APPENDIX 1
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PROPOSED PART 543 – MINIMUM INTERNAL CONTROL STANDARDS FOR 

CLASS II GAMING

Sec.

543.1 What does this part cover?

543.2 What are the definitions for this part?

543.3 How do tribal governments comply with this part?

543.4 What are the rules of interpretation and of general application for this part? 

543.5 [RESERVED]

543.6 Does this part apply to small and charitable gaming operations?

543.7 What are the minimum internal control standards for bingo?

543.8 What are the minimum internal control standards for pull tabs?

543.9 What are the minimum internal control standards for card games?

543.10 What are the minimum internal control standards for gaming promotions?

543.11 What are the minimum internal control standards for patron deposit accounts and 

cashless systems?

543.12 [RESERVED]What are the minimum internal control standards for player tracking?

543.13 [RESERVED]

543.14 What are the minimum internal control standards for the cage, vault, cash and cash 

equivalents?

543.15 What are the minimum internal control standards for lines of credit?

543.16 What are the minimum internal control standards for security and management of 

server, server software and data associated with Class II gaming systems?

543.17 What are the minimum internal control standards for complimentary services or items?

543.18 How does a gaming operation apply for a variance from the standards of this part?

543.19 What are the minimum internal control standards for audit and accounting?

543.20 [RESERVED]

543.21 What are the minimum internal control standards for drop and count?

543.22 [RESERVED]

543.23 What are the minimum internal control standards for surveillance?

§ 543.1 What does this part cover?

This part establishes the minimum internal control standards for the conduct of Class II games on 

Indian lands as described in 25 U.S.C. 2701 et seq.

§ 543.2 What are the definitions for this part?

The definitions in this section apply to all sections of this part unless otherwise noted.

Accountability. All financial instruments, receivables, and patron deposits constituting the total 

amount for which the bankroll custodian is responsible at a given time.

Accumulated credit payout. Credit accrued in a player interface that is paid to a patron manually 

in lieu of a player interface payout (i.e. hand pay, manual pay).
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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. This definition 

permits the use of computer applications to perform the function(s) of an agent.

Bingo paper. A consumable physical object that has one or more bingo cards on its face.

Bingo sales. Sales transactions and/or the value of purchases made by players to participate in 

the game(s).

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

area for the gaming operation bankroll.

Chairman. The Chairman of the National Indian Gaming Commission. 

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.

Cashless system. A system that performs cashless transactions and maintains records of those 

cashless transactions.

Cashless transaction. A movement of funds electronically from one component to another, often 

to or from a patron deposit account, or promotional account.

Chips. Cash substitutes, in various denominations, issued by a gaming operation.

Class II game. Class II gaming shall have 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 part Part 547 

of this chapter.

Commission. The National Indian Gaming Commission established by the Indian Gaming 

Regulatory Act, 25 U.S.C. 2701 et seq.

Complimentary. A service or item provided at no or reduced cost, to a patron at the discretion of 

an agent authorized to issue such services or items.

Count. The act of counting and recording the drop and/or other funds. Also, the total funds 

counted for a particular game, player interface, shift, or other period.
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Count room. A secured room location where the count is performed in which the cash and cash 

equivalents are counted.

Credit line (see Lines of credit). The privilege granted by a gaming operation to a patron to (1) 

defer payment of debt or (2) to incur debt and defer its payment under specific terms and 

conditions.

Credit line limit. The maximum dollar amount of credit assigned to a patron by the gaming 

operation.

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

Drop. The process of removing the drop boxes from the player interface or point of purchase.

Drop proceeds. The total amount of financial instruments removed from the drop boxes.

Drop box. A locked container in which cash or cash equivalents are placed at the time of the 

transaction. 

Exception Report. A listing of occurrences, transactions or items that fall outside a 

predetermined range of acceptability.

Financial instrument. Any tangible item of value tendered in Class II game play, including, but 

not limited to bills, coins, vouchers, and coupons.

Gaming Promotion. A type of marketing activity conducted by a gaming operation which 

includes two, but not all three, of the following elements: prize, chance, consideration.

Generally Accepted Accounting Principles (GAAP). A widely accepted set of rules, conventions, 

standards, and procedures for reporting financial information, as established by the Financial 

Accounting Standards Board (FASB), including but not limited to the standards for casino 

accounting published by the American Institute of Certified Public Accountant (AICPA).

Governmental Accounting Standards Board (GASB). Generally accepted accounting principles 

used by state and local governments.

Independent. The separation of functions so that the person or process monitoring, reviewing or 

authorizing the controlled activity, function, transaction is separate from the persons or process 

performing the controlled activity, function, transaction.

Lines of credit. The privilege granted by a gaming operation to a patron to (1) defer payment of 

debt or (2) to incur debt and defer its payment under specific terms and conditions.

Manual payout. Hand payment to a player.
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Marker. A document, signed by the patron promising to repay credit issued by the gaming 

operation.

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”.

Patron deposit account. An account maintained on behalf of a patron, for the purpose of 

depositing and withdrawing funds for the primary purpose of interacting with a gaming activity.

Permanent Record. Those records that must be maintained for a minimum period of 5 years, 

including all documents that contain original signatures or represent audit papers.

Player interface. Any component(s) or components of a Class II gaming system, including an 

electronic or technological aid (not limited to terminals, player stations, handhelds, fixed units, 

etc.), that directly enables player interaction in a Class II game.

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

Promotional progressive pots and/or pools. Funds contributed to a game by and for the benefit 

of players and are distributed to players based on a predetermined event.

Restricted patron deposit account. An account that can be accessed only by a specific patron 

using a secured method.

SSAE. Standards for Attestation Engagements.

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

exceed 24 hours.

Shill. An agent financed by the gaming operation and acting as a player.

Short pay. The payment of the unpaid balance of an incomplete payout.

System of Internal Controls (SICS). An overall operational framework for a gaming operation 

incorporating principles of independence and segregation of function comprised of written 

policies, procedures, and standard practices based on overarching regulatory standards 

specifically designed to create a system of checks and balances in order to safeguard the integrity 

of a gaming operation and protect its assets. 

Smart card. A card with embedded integrated circuits that possesses the means to electronically 

store or retrieve account data, and is the only source of that data.
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Surveillance operation room(s). The secured area(s) where surveillance is taking place and/or 

where active surveillance equipment is located.

Surveillance system. A system of video cameras, monitors, recorders, video printers, switches, 

selectors, and other ancillary equipment used for surveillance.

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.

Unrestricted patron deposit account. An account that may be accessed by the holder of the 

account number.

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

§ 543.3 How do tribal governments comply with this part?

(a) Determination of Tier. 

