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Cage, Vault, Kiosk, Cash and Cash 

Equivalents

25 CFR 543.18 Toolkit

Version 1.0

Division of Public Affairs
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NIGC Cage, Vault, Kiosk, Cash, and Cash Equivalents–25 CFR 543.18 Toolkit

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

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

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

to 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 ways the NIGC does this 

is by providing training and technical assistance to Indian tribes and their gaming regulators.

The NIGC is pleased to present this Toolkit to all Compliance and Auditing staff. This reference guide is 

intended to assist Auditors, Gaming Commissioners, and Operations’ personnel in the performance of 

measuring compliance of their operation(s) with 25 CFR 543.18. The Toolkit is designed to provide each 

standard of 543.18, 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 Minimum Internal Control 

Standards (MICS) and does not take into account Operations’ Tribal Internal Control Standards (TICS) 

and/or System of Internal Control Standards (SICS), which may require further testing. The NIGC 

encourages Operations to develop standards that exceed the MICS because each Operation is unique, 

therefore a robust set of controls is warranted. 

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

traininginfo@nigc.gov. For more information, visit the NIGC website at http://www.nigc.gov.
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The Training Department has designed this Toolkit as a resource for understanding the Cage, Vault, Kiosk, Cash 

and Cash Equivalents 543.18 Minimum Internal Control Standards (MICS) and to use as a tool in conducting an 

audit of the revenue standards of all gaming departments in determining compliance with 543.18. This Toolkit 

table can help:

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

2) See the regulation for Cage, Vault, Kiosk, Cash and Cash Equivalent 543.18. (The regulation is listed in the 

first column of the table verbatim);

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

second column of the table); 

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

second column of the table under the intent information);

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

with current industry procedures); and

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

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

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

543.18. This Toolkit can be used by either the new or experienced auditor during various stages of the audit.
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GLOSSARY

Accountability

DEFINITION

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

bankroll custodian is responsible at a given time.

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

assigned tasks or actions on behalf of the gaming operation.

Automated 

payout

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

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

gaming operation bankroll.
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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.

Class II 

gaming

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

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

Class II 

gaming 

system

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

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

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

Check

A form (similar to a marker form) provided by the Gaming Operation that is completed as is necessary 

for the instrument to be presented to the patron’s bank for payment.

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.

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

money to or from a patron deposit account.

Manual 

payout

Any non-automated payout.
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MICS Minimum internal control standards in this part.

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

Also may be referred to as a “player".

Player 

interface

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

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

Class II game.

Prize payout Payment to a player associated with a winning or qualifying event.
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Sample A set of records, data, or elements drawn from a larger population and analyzed to estimate the 

characteristics of that population.

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

hours.

SICS (System 

of Internal 

Control 

Standards)

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

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

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

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

access, misappropriation, forgery, theft, or fraud.

Tier A Gaming operations with annual gross gaming revenues of more than $3 million but not more than $8 

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

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

equivalent value of cashable credits or cash through interaction with a voucher system.
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Citation Language Intent and Testing

§ 543.18(a)

543.18(a)

Supervision. Supervision must be 

provided as needed for cage, vault, 

kiosk, and other operations using cash 

or cash equivalents by an agent(s) with 

authority equal to or greater than those

being supervised. 

Intent: To provide for the proper supervision of cage, vault, kiosk, 

and other operations using cash or cash equivalents, which may 

include monitoring work, providing training, scheduling staff, and 

other supervisory functions.

Testing:

1. Review organizational chart, department schedules, 

and/or job descriptions for personnel who perform and 

supervise cage operations to determine the structure of 

supervision for revenue audit.

2. Observe supervision of the performance of cage 

operations to verify proper supervision is provided. 

3. Inquire with supervisory personnel to determine what 

types of tasks are performed as part of the supervision of 

the cage, such as monitoring staff, scheduling, providing 

training, etc. Further inquiries may be needed based on 

what is verified by reviews and observations from testing 

#1 and #2.
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§ 543.18(b)(1)(i-iv)

 

 543.18(b)(1)(i-iv)

Check cashing.

(1) If checks are cashed at the cage, the controls 

must provide for security and integrity. For each 

check cashing transaction, the agent(s) 

conducting the transaction must:

(i) Verify the patron’s identity;

(ii) Examine the check to ensure it includes the 

patron’s name, current address, and signature;

(iii) For personal checks, verify the patron’s 

check cashing authority and record the source 

and results in accordance with management 

policy; however

(iv) If a check guarantee service is used to 

guarantee the transaction and the procedures 

required by the check guarantee service are 

followed, then the above requirements do not 

apply.

