PRAIRIE BAND POTAWATOMI GAMING COMMISSION · PRAIRIE BAND POTAWATOMI GAMING ... means a report prepared that compares theoretical to actual hold by a gaming machine on a monthly

PRAIRIE BAND POTAWATOMI GAMING COMMISSION

MINIMUM INTERNAL CONTROL STANDARDS (TC3MICS)

Property of the Prairie Band Potawatomi Nation i October 11, 2006

PROPERTY OF THE PRAIRIE BAND POTAWATOMI NATION

October 11, 2006



Property of the Prairie Band Potawatomi Nation ii October 11, 2006

TABLE OF CONTENTS

Definitions ...................................................................................................................................................................iii

Foreword ...................................................................................................................................................................... 1

Frontispiece .................................................................................................................................................................. 2

Section A – GENERAL PROVISIONS ..................................................................................................................... 3

Section B – GAMING MACHINE STANDARDS .................................................................................................. 14

Section C – TABLE GAME AND CARD GAME STANDARDS ......................................................................... 25

Section D – DROP AND COUNT STANDARDS ................................................................................................... 40

Section E – CASINO CAGE ..................................................................................................................................... 51

Section F – ACCOUNTING ...................................................................................................................................... 58

Section G – INCOME CONTROL ........................................................................................................................... 62

Section H – SURVEILLANCE DEPARTMENT .................................................................................................... 66

Section I – SECURITY DEPARTMENT ................................................................................................................ 72

Section J – FEDERAL TAX REQUIREMENTS/STATE TAX REQUIREMENTS ........................................... 74

Section K – INFORMATION TECHNOLOGY ..................................................................................................... 78

Section L – COMPLIMENTARY SERVICES AND ITEMS ................................................................................ 82

Section M – INTERNAL AUDIT STANDARDS .................................................................................................... 86

Section N – EXTERNAL AUDIT STANDARDS .................................................................................................... 90

Section O – KEY CONTROL STANDARDS .......................................................................................................... 95

TECHNICAL STANDARDS ................................................................................................................................ 103

Technical Standards Attachment A ....................................................................................................................... 111

Technical Standards Attachment B ....................................................................................................................... 113



Property of the Prairie Band Potawatomi Nation iii October 11, 2006

DEFINITIONS

Except to the extent that the definitions contained therein conflict with any definition or regulation contained

with these minimum internal controls related to Electronic Gaming Devices (EGDs, Gaming Machines) and

Kiosks, the definitions contained in the Technical Standards (Technical Standards) are incorporated as though

fully set forth herein for EGDs and Kiosks. Incorporation of the Technical Standards for EGDs and kiosks in

no way diminishes or restricts the authority of the Gaming Commission to regulate all other gaming activities

and operations or promulgate, edit or otherwise amend rules regulating gaming activities or operations,

including these minimum internal controls.

1. Account access card: means an instrument used to access customer accounts for wagering at a gaming

machine. Account access cards are used in connection with a computerized account database. Account

access cards are NOT “smart cards”. (NIGC§542.2) NOTE: Account access cards are used at player

terminals and not a part of Class III machine definition. [Definition added per 2006 update.] (Technical

Standards)

2. Accountability: means all items of currency, chips, coins, plaques, tokens, receivables, and customer

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

(NIGC§542.2)

3. Accumulated credit payout: means credit earned in a gaming machine that is paid to a customer manually

in lieu of a machine payout. (NIGC§542.2)

4. Actual hold: means coins-in less coins-out, less manual payouts and less hopper fills.

5. Actual hold percentage: means the percentage calculated by dividing the win by the drop in table games or

coin-in for gaming machines (number of credits wagered). Can be calculated for individual tables or

gaming machines, type of table games or gaming machines on a per day or cumulative basis.

(NIGC§542.2)

6. Adjustment form: means a document used to describe and identify any change to player's cage account

balance not generated directly by player gaming activity.

7. Analysis report: means a report prepared that compares theoretical to actual hold by a gaming machine on a

monthly or other periodic basis.

8. Ante: means a player’s initial wager or predetermined contribution into the pot before the dealing of the

first hand. (NIGC§542.2)

9. Applicable law: means the Tribal Constitution, this Potawatomi Revised Law and Order Code, Title 12 as

amended and approved by the General Council on July 20, 1991, including all subsequent Title

amendments as enacted by Tribal Council, any applicable federal law, any applicable state law, Tribal

Gaming Regulations and the Compact.

10. Approved: a process of acceptance of any component of the system that would have an effect on the

integrity of any game and/or the system. (Technical Standards)

11. Authorized: used in conjunction with other terms to attest someone has approval from the Tribal Gaming

Commission for specified duties listed on a master authority sheet maintained by the Tribal Gaming

Commission or that some action has such approval. Changes to the master authority sheet must receive

written Commission documentation.

12. Bank (Bankroll): the inventory of currency, coins, chips, checks, tokens, receivables, and customer deposits

in the cage, pit area, gaming booths, and on the playing tables and cash in bank, which is used to make

change, pay winnings, bets, and pay gaming machine jackpots. (Foreign Currency, Foreign Coins, Foreign

Chips and Foreign Tokens may be included as needed)

13. Base jackpot: means the fixed, minimum amount of a progressive gaming or electronic gaming device

payout for a specific combination.

14. Bill validator (also known as a bill acceptor or bill changer, BVA): means the device that accepts and reads

currency by denomination and accepts inserted valid tickets in order to accurately register customer credits

at a gaming machine. (NIGC§542.2)(Technical Standards)

15. Bill validator content key: means the key that accesses the bill validator contents to review a customer

dispute involving currency, bill validator malfunctions or jams. Also, used by soft count employees to

access bill validator contents during the soft count.

16. Bill validator drop box (BV drop box) (See also bill acceptor): means a locked container securely attached

to the electronic gaming device for the purpose of collecting currency accepted by the bill validator. The

machine number is clearly visible on the box.



Property of the Prairie Band Potawatomi Nation iv October 11, 2006

17. Bill validator drop box release key: means the key used to release bill validator drop box from bill validator

device.

18. Bill validator drop box storage rack key: means the key used to access the storage rack where bill validator

drop boxes are secured.

19. Bill validator drop (BV drop): means cash and tickets contained in bill validator drop boxes.

20. Bill-in meter: means a meter included on a gaming machine accepting cash that tracks the number of bills

put in the machine. (NIGC§542.2)

21. Blackjack: means the card game played by a maximum of seven players and one dealer wherein each

player plays his hand against the dealer's hand with the object of obtaining a higher total card count than the

dealer by reaching 21 or as near 21 as possible without exceeding 21. (See also Compact Appendix B)

22. Boxperson: means the first-level supervisor assigned to an individual craps table who is responsible for

directly participating in and supervising the operation and conduct of a craps game.

23. Buy in: means the amount of money a player shall present for coin and chips in a poker game. Usually put

in a separate drop box by the dealer. May also refer to chips bought from the "house" or operator by the

player upon entering any other card game or promotional tournament.

24. Cage: means a secure work area within the gaming operation for cashiers and a storage area for the gaming

operation bankroll. (NIGC§542.2)

25. Cage accountability form: means an itemized list of the components that make up the cage accountability.

(NIGC§542.2)

26. Cage cashier: means the person in charge of the central banking function or the cashiers performing any of

the functions of the Cashier's Cage.

27. Calibration module: means the section of a weigh scale used to set the scale to a specific amount or number

of coins to be counted. (NIGC§542.2)

28. Card game: means a game in which the gaming operation is not party to wagers and from which the gaming

operation receives compensation in the form of a rake, a time buy-in, or other fee or payment from a player

for the privilege of playing. (NIGC§542.2)

29. Card room bank: means the operating fund assigned to the card room or main card room bank.

(NIGC§542.2)

30. Cash: legal tender issued by the United States Treasury in various denominations made of paper and metal.

31. Cash equivalent: means a treasury check, personal check, traveler’s check, wire transfer of funds, money

order, certified check, cashier’s check, a check drawn on the tribal gaming operation payable to the patron

or to the tribal gaming operation, or a voucher recording cash drawn against a credit card or charge card.

(Compact Appendix A, § 1(c)) Items included with cash to aggregate the Bank Total. (Excludes Foreign

Currency, Foreign Coins, Foreign Chips and Foreign Tokens)

32. Cash count sheet: means the form used to record the contents of the bankroll as they are counted.

33. Cash loads: means the initial currency, coins, chips, and tokens issued from a bankroll to a gaming table or

put into an electronic gaming device.

34. Cash out: the process by which a patron elects to and does receive coin, tokens, tickets or a combination

thereof in payment for game credits remaining on an electronic gaming device (EGD) and the simultaneous

reduction of credits shown on the EGD to zero. (Technical Standards)

35. Cash-out ticket (see ticket)(NIGC§542.2), (Technical Standards)

36. Cashier's count sheet (check out sheet): an itemized list of the components that make up the cage

accountability.

37. Cashier's count sheet reconciliation: means a detailed reconciliation of the beginning to the ending cage

accountability.

38. Casino: means operation in which several gaming activities or enterprises are operated.

39. Change bin: means a booth or small cage in the gaming area that is used to provide change to customers,

store change banks, make electronic gaming device fills, account for jackpot payouts, and make gaming

receipt payouts, store change aprons, extra coin, and/or account for jackpot and other payouts.

40. Change person: means a person who has an imprest fund of coins, tokens and currency for making change

for customers.

41. Chairman: means the Chairman of the National Gaming Indian Commission.

42. Cheating: means a person operating or playing in any game in a manner in violation of the written or

commonly understood rules of the game with the intent to create for himself, or someone in private with

him, an advantage over and above the chance of the game.



Property of the Prairie Band Potawatomi Nation v October 11, 2006

43. Chips: mean cash substitutes, in various denominations, issued by a gaming operation for use in wagering.

(NIGC§542.2)

44. Chip or gaming chip: means a non-metal or partly metal disc or plaque representative of value or money

substitutes in various denominations issued by the gaming operation and used for wagering.

45. Chip tray: means a device to hold and store coin and chips on a gaming table. Facilitates inventory counts.

Usually designed with clear locking covers to secure the table bank when the game is "closed" or not open

for play.

46. Chip and token float: means the monetary value of chips, tokens and tickets held by customers.

47. Class III gaming: means Class III gaming as defined in Indian Gaming Regulatory Act (IGRA) and as

provided for in the Compact that are not Class I or Class II gaming as defined in the IGRA. (IGRA)

48. Closer: means the original of the table inventory slip upon which each table inventory is recorded at the end

of each shift.

49. Coin: means those coins minted by the Treasury of the United States of America.

50. Coin-in: means the total amount wagered, which includes physical coins-in and credits played.

(NIGC§542.2)

51. Coin-in meter: means the meter that displays the total amount wagered in a gaming machine that includes

coins-in and credits played. (NIGC§542.2)

52. Coin meter count machine: means a device used in a coin room to count coin. (NIGC§542.2)

53. Coin room: means an area where coins and tokens are stored. (NIGC§542.2)

54. Coin room inventory: means coins and tokens in the coin room that are generally used for gaming machine

department operation. (NIGC§542.2)

55. Commission: means the Tribal Gaming Commission or Tribal Gaming Authority.

56. Communication connection: means a physical hardware connection and does not include wireless or

infrared communication equipment. (Technical Standards)

57. Compact: means the Prairie Band Potawatomi Nation - State of Kansas Gaming Compact governing

management and operation of Class III gaming facilities adopted pursuant to the Indian Gaming Regulatory

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

58. Compensation: means any wages, salaries, bonuses, and all other forms of remuneration for services

rendered.

59. Complimentary or comp: means a service or item provided at no cost, or at a reduced cost, to a customer.

(NIGC§542.2)

60. Computerized ticket validation system: a hardware and software system, physically located within the

gaming facility, that maintains a ticket database for validation when tickets are presented for payment or for

game credits. Each component of the computerized ticket validation system shall function as indicated by

the communication protocol implemented. (Technical Standards)

61. Contractor: means any individual, sole proprietorship, partnership, or corporation which manages any Class

III gaming activity or operation on behalf of the Tribe pursuant to a management contract approved by the

Chairman of the National Indian Gaming Commission.

62. Controlled forms storage area: an area secured by a lock whose access is limited to accounting/auditing

personnel or a Security Representative during those times when accounting/auditing personnel are

unavailable.

63. Counter game: means a game in which the gaming operation is party to wagers and wherein the gaming

operation documents all wagering activity. The term includes, but is not limited to, bingo, keno, and pari-

mutuel race books. The term DOES NOT INCLUDE table games, card games and gaming machines.

(NIGC§542.2)

64. Coupon: a paper message purporting to entitle the holder to cash, something of value or game credits. The

paper message may be from any source and may be printed by a ticket printer. (Technical Standards)

65. Count: means the total funds counted for a particular game, gaming machine, shift, or other period.

66. Count room: means a room where the coin and cash drop from gaming machines, table games or other

games are transported to and counted.

67. Count sheet: means a form used to record the count of currency, coins, chips, etc. from the drop box for a

game. Also a form used to count the currency, coin and chips in the game trays. Occasionally referred to as

the Master Game Report.

68. Count team: means personnel that perform either the count of the gaming machine drop and/or the table

game drop.

69. Craps: means a game using two six-sided dice.



Property of the Prairie Band Potawatomi Nation vi October 11, 2006

70. Craps boxperson (See also boxperson): means the person in charge of a craps table operation.

71. Craps stickperson: means the person working the craps table that controls the dice, calls the numbers

thrown, and is responsible for the speed of the game.

72. Credit slip: means the document reflecting the authorization for preparation of a credit with respect to

removal of gaming chips and coins from a gaming table. A casino form initiated to record the amount of

money or chips removed from a gaming table or the transfer of a negotiable check from a gaming table to a

casino cage, bankroll, or pit bank. (NIGC§542.2)

73. Currency: means paper bills printed by the Treasury of the United States of America.

74. Currency Transaction Report for Casinos (CTRC): means the form used for reporting under USC Title 31

requirements.

75. Customer (See also Patron): means a consumer or purchaser of goods or services at the gaming facility

other than participating in a gaming activity. (See Player for gaming activity)

76. Customer deposits: means the amounts placed with a cage cashier by customers for the customers' use at a

future time. Listed as (payable) in the bank. (NIGC§542.2)

77. Dealer: means an employee who operates a game, individually or as a part of a crew, administering house

rules and making payoffs. (NIGC§542.2)

78. Dedicated camera: means a video camera required to continuously record a specific activity.

79. Dependent: means any individual who receives over half of their support in a calendar year from any other

person.

80. Dispenser machine (WHIZ Machine): means a device that allows two parts of a three-part form to be rolled

forward with the top two document copies being removable with the third copy retained in the device’s

container in continuous form.

81. Distributor: means a person or business entity who obtains an electronic gaming device from a

manufacturer and who intends to furnish it to the Tribe. (Technical Standards)

82. Discard tray: means a tray, box, or specific area where cards used in a game are held awaiting the next

shuffle. Used primarily in baccarat and twenty-one, for example.

83. Drop (for gaming machines): means the total amount of cash, cash-out tickets, coupons, coins, and tokens

removed from drop buckets and/or bill validator drop boxes. (NIGC§542.2)

84. Drop (for table games): means the total amount of cash, cash-out tickets, coupons, coins, and tokens

removed from drop boxes, plus the amount of credit issued and transferred to the tables. (NIGC§542.2)

85. Drop box (tables games): means a locked container affixed to the gaming table into which the drop/rake is

placed and for deposit of cash, coin, and gaming chips and certain documents received at a gaming table.

The game type, table number, and shift are indicated on the box. (NIGC§542.2)

86. Drop box content keys: means the key used to open drop boxes. (NIGC§542.2)

87. Drop box release keys: means the key used to release drop boxes from tables. (NIGC§542.2)

88. Drop box storage rack keys: means the key used to release drop boxes from the storage rack. (NIGC§542.2)

89. Drop bucket: means a container located in the drop cabinet (or in a secured portion of the gaming machine)

for the purpose of collecting coins and tokens from the gaming machine. (NIGC§542.2)

90. Drop cabinet: means the wooden or metal base of the gaming machine that contains the gaming machine

drop bucket. (NIGC§542.2)

91. Drop count card: means a document prepared by the count team to record the amount of cash, chips, tickets

or tokens by denomination in a drop box or in an electronic gaming device.

92. Drop period: means the period of time that occurs between sequential drops.

93. Electronic Gaming Device (EGD): means gaming equipment, which is electric, electronic or mechanical, or

a combination thereof, which plays a game, which involves an element of prize, chance and consideration,

and which is linked to a central computer for purposes of security, monitoring, and auditing. The EGD

shall function as indicated by the communication protocol that is implemented. (Technical Standards)

94. Employee: means any executive, employee, independent contractor or agent of the Tribe or management

contractor that works for or at a gaming operation.

95. EPROM: means erasable programmable read-only memory or other equivalent game software media.

(NIGC§542.2)

96. Even money transfers: means the act of exchanging currency and chips for coin or other chips of equivalent

value.

97. Fill: means a transaction whereby a supply of chips, coins and tokens is transferred from a bankroll to a

table or gaming machine. (NIGC§542.2)



Property of the Prairie Band Potawatomi Nation vii October 11, 2006

98. Fill slip: means a document evidencing a transfer of chips, tokens, or cash from the casino cage to the

gaming table or a gaming machine. (NIGC§542.2)

99. Final fill/credit: transfer of chips, tokens, or cash to or from a gaming table at a shift-end to restore the table

to its impress amount. (Table Load)

100. Fiscal year: means the annual period used by a tribal gaming operation for internal accounting of its gaming

operations.

101. Fixed camera(Stationary Camera): a camera fixed into a set view position. Such camera view can only be

moved manually from its set position. The camera lens can zoom in or out from this set view position, but

the camera itself cannot otherwise move.

102. Floor pars: mean the sum of the theoretical hold percentages of all machines within a gaming machine

denomination weighted by the coin-in contribution.

103. Foreign chips and tokens: are chips and tokens of another casino that are found or redeemed. Following

prescribed procedures approved by the tribal regulatory authority, the operation can redeem these with

other operations for cash, tribal chips and/or tribal tokens for same amount. (Such items are included in the

Bank until such time as they are redeemed.)

104. Foreign currency and coins: currency and coins other than those issued by the United States Treasury

which are found or redeemed for cash or house chips or tokens. (Such items are included in the Bank)

105. Game, gaming activity: means any activity or operation in which any valuable consideration may be

wagered upon the outcome determined by chance, skill and in which any valuable prize is awarded to the

player so wagering and any activity in furtherance thereof, including owning, financing, managing,

participating in, conducting or assisting in any way in any such activity, which it is being conducted,

directly or indirectly, whether at the site in person or off tribal land. (Compact § 5(F))

106. Game credit: means the smallest unit of value that may be used to play a game on an EGD or that may be

cashed out in US coin, ticket, or approved tokens. (Technical Standards)

107. Game server: means an electronic selection device, utilizing a random number generator. (NIGC§542.2)

108. Gaming day: means the 24-hour period adopted for daily accounting of gross gaming revenues.

109. Gaming employee: means any natural person 18 years or older employed in the operation or management

of each gaming activity or operation, whether employed by or contracted to the Tribe by any person or

enterprise providing on or offsite services to the Tribe within or without the gaming facility regarding any

gaming activity or operation, including, but not limited to, gaming operation managers and assistant

managers; accounting personnel; surveillance personnel; cashier supervisors; dealers or croupiers, box

men; floor men; pit bosses; shift bosses; cage personnel; collection personnel; gaming consultants,

management companies and their principals; and any other natural person whose employment duties

require or authorize access to restricted areas of each gaming activity or operation not otherwise open to the

public. (Compact §5G)

110. Gaming enterprise: means any gaming activity or operation subject to the provisions of this TC3MICS and

Compact.

111. Gaming equipment: means any device, machine, paraphernalia, or equipment that is used or usable in the

playing phases of any gaming activity, whether or not specifically designed for the purpose, but excluding

tables and chairs normally used in the occupancy of any gaming operation.