(1) The determination of tier level shall be made based upon the annual gross gaming 

revenues indicated within the gaming operation's audited financial statements. 

(2) Gaming operations moving from one tier to another shall have nine (9) months from 

the date of the independent certified public accountant's audit report to achieve 

compliance with the requirements of the new tier. The TGRA may extend the deadline 

by an additional six (6) months if written notice is provided to the Commission no later 

than two (2) weeks before the expiration of the nine (9) month period.

(b) TICS. TGRAs shall ensure that TICS are established and implemented that provide a level of 

control that equals or exceeds those set forth in this part.

(1) Evaluation of Existing TICS. Each TGRA must, in accordance with the tribal gaming 

ordinance, determine whether and to what extent their TICS require revision to ensure 

compliance with this part. 
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(2) Compliance Date. All changes necessary to ensure compliance with this part shall be 

promulgated within twelve (12) months from the effective date of this part and 

implemented at the commencement at the next fiscal year. At the discretion of the 

TGRA, gaming operations may have an additional six (6) months to come into 

compliance with the TICS.

(c) SICS. Each gaming operation must develop and implement a SICS that, at a minimum, 

complies with the TICS.

(1) Existing gaming operations. All gaming operations that are operating on or before the 

effective date of this part, must comply with this part within the time requirements 

established in paragraph (b) of this section. In the interim, such operations must continue 

to comply with existing TICS.

(2) New gaming operations. All gaming operations that commence operations after the 

effective date of this part, must comply with this part before commencement of 

operations.

(d) Submission to Commission. Tribal regulations promulgated pursuant to this part are not 

required to be submitted to the Commission pursuant to Sec. 522.3(b) of this chapter.

(e) Enforcement of Commission MICS.

(1) Each TGRA is required to establish and implement TICS pursuant to paragraph (b) of 

this section. Each gaming operation is then required, pursuant to paragraph (c) of this 

section, to develop and implement a SICS that complies with the TICS. Failure to do so 

may subject the tribal operator of the gaming operation, or the management contractor, to 

penalties under 25 U.S.C. 2713.

(2) Recognizing that tribes are the primary regulator of their gaming operation(s), 

enforcement action by the Commission will not be initiated under this part without first 

informing the tribe and TGRA of deficiencies in the SICS of its gaming operation and 

allowing a reasonable period of time to address such deficiencies. Such prior notice and 

opportunity for corrective action is not required where the threat to the integrity of the 

gaming operation is immediate and severe.

§ 543.4 What are the rules of interpretation and of general application for this part? 

(a) Minimum Standards. A TGRA may establish and implement additional technical standards 

that are as stringent as, or more stringent than, those set out in this part. 
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(b) Only Applicable Standards Apply. Gaming equipment and software used with Class II 

gaming systems shall meet all applicable requirements of this part. For example, if a gaming 

operation does not offer lines of credit, then any standards that govern credit do not apply. 

(c) No Limitation of Technology. This part should not be interpreted to limit the use of 

technology or to preclude the use of technology not specifically referenced. 

(d) Severability. If any provision of this part is declared invalid by a court of competent 

jurisdiction, such decision shall not affect the remainder of this part. 

§ 543.5 [RESERVED]

§ 543.6 Does this part apply to small and charitable gaming operations?

(a) Small Gaming Operations. This part does not apply to small gaming operations provided that:

(1) The TGRA permits the operation to be exempt from this part;

(2) The annual gross gaming revenue of the operation does not exceed $3 million; and

(3) The TGRA develops and the operation complies with alternate procedures that:

(i) Protect the integrity of games offered;

(ii) Safeguard the assets used in connection with the operation; and

(iii) Create, prepare and maintain records in accordance with Generally Accepted 

Accounting Principles.

(b) Charitable Gaming Operations. This part does not apply to charitable gaming operations 

provided that:

(1) All proceeds are for the benefit of a charitable organization;

(2) The TGRA permits the charitable organization to be exempt from this part;

(3) The charitable gaming operation is operated wholly by the charitable organization‟s 

agents;

(4) The annual gross gaming revenue of the charitable operation does not exceed $3 

million; and

(5) The TGRA develops and the charitable gaming operation complies with alternate 

procedures that:
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(i) Protect the integrity of the games offered;

(ii) Safeguard the assets used in connection with the gaming operation; and

(iii) Create, prepare and maintain records in accordance with Generally Accepted 

Accounting Principles. For more information please see www.fasb.gov or 

www.fasb.org.

(c) Independent Operators. Nothing in this section exempts gaming operations conducted by 

independent operators for the benefit of a charitable organization.

§ 543.7 What are the minimum internal control standards for bingo?

(a) Internal Control Procedures. Subject to the approval and oversight of the TGRA, each gaming 

operation shall establish, implement and adhere to internal control policies and procedures that 

provide at least the level of control established by the standards of this section.

(b) Computerized Applications. For any computer applications utilized, alternate documentation 

and/or procedures that provide at least the level of control established by the standards of this 

section, as approved in writing by the TGRA, will be acceptable.

(c) Variances. The TGRA shall establish the threshold level at which a variance shall be 

reviewed. Any such review shall be documented. 

(d) Supervision. Supervision shall be provided for bingo operations as needed by an agent(s) 

with authority equal to or greater than those being supervised.

(de) Bingo Cards.

(1) Physical Inventory of bingo paper. 

(i) The bingo paper card inventory must be controlled in a manner designed to 

prevent unauthorized access, misappropriation, forgery, theft, or fraud. Such 

controls shall address bingo paper cards exchanged between two agents, increases 

and decreases to inventory, and inventory reconciliation.

(2) Bingo salesSales. 

(i) Bingo The sales of bingo cards must be controlled in a manner to adequately 

record, track, and reconcile all bingosuch sales, including but not limited to voids

of bingo cards. 
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(ii) When the sale of bingo cards sales areis recorded manually, total such sales 

are must be verified by an agent independent agentof the bingo sales being 

verified. 

(iii) No unauthorized person shall have unrestricted access to bingo card sales 

records.

(ef) Draw.

(1) The draw must be controlled in a manner that ensures the identity of each object 

drawn is accurately recorded and transmitted to the participants. 

(21) Controls must be present to ensureestablished requiring that all objects eligible for 

the draw are available to be drawn.

(2) The draw must be controlled in a manner that ensures random selection of the objects 

drawn.

(13) The draw must be controlled in a manner that ensures the identity of each object 

drawn is accurately recorded and transmitted to the participants.

(fg) Manual Payouts.

(1) Manual payouts Payouts must be controlled in a manner designed to verify winning 

events and prevent unauthorized access to, or misappropriation of, cash or cash 

equivalents. Such controls shall include, but not be limited to, the following:

(i) Manual payout Payout documentsrecords;

(ii) Validation and Verification;

(iii) Authorization and or signatures; and

(iv) Changes to Prize Payout amounts;

(v) Manually paid promotional prize payouts; and

(viiv) Voids.