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

security and integrity of the acceptance of checks by the Gaming 

Operation.

Testing: 

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

established to provide security and integrity for cashing of 

checks and determine whether the operation utilizes a 

check guarantee service.

2. If a third-party check guarantee service is used, inquire 

with cage personnel whether any checks are allowed to be 

cashed outside of (not utilizing) the guarantee service. 

Note: These standards apply for any checks cashed

outside of a guarantee service.

3. Observe check cashing procedures to verify the cashier: 

confirms the patron’s identity; examines the check to 

ensure it includes the patron’s name, current address, and 

signature; reviews the patron’s check cashing authority 

and documents results in accordance with policy, for 

personnel checks; and follows any other requirements 

established in the operation’s controls.

§ 543.18(b)(2)(i-v)

543.18(b)(2)(i-v) Check cashing. 

(2) When counter checks are issued, the 

following must be included on the check:

Intent: To provide for the protection of assets and require specific 

information be recorded on counter checks issued by the Gaming 

Operation so the instrument can be presented to the patron’s 

bank for payment.
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(i) The patron’s name and signature;

(ii) The dollar amount of the counter check;

(iii) Patron’s bank name, bank routing and 

account numbers;

(iv) Date of issuance; and

(v) Signature of the agent approving the counter 

check transaction.

Testing:

1. Inquire with cage personnel if the operation issues 

counter checks. If counter checks are not issued, these 

standards do not apply. Note: The issuance of counter 

checks has become very rare, particularly if the operation 

does not also offer marker credit.

2. Observe procedures for the issuance of counter checks 

and examine issued counter check(s) from cage cashier’s 

drawer to verify the counter check includes: the patron’s 

name and signature; the dollar amount; the patron’s bank 

name, routing number, and account number; date of 

issue; and signature for approval of the counter check 

issuance.

§ 543.18(b)(3-5)

543.18(b)(3) Check cashing. 

(3) Checks that are not deposited in the normal 

course of business, as established by 

management, (held checks) are subject to 

§543.15 lines of credit standards.

Intent: To provide for the protection of assets and require 

adherence to §543.15 if checks are not promptly deposited.

Testing: 

1. Review TICS and/or SICS to determine whether any cashed 

checks are held and not deposited in the normal course of 

business.

2. Inquire with cage and vault personnel to determine 

whether any cashed checks are held and not deposited in 

the normal course of business.

3. Review cage paperwork and/or general ledger for any 

indication of “held” checks. 
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4. If any checks are not deposited in the normal course of 

business, perform testing for §543.15 lines of credit 

standards.

543.18(b)(4) Check cashing. 

(4) When traveler’s checks or other guaranteed 

drafts, such as cashier’s checks, are presented, 

the cashier must comply with the examination 

and documentation procedures required by the 

issuer.

Intent: To provide for the protection of assets and require 

adherence to procedures from the issuer of traveler’s checks and 

guaranteed drafts.

Testing:

1. Review TICS and/or SICS and inquire with cage personnel 

to determine whether traveler’s checks and/or other 

guaranteed drafts (e.g., money orders, cashier’s checks, 

etc.) are cashed at the cage. 

2. For the instruments accepted, observe procedures for 

cashing these instruments to verify examination and 

documentation procedures, as required by the instrument 

or available issuer’s guidelines/procedures, are followed. If 

observation is not possible due to low frequency of 

transactions, inquire with cage personnel to confirm 

compliance with required procedures.

543.18(b)(5) Check cashing. 

(5) If a third party check cashing or guarantee 

service is used, the examination and 

documentation procedures required by the 

service provider apply, unless otherwise 

provided by tribal law or regulation.

Intent: To provide for the protection of assets and require

adherence to procedures from third-party check guarantee 

services.

Testing:

1. Review TICS and/or SICS and inquire with cage personnel 

to determine whether the operation uses a third-party 

check cashing guarantee service. Note: if the operation 
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does not utilize a third-party service, this standard does 

not apply.

2. Review contract, agreement, and/or procedures required 

by the third-party vendor for their guarantee of cashed 

checks. 