112. Gaming machine/Electronic Gaming Device (EGD): means a microprocessor-controlled electronic device,

which allows a player to play games of chance; some of which are affected by skill which device is

activated by the insertion of a coin, token or currency, or by the use of a credit and which awards game

credits, cash tokens, or replays, or a written statement of the player's accumulated credits which written

statements are redeemable for cash. All gaming machines shall be connected at all times online/real-time

to a central computing device for purposes of accounting, auditing, security and monitoring. (Compact,

Technical Standards, NIGC§542.2)

113. Gaming machine analysis report: means a report prepared that compares theoretical to actual hold by a

gaming machine on a monthly or other periodic basis. (NIGC§542.2)

114. Gaming machine booths, change banks or change bins: means a booth or small cage in the gaming machine

area used to provide change to players, store change aprons, extra coin, and account for jackpot and other

payouts. (NIGC§542.2)

115. Gaming machine count: means the total amount of coins, tokens, tickets and cash removed from a gaming

machine. The amount counted is entered on the Gaming Machine Count Sheet and is considered the drop.

Also, the procedure of counting the coins, tokens, tickets and cash or the process of verifying gaming

machine coin and token inventory.



Property of the Prairie Band Potawatomi Nation viii October 11, 2006

116. Gaming machine monitoring system: means a computer system used by a gaming operation to monitor

gaming machine activity on an online basis, to include, but not limited to, meter reading, monitoring of

security devices, etc.

117. Gaming machine pay table: means the reel strip combinations illustrated on the face of the gaming machine

that can identify payouts of designated coin amounts. (NIGC§542.2)

118. Gaming facility (Casino): means the gaming facility owned by the Prairie Band Potawatomi Nation

pursuant to the Compact between the Prairie Band Potawatomi Nation and the State of Kansas approved

under IGRA and any building, room or rooms in which Class III gaming is conducted. (Compact §5A,

NIGC§542.2)

119. Gaming operation: means any enterprise owned by the Tribe on its Reservation located within the

boundaries of Kansas for the conduct of Class III gaming in a gaming operation. (Compact, NIGC§542.2)

120. Gaming services: means any goods or services to the Tribe directly in connection with each Class III

gaming activity or operation in a gaming operation, including, but not limited to, equipment, maintenance

or security services for such gaming operation and concessions. (Compact §5J)

121. General Manager: is the senior executive exercising the overall management or authority over all the

operations of the operation and the carrying out by employees of the tribal gaming operation of their duties.

122. Gross Gaming Revenue (GGR): means annual total amount of cash wagered on gaming activities and

admission fees (including table or card fees), less any amounts paid out as prizes or pad for prizes awarded.

(NIGC§542.2)

123. Gross receipts: means any money collected or received from gaming activity or operation.

124. Hard count: means the total amount of coins and tokens removed from a gaming machine. The amount

counted is entered on the Gaming Machine Count Sheet and is considered the hard drop. Also, the

procedures of counting the coins and tokens or the process of verifying gaming machine coin and token

inventory.

125. Hold (hold percentage): means the relationship of win to coin-in for gaming machines and win to drop for

table games.

126. Hopper: means a piece of equipment in a gaming machine used to retain coins or tokens used to make

gaming machine payouts.

127. House bank game: means each player opposes the gaming operation, and the gaming operation opposes

each player.

128. IGRA: means the Indian Gaming Regulatory Act, Public Law 100-497, 102 Stat. 2426, 25 U.S.C. 2701, et

seq. (1988), as amended.

129. Immediate family: means a spouse (not one separated or divorced), parents, grandparents, siblings, children

and grandchildren by marriage or adoption.

130. Immediate notification: means communication to specified parties within the same regular scheduled shift

of a gaming day.

131. Imprest bank: means an advance or loan of money to be used to transact business outside the primary area

where money is centrally stored, which is usually the cashier's cage. Includes change banks, carts, pouches,

registers and kiosks.

132. Imprest basis: means the basis on which funds are replenished from time to time by exactly the amount of

the net expenditures made from the funds and amounts received and in which a review of the expenditure is

made by a higher authority before replenishment. (Compact Appendix A § (1) (m))

133. Income control: is that group of individuals in the accounting department who are responsible for the daily

audits of records generated on the casino floor, both gaming and non-gaming. There are no incompatible

functions in this department as the staff reports directly to the Income Control Supervisor, who in turn

reports to the Financial Controller.

134. Incompatible function: means a function, for accounting and internal control purposes, that places any

person or department in a position to either perpetrate and/or conceal errors or fraud in the normal course of

his/her duties. Anyone both recording transactions and having access to the relevant assets is in a position

to perpetrate or conceal errors or fraud. (Compact Appendix A § (1) (n))

135. Independent accountant: means an independent certified public accountant suitably qualified and

sufficiently independent to act as auditor of the tribal gaming operation.

136. Inspector: means an employee and agent of the Tribal Gaming Commission duly appointed by the Tribal

Gaming Commission as an inspector.

137. Instant notification: communication to specified parties without any delay being purposely introduced.



Property of the Prairie Band Potawatomi Nation ix October 11, 2006

138. Internal audit: means persons who perform audit function of a gaming operation that are independent of the

department subject to audit. Independence is obtained through the organizational reporting relationship as

the internal auditor shall not report to management of the gaming operation. Internal audit personnel may

provide audit coverage to more than one operation within the Tribe’s gaming holdings. Internal audit

activities should be conducted in a manner that permits objective evaluation of areas examined.

(NIGC§542.2)

139. Internal control procedures (See also Procedures): means the detailed description of steps or processes

taken or to be followed to meet the intent of the ICS as approved by the Tribal Gaming Commission.

140. Internal Controls System (internal controls, ICS): means plan of organization and all of the coordinated

methods and measures adopted within a business to safeguard its assets, check the accuracy and reliability

of its accounting data, provide adequate separation of incompatible procedures and functions, promote

operational efficiency, and encourage adherence to prescribed managerial policies.

141. IRS: means the United States Internal Revenue Service.

142. Jackpot payout: means the portion of a jackpot paid by gaming machine personnel. The amount is usually

determined as the difference between the total posted jackpot amount and the coins paid out by the

machine. This term may also describe the total amount of the jackpot. (NIGC§542.2)

143. Jackpot payout slip: means a form on which the portion of a jackpot paid by gaming operation personnel is

recorded.

144. Key: means a mechanical instrument by which a lock is opened, an optical pad or camera recognition

device or logged computerized personal identification numbers entered on a pad that permits access to a

restricted area or item.

145. Key employee: means any natural person employed in the operation or management of each gaming

activity or operation in the capacity of (i) counting room supervisor; (ii) chief of security; (iii) custodian of

gaming supplies or cash; (iv) floor manager; (v) pit boss; (vi) dealer; (vii) croupier; (viii) approver of

credit; (ix) custodian of gambling devices including persons with access to cash and accounting records

within such devices; (x) any other person whose total cash compensation is in excess of $50,000 per year;

(xi) the four most highly compensated persons in the gaming operation; and (xii) security department

employees. (Compact § 5)

146. Key control ledger: means a ledger which authorized personnel sign to receive or use keys to sensitive

areas, such as drop boxes, count room and cashier's cage.

147. Kiosk: means a self-service device located on the gaming floor that provides a means for payment of a

ticket that has been validated and redeemed by the computer ticket validation system. (Technical

Standards)

148. Kobetron: means a machine that calculates the identification signature of EPROMs from gaming machines.

This signature is then compared to approved signatures for programming verification.

149. Linked electronic game: means any game linked to two (2) or more gaming operations that are physically

separate and not regulated by the same Tribal gaming regulatory authority. (NIGC§542.2)

150. Layout: means in table games a diagram, usually on felt, with spaces for bets. Pay offs and odds shall be

posted either on the lay out or near the game within view of the player.

151. Limit: means the minimum and maximum amount that customers may wager in a table game. Amounts are

designated by management.

152. Load: means the amount of coins or tokens in the hopper.

153. Loose coin: means coin held in a cage, change bin, vault, or count room or on gaming tables, which has

not been put in wrappers. May also include bent or damaged coins.

154. Logs: means a document used for recording and tracking information and activity.

155. Machine payout form: means a document used to log all progressive jackpots and amounts won greater

than $1,200.

156. Main card room bank: means a fund of cash, coin, and chips used primarily for card room use. Used to

make even money transfers between various games as needed. May be used similarly in other areas of the

gaming operation. (NIGC§542.2)

157. Management contractor: means any individual, sole proprietorship, partnership, corporation or other entity,

which manages any Class III gaming activity or operation on behalf of the Tribe pursuant to a management

contract approved by the Chairman of the National Gaming Commission. (Compact §5(R))

158. Manager: can be defined as a manager of the department being discussed, to include shift managers and

assistant shift managers able to carry out manager duties under a job description.



Property of the Prairie Band Potawatomi Nation x October 11, 2006

159. Manager on Duty (MOD, Shift Supervisor, Assistant Shift Supervisor): means the person with overall

responsibility for gaming operations during a shift.

160. Manufacturer: means a person or business entity who manufactures, produces, or assembles an EGD or a

TITO system or any component thereof and who intends to furnish it to a distributor or the Tribe.

(Technical Standards)

161. Manufacturer/manufacturer-distributor: means any individual, sole proprietorship, partnership or

corporation, which assembles, produces, makes, prints, or supplies Class III gaming equipment or supplies

for sale, lease, use, or distribution to the Tribe or a licensed gaming operator for a Class III gaming activity.

(Compact §5(P))

162. Master game program number: means the game program number listed on a gaming machine EPROM.

163. Master gaming report/sheet (Game count sheet): a form used to record, by shift and day, each table game’s

winnings and losses. This form reflects the opening and closing table inventories, the fills and credits, and

the drop and win.

164. Mechanical coin counter: means a device used to count coins that may be used in addition to or in lieu of a

coin weigh scale.

165. Meter: an electronic (soft) or a mechanical (hard) apparatus in a gaming machine. Shall record the number

of coins wagered, the number of coins dropped, the number of times the handle was pulled, and/or the

number of coins paid out to winning players. (NIGC§542.2)

166. Meter reading summary: means a report reflecting the meter readings on gaming machines. The number is

recorded when the drop bucket and/or bill validator is removed from the cabinet.

167. Minimum Internal Controls (TC3MICs): means minimum internal controls of the Commission. The Tribal

Gaming Commission's adopted and published minimum internal controls through its authority to

promulgate rules that are comprehensive and establish minimums for internal control procedures required

of gaming operations that satisfy the Commission, the Compact and NIGC. Such standards may be

changed periodically by the Commission. (See Section on changes to ICS)

168. Minimum Internal Control Standards (MICS): means minimum internal control standards in Section 542 of

NIGC. (NIGC§542.2)

169. Motion activated dedicated camera: means a video camera that, upon its detection of activity or motion in a

specific area, begins to record the activity or area. (NIGC§542.2)

170. Multi-game machine: means a gaming machine that includes more than one type of game option.

(NIGC§542.2)

171. National Indian Gaming Commission (“NIGC”): means the commission by that name established by the

Indian Gaming Regulatory Act (1988) or commonly known as “IGRA”.

172. Net revenues: means gross gaming revenues, less amounts paid out as, or paid for, prizes, and total gaming-

related operating expenses, excluding management fees. (NIGC§542.2)

173. Non-house banking card game: means a card game where the house does not participate in or have any

interest in the outcome of the wager.

174. Officer: means an agent of the State Gaming Agency to include the Executive Director and others

authorized by the Executive Director for enforcement or compliance duties.

175. Opener: means the duplicate copy of the table inventory slip upon which each table inventory is recorded

at the end of each shift and serves as the record of each table inventory at the beginning of the next or

succeeding shift.

176. Operator: means a person contracted, appointed or hired by the Tribe to perform, promote, conduct, or

operate any lawful, tribally licensed gaming activity or operation on tribal lands at a gaming operation. In

the case of a gaming activity owned and operated solely by the Tribe, this person shall be the senior gaming

management official employed to operate the game or games. In the case of a game or games operated

pursuant to a management contract, that person shall be the senior management official designated by the

management contract on its management contractor's license application.

177. Order for credit: means a form that is used to request the transfer of chips from a table to the cage. The

order precedes the actual transfer transaction that is documented on a credit slip.

178. PIN (Personal Identification Number): means a number assigned and controlled as a key to sensitive areas

of the casino or to locked containers or number used to access a player’s account.

179. Par percentage: means the percentage of each dollar wagered that the house wins (i.e., gaming operation

advantage). (NIGC§542.2)



Property of the Prairie Band Potawatomi Nation xi October 11, 2006

180. Par sheet: means a specification sheet for a gaming machine that provides machine hold percentage, model

number, hit frequency, reel combination, number of reels, number of coins that can be accepted and reel

strip listing. (NIGC§542.2)

181. Patron (See also Customer): means a consumer or purchaser of goods or services at the gaming facility

other than participating in a gaming activity. (See Player for gaming activity)

182. Participate: in any gaming activity or operation means manage, operate, direct, own, finance, furnish,

supply or in any way assist in the establishment of, or operation of, any Class III gaming activity or

operation, directly or indirectly, whether at the site in person or off of the reservation. (Compact §5(S))

183. Payout: means the transaction associated with a winning event. (NIGC§542.2)

184. Pit: means the area enclosed or encircled by an arrangement of gaming stations in which gaming operation

personnel administer and supervise the games played at the tables by the patrons located on the outside

perimeter of the area. Configuration shall ensure the security of assets within the pit.

185. Pit podium: means a stand located in the middle of the tables used as a workspace and record storage area

for table games supervisory personnel. (NIGC§542.2)

186. Player: means any person participating in any gaming activity with the chance of winning money or other

benefit. Does not include an operator or any assistant of an operator. (See also Customer and Patron)

187. Player tracking system: means a system typically used in gaming machine departments and table games

that can record the gaming play of individual players. (NIGC§542.2)

188. Poker: means a card game using a single 52-card deck. Players, preferably five or more, wager against each

other based on the value of their hands, the bets forming a pool or pot to be taken by the winner. Variations

of poker are authorized upon tribal regulatory approval.

189. Policy: means a plan or course of action designed to influence and determine decisions and actions.

190. Primary and secondary jackpots: means promotional pools offered at certain card games that can be won in

addition to the primary pot. (NIGC§542.2)

191. Procedure (See also Internal Control Procedure): means a way of performing, or a method used, in dealing

with the affairs of a business.

192. Program storage media: the device in which the game program resides as defined in Attachment A and

whose operation is described in Attachment A. (Technical Standards)

193. Progressive gaming machine: means a gaming machine, with a payoff indicator, in which the payoff

increases as it is played (i.e., deferred payout). The payoff amount is accumulated, displayed on a machine

and shall remain until a player lines up the jackpot symbols that result in the progressive amount being

paid. (NIGC§542.2)

194. Progressive jackpot: means a deferred payout from a progressive gaming machine. (NIGC§542.2)

195. Progressive table game: means table games that offer progressive jackpots. (NIGC§542.2)

196. Promotional payouts: mean merchandise, coupons or awards given to players by the gaming operation

based on their wagering activity. (NIGC§542.2)

197. Promotional progressive pots and/or pools: means funds contributed to a table game by and for the benefit

of players. Funds are distributed to players based on a predetermined event. (NIGC§542.2)

198. Rake: means a Commission charged by the gaming operation for maintaining or dealing a game such as

poker. (NIGC§542.2)

199. Rake circle: means the area of a table where rake is placed. (NIGC§542.2)

200. Rake-off: means the amount of coin or chips taken from certain card game pots by the dealer to be put in

the drop box. The rake-off is the casino's fee for running the game.

201. Randomness: means the observed unpredictability and absence of pattern in a set of events that have

definite probabilities of occurrence.

202. Random number generator: means a device that generates numbers in the absence of a pattern. Also

commonly used in gaming machines to generate game outcome. (NIGC§542.2)

203. Redemption: means the process by which a ticket is presented by a patron for payment at a casino cage or

inserted into a kiosk or bill validator of an EGD, recognized by the computer ticket validation system as

valid, and the patron is paid in US currency and coin or by check the amount printed on the ticket, or, in the

case of acceptance of the ticket in an EGD, game credits plus any residual in an amount equivalent to the

amount printed on the ticket. The redemption process must be completed entirely prior to the award of a

merchandise prize. (Technical Standards)

204. Reel strip settings: mean setting positions on gaming machine reels so that they correspond to the

calibrations regulating winning combinations and payoffs.

205. Reel symbols: means symbols listed on reel strips of gaming machines.



Property of the Prairie Band Potawatomi Nation xii October 11, 2006

206. Reservation: means that portion of the Prairie Band Potawatomi Nation Reservation, located within the

boundaries of Kansas. (Compact Sec 5(W))

207. Related party: means an individual that is a relative, immediate family member, dependent or an

organization owned or controlled (5%) by such individuals, relatives, immediate family members and

dependents or is a Key Employee.

208. Relative: means a member of the immediate family plus uncles, aunts, nephews, nieces, first cousins, and

dependents.

209. Residual: means the value in dollars and cents remaining after an EGD registers the maximum game credits

possible following insertion and redemption of a ticket, token(s) or US currency and/or coin. (Technical

Standards)

210. Residual ticket: means a ticket printed in an amount remaining following the insertion and redemption of a

ticket or the insertion and acceptance of US currency and/or coin or approved token into an EGD.

(Technical Standards)

211. Revoke: means to permanently void and recall all rights and privileges to obtain or hold a license.

212. Runner: means a gaming employee who transports chips/cash to or from a gaming table and a cashier.

213. Security department: means a department within, or utilized by, a gaming operation whose employees

assist in maintaining compliance with all internal controls but do not participate in operating table games or

gaming machines and do not participate in cashier cage operations. The main duty of security is to ensure

implementation of all procedures and policies to insure the safety and protection of the facility, its

customers and employees.

214. Security department representative/member: means any person who is a member of the Security

Department as provided in the organization of the operation.

215. Sensitive areas: are those areas that the Tribal Gaming Commission considers susceptible to potential

weaknesses in the ICS of the Casino's operation and, therefore, require strict control over access (i.e., pits,

count rooms, cages, surveillance rooms, vaults)

216. Shift: means any time period designated by management up to 24 hours.

217. Shift manager: means the person with overall responsibility for gaming operations during a shift for the

department assigned and licensed for. (Table Games Shift Manager, Gaming Machines Shift Manager,

Cage Shift Manager, etc.)

218. Shill: means an employee financed by the house and acting as a player for the purpose of starting or

maintaining a sufficient number of players for a game. (NIGC§542.2)

219. Shoe: means a device used to hold cards before dealing.

220. Short pay: means a payoff from a gaming machine that is less than the listed amount.

221. Signature (employee): means at a minimum, the first initial and full last name accompanied by the Tribal

Gaming Commission license number. Signature shall match signature card on file. License numbers shall

be legible at all times.

222. Simultaneous notification: is defined as communication to specified parties within the hour.

223. Slip dispenser (WHIZ machine): a locked device used primarily in a cage to dispense fill and credit slips in

numerical sequence.

224. Slots: mean electronic gaming devices.

225. Slot fills: means coin required to fill tubes or hoppers of a gaming machine when it is first put into

operation. Subsequently, additional coins placed in a machine so that it can continue to make automatic

payouts.

226. Slug: means non-gaming counterfeit/altered coin used to cheat a gaming machine.

227. Soft count: means the count of the contents in a drop box or a bill validator canister. Also, the amount

counted that is entered on the Game Count Sheet, as part of the drop. The entire procedure of counting drop

box and bill validator contents of card and table games is referred to as the soft count.

228. Standard Operating Procedure: refers to an established procedure to be followed in a given situation. As

part of its standard operating procedure, a gaming operation is required to provide step by step instructions

so that anyone coming into the operation would be able to follow the instructions and actually perform the

task.

229. State Gaming Agency (SGA/Agency): means such agency of the State of Kansas as the State of Kansas

may designate as the Agency responsible for oversight of Class III gaming conducted pursuant to the

Compact. (Compact)

230. Statistical drop: means total amount of money, chips and tokens contained in the drop boxes, plus and

minus other transactions allowed by the State gaming laws. (NIGC§542.2; Compact)



Property of the Prairie Band Potawatomi Nation xiii October 11, 2006

231. Statistical win: means closing bankroll or tokens returned to the cage plus drop, minus opening bankroll,

minus fills to the table. (NIGC§542.2) Portions pertaining to credit and markers deleted per State Law.