(gh) Cash or and Cash Equivalent Controls. Cash or and cash equivalents must be controlled in a 

manner designed to prevent unauthorized access, misappropriation, forgery, theft, or fraud. Such 

controls shall be in accordance with cash and cash equivalent controls established in sub part 

543.14.
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(hi) Class II Gaming systemsTechnologic Aids to the Play of Bingo. Internal control procedures 

must be established to safeguard the integrity of all or part of a Class II gaming 

systemtechnologic aids to the play of bingo during installations, operations, modifications, and 

retirements. Such procedures must include, but not be limited to, the following:

(1) Shipping and receiving;

(2) Access credential control methods; 

(3) Record keeping and audit processes; 

(4) System software signature verification; 

(5) Testing;

(6) Display of rules and necessary disclaimers such as “Malfunctions void all prizes and 

pays and plays.", etc.

(7) Dispute resolution; 

(8) Malfunctions; and

(9) Removal, retirement, and/or destruction.

§ 543.8 What are the minimum internal control standards for pull tabs?

(a) Internal Control Procedures. Subject to the approval and oversight of the TGRA, each gaming 

operation shall establish, implement and adhere to internal control policies and procedures that 

provide at least the level of control established by the standards of this section.

(b) Computerized Applications. For any computer applications utilized, alternate documentation 

and/or procedures that provide at least the level of control established by the standards of this 

section, as approved in writing by the TGRA, will be acceptable.

(c) Variances. The TGRA shall establish the threshold level at which a variance shall be 

reviewed. Any such review shall be documented. 

(d) Supervision. Supervision shall be provided during the pull tab operations and over the pull 

tab storage areas by an agent(s) with authority equal to or greater than those being supervised.

(de) Pull Tab Inventory of pull tabs. The pull tab inventory must be controlled in a manner 

designed to prevent unauthorized access, misappropriation, forgery, theft, or fraud. Such controls 

shall address tabs exchanged between two agents, increases and decreases to inventory, and 

inventory reconciliation.
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(cf) Pull Tab Sales. 

(1) Pull tab sales must be controlled in a manner to adequately record, track, and 

reconcile all pull tab sales and voids.

(2) When pull tab sales are recorded manually, total sales are verified by an agent 

independent of the pull tab sales being verified. 

(3) No person shall have unrestricted access to pull tab sales records.

(dg) Winning Pull Tabs. 

(1) Redeemed pull tabs must be controlled in a manner to adequately record, track, and 

reconcile all pull tab payouts.

(2) The redeemed pull tabs shall be defaced so that they cannot be redeemed for payment 

again.

(eh) Cash or and Cash Equivalent Controls. Cash or and cash equivalents must be controlled in a 

manner designed to prevent unauthorized access, misappropriation, forgery, theft, or fraud. Such 

controls shall be in accordance with cash and cash equivalent controls established in sub part 

543.14.

§ 543.9 What are the minimum internal control standards for card games?

(a) Internal Control Procedures. Subject to the approval and oversight of the TGRA, each gaming 

operation shall establish, implement and adhere to internal control policies and procedures that 

provide at least the level of control established by the standards of this section.

(b) Computerized Applications. For any computer applications utilized, alternate documentation 

and/or procedures that provide at least the level of control established by the standards of this 

section, as approved in writing by the TGRA, will be acceptable.

(c) Variances. The TGRA shall establish the threshold level at which a variance shall be 

reviewed. Any such review shall be documented. 

(d) Supervision. Supervision shall be provided during the card room operations by an agent(s) 

with authority equal to or greater than those being supervised.

(e) Inventory of Playing Cards. The playing card inventory must be controlled in a manner 

designed to prevent unauthorized access, misappropriation, forgery, theft, or fraud. Such controls 

shall address tabs cards exchanged between two agents, increases and decreases to inventory, 

and inventory reconciliation.
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(f) Shill Funds. Issuance and return of shill funds shall be recorded and have the written approval 

of another agent.

(g) Cash or and Cash Equivalent Controls. Cash or and cash equivalents must be controlled in a 

manner designed to prevent unauthorized access, misappropriation, forgery, theft, or fraud. Such 

controls shall be in accordance with cash and cash equivalent controls established in sub part 

543.14.

(h) Posted Rules. The rules shall be displayed or available for patron review at the gaming 

operation, including rules governing contests, prize payouts, fees, etc. 

(i) Promotional Progressive Pots and Pools such as Contests, Tournaments, Drawings and 

Giveaway Programs. Funds contributed by patrons to prize pools shall be returned and 

documented in accordance with the posted rules.

(1) Promotional pool contributions shall be controlled in a manner to properly distinguish 

between gaming revenue and promotional pool contributions. 

(i) Promotional pool contributions shall be placed in a locked container;

(ii) Agents transporting the locked container shall be precluded from having 

access to the contents keys. 

(2) At least once a dayweek, increases and decreases to the promotional pool amount 

shall be verified, supported by documentation, recorded and reconciled to the cash by an 

agent independent of the card room.

§ 543.10 What are the minimum internal control standards for gaming promotions?

(a) Internal Control Procedures. Subject to the approval and oversight of the TGRA, each gaming 

operation shall establish, implement and adhere to internal control policies and procedures that 

provide at least the level of control established by the standards of this section.

(b) Computer Applications. For any computer applications utilized, alternate documentation 

and/or procedures that provide at least the level of control established by the standards of this 

section, as approved in writing by the TGRA, will be acceptable.

(c) Variances. The TGRA shall establish the threshold level at which a variance shall be 

reviewed. Any such review shall be documented. 

(d) Supervision. Supervision shall be provided for gaming promotions as needed by an agent(s) 

with authority equal to or greater than those being supervised.
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(e) Gaming Promotions. Controls must be established in a manner designed to prevent 

unauthorized access, cheating, misappropriation, forgery, theft, or fraud. Such controls must 

include, but not be limited to, the following:

(1) Rules of the gaming promotion;

(2) Gaming promotion accounting; and 

(3) TGRA approval.

§ 543.11 What are the minimum internal control standards for patron deposit accounts 

and cashless systems?

(a) Internal Control Procedures. Subject to the approval and oversight of the TGRA, each gaming 

operation shall establish, implement and adhere to internal control policies and procedures that 

provide at least the level of control established by the standards of this section.

(b) Computer Applications. For any computer applications utilized, alternate documentation 

and/or procedures that provide at least the level of control established by the standards of this 

section, as approved in writing by the TGRA, will be acceptable.