3. Observe check cashing procedures to verify the 

examination and documentation procedures required by 

the third-party provider are followed.

4. Inquire with cage and/or accounting personnel to 

determine whether any returned checks were not 

guaranteed by the provider due to failure to follow

required procedures Review supporting documentation 

for such instances if they occurred to determine 

procedures not followed. 

§ 543.18(c)

543.18(c)(1) Cage and vault accountability.

(1) All transactions that flow through the cage 

must be summarized for each work shift of the 

cage and must be supported by documentation.

Intent: To provide for the protection of assets and ensure 

accountability of cage transactions and inventory by shift.

Testing:

1. For the selected test period, examine cage count 

summaries (count sheets, accountability, inventory) and 

supporting documentation. Trace supporting 

documentation to count summaries to confirm cage 

inventory is properly supported for each shift.
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543.18(c)(2) Cage and vault accountability.

(2) Increases and decreases to the total cage 

inventory must be verified, supported by 

documentation, and recorded. Documentation 

must include the date and shift, the purpose of 

the increase/decrease, the agent(s) completing 

the transaction, and the person or department 

receiving the cage funds (for decreases only).

Intent: To provide for the protection of assets and ensure 

accountability of cage inventories.

Testing: 

1. For the selected test period, examine supporting 

documentation for increases and decreases to the cage 

inventory to verify documentation includes date and shift, 

purpose/reason, identification of the personnel 

completing the transaction(s), and the personnel receiving 

cage funds (for decreases).

543.18(c)(3) Cage and vault accountability.

(3) The cage and vault inventories (including coin 

rooms) must be counted independently by at 

least two agents, attested to by signature, and 

recorded in ink or other permanent form at the 

end of each shift during which the activity took 

place. These agents must make individual counts 

to compare for accuracy and maintain individual 

accountability. All variances must be 

documented and investigated.

Intent: To provide for the protection of assets and ensure 

accountability of cage and vault inventories.

Testing: 

1. Observe shift change inventory count(s) to confirm cage 

and vault inventories are counted independently by at 

least two persons and that each person performing the 

count(s) does not have prior knowledge of the amounts 

counted. Note: the standard requires at least two active 

independent counts, one person performing a count and 

another person only observing the count does not satisfy 

this standard.

2. Review documentation for counts to confirm 

documentation is signed by personnel performing the 

independent counts and counts are recorded in ink or 

other permanent form. 

3. If any variances between the independent counts occur, 

verify they the variance is resolved either through a 
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matching recount of funds or an investigation determining 

the cause of the discrepancy.

543.18(c)(4) Cage and vault accountability.

(4) The gaming operation must establish and 

comply with a minimum bankroll formula to 

ensure the gaming operation maintains cash or 

cash equivalents (on hand and in the bank, if 

readily accessible) in an amount sufficient to 

satisfy obligations to the gaming operation’s 

patrons as they are incurred.

Intent: To safeguard the integrity of the gaming operation by 

ensuring that it is able to meet its obligations to patrons.

Testing: 

1. Review TICS and/or SICS to determine the established 

minimum bankroll formula.

2. For the selected test period, review documentation for 

the calculation of the minimum bankroll formula and 

supporting documentation. Verify the calculation was 

performed properly by recalculating the formula and 

confirming the correct numbers were used for the 

calculation.

3. Verify that the gaming operation maintains cash or cash 

equivalents readily accessible in the amount determined 

by the minimum bankroll formula.

§ 543.18(d)

543.18(d)(1) Kiosks.

(1) Kiosks must be maintained on the cage 

accountability and must be counted 

independently by at least two agents, 

Intent: To provide for the protection of assets and ensure 

accountability of kiosks as part of the cage’s inventory.

Testing:

1. Observe count for kiosks to confirm kiosk funds are 

counted independently by at least two persons and that 
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documented, and reconciled for each increase or 

decrease to the kiosk inventory.

each person performing the count(s) does not have prior 

knowledge of the amounts counted. Note: the standard 

requires at least two active independent counts, one 

person performing a count and another person only 

observing the count does not satisfy this standard.

2. For the selected test period, examine kiosk reconciliation 

documentation (kiosk count documentation, cage 

inventory documentation, etc.) to verify increases and 

decreases of kiosk inventory is reconciled to the cage 

inventory and maintained on the cage’s accountability.

543.18(d)(2) Kiosks.

