COMANCHE NATION GAMING COMMISSION. Policy and Procedures

Transcription

1 COMANCHE NATION GAMING COMMISSION Policy and Procedures POLICY NUMBER RESOLUTION EFFECTIVE DATE SCOPE FORMS CNGC-F CNGC-F CNGC-F CNGC-F CNGC-F Role of the Compliance Department CNGC-P CNGC-R- Compliance Director Compliance Auditor Gaming Agent Supervisor Gaming Agent Monthly Compliance Department Report Monthly Compliance CBC Department Report Casino Monthly Submissions Checklist State Audit Checklist Facility License Audit Checklist Section Purpose A. Provide guidelines to the Comanche Nation Gaming Commission for the overall role of the Compliance Department. Section Overall Role of the Compliance Department A. The Comanche Nation Gaming Commission Compliance Department's main function is to monitor the various Comanche Nation Casinos management and operations to ensure compliance with all applicable Tribal, State, and Federal laws and regulations including but not limited to, the following: 1. Indian Gaming Regulatory Act of 1988 (IGRA); 2. National Indian Gaming Commission (NIGC) orders and final decisions; 3. Title 31 compliance under the Currency and Foreign Transactions Reporting Act of 1970 (commonly referred to as the Bank Secrecy Act ); 4. Oklahoma Horse Racing Act (Senate Bill 1252); 5. Comanche Nation and State of Oklahoma Tribal Gaming Compact (TGC); 6. Comanche Nation Tribal Gaming Ordinance (CNGO); 7. Comanche Nation Tribal Internal Control Standards (also known as the casinos Operations Manual); 8. Tribal Internal Control Standards (TICS); 9. Comanche Nation Gaming Commission (CNGC) Policies, Procedures, & Regulations; and 10. Applicable Environmental, Public Health & Safety Laws (EPHS). B. The Compliance Department's goals are to: 1. Protect the integrity of the gaming activities; 2. Ensure a fair game is offered; 3. Safeguard Comanche Nation s assets; 4. Uphold the reputation of the Tribe and the Gaming Operations for honesty and fairness; and 5. Instill patrons with the confidence that Comanche Nation Casinos meet the highest standards of regulation and internal controls. C. The department personnel monitoring the Compliance Department include, but not limited to the following: 1. Director of Compliance; 2. Gaming Agent Supervisors; 3. Gaming Agents; and 4. Compliance Auditor. D. The Compliance Department monitors gaming compliance through the following methods including but not limited to: CNGC-P Page 1 of 5

2 1. Ensuring all regulatory deadlines are met; 2. Perform follow-up audits to ensure external and internal audit findings are corrected; 3. Developing audit checklists; 4. Retaining documentation; 5. Gaming machine software testing/installation; 6. Financials; 7. EPHS Inspections; 8. State Compact Audit; 9. Auditing financial documentation; and 10. Employing Gaming Agents capable of on-site compliance investigating. E. The Compliance Department performs the following audits but not limited to: 1. Casino Monthly Submissions Checklist (Regulatory Deadline, see Section Regulatory Deadline Reports); 2. State Audit Checklist; 3. Facility License Audit Checklist; 4. Marketing & Promotions Audit Checklist; and 5. Gaming Machine Audit Checklist. F. The Director of Compliance is responsible for submitting a Monthly Compliance Department Report and a Monthly Compliance CBC Report to the Executive Director by the 2nd Friday of the following month, unless another deadline is assigned by the Executive Director. G. The Monthly Compliance Department Report shall include the following items: 1. CNGC Compliance Department Gaming Machine Summary; 2. Card/Poker Tables count by game at each casino and in total; 3. Compacted Machine Count by Vendor at each casino and in total; 4. Notice s Issued (NOC, PNOV, NOV); 5. Gaming Machine Activity; 6. Other Regulating Audit Activity; 7. Gaming Agent Activity; 8. Compliance Auditor Activity; 9. Compliance Projects; and 10. Training Reports. Section Regulatory Deadline Reports (Including but not limited to) A. Federal (NIGC) & Tribal (CNGC) 1. Accounting - Due by 15 th of each month, unless otherwise stated: Financial reports shall be performed and produced accordingly to set standards of Governmental Accounting Standards Board (GASB), Generally Accepted Accounting Principles (GAAP), and Financial Accounting Standards Board (FASB). The submitted reports shall include but not limited to the following: a. Balance Sheets Current and Prior month comparison format; b. Income Statements MTD & YTD; c. Statement of Cash Flows; d. Trial Balance; e. Minimum Bankroll; f. Check Registers (All Accounts); g. Credit Card Statements; h. Bank Statements (All Accounts); i. Bank Reconciliations (All Accounts); j. Reconciliation Reports of all accounts shall include but not limited to the following: i. Account Payables; ii. Account Receivables; iii. Accumulated Depreciation/Depreciation Schedule; iv. Cash In Banks; v. Cash On Hand; CNGC-P Page 2 of 5