(c) Conflicts of Standards. If there are any inconsistencies between these regulations and external 

standards incorporated by this provision, such as Title 31 and Credit Card Act, such other 

applicable standards shall prevail.

(d) Variances. The TGRA shall establish the threshold level at which a variance shall be 

reviewed. Any such review shall be documented.

(e) Patron Deposit Accounts and Cashless Systems.

(1) Patron deposit accounts and cashless systems must be controlled in a manner 

designed to prevent unauthorized access, misappropriation, forgery, theft, or fraud. 

(2) All smart cards (i.e., cards that possess the means to electronically store or retrieve 

data) that maintain the only source of account data are prohibited.

(3) Patron deposit accounts may be unrestricted or restricted to a specific patron.

(4) Establishment of patron deposit accounts. The following standards apply when the 

patron establishes an account and optionally makes an initial deposit.

(i) For restricted patron deposit accounts:
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(A) The patron must appear at the gaming operation in person, at a 

designated area of accountability, and present a valid government issued 

picture identification credential. 

(B) An agent must examine the patron‟s identification and record, at a 

minimum, the following information:

(1) Type, number, and expiration date of the identification; 

(2) Patron‟s name; 

(3) A unique account identifier; 

(4) Date the account was opened; and 

(5) The agent‟s name. 

(C) The agent must require the patron to sign the account documentation 

before the account is activated.

(D) The agent or cashless system shall provide the patron deposit account 

holder with a secure method of access.

(ii) For unrestricted patron deposit accounts:

(A) The patron must be informed of the unrestricted nature of the account, 

and the fact that the account may be accessible to anyone with the account 

number.

(B) The patron must acknowledge and accept the risks associated with 

unrestricted accounts.

(5) Patron deposits, withdrawals and adjustments. 

(i) Prior to the patron making a deposit or a withdrawal from a patron deposit 

account, the agent or cashless system must verify the identity of the patron deposit 

account, the patron identity for restricted accounts, and availability of funds. 

Reliance on a secured personal identification number (PIN) entered by the patron 

is an acceptable method of verifying patron identity.

(ii) Adjustments made to the patron deposit accounts must be performed by an 

agent.

(iii) When a deposit, withdrawal or adjustment is processed by an agent, a multipart transaction record must be created containing the following information: 
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(A) Same document number on all copies;

(B) Type of transaction, (e.g., deposit, withdrawal, or adjustment);

(C) Name or other identifier of the patron for restricted patron deposit 

accounts;

(D) The unique account identifier;

(E) Patron signature for withdrawals, unless a secured method of access is 

utilized;

(F) Date and time of transaction;

(G) Dollar amount of transaction;

(H) Nature of deposit, withdrawal, or adjustment (e.g., cash, check, chips); 

and

(I) Signature of the agent processing the transaction.

(iv) When a patron deposits or withdraws funds from a patron deposit account 

electronically, the following shall be recorded and reported:

(A) Date and time of transaction;

(B) Location (e.g., player interface, kiosk);

(C) Dollar amount of transaction; and

(D) The unique account identifier.

(v) Detailed patron deposit account transaction records must be available to the 

patron upon reasonable request.

(vi) If electronic funds transfers are made to or from a gaming operation bank 

account for patron deposit account funds, the bank account must be dedicated and 

may not be used for any other types of transactions.

§ 543.12 [RESERVED]What are the minimum internal control standards for player 

tracking systems used in conjunction with Class II gaming?

(a) Internal Control Procedures. Subject to the approval and oversight of the TGRA, each 

gaming operation shall establish, implement and adhere to internal control policies and 

procedures that provide at least the level of control established by the standards of this section.
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(b) Computer Applications. For any computer applications utilized, alternate documentation 

and/or procedures that provide at least the level of control established by the standards of this 

section, as approved in writing by the TGRA, will be acceptable.

(c) Variances. The TGRA shall establish the threshold level at which a variance shall be 

reviewed. Any such review shall be documented. 

(d) Player Tracking Systems. Controls must be established in a manner designed to prevent 

unauthorized access, cheating, misappropriation, forgery, theft, or fraud when a player tracking 

system is used in conjunction with Class II gaming. Such controls must include, but not be 

limited to, the following:

(1) Operation of player tracking programs;

(2) Security of player tracking accounts; and

(3) Audit and accounting.

§ 543.13 [RESERVED]

§ 543.14 What are the minimum internal control standards for the cage, vault, cash and 

cash equivalents?

(a) Internal Control Procedures. Subject to the approval and oversight of the TGRA, each gaming 

operation shall establish, implement and adhere to internal control policies and procedures that 

provide at least the level of control established by the standards of this section.

(b) Computer Applications. For any computer applications utilized, alternate documentation 

and/or procedures that provide at least the level of control established by the standards of this 

section, as approved in writing by the TGRA, will be acceptable.

(c) Variances. The TGRA shall establish the threshold level at which a variance shall be 

reviewed. Any such review shall be documented. 

(d) Supervision. Provide supervision for cage, vault, and other operations using cash or cash 

equivalents as needed by an agent(s) with authority equal to or greater than those being 

supervised.

(de) Cash or and Cash Equivalent Controls. 

(1) Cash or and cash equivalents must be controlled in a manner designed to prevent 

unauthorized access, misappropriation, forgery, theft, or fraud. Such controls must 

include, but not be limited to, the following actions:
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(i) Counting;

(ii) Recording increases and decreases to inventory;

(iii) Inventory reconciliation;

(iv) Issuance and redemption;

(v) Transfers;

(vvi) Inspecting, validating and verifying;

(vivii) Cancelations and voids;

(viiviii) Authorization; and

(viiiix) Document retention.

(ef) Check Cashing. Check cashing must be controlled in a manner designed to prevent 

unauthorized access, misappropriation, forgery, theft, or fraud. Such controls must include, but 

not be limited to, the following:

(1) Acceptance of checks;

(2) Deposit of checks (Checks not deposited in the normal course of business are subject 

to § 543.15 Lines of Credit standards).

(3) Collecting and recording returned checks; 

(4) Re-deposit; and 

(5) Write-off authorization.

(6) If a third party check cashing or guarantee service is used, the examination and 

documentation procedures required by the service provider shall apply unless otherwise 

provided by Tribal tribal law or regulation. 

(fg) Cage and Vault Accountability. 

(1) Increases and decreases to cage inventory shall be verified, supported by 

documentation, and recorded. Unverified transfers of cash and/or cash equivalents are 

prohibited. 

