets by establishing 

and implementing procedures for the redemption of tickets which 

include verifying the ticket in the validation system, verifying patron is 

paid appropriately, documenting payment of vouchers which cannot be 

validated (printer errors, expired (if honored), etc.), retaining voucher for 

reconciliation and supervisory verification for payouts over $500 when 

the system is down.

Testing: 1. Interview appropriate personnel to verify actual procedure 

(Cage management, Cage cashier). 2. Review TICS to ensure controls 

are established and review SICS to determine the procedures for 

verifying authenticity, payment of mutilates, expired, lost, stolen 

vouchers and manual payments of vouchers. 3. Review sample of 

vouchers redeemed and manual vouchers redeemed including those 

in the cashier’s drawer. Review sample of reports from validation 

system. (Look at sample as defined in the Glossary) (Note: Manual 

payouts exist when the system is down.) 4. Observation of a voucher 

redemption paid by an employee (e.g. cage, slot booth, etc.) and 

if possible observe redemption at a kiosk either live or through 

surveillance coverage.

543.8(i)(2) (2) Vouchers paid during a period while the voucher 

system is temporarily out of operation must be 

marked “paid” by the cashier.

Intent: To prevent misappropriation of assets by ensuring a voucher 

redeemed while the validation system is out of operation is properly 

marked as paid so it cannot be redeemed again.

Testing: 1. If no sample can be located, Interview appropriate 

personnel to verify procedure (e.g. Cage Cashier, Floor Cashier) 2. 

Review TICS and or SICS to determine procedure for paying vouchers 

when voucher system is down. 3. Review sample of vouchers paid 

while system is down. (Look at sample as defined in the Glossary)
Citation Language Intent and Testing

§ 543.8 (i)

543.8(i)(3) (3) Vouchers redeemed while the 

voucher system was temporarily out 

of operation must be validated as 

expeditiously as possible upon restored 

operation of the voucher system. 

Intent: To prevent potential misappropriation of assets by ensuring vouchers 

redeemed while the validation system is out of operation are validated through 

the validation system as soon as reasonably possible to ensure tickets are 

properly recorded as redeemed in the system and for reconciliation purposes.

Testing: 1. Interview appropriate personnel if no sample can be located to 

verify procedure (e.g. Cage Cashier, Floor Cashier) 2. Review TICS and or SICS 

to determine procedure for paying vouchers when voucher system is down. 

3. Review sample of vouchers paid while system is down. Including reviewing 

the report from the validation system to verify tickets were redeemed within a 

reasonable time frame after the system was restored. (Refer to the Glossary for 

a definition of sample.)

543.8(i)(4) (4) Paid vouchers must be maintained 

in the cashier’s accountability for 

reconciliation purposes.

Intent: To prevent potential misappropriation of assets by ensuring vouchers are 

accounted for and available for reconciliation purposes.

Testing: 1. Interview appropriate personnel to determine accountability for 

reconciliation procedure (Cage Management, Cage Cashiers), 2. Observe 

vouchers in the cashier’s bank and end of shift reconciliation.

543.8(i)(5) (5) Unredeemed vouchers can only 

be voided in the voucher system by 

supervisory employees. The accounting 

department will maintain the voided 

voucher, if available.

Intent: To prevent potential misappropriation of assets by requiring supervisory 

personnel to void unredeemed vouchers and to providing for a separate 

department to maintain voided vouchers. 

Testing: 1.Test sample of voided vouchers and the report that identifies the 

person who voided the voucher. (Look at sample as defined in the Glossary) 

(Best Practice would dictate that the vouchers are voided by accounting 

or revenue audit and that the voucher be maintained in accordance with 

documentation retention policy)
Citation Language Intent and Testing

§ 543.8 ( j-k)

543.8(j) (j) All relevant controls from § 543.20, 

Information and Technology will apply. 

To See Information Technology Tool Kit 543.20.

543.8(k) (k) Revenue Audit. Standards for 

revenue audit of bingo are contained in 

§ 543.24, Revenue Audit. 

To See Revenue Audit Tool Kit 543.24.

543.8(l) (l) Variance. The operation must 

establish, as approved by the TGRA, 

the threshold level at which a 

variance, including deviations from the 

mathematical expectations required 

by 25 CFR 547.4, will be reviewed to 

determine the cause. Any such review 

must be documented. 

Intent: To reduce potential misappropriation of assets and compromise to 

the bingo game by establishing a threshold level at which variances and 

mathematical deviations from expectations can be identified and reviewed 

including the requirement to document reviews completed.

Testing: 1. Interview appropriate personnel to determine variance level 

threshold and if written approval has been received for the level (e.g. TGRA, 

Bingo Management, Revenue Audit personnel). 2. Review SICS to determine 

variance threshold and procedure. 3. Review documentation where review 

was performed on a variance or deviation from the mathematical expectations 

exceeded the threshold level. 

SEVERITY

MATRIX § 543.8( j-k)
5 CFR 543.8 Toolkit

Version 1.0

NIGC Compliance Division

National Indian Gaming Commission Training Manager 

Training Program