(Compact)

232. Stickman: runs the craps games and calls the results of each roll.

233. Sufficient clarity: means use of monitoring and recording at a minimum of twenty (20) frames per second.

Multiplexer tape recordings are insufficient to satisfy the requirement of sufficient clarity. (NIGC§542.2)

234. Surveillance: means the placement of cameras in a casino located in the overhead structure of a building

from which the casino area can be viewed without detection from the casino. Cameras include dedicated,

fixed, and pan-tilt-zoom (ptz) cameras.

235. Surveillance room: means a secure location in a gaming operation used primarily for casino surveillance.

(NIGC§542.2)

236. Surveillance system: means a system of video cameras, monitors, recorders, video printers, switches,

selectors and other ancillary equipment used for casino surveillance. (NIGC§542.2)

237. Table bank (table inventory): means coin and chips assigned to a gaming table as an imprest fund or

inventory.

238. Table games: means games that are banked by the house or a pool whereby the house or the pool pays all

winning bets and collects from all losing bets. (NIGC§542.2)

239. Table game drop: means the sum of the total amounts of currency, coin, tokens, gaming chips, customer

checks and other cash equivalent(s) removed from a drop box.

240. Table game win or loss: determined by adding the amount of cash or coin, closer, funds removed from a

drop box (drop), plus credits, and subtracting opener and fills removed from a drop box.

241. Table games supervisory personnel (games/pit supervisor): means individuals who are trained and licensed

to supervise all games in a particular pit area.

242. Table Supervisor: means the person who supervises specific gaming tables in a pit and is responsible to a

higher table games supervisor.

243. Table inventory: means the total coins, chips and cash at a table. Table inventory is kept in a table tray

located on a gaming table to store coins, chips or tokens used in that game. (NIGC§542.2)

244. Table inventory form (see Opener and Closer): forms used to document inventory of chips, coins and

tokens on a table at the beginning and ending of a shift.

245. Theoretical hold: means the intended hold percentage or win of an individual gaming machine as computed

by reference to its payout schedule and reel strip settings or EPROM. (NIGC§542.2)

246. Theoretical hold worksheet: means a worksheet provided by the manufacturer for all gaming machines that

indicate the theoretical percentages that the gaming machine should hold based on adequate levels of coin-

in. The worksheet also indicates the reel strip settings, number of credits that may be played, the payout

schedule, the number of reels and other information descriptive of the particular type of gaming machine.

(NIGC§542.2)

247. Ticket: an approved paper token printed by a ticket printer, in an EGD with a game and containing that

printer, immediately following the insertion of US currency and/or coin, approved token or valid ticket into

the EGD in the case of a residual or following the patron activation of the cash out selection on the EGD.

A ticket shall record the value of game credits at cashout or residual in dollars and cents in numerical form,

the time of day it was printed, the date of printing showing the month, day and year, a gaming device

number identifying the EGD in which the ticket is printed, a unique validation number or barcode capable

of being read by a ticket reader, and an identifier unique to the gaming facility such as a logo or name.

Tickets will expire 30 days from the date of issue and tickets shall so state. (Technical Standards)

248. Ticket In/Ticket Out (TITO): means a process by which an EGD has the ability to accept or dispense

tickets as a means for payment and communicates with a computerized ticket validation system. (Technical

Standards)

249. Ticket reader: means an optical device in an EGD or kiosk or at the cage capable of reading tickets and

sending information to the computerized ticket validation system. Bill validators may incorporate this

technology.

250. Ticket printer: means a device in an EGD that is capable of printing an approved ticket based on

instructions received from the EGD, which has received data from the computerized ticket validation

system. (Technical Standards)

251. Timely notification: communication to specified parties within the same gaming day.

252. Token: means an object of a design and substance approved in writing by the Tribal Gaming Commission.

The object shall represent a value shown on the object and be capable of being inserted into an EGD, which



Property of the Prairie Band Potawatomi Nation xiv October 11, 2006

causes the appropriate number of game credits to register. (Technical Standards) Token means a coin-like

cash substitute, in various denominations, used in gaming transactions. (NIGC§542.2)

253. Slot token: means a metal disk representative of value issued by the Tribe for use in gaming machines or at

table games at a Tribal gaming operation or a coin-like money substitute, in various denominations, used

for gambling transactions. (See Value of Chips and Tokens)

254. Tournament: means a contest to determine the best player within a set of Tribal Gaming Commission and

Compact approved parameters such as time period or amount of chips remaining in front of each player.

255. Tournament chips: means special chips that have no stated value that can be assigned artificial values for the

duration of the tournament.

256. Tribal Gaming Commission (tribal regulatory authority): means the Tribal Gaming Commission established

by the Tribe through Title 12, as the agency primarily responsible for regulatory oversight of Class III

gaming conducted pursuant to the Class III Gaming Compact between the Prairie Band Potawatomi Nation

in Kansas and the State of Kansas.

257. Tribal gaming regulations: means those regulations adopted by the Tribe to regulate Class III gaming

conducted pursuant to the IGRA, Title 12 of the Potawatomi Law and Order Code as Amended, the

Compact as provided in Section 7 and Appendices A and B and other applicable law. These TC3MICs are

regulations approved and adopted. (Commission Resolution)(Compact§7)

258. Tribe: means the Prairie Band of Potawatomi Indians, recognized by the federal government and operating

pursuant to the Tribal Constitution and By-laws, and "tribal" means belonging or pertaining to the Tribe.

259. Twenty-One or Blackjack: means the card game played by a maximum of seven players and one dealer

wherein each player plays his hand against the dealer's hand with the object of obtaining a higher total card

count than the dealer by reaching 21 or as near 21 as possible without exceeding 21. (Compact Appendix

B)

260. Valid: means a ticket that has not been previously redeemed, has not expired, has not been voided and is

not in an unredeemable state as determined by the computerized ticket validation system. (Technical

Standards)

261. Validation: means the process that is used to verify the validity of a ticket that is presented for game credits

or payment. When presented for game credits or payment, the ticket information is compared to the data

stored on the computerized ticket validation system, based on the unique identifying number, for validation

prior to registration of game credits or payment. (Technical Standards)

262. Value of tickets, chips and tokens: tickets, chips and tokens are solely representative of evidence a debt

owed to their custodian by the Prairie Band Potawatomi Gaming Operation and are not the property of

anyone other than the Prairie Band Potawatomi Gaming Operation. Use of the Prairie Band Potawatomi

Gaming operation’s tickets, chips or tokens for any monetary purpose whatsoever is prohibited. The

Prairie Band Potawatomi Gaming Operation shall redeem the tickets, chips and tokens from its players by

cash or check drawn on an account of the gaming operation. Promotional chips and tokens shall bear an

inscription "No Cash Value".

263. Vault: means a secure area within the gaming operation where tokens, checks, cash, coins, and chips are

stored. (NIGC§542.2)

264. Vice President and General Manager: see General Manager.

265. Wager: means a sum of money or thing of value risked on an uncertain occurrence.

266. Weigh/count: means the value of coins and tokens counted by a count machine. (NIGC§542.2)

267. Weigh/count and wrap: means the comparison of the weighed gaming machine drop to counted and

wrapped coin.

268. Weigh scale: means a scale that calculates (by weight) the amount of money in a given bucket/bags from a

gaming machine/slot.

269. Weigh scale calibration module: means the device used to adjust a coin weigh scale. (NIGC§542.2)

270. Weigh scale interface: means a communication device between the weigh scale used to calculate the

amount of funds included in drop buckets and the computer system used to record the weigh data.

271. Weigh tape: means the tape where weighed coin is recorded. (NIGC§542.2)

272. Wide area progressive gaming machine: means a progressive gaming machine that is linked to other

operations, and play on the machines affect the progressive meters on all of the linked machines and

increase as wagers are placed on any linked machine. (NIGC§542.2)

273. Win: synonymous with Gross Gaming Revenue. Means the net win resulting from all gaming activities.

Net win results from all wins prior to considering associated operating expenses.



Property of the Prairie Band Potawatomi Nation xv October 11, 2006

274. Win/drop report: means a record of the computation of win/loss by denomination of each gaming machine

and each type of table game. Reports are created daily and at the end of each month.

275. Win-to-write hold percentage: means win divided by write to determine hold percentage. (NIGC§542.2)

276. Work papers: documents containing the evidence to support the auditors’ findings, opinions, conclusions,

and judgments.

277. Wrap: means the method of storing coins after the count process has been completed, including, but not

limited to, wrapping, racking, or bagging. Wrap may also refer to the total amount or value of the counted

and stored coins. (NIGC§542.2)



Property of the Prairie Band Potawatomi Nation 1 October 11, 2006

FOREWORD

These TC3MICs are subject to all definitions contained in Title 12 of the Law and Order Code as Amended, in

IGRA, all those promulgated by the National Indian Gaming Commission (NIGC) and the Tribal State Compact

between the Prairie Band Potawatomi Nation in Kansas and the State of Kansas (Compact) unless a different

meaning clearly appears from the context. (Law and Order Code, Title 12, as Amended), (Compact §4 and §5),

(NIGC§542.4)

If there is a direct conflict between an internal control standard established in a Tribal-State compact and a

standard or requirement of the NIGC, then the internal control standard established in a Tribal-State compact

shall prevail. (NIGC §542.4(a)) If an internal control standard in a Tribal-State compact provides a level of

control that equals or exceeds the level of control under an internal control standard or requirement set forth by

the NIGC, the Tribal-State compact shall prevail. (NIGC §542.4(b)) If an internal control standard set forth by

the NIGC provides a level of control that exceeds the level of control under a Tribal-State compact, then the

NIGC shall prevail. (NIGC §542.4(a)) If the level of control of the Prairie Band Potawatomi Gaming

Commission exceeds the levels of the NIGC and the Compact, the Prairie Band Potawatomi Gaming

Commission internal control will prevail.

Nothing in these regulations shall be construed to grant to the State jurisdiction in Class II gaming or extend the

State’s jurisdiction in Class III gaming. (NIGC §542.4(c))

The following are Class III Minimum Internal Controls (TC3MICs) adopted by the Tribal Gaming Commission

(Commission) and Tribal Council (Council) of the Prairie Band Potawatomi Nation for Class III gaming

operations. These TC3MICs are subject to all definitions contained in IGRA and all regulations promulgated by

the National Indian Gaming Commission and the Compact. (Compact §4), (NIGC§542.4) All previous versions

are superseded.

The TC3MICS are designed to provide a basic framework for the Casino in establishing and maintaining their

Internal Control System (ICS). The tribal gaming operation shall submit a description of the operation’s

internal control system, administrative and accounting controls and policies and procedures to the Tribal

Gaming Commission and the State Gaming Agency for approval before the new controls are to commence. The

Casino's responsibility is to ensure that Casino internal control systems comply with at least these TC3MICs,

NIGC MICS and the Compact. If a minimum ICS standard is not compliant, Casino management's

responsibility is to see that compensating internal controls are developed and submitted to the Tribal Gaming

Commission for approval. Immediate notification of discovery of the inconsistency is to be reported to the

Tribal Gaming Commission. Some inconsistencies may require simultaneous notification to the State Gaming

Agency.

The existence of manual and computerized systems also creates situations that may require variations in the

ICS. All ICS developed shall meet these minimums regardless of whether operating in a manual or a

computerized environment.

Tribal Gaming Commissioners, Commission Inspectors, Officers of the State Gaming Agency, Agents of the

Kansas Bureau of Investigation and Agents of the National Indian Gaming Commission and other persons

authorized by the Tribal Gaming Commission and Executive Director of the State Gaming Agency are to be

afforded unfettered access to any and all areas requested in the gaming facilities as provided in the Compact

between the Tribe and the State of Kansas. (Compact §10A, 11) State Gaming Officers and Agents of the

Kansas Bureau of Investigation requesting to view documents and records will be afforded immediate access

and consideration. Copies of records requested shall be provided immediately except in those instances where a

breach of the Compact between the Prairie Band Potawatomi and the State of Kansas or an illegal act may have

occurred in which case the copies will be provided instantly. Copies of records obtained by the regulatory

bodies are subject to the requirements of the Tribal Law and the Compact. (Compact §11) The Tribal Gaming

Commission may investigate suspected misconduct of employees of the gaming facility, who are not gaming

employees, but are employed in ancillary facilities located within the same building as the gaming facility

(Compact §15D)




FRONTISPIECE

The Compact provides that the Tribal Gaming Commission shall have unfettered access to all areas of the

gaming operation at all times, and personnel employed by the Casino shall for such purposes provide the Tribal

Gaming Commission access to locked and secured areas of the gaming operation to monitor the compliance of

the gaming operation with Tribal regulations. The same unfettered as well as free and unrestricted access is

afforded to Officers of the State Gaming Agency to monitor the compliance of the operation with the Compact.

(Compact §10A, 11A, 12A)

At least one (1) Tribal Gaming Inspector shall be present in the gaming operation during all hours of gaming

operation and shall have immediate access to any and all areas of each gaming activity or operation for the

purpose of ensuring compliance with this Compact and applicable law. (Compact §10B2)

All employees at the Casino shall receive copies of the relevant sections of the Tribal Minimum Internal

Controls and the State Gaming Compact, pertinent to their job title. A signed statement acknowledging receipt,

understanding, and compliance with the controls and Compact shall be placed in every employee’s personnel

file upon hire. The Human Resource Department shall be responsible for the distribution of the pertinent areas

and collection of the acknowledgement. A copy of this acknowledgement shall be forwarded to the Tribal

Gaming Commission for insertion into the employee’s license file. The Casino operator shall train all personnel

in accounting and internal control practices and procedures relevant to each employee’s individual functions.



SECTION A

GENERAL PROVISIONS


I. Authority of the Gaming Commission

The Prairie Band Potawatomi Gaming Commission (Commission), a governmental subdivision of the

Prairie Band Potawatomi Nation, is granted the exclusive authority to regulate all gaming activities or

operations under the Prairie Band Potawatomi Law and Order Code as amended. (Title 12 §12-3-2) The

Tribal Gaming Commission is primarily responsible for regulatory oversight of Class III gaming conducted

by the Tribe. (NIGC §542.3(g)(2))

II. Powers of the Gaming Commission Regarding Regulations

The Commission has the delegated power to enact and enforce such rules and regulations regarding its

activities and governing its internal affairs, as it may deem necessary and proper to effectuate the powers

granted and duties imposed by Title 12 and any other applicable law. (Title 12 §12-3-20 (A)) (NIGC

§542.3(g)(1))

The Commission, through these regulations, asserts its authority to promulgate rules that are

comprehensive and establish minimums for internal control procedures required of gaming operations that

satisfy the Tribal Gaming Commission, Title 12 PBP Law and Order Code, the Compact and NIGC. Such

standards may be changed periodically by the Tribal Gaming Commission. These regulations shall ensure

that the interests of the Tribe and the State relating to Class III gaming are preserved and protected. These

regulations shall maintain the integrity of such gaming activity or operation and shall reduce the dangers of

unfair and illegal practices in the conduct of Class III gaming. (Title 12, Compact, NIGC)

III. Changes to Prairie Band Potawatomi Tribal Gaming Commission TC3MICS

In compliance with the Compact and the National Indian Gaming Commission’s Minimum Internal

Controls, the Tribal Gaming Commission hereby adopts these regulations (Tribal Minimum Internal

Controls) to govern the operation and management of the Prairie Band Potawatomi Nation’s Class III

gaming operation. (NIGC §542.3(c))

IV. Non-Compliance

Failure to comply with any of the requirements of the Prairie Band Potawatomi Gaming Commission

Minimum Internal Controls may result in action against the corporation, vendor, or individual license (as

applicable), to possibly include a levying of fines. (NIGC §542.3(g))

V. Penalties and Fines for Violations of the Tribal Minimum Internal Controls

Any violation of the Prairie Band Potawatomi Minimum Internal Controls may result in an imposition of a

fine and/or license suspension or revocation. The Tribal Gaming Commission shall issue and publish a

matrix determining a fine structure. All licensees shall be made aware of the matrix and penalties that shall

incur a fine.

This section shall apply equally to individual employees and to the management company (if applicable).

Nothing contained herein or any civil penalties imposed herein or any civil penalties imposed hereunder

shall preclude any criminal prosecution, which may result from a violation of these Minimum Internal

Controls.



SECTION A

GENERAL PROVISIONS


VI. Gaming Operation Request for Variance from NIGC MICS

A. The gaming operation may apply for a variance from the NIGC MICS, and the Tribal Gaming

Commission may approve such variance. (NIGC§542.18 (a))

1. The Gaming Commission may approve a variance for a gaming operation if it is determined

that the variance will achieve a level of control sufficient to accomplish the purpose of the

standard it is to replace. (NIGC§542.18 (a)(1))

B. For each enumerated standard for which the Tribal Gaming Commission approves a variance, it shall

submit to the Chairman of the NIGC within thirty (30) days a detailed report, which shall include the

following:

1. A detailed description of the variance;

2. An explanation of how the variance achieves the level of control sufficient to accomplish the

purpose of the standard it is to replace; and

3. Evidence that the Tribal Gaming Commission has approved the variance. (NIGC§542.18

(a)(2)(i)(ii)(iii))

C. In the event the Tribal Gaming Commission or the Tribe chooses to submit a variance request

directly to the Chairman, it may do so without the approval requirement set forth in paragraph VI.B

of this section, and such request shall be deemed as having been approved by the Tribal Gaming

Commission. (NIGC§542.18 (a)(3))

D. Review by the Chairman: (NIGC§542.18 (b))

1. Following receipt of the variance approval, the Chairman or his or her designee shall have sixty

(60) days to concur with or object to the approval of the variance. (NIGC§542.18 (b)(1))

2. Any objection raised by the Chairman shall be in the form of a written explanation based upon

the following criteria: (NIGC§542.18 (b)(2))

a. There is no valid explanation of why the gaming operation should have received a

variance approval from the Tribal Gaming Commission on the enumerated standard; or

(NIGC§542.18 (b)(2)(i))

b. The variance as approved by the Tribal Gaming Commission does not provide a level of

control sufficient to accomplish the purpose of the standard it is to replace. (NIGC§542.18

(b)(2)(ii))

E. If the Chairman fails to object in writing within sixty (60) days after the date of receipt of a complete

submission, the variance shall be considered concurred with by the Chairman. (NIGC§542.18 (b)(3))

F. The sixty (60) day deadline may be extended provided such extension is mutually agreed upon by the

Tribal Gaming Commission and the Chairman. (NIGC§542.18 (b)(4))

G. Curing the Chairman’s objections: (NIGC§542.18 (c))

1. Following an objection by the Chairman to the issuance of a variance, the Tribal Gaming

Commission shall have the opportunity to cure any objections noted by the Chairman.

(NIGC§542.18 (a)(3)(c)(1))

2. Tribal Gaming Commission may cure the objections raised by the Chairman by: (NIGC§542.18

(c)(2))

a. Rescinding its initial approval of the variance or (NIGC§542.18 (c)(2)(i))

b. Amend its initial approval and resubmit it to the Chairman. (NIGC§542.18 (c)(2)(ii))

H. Upon any resubmission of a variance approval, the Chairman shall have thirty (30) days after the

date of receipt of the resubmitted variance, to be considered concurred with by the Chairman.

(NIGC§542.18 (c)(3)) (NIGC§542.18 (c)(4))



SECTION A

GENERAL PROVISIONS


I. The thirty (30) day deadline may be extended, provided such extension is mutually agreed upon by

the Tribal Gaming Commission and the Chairman. (NIGC§542.18 (c)(5))

J. Upon receipt of objections to a resubmission of a variance, the Tribal Gaming Commission shall be

entitled to an appeal to the full NIGC in accordance with the following process: (NIGC§542.18

(d)(1))

1. Within thirty (30) days of receiving an objection to a resubmission, the Tribal Gaming

Commission shall file its notice of appeal. (NIGC§542.18 (d)(1)(i))

2. Failure to file an appeal within the time provided shall result in a waiver of the opportunity for

an appeal. (NIGC§542.18 (d)(1)(ii))

3. An appeal shall specify the reasons why the Tribal Gaming Commission objections should be

reviewed and shall include supporting documentation, if any. (NIGC§542.18 (d)(1)(iii))

4. The Tribal Gaming Commission shall be provided with any comments offered by the Chairman

of the NIGC on the substance of the appeal by the Tribal Gaming Commission and shall be

offered the opportunity to respond to any such comments. (NIGC§542.18 (d)(1)(iv))

5. Within thirty (30) days after receipt of the appeal, the NIGC Commission shall render a

decision based upon the criteria contained within paragraph VI.B. of this section unless the

Tribal Gaming Commission elects to provide the NIGC additional time, not to exceed an

additional thirty (30) days. (NIGC§542.18 (d)(1)(v))

6. In the absence of a decision in the time provided, the Tribal Gaming Commission’s

resubmission shall be considered concurred with by the NIGC and become effective.