(2) The cage and vault inventories (including coin rooms/vaults) shall be counted 

independently by at least two agents, attested to by signature, and recorded in ink or other 

permanent form at the end of each shift during which activity took place. 
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(gh) Chip(s) and Token(s). Controls must be established to ensure accountability of chip and 

token inventory. Such controls must include, but not be limited to, the following:

(1) Purchase;

(2) Receipt;

(3) Inventory;

(4) Storage; and 

(5) Destruction.

(hi) Cage and Vault Access. Controls must be established in a manner designed to prevent 

unauthorized access, misappropriation, forgery or fraud. Such controls must include, but not be 

limited to, the following:

(1) Physical access to the cage to cage department agents, designated staff, and other 

persons authorized; and

(2) Transportation of extraneous items (e.g., personal belongings, tool boxes, beverage 

containers, etc.) into and out of the cage.

§ 543.15 What are the minimum internal control standards for lines of credit?

(a) Internal Control Procedures. Subject to the approval and oversight of the TGRA, each gaming 

operation shall establish, implement and adhere to internal control policies and procedures that 

provide at least the level of control established by the standards of this section.

(b) Computer Applications. For any computer applications utilized, alternate documentation 

and/or procedures that provide at least the level of control established by the standards of this 

section, as approved in writing by the TGRA, will be acceptable.

(c) Variances. The TGRA shall establish the threshold level at which a variance shall be 

reviewed. Any such review shall be documented. 

(d) Establishment of Lines of Credit Policy. 

(1) If a gaming operation extends lines of credit, controls must be established to 

safeguard the assets of the gaming operation. Such controls must include the 

establishment of a lines of credit policy including the following:

(i) A process for the patron to apply for, modify, and/or re-establish lines of 

credit, to include required documentation and credit line limit;
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(ii) Credit issuer authorization levels;

(iii) Identification of agents authorized to issue lines of credit;

(iv) A process for verifying lines of credit worthiness of applicants; 

(v) A system for recording patron information; to include:

(A) Name, current address, and signature;

(B) Identification credential;

(C) Authorized credit line limit; and

(D) Approval by an agent authorized to approve credit line limits;

(vi) A process for issuing lines of credit to include the following: 

(A) Notice to patron of lines of credit terms including patron written 

acknowledgment by signature;

(B) Completion of a uniquely identified, multi-part, lines of credit 

issuance form, such as a marker or counter check, which includes the 

terms of that lines of credit transaction;

(C) Signatory requirements;

(D) Determining the amount of the patron‟s available lines of credit;

(E) Creation and maintenance of current lines of credit balance record 

updated at the time of each transaction to assure that lines of credit issued 

is within the established limit and balance for that patron. 

(F) Requirement that the agent issuing the lines of credit must be 

independent of the agent who authorized the lines of credit.

(vii) A policy establishing credit line limit exceptions to include the following:

(A) Identification of the agent(s) authorized to permit a credit line limit to 

be exceeded; 

(B) Authorization thresholds; and

(C) Required documentation.
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(viii) A policy governing increases and decreases to a patron‟s lines of credit 

account balances to include the following:

(A) Documentation and record keeping requirements;

(B) Independence between the department that receives the payment and 

the department that maintains custody of the credit balance for payments 

made by mail; 

(C) Collections;

(D) Periodic audits and confirmation of balances; and

(E) If a collection agency is utilized, a process to ensure documentation of 

increases and decreases to the lines of credit account balances.

(ix) A policy governing write-offs and settlements to include:

(A) Identification of agent(s) authorized to approve write-offs and 

settlements;

(B) Authorization levels for write-offs and settlements of lines of credit 

instruments;

(C) Required documentation for write-offs and settlements;

(D) Independence between the agent who established the lines of credit 

and the agent writing off or settling the lines of credit instrument. 

(E) Necessary documentation for the approval of write-offs and 

settlements and transmittal to the appropriate department for recording and 

deductibility.

§ 543.16 What are the minimum internal control standards for security and management 

of server, server software and data associated with Class II gaming systems?

(a) Internal Control Procedures. Subject to the approval and oversight of the TGRA, each gaming 

operation shall establish, implement and adhere to internal control policies and procedures that 

provide at least the level of control established by the standards of this section.

(b) Computerized Applications. For any computer applications utilized, alternate documentation 

and/or procedures that provide at least the level of control established by the standards of this 

section, as approved in writing by the TGRA, will be acceptable.
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(c) Class II Gaming systems and Physical Controls. Controls must be established to ensure:

(1) Control of physical and logical access to server, server software and data associated 

with Class II gaming systems, including accounting, voucher, cashless and player 

tracking, among others used in conjunction with Class II gaming;

(2) Physical and logical protection of storage media and its contents, including recovery 

procedures;

(3) Access credential control methods; 

(4) Record keeping and audit processes; and,

(5) Departmental independence, including, but not limited to, means to restrict agents that 

have access to server, server software and data from having access to financial 

instruments.

(d) Independence. All personnel having access to Class II gaming servers, server software 

and/or data are independent of and restricted from access to:

(1) Financial instruments (e.g. cash, cash equivalents, vouchers, and coupons);

(2) Signatory authority over financial instruments and payouts forms; and

(3) Accounting, audit, and ledger entries.

§ 543.17 What are the minimum internal control standards for complimentary services or 

items?

(a) Internal Control Procedures. Subject to the approval and oversight of the TGRA, each gaming 

operation shall establish, implement and adhere to internal control policies and procedures that 

provide at least the level of control established by the standards of this section.

(b) Computerized Applications. For any computer applications utilized, alternate documentation 

and/or procedures that provide at least the level of control established by the standards of this 

section, as approved in writing by the TGRA, will be acceptable.

(c) Variances. The TGRA shall establish the threshold level at which a variance shall be 

reviewed. Any such review shall be documented. 

(d) Supervision. Supervision shall be provided for approval of complimentary services as 

needed by an agent(s) with authority equal to or greater than those being supervised.
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(de) Complimentary Services and or Items. Controls must be established in a manner designed to 

prevent unauthorized access, misappropriation, forgery, theft, or fraud. Such controls must 

include, but not be limited to, the following:

(1) How the gaming operation delegates to its personnel the authority to approve the 

issuance of complimentary services and or items, including levels of authorization for the 

agents approving the issuance of complimentary services and or items;

(2) Written limits and conditions on the approval and issuance of complimentary services 

or items, and how the conditions or limits of authority may be modified, ;

(3) Documentation and recordation requirements for the authorization, issuance, and 

tracking of complimentary services and or items, including cash and non-cash gifts; 

(i) Complimentary issuance records shall include the following for all 

complimentary items and services equal to or exceeding an amount established by 

the TGRA.

(A) Name of patron who received the complimentary service or item;

(B) Name(s) of issuer of the complimentary service or item;

(C) The actual cash value of the complimentary service or item;

(D) The type of complimentary service or item (i.e., food, beverage, etc.); 

and

(E) Date the complimentary service or item was issued.