(2) Currency cassettes must be counted and 

filled by an agent and verified independently by 

at least one agent, all of who must sign each 

cassette.

Intent: To provide for the protection of assets and accountability 

for the count and filling of kiosk cassettes.

Testing:

1. Observe count and filling of kiosk cassettes to confirm 

funds are counted and independently verified by at least 

two separate personnel. 

2. Review documentation of count and independent 

verification to ensure each person signed for 

accountability of the count and verification for each 

cassette.

543.18(d)(3) Kiosks.

(3) Currency cassettes must be secured with a 

lock or tamper resistant seal and, if not placed 

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

currency cassettes for kiosks.

Testing:
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inside a kiosk, must be stored in a secured area 

of the cage/vault.

1. Observe cassettes for kiosks to ensure each cassette is 

secured by a lock or tamper resistant seal and stored 

cassettes are in a secured area of the cage/vault.

543.18(d)(4) Kiosks.

(4) The TGRA or the gaming operation, subject to 

approval of the TGRA, must develop and 

implement physical security controls over the 

kiosks. Controls should address the following: 

forced entry, evidence of any entry, and 

protection of circuit boards containing 

programs.

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

security of kiosks.

Testing:

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

established for the physical security of kiosks and the 

controls address forced entry, evidence of entry, and 

protection of program circuit boards.

2. Observe kiosks to confirm the established physical security 

controls are in place.

543.18(d)(5) Kiosks.

(5) With regard to cashless systems, the TGRA or 

the gaming operation, subject to the approval of 

the TGRA, must develop and implement 

procedures to ensure that communications 

between the kiosk and system are secure and 

functioning.

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

communication between kiosks and cashless systems.

Testing:

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

established to ensure communication between kiosk(s) 

and the cashless wagering system is secure and

functioning properly.

2. Inquire with cage personnel to determine whether the 

operation uses a cashless system for wagering (e.g., Patron 

Player Account). If the operation does not use a cashless 

system, this standard does not apply.
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3. Observe, inquire with operational personnel, and review 

supporting documentation as needed to confirm 

procedures are performed as required by the controls.

543.18(d)(6)(i-xii) Kiosks.

(6) The following reconciliation reports must be 

available upon demand for each day, shift, and 

drop cycle (this is not required if the system 

does not track the information, but system 

limitation(s) must be noted):

(i) Starting balance dollar amount per financial 

instrument;

(ii) Starting balance number of items per 

financial instrument;

(iii) Dollar amount per financial instrument 

issued;

(iv) Number of items per financial instrument 

issued;

(v) Dollar amount per financial instrument 

redeemed;

(vi) Number of items per financial instrument 

redeemed;

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

reports to perform kiosk count reconciliations.

Testing:

1. Review TICS and/or SICS and inquire with cage personnel 

to determine whether any system limitations are noted for 

the availability of any of the required information from the 

kiosk reconciliation reports. 

2. For the selected test period, examine kiosk reconciliation 

reports to confirm the required information is available 

upon demand for each day, shift, and drop period from 

the kiosk system. If any information is not tracked by the 

system, confirm the limitation is noted.
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(vii) Dollar amount per financial instrument 

increases;

(viii) Number of items per financial instrument 

increases;

(ix) Dollar amount per financial instrument 

decreases;

(x) Number of items per financial instrument 

decreases;

(xi) Ending balance dollar amount per financial 

instrument; and

(xii) Ending balance number of items per 

financial instrument.

§ 543.18(e)

543.18(e)(1) Patron deposited funds. If a gaming 

operation permits a patron to deposit 

funds with the gaming operation at the 

cage, and when transfers of patron 

deposited funds are transferred to a 

gaming area for wagering purposes, the 

following standards apply:

(1) The receipt or withdrawal of a patron deposit 

must be documented, with a copy given to the 

patron and a copy remaining in the cage.

Intent: To provide for the protection of assets and accountability 

of patron deposited funds.

Testing:

1. Perform observation of receipt and withdrawal of patron 

deposited funds to confirm a copy of the transaction 

documentation is provided to the patron and a copy 

remains in the cage. 