(NIGC§542.18 (d)(1)(vi))

K. The Tribal Gaming Commission may appeal the Chairman’s objection to the approval of a variance

to the full NIGC without resubmitting the variance by filing a notice of appeal with the full NIGC

within thirty (30) days of the Chairman’s objection and complying with the procedures described in

paragraph VI.J. of this section. (NIGC§542.18 (d)(2))

L. Effective date of the variance: The gaming operation shall comply with the standards that achieve a

level of control sufficient to accomplish the purpose of the standard it is to replace until such time as

the NIGC objects to the Tribal Gaming Commission’s approval of a variance as provided in

paragraph VI.D., E., and F. of this section or there is concurrence in a variance by the Chairman of

the NIGC or the NIGC concurs with the Tribal Gaming Commission’s approval of a variance.

(NIGC§542.18 (e))

VII. Organization of the Tribal Gaming Operation

A. The gaming operation shall have a system of internal control that includes the following:

1. Administrative control, which includes, but is not limited to, the plan of organization and the

procedures and records that are concerned with the decision processes leading to the

management’s authorization of transactions; and

2. Accounting control, which includes the plan of organization and the procedures and records that

are concerned with the safeguarding of assets and the reliability of financial records and are

consequently designed to provide reasonable assurance that:

a. Transactions are executed in accordance with management’s general and specific

authorization, which shall include the requirements of these standards;

b. Transactions are recorded as necessary to permit preparation of financial statements in

conformity with generally accepted accounting principles and with these standards and to

maintain accountability of assets;

c. Access to the assets is permitted only in accordance with management’s authorization,

which shall include the requirements of these standards; and

d. The recorded accountability for assets is compared with existing assets at reasonable

intervals, and appropriate action is taken with respect to any differences.



SECTION A

GENERAL PROVISIONS


B. The gaming operation’s system of internal control shall provide for:

1. Competent personnel with an understanding of prescribed procedures; and

2. The segregation of incompatible functions so that no employee is in a position to perpetrate and

conceal irregularities in the normal course of his or her duties.

VIII. Responsibility to Report Violations to the Tribal Gaming Commission

All internal auditors of the gaming operation, financial statement auditors, Tribal Gaming Inspectors, and

employees of the Casino are required to report any violation of the Casino ICS to Casino management and

to the Tribal Gaming Commission. Deviations that violate the ICS may result in disciplinary actions.

Tribal Gaming Inspectors shall report instantly any violations of the Tribal State Gaming Compact or of

applicable law by any person, whether or not such person is associated with any tribal gaming activity or

operation, to the Tribal Gaming Commission, which shall forward such reports to the State Gaming

Agency. (Compact §10 (b))

IX. Changes to Casino ICS

Before the operator receives Tribal Gaming Commission approval for initial ICS and changes to the

approved ICS, the operator shall comply with the following procedures for requesting approval of changes

to the ICS. The operator shall not alter the approved ICS unless and until the Tribal Gaming Commission

approves such changes and evidence such approval in writing. The Kansas State Gaming Agency shall

receive a copy of the Casino internal controls for approval, as required by the Compact. (Compact §7 (a))

X. Definitions of Types of Changes to ICS

A. Changes required by the Tribal Gaming Commission shall be enacted immediately.

B. Each proposed change to the ICS shall be classified per category and each category shall be

submitted separately. The categories are Substantive, Administrative, New Games, and Emergency.

These categories are defined as follows:

1. Emergency would represent a change to the ICS that if not approved and implemented by a

given date would negatively impact the internal controls or cause serious interruption to gaming

activities. Changes designated as Emergency may be submitted for approval at any time. (The

emergency classification of changes to the ICS is expected to be rare.)

2. Substantive would be a change to the ICS that affects the method of complying with the

TC3MICS.

3. Administrative would be a change to the ICS that is editorial, clarifies procedures or changes

position descriptions or titles, but has no effect on the existing ICS.

4. New Games represents internal control changes needed before the operator shall run a Tribal

Gaming Commission and State Gaming Agency approved game, which was not previously

included in the TC3MICs, ICS and Compact.

XI. Timing of Submission of Changes to ICS

The operator shall be permitted to submit requested Substantive, Administrative or New Games changes to

the ICS once each calendar quarter during the first seven (7) gaming days of each calendar quarter. These

requests for change shall be submitted to the Tribal Gaming Commission.



SECTION A

GENERAL PROVISIONS


XII. Method for Gaming Operations to Submit Proposed Changes to ICS

A. A gaming operation shall comply with the following provisions to propose changes to the ICS. No

changes shall be implemented by a gaming operation until written approval by the Tribal Gaming

Commission and said approved changes are submitted for approval to the State Gaming Agency.

1. Each request for change shall contain redlined copies of the pages of the ICS proposed to be

changed. A letter requesting approval for the changes and the reason for the change shall

accompany the changes. One redlined and one clean copy of the pages shall be delivered to the

Tribal Gaming Commission. After approval by the Tribal Gaming Commission, the approved

submission will be sent to the State Gaming Agency. (Compact§7(a))

2. Any proposed modifications and changes shall require that all tables of contents, references,

and indexes are updated, if applicable.

3. The gaming operation shall keep a log of all approved ICS changes. At a minimum this log

should include:

a. The page number,

b. Revised date, effective date, and

c. Change number.

4. Each changed page shall include the revision and Tribal Gaming Commission approval dates.

5. Any changes, which are required to be made as a result of an independent certified public

accounting firm's audits and related reportable conditions, shall be submitted at the next

submission date following the issuance of the auditor's report.

6. The Tribal Gaming Commission shall maintain the control document of the Casino internal

control standards. As changes are approved, the Tribal Gaming Commission shall make such

changes and ensure that all parties shall receive a revised copy.

XIII. Tribal Gaming Commission Approval Procedures

A. After receipt of the proposed changes, Tribal Gaming Commission staff shall read each proposed

change to determine that it is complete, carefully prepared, and that extensive comments are not

necessary.

B. The Tribal Gaming Commission staff shall proceed with a detailed review to determine compliance

with the Commission, the Compact, and that the ICS are consistent with the overall TC3MICs.

1. When revised pages of a change are resubmitted, the proposed changes shall not include further

new changes to the ICS. If new changes are requested, these pages shall be submitted as a new

change at the next submission date within the specified time periods.

2. When changed pages are resubmitted after revisions only those pages that require additional

revisions shall be resubmitted, and the revision date on all pages of the change shall be updated

to coincide with the revised submission date.

3. When the Tribal Gaming Commission approves a change, a letter of approval from the Tribal

Gaming Commission shall be delivered to the gaming operation, with a finalized (clean) and

red-lined copy of changes sent to the State Gaming Agency. (Compact§7(a))

4. The effective date shall be stated in the aforementioned letter.

5. The Tribal Gaming Commission may reject or disallow any proposed modifications or changes

at its discretion.

C. The General Manager and/or one individual of the operation designated by the General Manager

shall be assigned the responsibility for submitting ICS changes to the Tribal Gaming Commission. A

letter should be on file with the Tribal Gaming Commission stating who this individual shall be. If

said responsibility is designated to a different individual, an updated letter shall be mailed to the

Tribal Gaming Commission. If a submission is received from any other individual, the submission in

its entirety shall be returned.



SECTION A

GENERAL PROVISIONS


XIV. Additional Approval Procedures

A. In addition to complying with the TC3MICs, the operator shall comply with the Compact between

the Prairie Band Potawatomi Nation and the State of Kansas. (Compact §10, §12)

B. These regulations (TC3MICs) include general names for positions and forms. The Casino's ICS shall

include specific position titles, formal names and license numbers.

C. When the term "non-gaming employee" is used throughout these TC3MICS, an approved "non-

gaming employee" shall be a member of the food and beverage personnel, valet, maintenance and

housekeeping, and other personnel as determined by the Tribal Gaming Commission.

D. The lowest level of employee with the authority for that employee's respective duty should be listed

in the procedures. Employees with higher authority within the same department may perform these

duties, except where specifically noted in the TC3MICs. When a higher level employee performs the

duties of a lower level employee, he/she shall not perform verification of his/her own work.

E. Sensitive areas are those areas that the Tribal Gaming Commission considers susceptible to potential

weaknesses in the ICS of the Casino's operation and, therefore, require strict control over access (i.e.,

pits, count rooms, cages, surveillance rooms, and vaults).

F. The Casino ICS shall include:

1. Organizational charts for the management contractor or operator and the Tribal gaming

operation from the Board of Directors directly down to any Indian Gaming Division and for all

Tribal gaming operation operational departments including:

a. Live games,

b. Gaming machines,

c. Drop and count team participants,

d. Casino cashiering,

e. Internal audit,

f. Casino accounting,

g. Surveillance,

h. Security,

i. Purchasing and contract administration, and

j. Management information systems on site, off site and in or at all other integrated

locations.

2. The organizational charts shall include both the title description AND the name of the

individual filling that particular position with changes in individuals updated as these changes

occur.

3. Detailed job descriptions of each of the Casino employee positions shown on the organizational

charts, which shall include:

a. Duties and responsibilities,

b. Immediate supervisor,

c. Signatory ability including alternate procedures in cases in which the required signatory is

unable to perform his/her duty, and

d. Access to sensitive assets and areas.

4. Types of training employees receive regarding the Tribal Gaming Commission, the Casino's

ICS and procedures in a brief outline or general description.

5. All manual procedures and forms, as well as computerized procedures and forms, if applicable,

shall be described throughout the ICS.



SECTION A

GENERAL PROVISIONS


G. Vendors, guests, and all operator affiliated officers, executives, internal auditors and other employees

shall not have unaccompanied access to sensitive areas of the Casino.

1. If a reason exists for such person or persons to access a sensitive gaming area, the Tribal

Gaming Commission shall be notified and give written permission prior to each access.

2. A Tribal Gaming Commissioner or Inspector shall accompany such person or persons while in

any sensitive gaming area.

3. A Tribal Gaming Commissioner or Inspector shall also accompany such person or persons into

the surveillance room.

4. Procedures to allow for these accesses shall be included in the ICS.

5. All occupational licensees shall wear Tribal Gaming Commission issued identification badges

at all times unless otherwise authorized by the Tribal Gaming Commission. All licensees are to

use only the license number issued by the Tribal Gaming Commission for identification

purposes in gaming operations.

6. Non-gaming employees shall be the responsibility of the manager. (See also Section XVI (I))

a. Sufficient records shall be maintained on all non-gaming employees.

b. Records shall be subject to audit on a regular basis.

c. The manager shall provide appropriate identification badges approved by the Commission

for access to only the defined Casino areas.

d. The Commission shall receive a list of non-gaming employees of the manager with

updates daily if such is necessary.

e. Levels of access to the facility for employees shall be provided while employees are on

the Reservation.

f. See also Section XVII, (G).

H. The Commission may investigate suspected misconduct of employees of the gaming facility who are

not gaming employees but who are employed in ancillary facilities located within the same building

as the gaming facility. If the Tribal Gaming Commission determines that the conduct of any

employee in the course of the employee's employment in such ancillary facilities poses a threat to

the effective regulation of gaming or creates or enhances the dangers of unfair or illegal practices,

methods and activities in the conduct of gaming, such employee shall be dismissed by the Tribe

from such employment with notification to the State Gaming Agency. (Compact §16 (D))

I. All promotions shall be submitted to the Tribal Gaming Commission for approval using approved

templates.

J. All changes to the gaming floor, with the gaming floor changes shown in diagram and narrative, shall

be submitted to the Tribal Gaming Commission for approval. The Gaming Commission will forward

a copy to the State Gaming Agency.

XV. Tips and Gratuities

A. No gaming employee shall accept currency as a tip or gratuity from any patron unless the Casino

allows such a practice and has provided procedures for accepting such tip or gratuity in its internal

control standards, which have been approved by the Tribal Gaming Commission.

B. SECURITY, ACCOUNTING AND SURVEILLANCE EMPLOYEES ARE PROHIBITED FROM

ACCEPTING TIPS IN ANY FORM.

C. NO EMPLOYEE SHALL SOLICIT ANY TIP OR GRATUITY.

D. No gaming key person or any other employee who serves in a supervisory position shall accept tips

or gratuities from a patron.



SECTION A

GENERAL PROVISIONS


E. Tip bets placed by the patron for the dealer shall not remain in action, unless the bet is won, then the

dealer shall immediately place the tip in the tip box. In case of a tie, the bet may be allowed to

remain in action as a patron option.

F. All tips and gratuities given to dealers, cage cashiers, and gaming machine attendants shall be:

1. Immediately deposited into a transparent locked box reserved for that purpose;

2. Distributions to dealers, cage cashiers, and gaming machine attendants from this pool shall be

made following the Casino's payroll accounting practices and shall be subject to all applicable

state and federal withholding taxes; and

3. Management shall develop procedures for the drop, count, recordation and distribution of tips

for approval by the Tribal Gaming Commission.

G. If non-value chips are received by a Roulette tab, the marker button indicating their specific value

shall not be removed from the slot or receptacle attached to the outer rim of the Roulette wheel until

after a Dealer, in the presence of a Games Supervisor has converted them into value chips which are

subsequently deposited into the tip box.

H. Upon receipt from a patron of a tip or gratuity, a Dealer assigned to the gaming table shall extend

his/her arm, tap the gaming chip on the table and deposit such tip or gratuity in the tip box reserved

for such purpose.

I. Employees who are used exclusively for serving food and beverages, valet, and/or positions

providing a service to patrons who are not considered gaming employees for purposes of this rule,

are required to maintain a log of tips and gratuities received for purposes of filing correct state and

federal tax returns.

1. These employees shall report on a daily basis the amount of their tips on their time cards or

other manner approved by the employer, which shall be subject to all applicable state and

federal withholding taxes.

2. Note: If tips are already pooled, this section does not apply or the Casino may calculate tips in

other methods approved by the Internal Revenue Service (IRS).

J. Additionally, a log listing the employee, the date, and that employee's social security number shall be

maintained in the main casino cage.

1. The names of those employees exchanging chips and/or tokens received as tips or gratuities

shall be filled out by the cashier upon the exchange and initialed by the employee.

2. The log shall be submitted to and maintained by the accounting department.

3. A December 31 year-end total-per-employee of these transactions shall be maintained and are

included as part of the reporting requirements of the Tribal Gaming Commission.

XVI. Gaming Chip and Token Handling Procedures

Management shall develop and implement procedures for gaming chip and token handling, which include

proving gaming chips and gaming tokens, sizing gaming chips, and counterfeit currency procedures. The

standard set forth in the proving of gaming chips and gaming tokens, (breakdown, cut out, etc.) shall be

adopted by all departments, so as to be easily distinguishable by supervisory personnel, the Surveillance

Department and Gaming Commissioners and Inspectors. These procedures shall be incorporated in the

Casino internal control standards.

XVII. W2G Issuance Standards

Only the player who actually won the jackpot may claim or accept the winnings. All departments under the

requirement of filing a W2G shall see the Federal Tax Reporting Section.



SECTION A

GENERAL PROVISIONS


XVIII. Cashing-In/Prize Payouts

A. The Casino shall comply with all applicable provisions of the Internal Revenue Code including, but

not limited to the prompt filing of any cash transaction reports, W-2G reports and any 1099 reports

that may be required by the Internal Revenue Service of the United States or under the Compact.

B. The patron shall be required to produce an identification card confirming information required by the

forms prior to completion of the transaction, e.g. acceptance of cash or disbursement of winnings. A

Social Security card need not be presented to verify a patron's Social Security Number.

XIX. Forms, Records, Documents, and Retention

A. All information required by the system of internal controls shall be placed on a form, record, or

document or stored in data in ink, on a computer disk or other permanent form.

B. Sensitive forms shall be sequentially pre-numbered using numeric or alpha numeric coding schemes.

Only one iteration of a series of numbering shall be used in a fiscal year.

C. Whenever duplicate or triplicate copies are required of a form, record, or document:

1. The original, duplicate, and triplicate copies shall be color-coded;

2. Forms, records, or documents that are required to be inserted in a locked dispenser shall be

maintained with the last copy being retained in a continuous unbroken form in the dispenser;

3. When exceptions are noted regarding forms or serial numbers of forms required to be accounted

for or copies of forms required to be compared for agreement, the Tribal Gaming Commission

shall receive immediate written notification of said exceptions. Once the investigation is

completed, the Tribal Gaming Commission shall receive immediate and timely notification.

D. Unless otherwise specified or exempted by the Tribal Gaming Commission, all forms, records, and

documents and stored data required to be prepared, maintained, and controlled shall:

1. Have the title of the form, record, document, or stored data imprinted or pre-printed thereon or

therein;

2. Be located on Prairie Band Potawatomi Nation lands or such other location as approved by the

Tribal Gaming Commission. The State Gaming Agency shall be notified in writing of the

location of the records; and

3. Be retained for a period of at least five (5) years in a manner that assures accessibility to

Inspectors, Commissioners, personnel of the State Gaming Agency and other authorized

individuals.

E. The following logs (written or computerized) shall be maintained and be available for inspection by

the Tribal Gaming Commission and the State Gaming Agency in accordance with the Kansas State

Compact:

1. A surveillance log, recording all surveillance activities in each monitoring room of the gaming

operation;

2. A security log, recording all unusual occurrences for which the assignment of a security

department employee is made;

3. A cashier’s cage log, recording all exchanges of gaming chips for cash by persons who cannot

reasonably be thought to have been gaming;

4. A machine entry log, recording all occasions on which electronic gaming equipment is opened

by any mechanic or attendant, except to the extent that such entries may be automatically

recorded by a computer system activated by each entry; and

5. A machine location log, recording the location and each movement of any electronic gaming

equipment within the gaming operation. (See also Compact Appendix A)



SECTION A

GENERAL PROVISIONS


XX. Signatures

A. All signatures required on forms, records, and documents outlined in the Internal Controls shall:

1. Include at a minimum, the signer's first initial and last name in the same manner as recorded on

a signature control record maintained in the Tribal Gaming Commission office and income

control department;

2. Be immediately adjacent to the signer's Tribal Gaming Commission license number. A license

number issued by the Prairie Band Potawatomi Tribal Gaming Commission is the only valid

identification number to be used in gaming operations and activities; and

3. Signify that the signer has prepared forms, records, and documents, and/or authorized to a

sufficient extent to attest to the accuracy of the information recorded thereon, in conformity

with the system of internal controls.

B. Signature records shall be prepared for each person required by these standards to sign or initial

forms, records, and documents. The records shall:

1. Include specimens of signatures and initials of signers;

2. Be maintained on a dated signature card file, alphabetically by name;

3. Be adjusted on an immediate basis to reflect changes in personnel with simultaneous (within the

hour) notification to the Tribal Gaming Commission.

C. Signature records shall be securely stored concurrently in the Tribal Gaming Commission Office and

Income Control Department. Records maintained by the Tribal Gaming Commission are the control

documents. (See also Compact)

XXI. Gaming Restrictions

A. No patron under the age of twenty-one (21) years shall be permitted on the gaming floor except

while going to/from the hotel and designated eating areas.

B. All employees shall be responsible for checking IDs to assure compliance.

XXII. Public Health and Safety

A. Compliance: The construction, maintenance and operation of the tribal gaming facility shall comply

with the most recent edition of:

1. The Uniform Building Code;

2. The Uniform Mechanical Code;

3. The Uniform Plumbing Code;

4. The Uniform Fire Code;

5. The National Electric Code;

6. The Americans with Disabilities Act;

7. Public health standards for food and beverage handling in accordance with United States Public

Health Service requirements; and

8. Other applicable local building codes and standards.

B. Emergency Service Accessibility: The Tribal Gaming Commission shall make provisions for

adequate emergency accessibility and service.

C. Alcoholic and Cereal Malt Beverages: No alcoholic or cereal malt beverages shall be served or

consumed on any gaming floor, nor anywhere within the gaming facility between the hours of 2:00

a.m. and 9:00 a.m. Sale, possession and consumption of alcoholic and cereal malt beverages in the

gaming facility shall be regulated pursuant to state law as provided in 18 U.S.C. 1161.