(ii) Reserved.

§ 543.18 How does a gaming operation apply for a variance from the standards of this 

part?

(a) Variance.

(1) Should a TGRA grant a variance to any provision of these MICS, the TGRA shall 

deliver a notice of the same to the Commission within ten (10) days of such approval.

(i) The notice shall contain a complete copy of the information presented to the 

TGRA and the variance as granted.

(ii) The notice shall be forwarded to the Commission within ten (10) days of the 

granting of the Variance.
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(2) During a thirty (30) day period when the Commission first receives the notice 

required by this subpart, the Chairman may request additional information from the 

TGRA concerning the subject of variance. Such request shall suspend the thirty (30) day 

period until the Chairman receives the TGRA response.

(b) Commission Review.

(1) Within the thirty (30) day review period, the Commission may:

(i) Advise the TGRA, in writing, that it has no objection.

(ii) Provide the TGRA a written statement itemizing its objections. 

(iii) Take no action, in which case, the TGRA‟s variance shall be final. 

(2) If the Commission has provided the TGRA a statement itemizing objections to the 

variance: 

(i) The TGRA shall reconsider the variance taking into account the objections 

itemized by the Commission.

(ii) The TGRA may seek reconsideration by submitting a request to the Chairman 

and members of the Commission.

(iii) Upon receipt of a request for reconsideration, the Commission shall conduct 

an informal hearing with the TGRA within 30 days, which may be conducted in 

person or through the exchange of documents, as requested by the TGRA.

(iv) After the informal hearing, the Commission must issue a written decision 

within 14 days. If the Commission disapproves the variance, such written decision 

must include an explanation of why the requested variance creates an imminent 

threat to the integrity of the tribal gaming operation.

§ 543. 19 What are the minimum internal control standards for audit and accounting?

(a) Internal Control Procedures. Subject to the approval and oversight of the TGRA, each gaming 

operation shall establish, implement and adhere to internal control policies and procedures that 

provide at least the level of control established by the standards of this section.

(b) Computerized Applications. For any computer applications utilized, alternate documentation 

and/or procedures that provide at least the level of control established by the standards of this 

section, as approved in writing by the TGRA, will be acceptable.
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(c) Conflicts of Standards. When establishing SICS the gaming operation should review and 

consider incorporation of other external standards such as GAAP, SSAE, and standards 

promulgated by GASB and FASB. Accordingly, in the event of a conflictIf there are any 

inconsistencies between the MICS and the these regulations and external standards incorporated

external standards, by this provision, such as GASB, GAAP, FASB, and SSAE, such other 

applicablethe external standards shall prevail. 

(d) Operational Audits (formerly “Revenue Audit”). Controls shall be established to ensure:

(1) All audits are designed in a manner to detect unauthorized access, misappropriation, 

forgery, theft, or fraud.

(2) All audits are performed within seven (7) days of the audited activity‟s occurrence as 

follows, unless otherwise specified:

(i) Gaming revenue and payouts;

(ii) Increases and decreases to inventory;

(iii) Cash equivalent inventory count;

(iv) Exceptions, overrides, and voids;

(v) Complimentary services and items records (Weekly);

(vi) Manual increases and decreases to/from player accounts (Weekly);

(vii) Promotions, contests, and tournaments (Weekly); and

(viii) Key control records (Quarterly).

(3) Minimum bankroll calculations are audited periodically to ensure that the gaming 

operation maintains cash in an amount sufficient to satisfy the gaming operation‟s 

obligations. 

(4) At least bi-annually, an inventory of all drop, count, override, and panel keys are 

performed and increases and decreases in key inventory are reconciled.

(5) Audit results are summarized and recorded. 

(6) Audit Controls are developed to accountcontrolled inventories for recording the 

receipt, issuance, and use of controlled inventories (including but not limited to bingo 

cards, pull tabs, playing cards, keys, pre-numbered and/or multi-part forms, etc.).
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(7) Adjustments to original data are controlled to ensure all adjustments are properly 

completed and documented. 

(8) Exceptions are reviewed for suspect and/or unusual transactions.

(9) Documentation must be generated and maintained evidencing the performance of 

audit procedures. 

(10) If the audit is not performed by accounting agents, the agent(s) performing the audit 

are independent of the agents who performed the transactions being reviewed.

(e) Accounting. Controls must be established to ensure each gaming operation:

(1) Prepares accurate, complete, legible, and permanent records of all transactions 

pertaining to gaming revenue.

(2) Prepares general accounting records on a double-entry system of accounting, 

maintaining detailed, supporting, subsidiary records, and perform the following: 

(i) Record gaming activity transactions in an accounting system to identify and 

track all revenues, expenses, assets, and liabilities;

(ii) Produce income and balance sheet statements;

(iii) Produce appropriate subsidiary ledgers to support the balance sheet;

(iv) Inventory and safeguard assets;

(v) Prepare, review, and maintain accurate financial statements;

(vi) Prepare minimum bankroll calculations; and

(vii) Maintain and preserve all financial books, records, and relevant supporting 

documentation.

(f) Internal Audit. Controls shall be established to ensure:

(1) Internal auditor(s) perform audits of each department of a gaming operation, at least 

annually, to review compliance with TICS, SICS, and these MICS, TICS, and SICS.

(2) Internal auditor(s) are independent of the gaming operations with respect to the 

departments subject to audit (auditors internal to the operation, officers of the TGRA, or 

outside CPA firm may perform this function).
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(3) Internal auditors report directly to the Tribe, TGRA, audit committee, or other entity 

designated by the Tribe.

(4) Documentation (e.g., checklists, programs, reports, etc.) is prepared to evidence all 

internal audit work and follow-up performed as it relates to compliance with TICS, SICS, 

and these MICS, TICS, and SICS.

(5) Reports documenting audits performed are maintained and made available to the 

Commission upon request.

(6) All material exceptions resulting from internal audit work are investigated and 

resolved with the results documented.

(7) Internal audit findings are reported to management, responded to by management in 

the internal audit report stating corrective measures to be taken, and delivered to 

management, the Tribe, TGRA, audit committee, or other entity designated by the Tribe.

(g) Annual Audits.

(1) Agreed upon procedures. A CPA must be engaged to perform, in accordance with 

agreed upon procedures and the most recent versions of the Statements on Standards for 

Attestation Engagements and Agreed-Upon Procedures Engagements (collectively 

„„SSAE‟s‟‟), issued by the American Institute of Certified Public Accountants Inc., an 

assessment of whether the gaming operation is in compliance with these MICS, the TICS, 

and/or the SICS.

