Regulation of the flow of money through an Arizona Casino First and foremost, the Tribal casino is self regulated through the establishment of a Tribal Gaming Office (TGO). The TGO functions to ensure the casino is following the provisions of the State Compact, the Tribal Minimum Internal Controls (MICS) and the NIGC Minimum Internal Controls (25 CFR 542). The Tribal MICS must be at least as stringent as the NIGC MICS. The cash in a Tribal casino is constantly under surveillance and is subject to multiple levels of checks. For example, the cash that is collected through the Drop and Count process is under surveillance throughout the entire process. During the count process, no fewer that two members of the count team are always present. After all members of the count team have signed off as to the amount of cash counted, the cage manager or shift supervisor will recount the cash and then only when the two counts agree, the cash is accepted into the cage accountability for that shift. All cash is counted at each shift change and must balance either to the impressed amount for the cage drawer or the change in cage for the vault must balance to the activity for the shift. TGO also periodically audits the cash and the cash process. At least quarterly, the internal audit department of TGO (the internal audit department is employed by the Tribe and not by the gaming operation) follows the cash process through the casino and compares actual procedures to the Tribe's MICS. TGO also may employ an independent external auditor to assist them with this function. Many Tribes use a combination of both internal audit departments and external auditors. Furthermore, the TGO also employs Gaming Inspectors to be onsite at the gaming operation during all hours the gaming operation is open. The Inspectors function is to observe cash transactions such as the drop and count and the subsequent transfer from the count to the vault. The Arizona Department of Gaming (ADOG), in accordance with the State Compact $7(g), conducts an annual "comprehensive Compact compliance review" of the gaming operation. As part of the annual review, ADOG also reviews cash procedures in the casino. Each Tribal casino operation is subject to an annual audit by a Certified Public Accountant which includes an evaluation of internal controls in all areas of the casino. This evaluation includes following all cash dropped at a given time (generally two to three times a year) through the entire process from the gaming machines through to the postings in the casino's books. Finally, the NIGC reserves the right to conduct their own compliance audits on the |