SECTION A

GENERAL PROVISIONS


D. Unemployment Compensation/Workers Compensation: All key employees, standard gaming

employees and non-gaming employees shall be covered by Unemployment Compensation and

Workers Compensation benefits equivalent to that provided by state law.

E. Consultation with Local Authorities: The Tribe shall consult with appropriate state and county

officials concerning maintenance and safety of roads, bridges and other infrastructure made

necessary by implementation of this Compact. (Compact §26)

XXIII. Related Party Transactions

A. Any transactions over $500.00 between the operator or key employees of the operator for items,

services or contracts for the Casino that are considered related parties shall require Gaming

Commission approval prior to commencement of each transaction unless the party has a current

license or waiver with the Gaming Commission. Such transactions shall require in submission to the

Gaming Commission:

1. Name of the related party,

2. Amount of the transaction or payment under contract,

3. Items, services or terms of contract, and

4. How was fair market value established for the items, services or contracts.

B. Transactions under $500.00 shall be reported to the Commission not less than monthly



SECTION B

GAMING MACHINE STANDARDS


I. Gaming Machine Standards

A. Gaming Machine (EGD) Standards

1. Gaming Machines are Electronic Gaming Devices (EGDs). (See Definitions)

2. The procedures for the collection of the gaming machine drop and count thereof shall comply with

Section D. Drop and Count Standards. (NIGC§542.13(c)

3. Management contractors and operators shall comply with the Technical Standards. The Technical

Standards document along with its Attachment A and Attachment B is affixed to the

Tribal Gaming Commission Minimum Internal Controls. (Compact Appendix A and B)

4. A Computerized Ticket Validation System is approved in the Technical Standards. (See Technical

Standards)

5. Ticket In/Ticket Out (TITO) is approved for gaming machines meeting or exceeding the tenets of the

Technical Standards. (Technical Standards)

6. For this section only, credit or customer credit shall mean a unit of value equivalent to cash or cash

equivalents deposited, wagered, won, lost or redeemed by a customer or player.

(NIGC§542.13(a)(1)) (See also Game Credit)

7. Coins shall include tokens. (NIGC§542.13(a)(2)) (Technical Standards)

8. For any computer applications utilized, alternate documentation and/or procedures that provide at

least a level of control described by the standards in this section, as approved by the Tribal Gaming

Commission, will be acceptable. (NIGC§542.13(b))

II. Jackpot Payouts and Hopper Fills

A. The computerized gaming machine monitoring system shall be utilized to generate jackpot and fill slips.

Jackpot and fill slips shall be prepared manually when the computerized system malfunctions or is

unavailable.

B. Computer generated jackpot payouts and hopper fill slips shall use two-part forms.

C. Manual jackpot/fill slips shall use three-part forms, in a continuous numerical series and shall be pre-

numbered.

D. Un-issued manual jackpot/fill slips shall be stored within the casino warehouse in a secured area. The

receipt and issuance of jackpot/fill slips shall be logged to ensure slips are issued in numerical sequence.

Issued jackpot/fill slips shall be stored in a locked cabinet in Income Control until transfer to the Casino

Cage.

E. Computerized and manual jackpot/fill systems shall be restricted so as to prevent unauthorized access

and fraudulent payouts by one individual. (NIGC§542.13(d)(3))

1. The gaming operation shall establish, and the Tribal Gaming Commission shall approve, procedures

for controlling and routing payout forms in such a manner as to preclude any one individual from

producing a fraudulent payout by forging signatures or by altering the amount paid subsequent to the

payout and misappropriating the funds. (NIGC§542.13(d)(4))

2. Manual jackpot/fill slips shall be inserted into a locked dispenser. The dispenser shall allow the

original and the duplicate to be removed by the Cage Cashier while the triplicate remains secured

within the dispenser. Should a dispensing machine experience a jam, Security or

accounting/auditing personnel shall be called to clear the jam in the presence of Casino Cage

personnel after notifying a Tribal Gaming Inspector.

3. Access to the computerized system shall be controlled by both passwords and terminal restrictions.

Once the computerized jackpot or fill slip is printed, the stored data copy within the computerized

system shall not be changed or removed by any personnel, with the exception of accounting/auditing

personnel to make corrections.



SECTION B



F. At the time the jackpot is registered, the computerized gaming machine system shall send an electronic

signal with the jackpot information to the computer monitor located near the Casino Cage and/or

designated gaming machine floor terminal.

G. The jackpot payout and hopper fill slips (both computerized and manual) shall include the following

information: (NIGC§542.13(d)(1))

1. Date and time; (NIGC§542.13(d)(1)(i))

2. Machine number location; (NIGC§542.13(d)(1)(ii))

3. Machine denomination;

4. Numeric dollar amount of jackpot payout or gaming machine fill. The manual slips shall also

include the alpha dollar amount or description of personal property awarded, including fair market

value. Alpha is optional if another unalterable method is used for evidencing the amount of the

payout; (NIGC§542.13(d)(1)(iii))

5. Game outcome (including reel symbols, card values, suites, etc.) for jackpots payouts. Game

outcome shall not be required if a computerized fill system is used; (NIGC§542.13(d)(iv))

6. Preprinted or concurrently printed sequential number; and (NIGC§542.13(d)(v))

7. Signature of Cashier issuing the funds and at least two employees verifying and witnessing the

payout or gaming machine fill (except as otherwise provided in paragraph II.H. of this section.

(NIGC§542.13(d)(1)(vi))

H. Jackpot payouts of $10,000 or more shall require the radio notification of a Tribal Gaming Inspector, the

signature and verification of a Gaming Machine Shift Manager or manager on duty or Class III Category

I Gaming Management. Jackpots of $25,000 or more shall require the signature and verification of a

Gaming Machine Shift Manager or manager on duty or Class III Category I Gaming Management and a

Tribal Gaming Inspector. These predetermined amounts shall be documented and maintained by

management. (NIGC§542.13(d)(vi)(A))

1. With regard to jackpot payouts and hopper fills, the signature of one employee is sufficient if an on-

line accounting system is utilized and the jackpot or fill is less than $1,200.

(NIGC§542.13(d)(vi)(B))

2. On graveyard shifts (eight-hour maximum) payouts/fills less than $100 can be made without the

payout/fill being witnessed by a second person. (NIGC§542.13(d)(vi)(C))

I. Guest winnings under $500 may be paid in either cash or check. Winnings of $500 or more may be paid

by either cash or check, or a combination of both, at the discretion of the guest.

J. Automated jackpots and fills can only be voided in the system by the Cashier Supervisor or Cage Shift

Manager.

1. The authorization ID, document number, and machine number shall be required to void the entry in

the computerized system.

2. The Cashier shall clearly mark "void" across the face of the original and first copy of the computer

generated jackpot or fill slip.

3. The cashier and a gaming machine employee shall be required to sign both copies.

4. These two parts shall be then forwarded to accounting/auditing personnel for accountability and

retention.

K. When a manual fill or credit slip is voided, the Cashier shall clearly mark "void" across the face of the

original and first copy. The Cashier and one other person involved in the transaction then sign these

copies. These two parts shall be then forwarded to accounting/auditing personnel for accountability and

retention.

L. The two parts/three parts of each computer generated/manual jackpot/fill slip shall be distributed as

follows:



SECTION B



1. One part shall be issued with the funds to the gaming machine supervisor or gaming machine

attendant to make the payout and after the appropriate signature(s) are obtained, deposited in the

locked accounting box. NOTE: The accounting box shall not be accessible to Casino Cage

personnel.

2. One part shall be retained in the Casino Cage for reconciliation of the fill bank. (computer/manual)

3. One part shall be retained intact by the locked machine and thereafter in a continuous unbroken

form. (manual only)

M. Coins and tokens distributed to gaming machines for hopper fills shall be transported to the machine by

the Gaming Machine Technician, Gaming Machine Attendant, a Security Department representative,

hard count/impressment specialist or a gaming machine manager in secured bags containing loose coin or

tokens.

N. The opening of the secured bag and deposit of the coin or tokens into the gaming machine hopper shall

be witnessed by an approved verifier who shall sign the duplicate hopper fill slip.

1. Approved verifiers shall be detailed by job title within the Casino ICS.

2. The machine access shall be noted on the "Machine Entry Authorization Log" inside the gaming

machine.

3. The duplicate fill slip shall then be deposited into the locked accounting box for subsequent

reconciliation to the original copy.

O. For short pays of $10.00 or more, the payout form (customer dispute) shall include:

(NIGC§542.13(d)(2))

1. Date and time; (NIGC§542.13(d)(2)(i))

2. Machine number; (NIGC§542.13(d)(2)(ii))

3. Dollar amount of payout (both alpha and numeric); (NIGC§542.13(d)(2)(iii))

4. Signature of at least one employee witnessing and verifying the payout; (NIGC§542.13(d)(2)(iv))

5. Signatures of at least two employees verifying and witnessing the payout for payouts of more than

$50.00; (NIGC§542.13(d)(2)(iv)(A))

6. Alternatively, if an on-line accounting system is used, the signature of one employee is sufficient if

the amount is less than $3,000.00. (NIGC§542.13(d)(2)(iv)(A))

P. For promotional payouts and awards that are not reflected on the gaming machine pay table, the payout

form/documentation shall include the following information: (NIGC§542.13(e)(1))

1. Date and time; (NIGC§542.13(e)(1)(i))

2. Machine number and denomination; (NIGC§542.13(e)(1)(ii))

3. Dollar amount of payout (both alpha and numeric), and/or a description of personal property,

including fair market value; (NIGC§542.13(e)(1)(iii))

4. Type of promotion (e.g., double jackpots, four-of-a-kind bonus, etc); and (NIGC§542.13(e)(1)(iv))

5. Signatures of at least two employees verifying and witnessing the payout using a sequentially

numbered form. (NIGC§542.13(e)(1)(v))

III. Bill Validator/Ticket Reader/Ticket Printer Access

A. The coins and currency compartment as well as the compartment in which tickets are collected shall be

locked separately from the main cabinet area, and secured with a different key or combination than that

used for the main cabinet door, except that a separate cash compartment shall not be required for coins or

tokens necessary to pay prizes in a machine which pays prizes through a drop hopper as permitted in this

section.

B. Keys to gain access to drop the acceptor compartment must be different from those to gain access to the

contents of the acceptor compartment.



SECTION B



C. Coin drop, bill acceptor and ticket compartment keys must be kept in a secure location. Except as

provided in this section, the compartment in which the inserted coins, tokens, bills, and tickets are

deposited shall be locked at all times.

D. A log is to be kept indicating the number of times the coin/cash/ticket compartments and ticket printers

or readers have been cleared, refilled or have been opened, including the date and time.

E. A Commissioner or Inspector must be present when the coin drop, bill acceptor, and ticket compartments

in the gaming cabinet are opened for the purpose of collecting the accumulated cash and tickets. Others

accessing these areas will be as approved by the Commission.

IV. Gaming Machine Department Funds Standards

A. The Gaming Machine booths, kiosks and change banks shall be maintained at imprest levels.

1. Kiosks that have been active during a gaming day shall be counted and reconciled no less than at the

end of each gaming day.

2. The gaming machine booths and change banks that are active during the shift shall be counted down

and reconciled each shift by two employees utilizing appropriate accountability documentation.

Unverified transfers of cash and/or cash equivalents are prohibited. (NIGC§542.13(f)(1))

3. The counts shall be performed by the off-going and on-coming gaming machine attendant or gaming

machine supervisor (as applicable) and shall be documented on a count sheet. (NIGC§542.13(f)(1))

4. The count sheets shall be signed by both individuals involved in the count of the funds.

(NIGC§542.13(f)(1))

5. Funds transfer documents may be counted as funds in cases where the Main Bank cannot fill an

order before the end of the shift.

B. Cash variances shall be documented on a two-part gaming machine Variance Slip. This form shall be

signed by the gaming machine attendant and the gaming machine supervisor who verifies the outage.

The bank shall then be brought back to imprest by "selling" the Over/Short voucher to the Casino Cage.

C. All Cage redemption coin shall be wrapped, bagged or racked in the hard count room either before or

after the proceeds of the daily gaming machine drop. The wrapping of loose gaming machine booth and

cage cashier coin shall be performed at a time and location that does not interfere with the hard

count/wrap process or the accountability of that process. (NIGC§542.13(f)(2))

1. Transfers of unwrapped coin shall be documented on "Funds Exchange" forms. The forms shall be

signed by the employees involved in the transaction and taken to the Casino Cage.

2. A record shall be maintained evidencing the transfers of wrapped and unwrapped coin and retained

for at least 7 days. (NIGC§542.13(f)(3))

V. EPROM or Other Equivalent Media Standards

A. EPROMs shall include EPROMs or any other equivalent game software media. (NIGC§542.13(g))

B. The gaming operation shall develop, obtain Tribal Gaming Commission approval, and implement

procedures that include all of the following requirements. These procedures shall be documented in the

Casino internal control standards and include procedures for at least the following:

1. Receipt of EPROMs. (NIGC§542.13(g)(2)(iv))

a. EPROMs shall be shipped directly to the Tribal Gaming Commission. As EPROMs are received,

they shall be checked and witnessed by two Tribal Gaming Commission employees.

(NIGC§542.13(g)(2)(iv))

b. The EPROMs shall then be delivered to the Tribal Gaming Inspectors by the Gaming Commission,

who shall either secure the EPROMs in the EPROM cabinet or secure the EPROMs in the

Inspector’s Office until the EPROMs is kobetroned prior to being placed in a gaming machine.



SECTION B



c. The EPROM master game program number, par percentage, and the pay table shall be verified

to the par sheet when initially received from the manufacturer. (NIGC§542.13(g)(3))

2. Copying and verification of duplicated EPROMs before being offered for play. (NIGC§542.13(g)(2)(ii),

(iii))

a. Duplication of EPROMs shall require written approval from the Tribal Gaming Commission. In

addition, the Tribal Gaming Commission shall secure the duplicator. Duplicators shall not be

allowed on the casino premises without prior approval and/or knowledge of the Tribal Gaming

Commission. All duplication processes shall involve a Tribal Gaming Commissioner or Inspector,

to include verification via Kobetron. (NIGC§542.13(g)(2)(ii))

b. Duplication of gaming device program storage media (EPROM) shall be required when the

gaming machine department is going to replace EPROMs on the gaming floor.

c. Prior to duplicating, methods shall be implemented to ensure that EPROMs or other game

software media that have been previously programmed are blank prior to reprogramming.

d. Prior to being placed in a gaming machine for play, the duplicated EPROM shall be verified.

(NIGC§542.13(g)(2)(iii))

e. EPROM programs shall be copied with the use of an EPROM duplicator. The Tribal Gaming

Commission shall authorize all duplications of EPROMs.

f. Tribal Gaming Inspector and an employee of the Gaming Machines Department will verify

EPROMs prior to going live on gaming floor with duplicated EPROMs.

3. Securing the EPROM, duplicator, and master game EPROMs, from restricted access.

(NIGC§542.13(g)(2)(v))

a. All program EPROMs, payable EPROMs and any other EPROMs, which may affect the game

outcome, shall be either sealed with a pre-numbered seal to the logic board or secured in another

manner by Tribal Gaming Inspectors to prevent and make evident if there has been unauthorized

access. (NIGC§542.13(g)(4)) (NIGC§542.13(g)(2)(v))

i. Seal numbers used to secure the board to the frame of the gaming device shall be

maintained by the Tribal Gaming Inspector.

ii. The seals shall be labeled with the date, the signature and the license number of the

Tribal Gaming Inspector. (NIGC§542.13(g)(5)(viii))

iii. The seal numbers shall be recorded and maintained by the Tribal Gaming

Inspectors.

b. The key to accessing the logic board shall be maintained by the Tribal Gaming Commission. A

gaming machine technician and a Tribal Gaming Inspector shall observe each time a gaming

machine EPROM is accessed.

c. Only the Tribal Gaming Commission, or their designated Tribal Gaming Inspector(s), shall secure

the EPROM duplicator and master EPROMs from unrestricted access in a locked and secured area.

d. EPROMs returned to gaming devices shall be labeled with the program number. Supporting

documentation shall include the date, program number, information identical to that shown on the

manufacturer's label, and the initials of the Tribal Gaming Inspector replacing the EPROM.

(NIGC§542.13(g)(6))

4. Removal of EPROMs. (NIGC§542.13(g)(2)(i))

a. Approval shall be required by the Tribal Gaming Commission when the gaming machine

department is replacing an EPROM that controls the game outcome or function.

b. The Tribal Gaming Commission shall provide to the gaming operation procedures for the removal

of EPROMs. (NIGC§542.13(g)(2))

c. Records shall be maintained as to removal, verification, correction and duplication of EPROMs.

5. Verification of the existence of errors as applicable and the correction via duplication from the master

game program EPROMs. (NIGC§542.13(g)(2)(i))

6. Destruction EPROMs. (NIGC§542.13(g)(2)(iv))

a. All failed EPROMs that are not erasable or repairable shall be destroyed using a hammer or other

similar device in the presence of a Tribal Gaming Inspector and in view of surveillance within 72

hours after removal from the gaming machine.

b. A log shall be kept for each EPROM destruction, which shall state the following:



SECTION B



i. Date,

ii. Time,

iii. Number of chips destroyed, and

iv. Signatures of all those present.

v. A notification shall be sent to Tribal Gaming Commission upon destruction of all

EPROMs.

C. Records shall be maintained to document EPROM access. The following shall be recorded by the Tribal

Gaming Inspectors: (NIGC§542.41(g)(5))

1. Date and time; (NIGC§542.13(g)(5)(i))

2. Gaming machine number; (source and destination) (NIGC§542.13(g)(5)(ii))

3. Manufacturer; (NIGC§542.13(g)(5)(iii))

4. Program number; (NIGC§542.13(g)(5)(iv))

5. Signatures of gaming machine personnel involved; (NIGC§542.13(g)(5)(v))

6. Reason for access;

7. Reason for duplication; (NIGC§542.13(g)(5)(vi))

8. Indication whether the EPROM was destroyed and the signature of the gaming machine technician

involved;

9. Disposition of any permanently removed EPROM; (NIGC§542.13(g)(5)(vii))

10. Seal numbers; and (NIGC§542.13(g)(5)(viii))

11. Approved testing laboratory numbers, if available. (NIGC§542.13(g)(5)(ix))

D. For jackpots exceeding a predetermined amount, as determined by the gaming operation and approved by

the Tribal Gaming Commission, the gaming machine EPROM shall be tested for integrity against the par

sheet prior to the payout of the jackpot winnings or at the discretion of the Gaming Commission or

Inspectors.

E. At least annually, procedures shall be performed to insure the integrity of a sample of gaming machine

game program EPROMs, or other equivalent game software media, by personnel independent of the

gaming operation or the machines being tested. (NIGC§542.13(g)(1))

VI. Standard for Evaluating Theoretical and Actual Hold Percentages

A. Accurate and current theoretical hold worksheets shall be maintained for each gaming machine.

(NIGC§542.13(h)(1))

B. For multi-game/multi-denominational machines, an employee or department independent of the gaming

machine department shall: (NIGC§542.13(h)(2))

1. Weekly, record the coin-in total meter; (NIGC§542.13(h)(2)(i))

2. Quarterly, record the coin-in meters for each paytable contained in the machine; and

(NIGC§542.13(h)(2)(ii))

3. On an annual basis, adjust the theoretical hold percentage in the gaming machine statistical report to

a weighted average based upon the ratio of coin-in for each game pay table.

(NIGC§542.13(h)(2)(iii))

C. For those gaming operations that are unable to perform the weighted average calculation as required by

paragraph VI.B. of this section, the following procedures shall apply:

1. On at least an annual basis, calculate the actual hold percentage for each gaming machine;

(NIGC§542.13(h)(3)(i))

2. On at least an annual basis, adjust the theoretical hold percentage in the gaming machine statistical

report for each gaming machine to the previously calculated actual hold percentage; and

(NIGC§542.13(h)(3)(ii))

3. The adjusted hold percentage shall be within the spread between the minimum and maximum theoretical

payback percentages. (NIGC§542.13(h)(3)(iii))



SECTION B



D. The adjusted theoretical hold percentage for multi-game/multi-denominational machines may be

combined for machines with exactly the same game mix throughout the year. (NIGC§542.13(h)(4))

E. The theoretical hold percentages used in the gaming machine analysis reports should be within the

performance standards set by the manufacturer. (NIGC§542.13(h)(5))

F. Gaming machine in-meter readings shall be recorded at least weekly immediately prior to or subsequent

to gaming machine drop. On-line gaming machine monitoring systems can satisfy this requirement.