2. Review documentation for observed receipt and 

withdrawal transactions to confirm transaction activity 

was accurately documented.
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543.18(e)(2)(i-vi) Patron deposited funds. If a gaming operation 

permits a patron to deposit funds with the 

gaming operation at the cage, and when 

transfers of patron deposited funds are 

transferred to a gaming area for wagering 

purposes, the following standards apply:

(2) Both copies of the document of receipt or 

withdrawal must contain the following 

information:

(i) Same receipt number on each copy;

(ii) Patron’s name and signature;

(iii) Date of receipt and withdrawal;

(iv) Dollar amount of deposit/withdrawal (for 

foreign currency transactions include the US 

dollar equivalent, the name of the foreign 

country, and the amount of the foreign currency 

by denomination);

(v) Nature of deposit/withdrawal; and

(vi) Name and signature of the agent who 

conducted the transaction.

Intent: To provide for the protection of assets and accountability 

of patron deposited funds.

Testing:

1. Review documentation for observation completed in 

543.18(e)(1) of the receipt and withdrawal transactions to 

confirm both copies include the same receipt number, 

patron’s name and signature, date of transaction, dollar 

amount of transaction, nature of deposit/withdrawal, and 

name and signature of cage personnel performing the 

transaction. Note: for transactions in foreign currency, the 

documentation should include U.S dollar equivalent, name 

of the foreign country, and amount of foreign currency by 

denomination. It is recommended that the exchange rate 

at the date of the transaction also be documented.
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543.18(e)(3)(i-iii) Patron deposited funds. If a gaming operation 

permits a patron to deposit funds with the 

gaming operation at the cage, and when 

transfers of patron deposited funds are 

transferred to a gaming area for wagering 

purposes, the following standards apply:

(3) Procedures must be established and 

complied with for front money deposits to:

(i) Maintain a detailed record by patron name 

and date of all funds on deposit;

(ii) Maintain a current balance of all patron 

deposits that are in the cage/vault inventory or 

accountability; and

(iii) Reconcile the current balance with the 

deposits and withdrawals at least daily.

Intent: To provide for the protection of assets and accountability 

of patron deposited funds.

Testing:

1. Review TICS and/or SICS to determine what procedures 

are established for front money deposits.

2. Review current documentation for front money deposits;

confirm records by patron name and date including the 

current balance of all patron deposits in the cage/vault 

accountability are maintained. In addition, confirm that a 

reconciliation of the current balance of all patron deposits 

in the cage/vault accountability with the deposit and 

withdrawal transactions is performed at least daily.

§ 543.18(f)

543.18(f)(1),(2)(i-v) Promotional payments, drawings, and giveaway 

programs. The following procedures must apply 

to any payment resulting from a promotional 

payment, drawing, or giveaway program 

disbursed by the cage department or any other 

department. This section does not apply to 

payouts for card game promotional pots and/or 

pools.

Intent: To provide for the protection of assets and help ensure the 

integrity of promotional activity.

Testing:

1. For the selected test period, review payout 

documentation (related to promotional payments, 

drawings, and giveaway programs) and cage 

accountability documentation to confirm promotional 

payments are supported by documentation.
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(1) All payments must be documented to 

support the cage accountability.

(2) Payments above $600 (or lesser amount as 

approved by TGRA) must be documented at the 

time of the payment, and documentation must 

include the following:

(i) Date and time;

(ii) Dollar amount of payment or description of 

personal property;

(iii) Reason for payment; and

(iv) Patron’s name and confirmation that identity 

was verified (drawings only).

(v) Signature(s) of at least two agents verifying, 

authorizing, and completing the promotional 

payment with the patron. For computerized 

systems that validate and print the dollar 

amount of the payment on a computer 

generated form, only one signature is required.

2. For payments above $600 (or a lesser approved 

threshold), review payout documentation to confirm that 

it contains: the date and time; dollar amount or 

description of property; reason for payment; patron’s 

name and ID confirmation (for drawings only); and 

signature of at least two personnel verifying, authorizing, 

and completing the payment are documented. Note: Only 

one signature is required if a computerized system is 

utilized to validate and print the amount of the 

promotional payment.

§ 543.18(g)

543.18(g)(1-5) Chip(s) and tokens. Controls must be established 

and procedures implemented to ensure 

accountability of chip and token inventory. Such 

Intent: To provide for the protection of assets and accountability 

of chips and tokens.

Testing:
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controls must include, but are not limited to, the 

following:

(1) Purchase;

(2) Receipt;

(3) Inventory;

(4) Storage; and

(5) Destruction.