(2) The tribe must submit two copies of the agreed-upon procedures report to the 

Commission within 120 days of the gaming operation‟s fiscal year end in conjunction 

with the submission of the annual financial audit report required under 25 CFR Part 571.

(3) Require management to have sufficient knowledge and understanding of the purpose, 

nature, and scope of the agreed upon procedures to provide adequate oversight and 

participation in the process to ensure a meaningful and useful outcome.

(4) Reliance on Internal Audit. 

(i) Agreed upon procedures are to be performed by the CPA to determine that the 

internal audit procedures performed during the fiscal year have been properly 

completed. 

(ii) The CPA may rely on the work of internal audit for the completion of the 

MICS checklists as they relate to the standards covered by this Part.
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(5) Report Format. The Statements on Standards for Attestation Engagements and 

Agreed-Upon Procedure Engagements (SSAE‟s) are applicable to agreed agreed-upon 

procedures engagements required in this Part. All noted instances of noncompliance must 

be documented in the report with a narrative description, the number of exceptions and 

sample size tested.

§ 543.20 [RESERVED]

§ 543.21 What are the minimum internal control standards for drop and count?

(a) Internal Control Procedures. Subject to the approval and oversight of the TGRA, each gaming 

operation shall establish, implement and adhere to internal control policies and procedures that 

provide at least the level of control established by the standards of this section.

(b) Computerized Applications. For any computer applications utilized, alternate documentation 

and/or procedures that provide at least the level of control established by the standards of this 

section, as approved in writing by the TGRA, will be acceptable.

(c) Variances. The TGRA shall establish the threshold level at which a variance shall be 

reviewed. Any such review shall be documented. 

(d) Supervision. Supervision shall be provided for drop and count as needed by an agent(s) with 

authority equal to or greater than those being supervised.

(de) Count Room Access. Controls must be established to limit physical access to the count room 

to count team agents, designated staff, and other authorized persons. Such controls must include, 

but not be limited to, the following:

(1) Count team agents shall not be allowed to exit or enter the count room during the 

count except for emergencies or scheduled breaks.

(2) Surveillance shall be notified whenever count room agents exit or enter the count 

room during the count.

(3) The count team policy, at a minimum, shall address the transportation of extraneous 

items (e.g., personal belongings, tool boxes, beverage containers, etc.) into or out of the 

count room.

(ef) Count team. Controls must be established in a manner designed to ensure security of the 

count and the count room to prevent unauthorized access, misappropriation of funds, forgery, 

theft, and or fraud. Such controls must include, but not be limited to, the following:
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(1) For Tier A and B operations, all counts shall be performed by a minimum of two (2) 

agents. For Tier C operations, all counts shall be performed by a minimum of three (3) 

agents.

(2) For Tier A and B operations, at no time during the count shall there be fewer than two 

(2) count team agents in the count room until the drop proceeds have been accepted into 

cage/vault accountability. For Tier C operations, at no time during the count shall there 

be fewer than three (3) count team agents in the count room until the drop proceeds have 

been accepted into cage/vault accountability.

(3) For Tier A and B operations, count team agents shall be rotated on a routine basis 

such that the count team is not consistently the same two (2) agents more than four (4) 

days per week. This standard shall not apply to gaming operations that utilize a count 

team of more than two (2) agents. For Tier C operations, count team agents shall be 

rotated on a routine basis such that the count team is not consistently the same three (3) 

agents more than four (4) days per week. This standard shall not apply to gaming 

operations that utilize a count team of more than three (3) agents.

(4) Functions performed by count team agents shall be rotated on a routine basis.

(5) For Tier A and B operations, if the count is not viewed live, the operation must 

establish controls to ensure a review of the recording within seven (7) days by an agent 

independent of the count operation and the count being reviewed. For Tier C operations, 

the count shall be viewed live.

(65) Count team agents shall be independent of the department being counted and the 

cage/vault departments. An accounting agent may be used if there is an independent audit 

of all count documentation.

(fg) Drop. Controls must be established in a manner designed to ensure security of the drop 

process to prevent unauthorized access to gaming equipment and the drop, misappropriation of 

funds, forgery, theft, and or fraud. Such controls must include, but not be limited to, the 

following:

(1) Drop schedules and periods, including procedure to continue drop once started 

through completion.

(2) Security during transport of drop boxes, including escort by a minimum of two (2) 

agents, at least one of whom is independent of the revenue being dropped.

(3) All drop boxes shall be uniquely identified to correspond with the card table, player 

interface, and/or other location from which the drop box was removed.
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(4) Security over drop boxes removed and awaiting transport to the count room.

(5) Security of drop boxes until the count takes place.

(6) Notification to surveillance when a drop is to begin.

(7) Provisions for emergency drop. 

(gh) Count. Controls must be established in a manner designed to ensure security of the count 

process to prevent unauthorized access to count equipment and the drop, misappropriation of 

funds, improper manipulation of financial records, forgery, theft, and or fraud. Such controls 

must include, but not be limited to, the following:

(1) Establishment of a dedicated count room;

(2) Manual count process;

(3) Utilization, testing, and calibration of counters and/or validation systems; 

(4) Verification of count;

(5) Prevention of the comingling of funds until recorded per drop box; 

(6) Accurate and permanent forms of recordation for all cash and cash equivalents and 

rejected cash or cash equivalents;

(7) For card game counts, additional controls, as applicable, shall be established and 

procedures implemented to ensure:

(i) Fills/credits, Pit Marker marker Issueissue/Payment payment Slips slips are 

recorded and forwarded to the appropriate department for verification and 

reconciliation. 

(ii) Opening/closing card table inventory forms are examined and traced to or 

recorded on the appropriate documentation with discrepancies investigated and 

results documented.

(8) The reconciliation of count records to the total drop, which shall address, but not be 

limited to:

(i) Signature of each agent of the count team attesting to their participation in the 

count;

(ii) Reconciliation of the total drop by a count team agent who shall not function 

as the sole recorder; and 
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(iii) Documentation of all unresolved variances.

(9) Transfer of the drop following the count.

(10) All cash and cash equivalent inventory stored in the count room shall be secured 

from unauthorized access at all times.

(11) Access to stored drop boxes, full or empty.

(hi) Controlled keys or equivalents. Controls shall be established and procedures implemented to 

safeguard the use, access, and security of keys or other access methods in accordance with the 

following:

(1) Each of the following requires a separate and unique key lock or alternative secure 

access method:

(i) Drop cabinet;

(ii) Drop box release;

(iii) Drop box content; and

(iv) Storage racks and carts.

(2) Access to and return of keys or equivalents shall be manually or electronically 

documented with the date, time, and signature or other unique identifier of the agent 

accessing or returning the key(s).