However, the time between readings may extend beyond one week in order for a reading to coincide with

the end of an accounting period only if such extension is for no longer than six (6) days.

(NIGC§542.13(h)(10))

G. The employee who records the in-meter reading shall either be independent of the hard count team or

shall be assigned on a rotating basis, unless the in-meter readings are randomly verified quarterly for all

gaming machines and bill acceptors by a person other than the regular in-meter reader.

(NIGC§542.13(h)(11))

H. Upon receipt of the meter reading summary, the accounting department shall review all meter readings

for reasonableness using pre-established parameters. (NIGC§542.13(h)(12))

I. Prior to final preparation of statistical reports, meter readings that do not appear reasonable shall be

reviewed with gaming machine department employees or other appropriate designees, and exceptions

documented, so that meters can be repaired or clerical errors in the recording of meter readings can be

corrected. (NIGC§542.13(h)(13))

J. The computerized gaming machine monitoring system shall have the capability to produce, at least

weekly, reports showing week-to-date, month-to-date, year-to-date and life-to-date (if practicable) actual

hold percentage computations for individual machines and a comparison to each machine's theoretical

hold percentage. (NIGC§542.13(h)(14))

K. Each change to a gaming machine’s theoretical hold percentage, including progressive percentage

contributions, shall result in that machine being treated as a new machine in the statistical reports (i.e.,

not commingling various hold percentages), except for adjustments made in accordance with paragraph

VI.B. of this section. (NIGC§542.13(h)(15))

L. If promotional payouts or awards are included on the gaming machine statistical reports, it shall be in a

manner that prevents distorting the actual hold percentages of the affected machines.

(NIGC§542.13(h)(16))

M. The statistical reports shall be reviewed by both gaming machine department management and the

management employees independent of the gaming machine department on at least a monthly basis.

(NIGC§542.13(h)(17))

N. For those machines that have experienced at least 100,000 wagering transactions, variances of three

percent (3%) or more between theoretical hold and actual hold shall be investigated and resolved by a

department independent of the gaming machine department with the findings documented and provided

to the Gaming Commission upon request in a timely notification manner. (NIGC§542.13(h)(18))

O. Maintenance of the on-line gaming machine monitoring system data files shall be performed by a

department independent of the gaming machine department. Alternatively, maintenance may be

performed by gaming machine supervisory employees if sufficient documentation is generated and it is

randomly verified on a monthly basis by employees independent of the gaming machine department.

(NIGC§542.13(h)(19))



SECTION B



P. Updates to the on-line gaming machine monitoring system to reflect additions, deletions, or movements

of gaming machines shall be made at least weekly prior to in-meter readings and the weigh process.

(NIGC§542.13(h)(20))

VII. Computerized Gaming Machine Monitoring System

A. A gaming machine monitoring system shall be used to record and monitor the activities of all gaming

machines. A bill changer interface system is also used to monitor and record the activities of all bill

validators associated with gaming machines. The computer monitoring system provides on-line, real

time monitoring and data acquisition capability.

1. Records shall be maintained for each machine indicating the dates and type of changes made and the

recalculation of theoretical hold as a result of the changes. (NIGC§542.13(h)(6))

2. Records shall be maintained for each machine that indicate the date the machine was placed into service,

the date the machine was removed from operation, the date the machine was placed back into operation,

and any changes in machine numbers and designations. (NIGC§542.13(h)(7))

3. All of the gaming machines shall contain functioning meters that shall record coin-in or credit-in or on-

line gaming machine monitoring system that captures similar data. (NIGC§542.13(h)(8)) (Additional

meter requirements are listed in the Technical Standards, Section C.)

4. All gaming machines with bill acceptors (validators) shall contain functioning billing meters that record

the dollar amounts or number of bills accepted by denomination. (NIGC§542.13(h)(9))

B. The gaming machine monitoring and bill changer interface systems perform the following functions:

1. Record the number and total value of coins, tickets and/or tokens placed in gaming machines, including

wagers from the credit meter for the purpose of activating play.

2. Record the number and total value of coins, tickets and/or tokens deposited in the drop bucket or from

the credit meter of each gaming machine.

3. Record the number and total value of coins, tickets and/or tokens automatically paid by gaming

machines as the result of a jackpot.

4. Record the number and total value of coins, tickets and/or tokens to be paid manually as the result of a

jackpot.

5. Record the total number of dollar bills inserted into the bill validator to make change. Each bill validator

accepts denominations of U.S. currency and is equipped with a separate meter for each denomination.

6. Record the value of tickets wagered.

7. Have an on-line computer alert, alarm monitoring capability to ensure direct scrutiny of any device

malfunction, tampering, and open door on the gaming machine.

8. Be capable of logging in and reporting any revenue transaction not directly monitored by the coin, ticket

and/or token meter, such as coins and/or tokens placed in the gaming machine as a result of a hopper fill.

9. Identify any gaming machine taken off-line or placed on-line in the computer monitoring system,

including date, time, and machine number.

C. For the computerized gaming machine monitoring system, a personnel access listing is maintained which

includes at a minimum: (NIGC§542.13(a)(3))

1. Employee name or employee identification number (or equivalent); (NIGC§542.13(a)(3)(i))

2. Listing of functions employee can perform or equivalent means of identifying same.

(NIGC§542.13(a)(3)(ii))

VIII. Gaming Machine Hopper Contents Standards

A. When machines are temporarily removed from the gaming floor, gaming machine drop and hopper

contents shall be protected to preclude the misappropriation of stored funds and shall be witnessed by the

Tribal Gaming Inspector. (NIGC§542.13(i)(1))



SECTION B



B. When gaming machines are permanently removed from the gaming floor, the gaming machine drop and

hopper contents shall be counted and recorded by at least two employees with appropriate documentation

being routed to the accounting department for proper recording and accounting for initial hopper loads

and shall be witnessed by the Tribal Gaming Inspector. (NIGC§542.13(i)(2))

IX. Gaming Machine Warehouse Standards

When gaming machines are removed from the gaming floor, they shall be stored in a secured location

accessible by authorized gaming machine personnel under surveillance coverage.

X. Ticket Validation Standards

A. See the Technical Standards for gaming machines that utilize tickets approved by the Gaming

Commission, Tribal Council and accepted by the State of Kansas Compact.(Technical Standards)

B. The Gaming Commission shall be notified whenever the ticket validation system is not operating.

(NIGC§542.13(n)(11))

C. In addition to the applicable auditing and accounting standards in Section G Income Control of this

section, on a quarterly basis, the gaming operation shall foot all jackpot tickets equal to or greater than

$1,200.00 and trace totals to those produced by the validation system. (NIGC§542.13(n)(1)) (Technical

Standards)

D. The customer may request a ticket from the gaming machine that reflects all remaining credits. The

ticket shall be printed at that gaming machine by an internal document printer. The ticket shall be valid

for 30 days. (NIGC§542.13(n)(2)) (Technical Standards)

E. Tickets may be redeemed for payment or inserted in another gaming machine accepting tickets and

wagered during the specified valid time period. (NIGC§542.13(n)(2)) (Technical Standards)

1. The player shall redeem the ticket at a kiosk or at the cashier’s cage. The maximum amount that can be

redeemed at the kiosk shall not exceed $1,199.99 (NIGC§542.13(n)(3)) (Technical Standards)

2. Ticket redemption shall follow the requirements provided in the Technical Standards, where those

standards exceed the following:

a. The ticket shall be scanned by an optical reader or manually input into the computer by the Cashier

to communicate the ticket validation number to the central ticket validation system to determine

authenticity. (NIGC§542.13(n)(4) (i)(ii); (NIGC§542.13(n)(5))

b. The host computer shall verify the authenticity of the cash-out ticket and communicate directly to

the redeemer of the cash-out ticket. If the ticket is valid, the player is paid the appropriate amount,

and the ticket is noted as paid in the validation system and the validation system shall electronically

reconcile the cashier’s or kiosk’s banks for the paid tickets. (NIGC§542.13(n)(5) (6))

c. If the ticket is not valid, the ticket validation system shall reject the ticket, if a kiosk, or notify the

cashier and payment shall be refused. The appropriate manager on duty shall be notified and shall

resolve the dispute in either instance. Ticket disputes settled in amounts equal to or greater than

$50.00 shall require an Inspector or Commissioner signature. (NIGC§542.13(n)(7))

d. Cashiers may redeem tickets at the cage when a power or ticket validation system outage is

experienced after recording the following:

i. The ticket number, date and time, dollar amount and gaming machine number are

recorded on the surrendered ticket.

ii. The ticket shall be marked paid in large print across the front face of the ticket such

that optical scan areas are not covered by the print, and the ticket shall remain in

the cashier’s bank.

iii. Tickets shall be validated quickly after reconciliation of cashier’s bank or the

restoration of the power or the ticket validation system becomes available,

whichever occurs first. (NIGC§542.13(n)(8)(i)(ii)(iii)(iv)(v)(vi), (9))



SECTION B



F. Procedures shall be included that control ticket paper as a restricted item if a computerized ticket system

is not used to:

1. Mitigate the risk of counterfeiting ticket paper (NIGC§542.13(n)(10)(i))

2. Control the inventory of ticket paper (NIGC§542.13(n)(10)(ii))

3. Provide for the destruction of unused ticket paper (NIGC§542.13(n)(10)(iii))

4. Alternatively, if a gaming operation uses a computer validation system, this standard will not apply.

(NIGC§542.13(n)(10)(iv))

G. These ticket machine systems shall comply with the standards for bill validator drop and count, standards

for coin and token drop count, and the standards for EPROMs and other equivalent media.

(NIGC§542.13(n)(12))

XI. Progressive Gaming Machine Standards

A. A meter that shows the amount of the progressive jackpot shall be conspicuously displayed at or near the

machines to which the jackpot applies. (NIGC§542.13(k)(1); NIGC§542.13(l)(1))

1. At least once each day, the amount shown on each progressive jackpot meter shall be recorded except

for those jackpots that can be paid directly from a gaming machine's hopper; (NIGC§542.13(k)(2))

2. Explanations for meter reading decreases shall be maintained with the progressive meter reading sheets,

and where the payment of a jackpot is the explanation for a decrease, the gaming operation shall record

the jackpot payout number on the sheet or have the number reasonably available; and

(NIGC§542.13(k)(3))

3. Each gaming operation shall record the base amount of each progressive jackpot the operation offers.

(NIGC§542.13(k)(4))

4. The Tribal Gaming Commission shall approve procedures specific to the transfer of progressive

amounts in excess of the base amount to other gaming machines. Such procedures may also include

other methods of distribution that accrue to the benefit of the gaming public via an award or prize. Such

procedures shall be documented in the Casino internal control standards. (NIGC§542.13(k)(5))

B. Wide area progressive gaming machine systems shall be adequately restricted to prevent unauthorized

access (e.g., changing passwords at least quarterly, access to EPROMs, and physical access to computer

hardware, etc.). (NIGC§542.13(l)(2))

C. The Tribal Gaming Commission shall approve procedures, which shall be documented in the casino ICS,

for the wide area progressive system that: (NIGC§542.13(l)(3))

1. Reconcile meters and jackpot payouts; (NIGC§542.13(l)(3)(i))

2. Collect/drop of gaming machine funds; (NIGC§542.13(l)(3)(ii))

3. Verify jackpot, payment and billing to gaming operations on pro-rata basis; (NIGC§542.13(l)(3)(iii))

4. System maintenance; (NIGC§542.13(l)(3)(iv))

5. System accuracy; and (NIGC§542.13(l)(3)(v))

6. System security. (NIGC§542.13(l)(3)(vi))

D. Reports adequately documenting the procedures required in paragraph XI.C. of this section shall be

generated and retained, with copies being forwarded upon request to the Tribal Gaming Commission.

(NIGC§542.13(l)(4))

XII. Gaming Machine Tournaments

A. A “tournament” shall mean a contest to determine the best player within set parameters such as time

period or amount of credit won.

B. The gaming operation, subject to approval of the Tribal Gaming Commission, shall develop and

implement procedures for all table game and card game tournaments, to include, but not be limited to the

following:



SECTION B



1. Procedures for using gaming machines off the gaming floor, opening cabinets, and using machines in a

"tournament" mode;

2. Controls, including adequate segregation of duties, for the receipt, recording, and reconciliation of

tournament funds;

3. Controls for the receipt, inventory, storage, and destruction of non-value gaming chips or other

tournament items;

4. Procedures for the development of tournament payout structures;

5. Controls for tournament payouts to winning patrons;

6. Adequate documentation of tournament results;

7. Audit procedures for tournament activity, including the reconciliation of tournament funds received and

awarded.

C. Tournament prizes may be donated by the house or come directly from the buy-ins or a combination of both.

Fair market value of merchandise or prize or ticket redemption value amount shall be recorded.

D. All gaming machine tournament accounting procedures and any follow-up performed shall be documented,

maintained for inspection, and provided to the Tribal Gaming Commission upon request.

E. Tournament rules approved by the Tribal Gaming Commission shall be submitted to the State Gaming

Agency for approval.



Section C

TABLE GAME AND CARD GAME STANDARDS


I. Table Games and Card Game Computer Generated Documentation Standards

A. The procedures for the table game drop and count thereof shall comply with Section D, Drop and Count

Standards. (NIGC§542.12(b))

B. The Casino shall submit proposed game rules to the Tribal Gaming Commission for approval prior to the

game being implemented. Changes to game rules are subject to review and approval by the State

Gaming Agency prior to implementation. (Compact Appendix B)

1. Any game rule changes shall also be submitted in like manner prior to implementation.

2. Summaries of the rules of each game relevant to the method of play and odds paid to winning bets shall

be visibly displayed or available in pamphlet form in each gaming location.

3. Betting limits applicable to each gaming table shall be displayed at such gaming table.

C. The computer system shall be utilized to generate adequate documentation of all information recorded on

the source documents and transaction detail (e.g., fill/credit slips, etc.,) (NIGC§542.12(e)(1))

1. Computer system documentation shall be restricted to authorized personnel. (NIGC§542.12(e)(2))

2. Computer system documentation shall include, at a minimum:

a. System exception information (e.g., appropriate system parameter information, corrections, voids,

etc.). (NIGC§542.12(e)(3)(i))

b. Personnel access listing which includes, at a minimum:

i. Employee name or employee identification number (if applicable);

(NIGC§542.12(e)(3)(ii)(A))

ii. Listing of functions employees can perform or equivalent means of identifying the

same. (NIGC§542.12(e)(3)(ii)(B))

c. A computer generated list of the personnel access listing shall be provided to the Tribal Gaming

Commission whenever it is created or updated.

D. For any authorized computer applications utilized, alternate documentation and/or procedures, which

provide at least the level of control described by the standards in this section, as approved by the Tribal

gaming regulatory authority, shall be acceptable. (NIGC§542.12(a); NIGC§542.9(a))

II. Gaming Tables Personnel Assigned to the Operation and Conduct of Gaming

A. The following personnel shall be used to operate the live gaming tables:

1. Dealers shall be the persons assigned to each gaming table (including, but not limited to, Craps,

Baccarat, Blackjack, Roulette, or other banking and non-banking card and dice games) to directly

operate and conduct the game.

2. A table games supervisor shall be the individual assigned the responsibility for the overall supervision of

the operation and conduct of a given game at the table games played within the pits. Table games

supervisors shall oversee a maximum of five table games, within one pit area. In conjunction with

blackjack or poker, these five games shall consist of a maximum of two crap games or two roulette

games. It shall be permissible to include within the five games the simultaneous supervision of one

crap game and one roulette game. The table games manager shall however, utilize Casino

Operations personnel in a manner consistent with the demands of the games in operation (assessing

necessary qualifications) and always in the best interest of the patron, Gaming operation, the Prairie

Band Potawatomi Nation and the State of Kansas. The table games manager shall oversee any

intermediate supervisors assigned by the gaming operation to assist in supervision of table games in

the pits. (NIGC§542.12(h))

3. The table games manager shall be the supervisor assigned to each shift with the responsibility for the

supervision of live gaming tables. In the absence of the Director of Table Games, the table games

manager shall assume authority of the Director of Table Games.



Section C TABLE GAME AND CARD GAME STANDARDS


4. Director of Table Games shall be the executive assigned the responsibility and authority for the

supervision and management of the overall operation of the casino’s live gaming tables including, but

not limited to, the hiring and termination of all table games department personnel and the creation of

high employee morale and good customer relations, all in accordance with policies and procedures

established by the Vice President and/or General Manager.

5. Nothing in this standard shall be construed to limit the tribal gaming operation from utilizing

personnel in addition to those manners described herein.

III. Table Inventories

A. Whenever a gaming station is opened for gaming, operations shall commence with an amount of

gaming chips, tokens and coin to be known as the "table inventory". Gaming tokens, chips or coins

shall only be added or removed from the table inventory during the gaming day:

1. In exchange for cash;

2. In payment of winning wagers and collection of losing wagers made;

3. In exchange for gaming chips or coin received from a patron having an equal aggregate face value;

and

4. In accordance with fill and credit procedures described in these standards.

B. Cross fills (the transfer of chips between table games) and even cash exchanges are prohibited in the pit.

(NIGC§542.12(c)(20))

C. Each respective table inventory and its respective table inventory slip shall be maintained on the gaming

tables in trays. When a gaming table is not open for gaming activity, the trays shall be covered with a

transparent locked game bankroll lid that shall be clearly marked on the outside.

D. The game and table number shall be clearly marked and permanently affixed to the gaming table.

(NIGC§542.41(b)(5))

E. The table inventories and the table inventory slip (opener) shall be stored under the locked game

bankroll lid.

1. The information on the table inventory slip shall be visible from the outside of the cover.

2. All bankroll trays shall be stored either in the cashier's cage during non-gaming hours or secured to

the gaming table subject to arrangements for security approved by the Tribal Gaming Commission.

3. The keys to the locked, game bankroll lids containing the table inventory shall be maintained and

controlled by the Casino Operations Department.

a. The key sets, which contain keys to the bankroll lids, Blackjack shoe drawers, and drawers in the

pit stand, shall be placed in a key box when the gaming pit is closed and signed out via a key

control log to a tables games supervisor or table games manager.

b. At shift change, the outgoing table games supervisor shall relinquish the keys to the incoming

table games supervisor who shall sign for receipt via his/her signature on the Key Control Log. At

the close of gaming activity for the gaming day, the keys shall be returned to the Casino

Operations key box.

c. At no time shall the keys to the game bankroll lids be accessible to any cashier cage personnel or

to any person responsible for transporting gaming chips or coin to or from the gaming station, e.g.

Security Department personnel.





IV. Table Inventory Accountability

A. Table game inventory, including gaming chips and/or coins on the table, will be counted and recorded

either: (NIGC§542.12(d)(1))

1. At the close of each shift (for any tables open during the shift change), or

2. Whenever gaming activity at a gaming table is concluded for the day and the gaming table is to be

closed for any length of time.

B. The gaming chips, token and coin shall be counted and recorded in the table inventory sheet.

(NIGC§542.12(d)(1)(i))

1. The accuracy of the inventory forms prepared at shift end shall be verified by the outgoing table

games supervisor and the dealer. Alternatively, if the dealer is not available, such verification may

be provided by another table games supervisor. Verifications shall be evidenced by signature on the

inventory form. (NIGC§542.12(d)(3))

2. The table games supervisor assigned to the pit shall prepare a three-part table inventory slip, which

shall include the following:

a. Date and drop box shift ended;

b. Game and table number;

c. Total value of each denomination of chips and/or coins remaining at the gaming table; and

d. Total value of all denominations of chips and/or coins remaining at the gaming table.

3. The dealer assigned to the table shall count the contents of the tray in the presence of the table

games supervisor or higher authority assigned to the pit and agree to the count to the table

inventory opener slip located in the tray.