3 vi. Capital Assets; vii. Construction In Progress including detailed list; viii. Due To/From including detailed reports; ix. Inventory; x. Liabilities (Long Term/Current): a. Accrued Liabilities, Accrued Payroll, & related accounts; and b. Accrued Gaming Liabilities; xi. Notes Payable/Long Term; xii. Prepaid Expenses; and xiii. Kiosk/ATM/Bill breaker; k. Adjusting Journal Entries; l. Daily Drop Report to include: i. By Vendor; ii. Cash; and iii. Vouchers; m. Vendor Flash Reports separating the below: i. Class II; and ii. Class III (Compact); n. Guest to Drop Count; o. Cashier Variance per incident: Due Date within 48 hours of + $100; p. Cashier Variance report to include: i. By Cashier; ii. By Day; and iii. Payroll deduction registers (current month pay periods & next month 1 st pay period); q. Annual Compact Financial audit: Due Date 30 days upon completion; r. State Payments (G3 & G4 Form): Due Date 15 th of the month (G3 Form) and 20 th of the month (G4 Form); s. NIGC Fees: Due Date Quarterly (12/31, 03/31, 06/30, 09/30); and t. NIGC Worksheet: Due Date Quarterly (12/31, 03/31, 06/30, 09/30); 2. Licensing: Due Date 5 th of following month, unless otherwise stated: a. Gaming Machine Vendor Revenue Share; b. Intent to Do Business (ITDB): Due Date Prior to conducting business with vendor; and c. Disciplinary Action specifically for suspensions of an employee (including reason): Due Date Within 2 days of action taken; 3. Slots: Due by 15 th of each month, unless otherwise stated: a. Gaming Machine Count to include: i. Beginning/ending Class II total; and ii. Beginning/ending Class III (Compact) total; b. Gaming Machine Master Inventory (Back of House Accounting System Slot Master): Due Date 15 th or within 72 hours of floor change; c. Floor Plan: Due Date 15 th or within 72 hours of floor change; d. Gaming Machine Meter report to include: i. Bill-in meter vs. Actual drop vs Slot accounting system (SAS) report & Variance Investigations (Casino Cash Track); ii. Monthly Random (10% of each vendor) gaming machine coin-in meter readings & reconciliation to SAS Meter reading report & variance investigations; and iii. Gaming Machine Meter Report Quarterly Random (10% of each vendor) verification of game software media: Due Date Quarterly; e. Gaming Machine Statistical (Actual to Theoretical variance & investigations); CNGC-P Page 3 of 5

4 i. MTD (Class II in proper groupings; Class III individually); ii. YTD (Class II in proper groupings; Class III individually); and iii. Unresolved variances; f. Gaming Machine Progressive Liability Report; g. Gaming Machine Drop Variance per incident: Due Date within 48 hours of + $500; h. Game Install/Change/Removal: Due Date 20 days Prior to Implementation for CNGC approval; and i. Jackpot Listing to include in Excel format: i. Machine Number; ii. Date; iii. Amount; and iv. Vendor; 4. Table Games: Due by 15 th of each month, unless otherwise stated: a. Table/Card Game Count (Number of tables on floor broken down by game type); b. Floor Plan: Due Date 15 th or within 72 hours of floor change; c. Game Install/Change/Removal: Due Date 20 days Prior to Implementation for CNGC approval; and d. Table Games Statistical Reports with investigations (MTD & YTD) to include: i. Table Games performance detail; ii. Blackjack statistical variation report; iii. Blackjack statistical; iv. Blackjack player pool spreadsheet; and v. Poker (bad beat) spreadsheet; 5. Information Technology: Due by 5 th of each month, unless otherwise stated: a. Server Room Access List; b. Door Access List (including employee listing of area permissions); c. User Access and Permissions; d. Electronic Key Variance Log (any variances occurring within the prior month with investigations documented); and e. SAS user access and permission; 6. Marketing: Due by 15 th of each month, unless otherwise stated: a. Complimentary Report to include: i. Comanche Credit Report; ii. Complimentary Report (all no dollar threshold); iii. Discretionary comp report; and iv. Comp slip logs; b. Promotions: Due Date 10 th of the previous month; and c. Tournaments: Due Date 10 th of the previous month; 7. Security: Due by 5 th of each month, unless otherwise stated: a. Ban and Eviction Listing: Due Date Weekly (Friday by 3pm); b. Security Report to include: i. Tribal notification; ii. Criminal activity; iii. Possible tort claims; iv. Possible prize claims; and v. Medical assistance; 8. Human Resources: a. Employee Listing: Due Date 10 th of the month and upon revision; b. Organizational Chart: Due Date 5 th of the month and upon revision; c. Job Descriptions: Due Date 10 th of the month and upon revision; d. Employee Hires: Due Date Immediately upon hire; CNGC-P Page 4 of 5

5 e. Transfers: Due Date 7 calendar days prior to the transfer (if they receive a new badge the old badge shall be returned to CNGC within 3 business days.); f. Terminations (shall include reason for termination on the PAF): Due Date 3 days after the termination; and g. Current employee listing & employee termination list: Due Date 5 th of the month; 9. CNGBOD or Gaming Operations: a. DOJ Gambling Device Registration: Due Date January 1; b. Contracts: Due Date Prior to Execution for CNGC approval; c. Annual Financial/Agreed Upon Procedures (AUP) Audit: Due Date 120 days from end of Fiscal Year; d. Prize Claim: Due Date 48 hours of Filing; e. Tort Claim: Due Date 48 hours of Filing; f. Insurance Policies: Due Date Approved Revision or upon change; and g. Emergency Action Plan: Due Date Approved Final/Revision or upon change. B. State (OMES): 1. Compact Gaming Machine Inventory: Due Date Quarterly (03/31, 6/30, 9/30, 12/31); 2. Annual Financial Audit: Due Date 30 days of Completion; 3. Prize Claim: Due Date 48 hours of Filing; 4. Tort Claim: Due Date 48 hours of Filing; 5. Insurance Policies: Due Date Approved Revision; 6. State Payment: Due Date 15th of the month (G3 Form) and 20th of the month (G4 Form); 7. State Annual Oversight Fee (G1 Form including documentation): Due Date June 30 th ; 8. Emergency Action Plan: Due Date Annually, January 1; and 9. Organizational Chart: Due Date Approved Final/Revision. CNGC-P Page 5 of 5