(i) For Tier A and B operations, at least two (2) drop team agents are required to 

be present to access and return keys. For Tier C operations, at least three (3) drop 

team agents are required to be present to access and return keys. 

(ii) For Tier A and B operations, at least two (2) count team agents are required to 

be present at the time count room and other count keys are issued for the count. 

For Tier C operations, at least three (two for card game drop box keys in 

operations with three tables or fewer) count team agents are required to be present 

at the time count room and other count keys are issued for the count.

(iii3) Where an alternative access method is utilized, the use of such method shall be 

controlled in a manner consistent with the objectives of this standard.

(34) Documentation of all keys, including duplicates, shall be maintained including:

(i) Unique identifier for each individual key;
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(ii) Key storage location;

(iii) Number of keys made, duplicated, and destroyed; and

(iv) Authorization and access.

(45) Custody of all keys involved in the drop and count shall be maintained by a 

department independent of the count and drop agents and those departments being 

dropped and counted.

(56) Other than the count team, no agent shall have access to the drop box content keys 

while in possession of storage rack keys and/or release keys.

(67) Other than the count team, only agents authorized to remove drop boxes are allowed 

access to drop box release keys. 

(78) Utilization of keys at times other than the scheduled drop and count is must be

properly authorized and documented. 

(89) Emergency manual keys (a.k.ai.e., Override override Keykey) for computerized, 

electronic, and alternative key systems.

§ 543.22 [RESERVED]

§ 543.23 What are the minimum internal control standards for surveillance?

(a) Internal Control Procedures. Subject to the approval and oversight of the TGRA, each gaming 

operation shall establish, implement and adhere to internal control policies and procedures that 

provide at least the level of control established by the standards of this section.

(b) Computerized Applications. For any computer applications utilized, alternate documentation 

and/or procedures that provide at least the level of control established by the standards of this 

section, as approved in writing by the TGRA, will be acceptable.

(c) Surveillance Equipment and Control Room(s). Controls must be established in a manner 

designed to prevent unauthorized access and/or activities, cheating, misappropriation, forgery, 

theft, or fraud. Such controls must include, but not be limited to, the following:

(1) For Tier A, the surveillance system shall be maintained and operated from a secured 

location, such as a locked cabinet. For Tier B and C, the surveillance system shall be 

maintained and operated from a staffed surveillance operation room(s).

(2) The surveillance operation room(s) shall be secured to prevent unauthorized entry.
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(3) Access to the surveillance operation room(s) shall be limited to surveillance agents, 

designated staff, and other persons authorized.

(4) Surveillance operation room(s) access logs shall be maintained.

(5) Surveillance operation room equipment shall have total override capability over all 

other satellite surveillance equipment located outside the surveillance operation room.

(6) Power loss to the surveillance system.

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

alternative security measures, such as additional supervisory or security agents, 

shall be provided. 

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

auxiliary or backup power source shall be available and capable of providing 

immediate restoration of power to all elements of the surveillance system that 

enable surveillance agents to observe all areas covered by dedicated cameras.

(7) The surveillance system shall record an accurate date and time stamp on recorded 

events. The displayed date and time shall not significantly obstruct the recorded view.

(8) All surveillance agents shall be trained in the use of the equipment, and be 

knowledgeable of the games and house rules.

(9) Each camera required by the standards in this section shall be installed in a manner 

that will prevent it from being readily obstructed, tampered with, or disabled. 

(10) The surveillance system shall:

(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; and

(iv) For Tier B and C only, include sufficient numbers of monitors to 

simultaneously display gaming and count room activities.

(11) A periodic check of the surveillance systems shall be conducted. When a 

malfunction of the surveillance system is discovered, the malfunction and necessary 

repairs shall be documented and repairs initiated within seventy-two (72) hours.
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(i) If a dedicated camera malfunctions, immediate alternative security measures, 

such as additional supervisory or security agents, shall be provided. 

(ii) The TGRA shall 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 provided. 

(d) Additional Surveillance Requirements. With regard to the following functions, the additional 

specified requirements controls shall be implemented:

(1) Bingo.

(i) For manual draws, the surveillance system shall monitor the bingo ball 

drawing device or mechanical random number generator, which shall be recorded 

during the course of the draw by a dedicated camera to identify the balls numbers 

or other designations drawn or numbers selected.

(ii) The surveillance system shall monitor and record the activities of the bingo 

game, including drawing, calling, and entering, and the balls, numbers or other 

designations drawn or selected.

(2) Card games.

(i) Except for card game tournaments, a dedicated camera(s) shall 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) shall be used to provide an 

overview of tournament activities, including entrances/exits and any area where 

cash or cash equivalents are exchanged.

(3) Prize payoutsWinning Events. The TGRA shall establish standards for surveillance 

camera coverage of payouts prize winning events. Dedicated camera coverage is required 

when the progressive base value or prize amountin excess ofexceeds $3,000,000.00 for 

fixed prize payouts or progressive reset values. Such Recorded camera coverage shall 
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include the activities of patrons and agents at the time and location of the prize winning 

event.

(4) Cash and Cash Equivalents.

(i) The surveillance system shall monitor and record: 

(A) An view of the patron, cage agent, vault agent or count team agent(s) 

and the surrounding area and counting surface;

(B) Payouts of gaming winnings; 

(C) Entry and exit doors to and from the cage, vault and other secured 

count areas;

(D) All count equipment including but not limited to reject bins, weigh 

scales, wrapping machines, currency and coin counters, and chips sorters;

(E) Any area where the manipulation of recorded data may occur;

(F) Drop and count while in process; for Tier A and B operations, if the 

count is not viewed live, the operation must establish controls to ensure a 

review of the recording within seven (7) days by an agent independent of 

the count operation and the count being reviewed. For Tier C operations, 

the count shall be viewed live.

(G) All drop boxes and storage racks by either a dedicated camera or a 

motion-detector activated camera.

(ii) During the count process a dedicated overhead camera(s) or motion-detector 

activated camera(s) must cover the:

(A) Transaction area with the ability to identify cash and cash equivalent 

values;

(B) All counting surfaces used during the count; and 

(C) All drop boxes and their storage racks.

(e) Recording Retention. Controls must be established that include, but are not limited to, the 

following:

(1) All recordings required by this section shall be retained for a minimum of seven (7) 

days; and
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(2) Suspected or confirmed gaming crimes, unlawful or suspicious activity, or detentions 

by security personnel discovered within the initial retention period shall be copied and 

retained for a time period, not less than one (1) year.

(f) Logs. Logs must be maintained and demonstrate the following:

(1) Compliance with the storage, identification, and retention standards required in this 

section;

(2) Each malfunction and repair of the surveillance system as defined in this section; and

(3) Activities performed by surveillance agents.