4. Signatures attesting to the accuracy of the information on the opener shall be placed on such opener

by the dealer assigned to the station and the table games supervisor that observed the dealer count

the contents of the container.

5. Corrections on table inventory sheets (openers/closers) shall be made by crossing out the error,

entering the correct figure, and then obtaining the initials of at least two table games employees

who shall attest to the accuracy of the change. If a computer generated reporting system is utilized,

corrections to table games data shall be made using either of the following:

a. Crossing out the error on the document, entering the correct figure, and then obtaining the initials

of at least two table games employees who shall attest to the accuracy of the change. If this

procedure is used, an employee independent of the table games department shall enter the correct

figure into the computer system prior to the generation of related final reports.

b. If the corrections are made by the finance or income control department, the correction(s) shall be

initialed by the individual making the correction.

6. The original of the table inventory slip (Closer) shall be dropped by the Dealer or table games

supervisor taking the place of the unavailable dealer into the drop box attached to the table

immediately prior to the closing of the table. (NIGC§542.12(d)(4))

7. The duplicate of the table inventory slip (Opener) shall be placed in the chip tray in a manner that

once the cover is in place, the amounts on the Opener slip can be read through the clear cover.

8. The triplicate copy of the table inventory slip shall be forwarded to Casino accounting/auditing

personnel via a secured drop box designated for accounting/auditing paperwork.

C. The game bankroll lid shall be locked and secured to the gaming table by the table games supervisor.

1. Table games supervisory personnel are the only persons authorized to unlock the table tray lids.

2. The table games manager shall account for all the locked containers. If the locked containers are

transported to the cashier's cage, a cage cashier shall determine that all locked containers have

been returned.

D. Beginning and ending inventories shall be recorded on the master game sheet for shift win calculation

purposes. (NIGC§542.12(d)(2))





E. When the table is reopened and the inventory verified with both the Dealer and the Supervisor signing

the Opener, the slip shall be immediately deposited in the drop box attached to the gaming table by the

Dealer. (NIGC§542.12(d)(4))

1. Any discrepancy between the amount of gaming chips or coin counted and the amount of the

gaming chips and coins recorded on the opener shall be resolved through established procedures

with a table games manager and Accounting/auditing personnel. An Error Notification Form shall

be completed by the games supervisor who lists the date, table game number, and a description of

the discrepancy. The Error Notification Form shall be signed by the Dealer and the table games

supervisor and dropped into the drop box.

2. All discrepancies shall be immediately reported to a table games manager, Security Department

and the Tribal Gaming Inspector. Security shall complete the standard security report in writing

and provide instant, written notification to the Tribal Gaming Commission. The results of the

investigation performed by accounting/auditing personnel and Table Games Department

management personnel shall be provided to the Security Chief and the Tribal Gaming

Commission.

F. Table games will not be maintained on an imprest basis. (NIGC§542.12(d)(1)(ii))

V. Standards for Transporting Chips and Coin To and From Gaming Tables

A. All gaming chips or coins distributed to the gaming stations from the cashier's cage shall be transported

directly to the gaming stations from the cashier's cage by a Security Department representative (runner)

in a clear covered chip carrier. (NIGC§542.12(c)(8), (16))

B. Chips, tokens, or other cash equivalents shall be deposited on or removed from gaming tables only when

accompanied by the appropriate fill/credit forms. (NIGC§542.12(c)(19))

VI. Fill and Credit Slip Controls

A. Unissued and issued Manual Fill/Credit Slips shall be safeguarded and adequate procedures shall be

employed in their distribution, use and control. (NIGC§542.12(c)(2))

1. Personnel from the cashier or table games (pit) departments shall have not access to the secured

(control) copies of the fill/credit slips. (NIGC§542.12(c)(2))

2. All unissued, controlled forms shall be secured in the Controlled Forms Storage Area. This area

shall only be accessible to the accounting/auditing personnel. (NIGC§542.12(c)(2))

3. The numerical sequence of manual Fill/Credit Slips shall be accounted for by accounting/auditing

personnel, who have no incompatible functions. (NIGC§542.12(c)(2))

4. Manual Fill/Credit Slips shall be inserted into a locked dispenser, to which the key is maintained by

Casino accounting/auditing personnel.

a. Keys shall not be available to Cashier or Table Games personnel.

b. The Security Department shall maintain a key to be used for jams when accounting/auditing

personnel are not available.

c. If a dispenser becomes jammed or malfunctions, a Security representative shall be allowed to clear

the jam in the presence of a Casino Cage Supervisor.

d. Surveillance shall be notified any time that the locked dispenser is to be opened.

(NIGC§542.12(c)(2) part 2)

e. The dispenser shall allow the original and the copies to be written on simultaneously.

f. The original and duplicate shall be discharged by the Casino Cashier, while the triplicate

(accounting copy) shall remain secured in a continuous, unbroken form in the dispenser.

g. Access to the triplicate copies shall be restricted to Casino accounting/auditing personnel.

B. Computerized Fill/Credit slips shall be created on a blank form with sensitized paper, which allows all

information to imprint on all three copies simultaneously.





1. The blank forms (sensitized paper) shall not be controlled documents.

2. The stored computer data shall not be susceptible to change or removal by any personnel having

accessibility to funds after preparation of the Fill/Credit Slips. Casino accounting/auditing

personnel shall be the only department that may change any data. (NIGC§542.12(c)(5)(iii);

NIGC§542.12(c)(13)(ii))

C. The part of the fill slip that is placed in the table game drop box shall be of a different color for fills

than for credits, unless the type of transaction is clearly distinguishable in another manner (the checking

of a box on the form shall not be a clearly distinguishable indicator). (NIGC§542.12(c)(6))

D. If at any time a Fill/Credit Slip must be voided, all copies shall be marked "VOID" and signed by the

cashier and one other individual independent in the transaction. (NIGC§542.12(c)(3))

E. The voided copies shall be forwarded to Casino accounting/auditing personnel for accountability and

retention. (NIGC§542.12(c)(3))

VII. Table Game Fill Standards

A. When additional chips are needed at a gaming table, table games supervisory personnel shall request a

fill from the Casino Cashier Chip Bank. (NIGC§542.12(c)(4))

1. The Request for Fill may be automated through the use of a computerized system.

a. The table games supervisory personnel shall enter their authorization identification, game

number/type, table number, and the amount of chips and/or coin by denomination and in total.

b. The system shall record the date, shift, and time of the transaction.

c. The table games supervisory personnel shall approve the fill transaction with their authorization

identification.

2. When a manual fill is required, a two-part Request for Fill form accessible only to table games

supervisory personnel shall be prepared.

a. The request for fill shall be signed by a table games supervisor and the Security Department

Representative who is called to transport the original of the Request directly to the Casino

Cashier Chip Bank. (NIGC§542.12(c)(4))

b. The duplicate request for fill shall remain in clear view on the gaming table and shall not be

removed until the chips and/or coins are received.

B. A Fill Slip shall be prepared at the Cashier Chip Bank.

1. For computerized systems, the fill slip shall automatically print at the Casino Cashier Chip Bank

location. (NIGC§542.12(c)(4))

2. For manual systems, a Manual Fill Slip shall be prepared by the Casino Cashier using the

information contained on the Request.

a. The Manual Fill Slip shall be signed by the Cashier while all copies are still in the dispenser.

b. Once signed, the original and duplicate of the Manual Fill Slip shall be removed from the

dispenser while the triplicate remains locked within the dispenser.

3. Fill slips shall be in at least triplicate form in a continuous, prenumbered series.

(NIGC§542.12(c)(1))

a. One copy (drop box copy) of the fill slip shall be transported to the pit with the fill and, after the

appropriate signatures are obtained, deposited in the table game drop box.

(NIGC§542.12(c)(5)(i))

b. One copy (cage copy) shall be retained in the cage for reconciliation of the cashier bank upon

obtaining all appropriate signatures. (NIGC§542.12(c)(5)(ii))

c. For computer systems, one part shall be retained electronically so that only authorized persons

may gain access to it. For manual systems, one part shall be retained in a secure manner in a

continuous unbroken form. (NIGC §542.12(c)(5)(i))





4. Fill slips shall be concurrently numbered in a form utilizing the alphabet and only in one series at

a time. The alphabet need not be used if the numerical series is not repeated during the business

year. (NIGC§542.12(c)(1))

5. The Fill Slip shall record, at a minimum, the following information:

a. The total amount of gaming chips or coins being distributed; (NIGC§542.12(c)(7))

b. The total amount by denomination of all denominations of gaming chips or coins being

distributed; (NIGC§542.12(c)(7))

c. The game and table number to which the gaming chips or coins are being distributed;

(NIGC§542.12(c)(7))

d. The date, time and shift during which the preparation and subsequent distribution of gaming

chips or coins occur; (NIGC§542.12(c)(7))

e. The signature of the cashier who prepared the fill slip and issued the chips, tokens, or monetary

equivalent; and, (on the original and duplicate) (NIGC§542.12(c)(9)(i))

f. The signature of the appropriate Security Department representative (runner) who carried the

chips, tokens, or monetary equivalents from the cage to the pit; (on the original and duplicate.

(NIGC§542.12(c)(9)(ii))

g. The signature of the dealer or Boxperson who received the chips, tokens or monetary equivalents

at the gaming table; and (on the original and duplicate) (NIGC§542.12(c)(9)(iii))

h. The signature of the table games supervisory personnel who supervised the fill transaction (on

the original and duplicate). (NIGC§542.12(c)(9)(iv))

6. Signatures on the fill slip shall constitute that each has counted the amount of the fill and the

amount agrees with the fill slip.

C. After being communicated to the cage, the fill slip shall then be signed by the Chip Bank Cashier, and

the appropriate gaming chips and/or coins shall be prepared for transport to the pit by a security

department representative (runner). (NIGC§542.12(c)(8))

1. A Security Department Representative (runner) shall verify that the amount of gaming chips

and/or coins agree to the fill slip and shall sign all the copies of the fill slip presented, attesting to

the accuracy of the information recorded.

2. Before the fill leaves the Chip Bank, the cashier shall acknowledge the fill slip in the system for

tracking and control purposes. The gaming chips and/or coin shall then be transported directly to

the gaming table by the Security Department Representative.

3. The Chip Bank Cashier shall maintain a record of the fill transaction until the properly completed

duplicate fill slip to which it relates to is returned by the Security Department Representative.

a. For computerized systems, the Chip Bank Cashier shall maintain the triplicate copy of the

computerized fill slip.

b. For manual systems, the Chip Bank Cashier shall maintain the original request for fill

corresponding to the outstanding fill transaction.

D. Upon receipt of the gaming chips and/or coin at the appropriate gaming table, the table games

supervisor assigned to the pit and the Dealer shall verify that the chips and/or coin agree to the

amounts recorded on the Fill Slip by breaking down the chips and/or coin in full view of the public

before placing the chips in the table tray. (NIGC§542.12(c)(10))

1. The original and duplicate copies of the fill slip shall be signed by the dealer and table games

supervisor attesting to the accuracy and receipt of the fill.

2. For computerized systems, the original fill slip shall be deposited in the drop box by the Dealer in

the presence of the Security Department Representative. (NIGC§542.12(c)(11)) The table games

supervisor shall confirm receipt of the fill in the computer system.

3. For manual systems, the original of the Fill Slip and the duplicate Request for fill shall be

deposited in the drop box by the Dealer under the observation of the Security Department

Representative. (NIGC§542.12(c)(11))





E. The duplicate Fill Slip containing the appropriate signatures shall be returned to the Chip Bank

Cashier by the transporting Security Department Representative. The Chip Bank Cashier shall then

match the duplicate Fill Slip to the triplicate maintained in the pending file, which will be held for end

of shift reconciliation.

VIII. Table Game Credit Standards

A. When the need to remove chips from a gaming table arises, table games supervisory personnel shall

request a credit from the Casino Cashier Chip Bank. (NIGC§542.12(c)(12))

1. The Request for Credit may be automated though the use of an automated system.

a. An authorized table games supervisor shall enter his/her authorization identification, game

number/type, table number, and the amount of chips and/or coin by denomination and in total.

b. The system shall record the date, shift, and time of the transaction.

c. The table games supervisor shall then approve the credit transaction with their authorization

identification.

2. When a manual credit is required, a two-part Request for Credit form accessible only to table

games supervisory personnel shall be prepared.

a. The request for credit shall be signed by a table games supervisor and the Security Department

Representative, who is called to transport the duplicate of the Request directly to the Casino

Cashier Chip Bank.

b. The original request for credit shall remain in clear view on the gaming table and shall not be

removed until the chips and/or coins are received. (NIGC§542.12(c)(7))

B. A Credit Slip shall be prepared at the Cashier Chip Bank.

1. For computerized systems, the credit slip shall automatically print at the Casino Cashier Chip

Bank location. (NIGC§542.12(c)(12))

2. For manual systems, a Manual Credit Slip shall be prepared by the Casino Cashier using the

information contained on the Request.

a. The Manual Credit Slip shall be signed by the Cashier while all copies are still in the dispenser.

b. Once signed, the original and duplicate of the Manual Credit Slip shall be removed from the

dispenser while the triplicate remains locked within the dispenser. (NIGC§542.12(c)(13)(ii))

3. Credit slips shall be in at least triplicate form in a continuous, prenumbered series.

(NIGC§542.12(c)(13))

a. One copy (drop box copy) of the credit slip shall be transported to the pit with the credit and,

after the appropriate signatures are obtained, deposited in the table game drop box.

(NIGC§542.12(c)(13)(i))

b. One copy (cage copy) shall be retained in the cage for reconciliation of the cashier bank upon

obtaining all appropriate signatures. (NIGC§542.12(c)(13)(i))

c. For computer systems, one part shall be retained electronically so that only authorized persons

may gain access to it. For manual systems, one part shall be retained in a secure manner in a

continuous unbroken form. (NIGC§542.12(c)(13)(ii))

4. Credit slips shall be concurrently numbered in a form utilizing the alphabet and only in one series

at a time. The alphabet need not be used if the numerical series is not repeated during the

business year. (NIGC§542.12(c)(1))

5. The Credit Slip shall record, at a minimum, the following information: (NIGC§542.12(c)(13))

a. The denomination of gaming chips and/or coins removed from the gaming table to the Chip

Bank; (NIGC§542.12(c)(14))

b. The total amount of each denomination of gaming chips and/or coins being removed from the

gaming table to the Chip Bank; (NIGC§542.12(c)(14))

c. The total amount of all denominations of gaming chips and/or coins being removed from the

gaming table to the Chip Bank; (NIGC§542.12(c)(14))

d. The game and table number from which the gaming chips and/or coins are being removed;

(NIGC§542.12(c)(14))





e. The date, shift and time during which the removal of gaming chips and/or coins occur;

(NIGC§542.12(c)(14))

f. Signature of cashier who received the items transferred from the pit and prepared the credit slip;

(NIGC§542.12(c)(17)(i))

g. Security Department representative (runner, who transported the items transferred from the pit to

the cage; (NIGC§542.12(c)(17)(ii))

h. The signature of the dealer assigned to the gaming station from which the gaming chips or coins

are to be removed; (NIGC§542.12(c)(17)(iii))

i. The signature of the table games supervisor who supervised the credit transaction.

(NIGC§542.12(c)(17)(iv))

6. Signatures shall constitute that each has counted the amount of the credit and the amount agrees

with the credit slip. (NIGC§542.12(c)(17))

C. Two parts (original and copy) of the credit slip shall be transported by the runner directly to the pit.

(NIGC§542.12(c)(13)(i)

D. The Chip Bank Cashier shall maintain a record of the credit transaction until the properly completed

original credit slip and corresponding chips and/or coin are delivered by the Security Department

Representative.

1. For computerized systems, the Chip Bank Cashier shall maintain the triplicate copy of the

computerized credit slip.

2. For manual systems, the Chip Bank Cashier shall maintain the original request for credit

corresponding to the outstanding fill transaction.

E. Upon completion of the hand of play at the gaming table, the chips and/or coin shall be prepared for

credit. The Dealer shall break down and verify the amount of chips and/or coin as listed on the Credit

Slip in full view of the table games supervisor, Security Representative, and the public.

(NIGC§542.12(c)(15))

1. The table games supervisor, Dealer, and Security Department Representative (runner) will sign

the Credit Slip attesting to the accuracy and value of the chips being credited.

2. The duplicate credit slip shall be dropped in the table game drop box by the dealer.

(NIGC§542.12(c)(18))

3. The original copy of the credit slip shall be then transported by the Security Department

Representative along with the gaming chips and/or coin to the Chip Bank for verification and

signature of the cashier. (NIGC§542.12(c)(13)(i), (c)(16), (c)(18))

F. Upon receipt of the gaming chips and/or coin at the Chip Bank, the Chip Bank Cashier shall verify

that the chips and/or coin agree to the amounts recorded on the Credit Slip by counting the chips

and/or coin while in the presence of the Security Department Representative.

1. For computerized credit transactions, the following shall apply:

a. The Cashier shall sign the credit slip and acknowledge receipt in the computer system.

(NIGC§542.12(c)(13)(i))

b. The original of the credit slip shall be maintained by the Chip Bank Cashier for end of shift

reconciliation and accountability.

2. For manual credit transactions, the following shall apply:

a. The Cashier shall sign the credit slip. (NIGC§542.12(c)(13)(i))

b. The original of the credit slip shall be maintained by the Chip Bank Cashier for end of shift

reconciliation and accountability.

c. The triplicate shall be retained in the locked dispenser machine.





IX. Standards for Accepting Cash at Gaming Tables

A. Gaming Machine Tickets shall not be accepted or used at gaming tables.

B. The cash shall be spread on the top of the gaming table by the dealer accepting it in full view of the

patron who presented it and the table games supervisor assigned to the pit.

C. The dealer shall announce the amount of cash in a tone of voice calculated to be heard by the patron

who presented the cash and the table games supervisor assigned to the pit. All cash changes of $200 or

over shall be verbally acknowledged by the Games Supervisor.

D. Immediately after an equivalent amount of gaming chips has been given to the patron, the cash shall be

taken from the top of the gaming table and placed by the dealer into the drop box attached to the

gaming table, except that coins may be retained in the table inventory in lieu of gaming chips of

equivalent amounts.

E. Gaming chip purchases shall only be allowed at a live table game. Chip purchases shall be completed

by the Dealer or Cashier who has been presented with the cash.

F. The gaming operation reserves the right to demand redemption of its gaming chips from any person in

possession of them. Such person shall redeem the gaming chips upon presentation of an equivalent

amount of cash and the completion of all relevant paperwork.

G. Currency may be played on all table games with acknowledgment by a table games supervisor.

H. Call bets in the pit are prohibited.

X. Table Game and Card Game (Poker) Tournaments

A. A “tournament” shall mean a contest to determine the best player within a set of parameters such as

time period or amount of chips won in front of each player.

B. The gaming operation, subject to approval of the Tribal Gaming Commission, shall develop and

implement procedures for all table game and card game tournaments, to include, but not be limited to

the following:

1. Controls, including adequate segregation of duties, for the receipt, recording, and reconciliation of

tournament funds;

2. Controls for the receipt, inventory, storage, and destruction of non-value gaming chips or other

tournament items;

3. Procedures for the development of tournament payout structures;

4. Controls for tournament payouts to winning patrons;

5. Adequate documentation of tournament results; and

6. Audit procedures for tournament activity, including the reconciliation of tournament funds received

and awarded.

C. Tournament prizes may be donated by the house or come directly from the buy-ins or a combination of

both. Fair market value of merchandise or prize or ticket redemption value amount shall be recorded.

D. All table game and poker tournament accounting procedures and any follow-up performed shall be

documented, maintained for inspection, and provided to the Tribal Gaming Commission upon request.

E. Tournament rules approved by the Tribal Gaming Commission shall be submitted to the State Gaming

Agency for approval.





XI. Acceptance of Tips and Gratuities

A. No gaming operation employee who serves in a supervisory capacity shall be allowed to accept tips or

gratuities from any player or patron of the casino.

B. All tips and gratuities given to Dealers shall be handled in accordance with Section A General

Provisions, Paragraph XV. of these standards.

C. Upon receipt from a patron of a tip or gratuity, a Dealer assigned to a gaming table shall extend his/her

arm, tap the gaming chip on the table, and deposit such tip or gratuity in the tip box reserved for such

purpose.