1. Review TICS and/or SICS to determine what controls and 

procedures are established for accountability of chips and 

tokens, including purchases, receipt, inventory, storage, 

and destruction.

2. For the selected test period, review supporting 

documentation for chip and token purchases, receipts, 

inventories, storage, and destructions, and cage/vault 

accountability documentation to confirm chips and tokens 

are properly accounted for in accordance with established 

controls and procedures.

§ 543.24 18(h)

543.18(h)(1)(i-v) 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.

Intent: To prevent potential misappropriation of assets by 

establishing and implementing procedures for the redemption of 

vouchers which include verifying the voucher 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. 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.

2. Interview appropriate personnel to verify actual 

procedure (Cage management, Cage cashier)
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(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.

3. Review sample of vouchers redeemed and manual 

vouchers redeemed including those in the cashier’s 

drawer to verify the payment is documented Review 

sample of reports from validation system to confirm 

supervisory verification. (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.) either live or 

through surveillance coverage.

543.18(h)(2) Vouchers. 

(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. Review TICS and or SICS to determine the procedure for 

paying vouchers when the voucher system is down. 

2. If no sample can be located, interview appropriate 

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

Cashier) 

3. Review sample of vouchers paid while the system is down. 

(Look at sample as defined in the Glossary)
27

543.18(h)(3) Vouchers. 

(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. Review TICS and/or SICS to determine the procedure for 

paying vouchers when the voucher system is down.

2. Interview appropriate personnel if no sample can be 

located to verify procedure (e.g. Cage Cashier, Floor 

Cashier) 

3. Review sample of vouchers paid while the 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.

543.18(h)(4) Vouchers. 

(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.

3. Review cashier’s reconciliation report from the voucher 

redemption system. 
28

543.18(h)(5) Vouchers. 

(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 a sample of voided vouchers and the report that 

identifies the person who voided the voucher to 

determine that it was completed by supervisory 

employees. 

2. Review permission listing from the voucher redemption 

system to verify only supervisory employees can void 

unredeemed vouchers. 

§ 543.18(i)

543.18(i)(1) Cage and vault access. Controls must be 

established and procedures implemented to:

(1) Restrict physical access to the cage to cage 

agents, designated staff, and other authorized 

persons; and

Intent: To provide for the protection of assets and restrict access 

to cash handling and storage areas.

Testing: 

1. Review TICS and/or SICS to determine what controls and 

procedures are established for restricting access to the 

cage and vault. 

2. Review current access listing to determine access to the 

cage and vault area is adequately restricted. Inquire

and/or observe with cage and vault management how 
29

access is restricted (door buzzer, key card, and/or physical 

key(s)) and confirm access to key cards and/or keys 

granting access to cage and vault areas is adequately 

controlled.

543.18(i)(2) Cage and vault access. Controls must be 

established and procedures implemented to:

(2) Limit transportation of extraneous items 

such as personal belongings, tool boxes, 

beverage containers, etc., into and out of the 

cage.

Intent: To provide for the protection of assets and limit 

extraneous items from being in cage and vault areas.

Testing: 

1. Review TICS and/or SICS to determine what controls and 

procedures are established for limiting extraneous items in 

the cage and vault. 

2. Observe cage and vault areas to confirm extraneous items 

are limited in the cage and vault areas in accordance with 

established controls.

§ 543.18(j)

543.18(j) Variances. The operation must establish, as 

approved by the TGRA, the threshold level at 

which a variance must be reviewed to 

determine the cause. Any such review must be 

documented.

Intent: To provide for the protection of assets and establish 

review and investigation processes for identified variances in cage 

and vault accountabilities and transactions.

Testing: 

1. Review TICS and/or SICS to determine what controls and 

procedures are established for the threshold level at which 
30

variances are reviewed. Note: It is recommended that the 

controls also identify the type(s) of variances reviewed. 

2. For the selected test period, inquire with cage and/or 

accounting personnel to determine whether any variances 

for the established threshold had occurred.

3. Review system reports (if available) and cage and vault 

count accountability documents to determine whether

any variances for the established threshold had occurred. 

For variances identified, review documentation for 

variance review(s) to determine whether the cause was 

identified and the reviews were adequately documented.
31

25 CFR 543.18 Toolkit

Version 1.0

NIGC Division of Public Affairs

National Indian Gaming Commission Training Manager 

Training Program

Training Manager