XII. Cards and Dice Control

A. All shipments of cards and dice shall be required to be communicated to the Tribal Gaming

Commission with a 14-day notification from the manufacturer. In the case of an emergency, the 14-day

notification can be waived, but only upon Tribal Gaming Commission approval.

B. All cards and dice shall be received from the manufacturer as a restricted shipment.

1. When cards and dice are received from the supplier to the designated receiving area, the packages

shall be inspected for quantity and obvious damage by at least two employees from different

departments.

2. The Tribal Gaming Inspector shall be instantly notified and may be present to verify all receipts of

cards and dice.

3. The Tribal Gaming Commission shall be instantly notified of all shipments and receipt of playing

cards and dice.

4. Any deviation between invoice/packing list amount and any defects found shall be promptly

reported to the Director of Table Games and the Tribal Gaming Inspector.

C. A card and dice inventory (control) log shall indicate the date, quantity received, where distributed to

and returned from tables and removed from play (marked) by the table games department, and when

destroyed. (NIGC§542.12(f)(4); NIGC§542.9(d)(4))

D. The cards and dice shall be stored in a location requiring dual access to prevent unauthorized access and

reduce the possibility of tampering. The keys shall be maintained in the cage or other secured area, and

shall be accessed by a member of the Table Games Department and a member of Security with

immediate notification of a Tribal Gaming Inspector. (NIGC§542.12(f)(1); NIGC §542.9(d)(1))

E. Used cards and dice shall be maintained in a secure location until "marked" or "scored" to prevent

unauthorized access and reduce the possibility of tampering. (NIGC§542.12(f)(2); NIGC §542.9(d)(2))

1. Dice shall be immediately scored as they are taken off of the table games by a table games

supervisor, a tag shall be signed by the dealer and table games supervisor, and the dice will be

placed in a bag and sealed with the signed tag.

2. The cards and dice shall be stored in a designated pit stand until they are transported to the dual

access card and dice room. (NIGC§542.12(f)(1))

3. Table Games management/supervisor or manager on duty shall remove any cards or dice in play, if

there is any indication of tampering, flaws, scratches, marks or other defects that might affect the

integrity of the game.

a. The Tribal Gaming Inspector shall be instantly notified of the removal.

b. Cards and dice that indicate tampering, flaws, scratches, marks or other defects that might affect

the integrity of the game shall be removed instantly at the request of the Tribal Gaming

Commission.





c. Where playing cards or dice are retained to officially investigate a certain game, cards, or dice,

they shall not be destroyed. (NIGC§542.12(f)(3)(i); NIGC§542.9(d)(3)(i))

F. The gaming operation shall utilize either reusable plastic cards or traditional table games cards.

1. For plastic cards, the Casino may use them for up to three (3) months if the plastic cards are

routinely inspected and washed or cleaned at least every three (3) days in a manner approved by the

Tribal Gaming Commission. (NIGC§542.9(e); NIGC§542.12(g))

2. For traditional table games cards (not plastic cards), the table games personnel shall verify that all

cards are present and immediately mark the corner of the cards with a permanent marker as the

cards are being taken off of a table game, which shall not exceed 7 days. (NIGC§542.12(f)(3))

After being marked, a table games supervisor shall verify the mark; both the dealer and the

supervisor shall sign a tag, place the decks in bags and seal them with the signed tag.

G. Additionally, used playing cards and dice shall be destroyed by shredding or other means, as approved

by the Tribal Gaming Commission. Occasionally, cards may be used as a promotional or retail product;

such decks of cards shall have a hole drilled through them in the presence of an Inspector.

XIII. Statistics

A. Records shall be maintained which include statistical drop, statistical win, statistical win to statistical

drop hold percentage by table and type of game indicating any single-deck blackjack games that were

dealt for an entire shift: (NIGC§542.12(i)(1))

1. By shift; (NIGC§542.12(i)(2))

2. Each day; (NIGC§542.12(i)(2))

3. Cumulative month-to-date; and (NIGC§542.12(i)(2))

4. Cumulative year-to-date. (NIGC§542.12(i)(2))

B. The Financial Controller or Director of Finance or Accounting Supervisor shall review pit statistical

information on at least a monthly basis. (NIGC§542.12(i)(3))

C. The management in paragraph XIII.B. of this section shall investigate any unusual fluctuations in hold

percentage with pit supervisory personnel. The results of such investigations shall be documented,

maintained for inspection and provided to the Tribal Gaming Commission upon its conclusion.

(NIGC§542.12(i)(4), (i)(5))

XIV. Receipt of Chips from Manufacturer

A. All shipments of gaming chips shall be required to be communicated to the Tribal Gaming Commission

with a 14-day notification from the manufacturer. In case of an emergency, the 14-day notification can

be waived, but only upon Tribal Commission approval.

B. All table game chips (incl. Roulette) shall be received from the manufacturer as a restricted shipment.

C. When gaming chips are shipped or received from the manufacturer, they shall be opened and checked

by at least two (2) employees of the casino including a Cashier Cage representative and a representative

from the accounting/auditing department. All ordered chip specifications shall match chips received.

The Tribal Gaming Inspector shall be instantly notified and shall be present to verify all receipt of

chips.

D. Any deviation between the invoice accompanying the gaming chips and the actual chips received, or

any defects found in the chips, shall be instantly reported to a Tribal Gaming Inspector.





E. After checking the chips received, the following shall be recorded in a chip inventory ledger:

1. The denomination of the chips received;

2. The number of each denomination of chip received;

3. The number and description of all non-value chips received;

4. The date of receipt; and

5. The signature of the individuals who checked and received the chips.

XV. Inventory of Gaming Chips

A. Casino management, as approved by the Tribal Gaming Commission, shall establish and comply with

procedures for the receipt, inventory, storage and destruction of gaming chips and tokens. These

procedures shall be included in the Casino internal control standards. (NIGC§542.14(e))

B. Any chips received that are part of the secondary set of chips (second rack) shall be recorded in the

Chip inventory ledger as such and shall be stored in the Main Bank.

C. The second rack of chips shall be secured in cabinets with a dual-lock system and a pre-numbered seal.

1. One lock/key shall be maintained by the cage, and the second key shall be maintained by the Tribal

Gaming Inspectors.

2. The second rack of chips shall be inventoried by independent accountants and sealed by a Tribal

Gaming Inspector.

3. In the event the seal is broken or chips are taken out of the second rack and placed into action, an

inventory shall be completed at that time and proper entries made in the chip inventory ledger.

4. The Tribal Gaming Commission shall be instantly notified if this occurs.

D. Chips taken from or returned to the secondary set of chips shall be performed by a Cage Supervisor in

the presence of the Main Bank Cashier and Tribal Gaming Inspector.

E. The Tribal Gaming Commission shall provide approval prior to any casino employee accessing the

chips in the secondary set.

XVI. Destruction of Chips

A. Prior to the destruction of gaming chips the casino shall notify the Tribal Gaming Commission in

writing of the following:

1. Date and location at which the destruction shall be performed;

2. The denomination, the number, and the amount of the value chips to be destroyed;

3. The description and number of non-value chips to be destroyed; and

4. A detailed explanation of the method of destruction.

B. The destruction of the gaming chips shall be carried out in the presence of a Tribal Gaming Inspector

and a representative from Accounting or the Cage Department, with an immediate inventory prior to

destruction.

C. The destruction of the chips shall be logged in the chip inventory ledger.

XVII. Control Over Table Layouts

A. All shipments of table layouts shall be required to be communicated to the Tribal Gaming Commission

with a 14-day notification from the manufacturer. In the case of an emergency, the 14-day notification

can be waived, but only upon Tribal Gaming Commission approval.





B. All table game layouts shall be received from the manufacturer as a restricted shipment.

1. When table layouts are received from the supplier, they shall be inspected for quantity and obvious

damage by at least two employees from different departments.

2. The layouts shall be recorded in the table layout inventory ledger.

3. The Tribal Gaming Inspector shall be notified and present to verify receipt of all table layouts.

4. Any deviation between the invoice/packing list amount and any defects found shall be promptly

reported to the Tribal Gaming Commission.

C. Procedures for the disposal of table layouts shall be developed and submitted to the Tribal Gaming

Commission for approval.

XVIII. Disposal of Live Games

The Director of Table Games shall notify the Tribal Gaming Commission in writing and shall receive

written approval from the Tribal Gaming Commission prior to disposing of or removing from the premises

live gaming devices, including equipment and layouts.

XIX. Poker Room Standards

A. Gaming Machine Tickets shall not be accepted at the Poker Bank or as a wager in poker games.

B. All standards pertaining to table games shall apply to the poker games, unless specifically addressed in

this section.

C. Supervision shall be provided at all times the card room is in operation by personnel with authority

equal to or greater than those supervised. A Poker Bank shall be located in the Poker Room for the

redemption of chips by players and even exchanges with Poker Dealers to replenish their card table

banks. The Poker Bank inventory shall consist of currency, coin, and gaming chips.

(NIGC§542.9(c)(1))

D. The Poker Bank shall be maintained on an imprest basis.

E. Transfers between the Poker Bank and the Main Bank shall be authorized and documented through the

use of a Funds Transfer/Order Form as approved by the Tribal Gaming Commission.

(NIGC§542.9(c)(2))

F. At the end of each shift, the table banks shall be counted, recorded and reconciled by a supervisor and

second verifying dealer or supervisor. Each verifier shall be attest to the accuracy of the count by their

signature on the check-out form. (NIGC§542.9(g)(2))

G. The main card room bank shall be counted, recorded, and reconciled at least once per gaming shift by

the Poker Bank Chip Supervisor and dealer or second Supervisor. (NIGC§542.9(g)(1)) Any

discrepancies shall be documented and subsequently forwarded to accounting/auditing personnel.

H. The table bank shall be used only for the purpose of making change and handling player buy-ins.

I. The gaming operation shall develop and submit procedures for the even exchange of funds between the

Poker Bank and the dealer table banks for approval by the Tribal Gaming Commission. Exchanges

must occur at the tables and must be verified by the Dealer and the runner. (NIGC§542.9(c)(2),(3))

J. A rake collected or ante placed shall be done in accordance with the posted rules. (NIGC§542.9(c)(5))





K. In the event that a shill is utilized, the following shall apply: (NIGC§542.9(f))

1. Issuance of shill funds shall have the written approval of the Supervisor. (NIGC§542.9(f)(1))

2. Shill returns shall be recorded and verified on the shill sign-out form. (NIGC§542.9(f)(1))

3. The replenishment of shill funds shall be documented. (NIGC§542.9(f)(1))

XX. Card Game Jackpot (Progressive) Collection and Payout Standards

A. All funds contributed by players into the pools shall be returned when won in accordance with the

posted rules with no Commission or administrative fee withheld. (NIGC§542.9(h)(1))

B. Rules governing promotional pools shall be conspicuously posted and designate: (NIGC§542.9(h)(2))

1. The amount of funds to be contributed from each pot; (NIGC§542.9(h)(2)(i))

2. What type of hand it takes to win the pool (e.g., what constitutes a “bad beat”);

(NIGC§542.9(h)(2)(ii))

3. How the promotional funds shall be paid out; (NIGC§542.9(h)(2)(iii))

4. How/when the contributed funds are added to the jackpots; and (NIGC§542.9(h)(2)(iv))

5. Amount/percentage of funds allocated to primary and secondary jackpots, if applicable.

(NIGC§542.9(h)(2)(v))

C. Promotional pool contributions shall not be placed in or near the rake circle, in the drop box, or

commingled with gaming revenue from card games or any other gambling game. (NIGC§542.9(h)(3))

D. The amount of the jackpot shall be conspicuously displayed in the card room. (NIGC§542.9(h)(4))

1. At least once a day, the posted pool amount shall be updated to reflect the current pool amount.

(NIGC§542.9(h)(5))

2. At least once a day, increases to the posted pool amount shall be reconciled to the cash previously

counted or received by the cage by personnel independent of the card room. (NIGC§542.9(h)(6))

3. All decreases to the pool shall be properly documented, including a reason for the decrease.

(NIGC§542.9(h)(7))

E. If promotional funds are displayed in the card room, they shall be placed in a locked container in plain

view of the public. (NIGC§542.9(i)(1))

1. Persons authorized to transport the locked container shall be precluded from having access to the

contents keys. (NIGC§542.9(i)(2))

2. The contents key shall be maintained by personnel independent of the card room.

(NIGC§542.9(i)(3))

3. At least once each day, the locked container shall be removed by two persons, one of whom is

independent of the card games department, and transported directly to the cage or other secure

room to be counted, recorded, and verified. (NIGC§542.9(i)(4))

4. The locked container shall then be returned to the card room where the posted pool amount shall be

updated to reflect the current pool amount. (NIGC§542.9(i)(5))

F. If promotional progressive funds are maintained by the cage, the following shall apply:

1. When promotional funds are removed from the card game, they shall be placed in a locked

container in plain view of the public. (NIGC§542.9(j)(1))

2. Persons authorized to transport the locked container shall be precluded from having access to the

contents keys. (NIGC§542.9(j)(2))

3. At least once a day, the locked container shall be removed by two individuals, one of whom is

independent of the card games department, and transported directly to the cage or other secured

room to be counted, recorded and verified prior to accepting the funds into cage accountability.

(NIGC§542.9(j)(4))

4. The contents key shall be maintained by personnel independent of the card room.

(NIGC§542.9(j)(3))





5. The posted pool amount shall then be updated to reflect the current pool amount.

(NIGC§542.9(j)(5))

G. Each card game table shall have a drop box that is used exclusively for the deposit of house rakes, time

buy-ins and/or antes. The card tables shall be equipped with a drop slot cover that drops the rake

amount directly into the rake drop box.



Section D DROP AND COUNT STANDARDS


I. Computerized applications

For any computer applications utilized, alternate documentation and/or procedures that provide at least the

level of controls described by the standards in this section, as approved by the Tribal Commission, shall be

acceptable. (NIGC§542.41(a))

II. Physical Characteristics of Table Games Drop Boxes

A. Each gaming table in the Casino shall have attached to it a metal container known as a "drop box" in

which shall be deposited all cash, cash equivalents, Fill and Credit Slips, Requests for Fill and Credit

forms, table inventory slips, and Error Notification Slips.

B. Each Drop Box maintained by the Gaming operation shall have the following characteristics:

1. A slot opening through which currency, coin, forms, records, cash equivalents and documents can

be inserted into the Drop Box;

2. A mechanical device that automatically closes and locks the slot opening upon removal of the Drop

Box from the gaming table;

3. All table game drop boxes shall be posted with a number corresponding to a permanent number on

the gaming table and marked to indicate game, table number, and shift. (NIGC§542.41(b)(5))

4. Emergency Drop Boxes have the same features, except for an identification marking with the word

"Emergency" permanently imprinted on the label. When a drop box is in use, a temporary marking

shall be made on that box to indicate the game, shift, and table number that is affixed to the Drop

Box by the Games Supervisor.

C. Keys issued for the drop shall be in accordance with Section O, Key Control Standards.

III. Transportation and Access of Table Game Drop Boxes

A. The setting out of empty drop boxes and the drop shall be a continuous process. (NIGC§542.41(b)(1))

B. Drop boxes shall be removed from the gaming tables once a day on a schedule filed with the Tribal

Gaming Commission.

C. At the end of the shift (defined here as a 24-hour period, a gaming day): (NIGC§542.41(b)(2))

5. All locked table game drop boxes shall be removed from the tables by at least two Security Officers

independent of the pit shift being dropped; (NIGC§542.41(b)(2)(i))

6. A separate drop box shall be placed on each table opened at any time during each shift;

(NIGC§542.41(b)(2)(ii))

7. Upon removal from the gaming tables, the drop boxes shall be placed in storage racks which also

serve as transportation carts; and

8. The drop boxes shall be locked in the storage rack/transportation carts and shall be transported by

at least two Security Officers directly to the soft count room and secured until the count takes

place. (Only the drop and count team shall have access to full or empty drop boxes and storage

carts, with the exception of emergency situations.) (NIGC§542.41(b)(2)(iii), (b)(4))

D. Security shall be provided over the drop boxes removed from the tables prior to transportation to the

count room.

E. If drop boxes are not place on all tables, then the Table Games Department shall document which tables

were open during the shift. (NIGC§542.41(b)(3))





F. If an emergency table drops needs to occur (e.g. a drop box becomes full during the shift or experiences

mechanical difficulties), the box shall be removed from the table and transported to the soft count room and

secured by at least one Security Officer and under the observation of the Tribal Gaming Inspector until the

daily drop and count takes place.

G. Surveillance shall be notified for the following:

1. When the scheduled drop is to begin so that surveillance may monitor the activities,

(NIGC§542.41(b)(6))

2. When an emergency drop occurs, and

3. Whenever a drop box is accessed.

IV. Physical Characteristics of Gaming Machine Bill Validator Drop Boxes & Buckets

A. The Technical Standards for Electronic Gaming Devices apply as approved by the Gaming Commission

and the State Gaming Agency.

B. Gaming machines shall have drop buckets into which coins or tokens that are retained by the gaming

machine are collected or a bill validator and/or a ticket printer. Drop bucket contents shall not be used

to make change or pay hand-paid payouts. (NIGC§542.41(g)(7))

C. All bill validator drop boxes and gaming machine drop buckets shall be posted with a number

corresponding to a permanent number on the gaming machine, which may include bar coded labels.

(NIGC§542.41(e)(5))

D. Each drop bucket or bill validator in use shall be:

1. Housed in a locked compartment separate from any other compartment of the gaming machine and

keyed differently than other gaming machine compartments; and (NIGC§542.41(g)(6)(i))

2. Identifiable to the gaming machine from which it is removed. If the gaming machine is identified

with a removable tag that is placed in the bucket or on the bill validator, the tag shall be placed on

top of the bucket or bill validator when it is collected. (NIGC§542.41(g)(6)(ii))

V. Transportation & Access of Gaming Machine Bill Validator Drop Boxes & Buckets

A. The collection procedures may include procedures for dropping gaming machines that have trays

instead of drop buckets. (NIGC§542.41(g)(8))

B. A minimum of three hard count team members shall be involved in the removal of the gaming machine

drop boxes and buckets, under the observation of a security officer and a Tribal Gaming Inspector. The

Drop team shall report to someone independent of the gaming machine department.

(NIGC§542.41(e)(1), (g)(1))

C. Hard count supervisor/designee shall notify surveillance when the drop is to begin. The gaming

machine drop shall be monitored by Surveillance. (NIGC§542.41(e)(3), (g)(3))

D. All bill validator drop boxes and drop buckets shall be removed only at a time previously designated by

the gaming operation and approved by the Tribal Gaming Commission. (NIGC§542.41(e)(2), (g)(2))

1. The bill validator drop boxes and drop buckets shall be removed by a hard count employee and

placed on a drop box storage rack until they are transported directly to the count rooms.

(NIGC§542.41(e)(4), (g)(5))





2. The contents of the bill validator drop boxes and the gaming machine drop buckets shall be

transported directly to the area designated for the counting of such drop proceeds. If more than one

trip is required to remove the contents of the machines, the filled carts of coins shall be securely

locked in the room designed for counting or in another equivalently secure area with comparable

controls. There shall be a locked covering on any carts in which the drop route includes passage

out of doors. (NIGC§542.41(g)(5))

3. Security shall be provided over the boxes and buckets removed from the gaming machine drop

cabinets and the bill validator drop boxes removed from the gaming machines, which are awaiting

transport to the count rooms. (NIGC§542.41(e)(4)(i), (g)(4))

4. The transportation of bill validator drop boxes and drop buckets to the count rooms shall be

performed by a minimum of two individuals, at least one of whom shall be a Security Department

employee. If more than one trip is required to remove the contents of the machines, the filled carts

shall be securely locked in the count rooms. There shall be a locked covering on any carts in which

the drop route includes passages out of doors. (NIGC§542.41(e)(4)(ii), (g)(5))

VI. Count Room Access

A. Access to the count rooms during the count shall be restricted to members of the Drop and Count team,

authorized observers, supervisors for resolution of problems, authorized maintenance personnel (to

include outside vendors for machine repair during count or redemption), and the Chief of

Security/designee (for emergency response or investigative purposes). (NIGC§542.41(d)(2);

NIGC§542.41(f)(2); NIGC§542.41(i)(3))

1. Authorized observers (including authorized maintenance personnel) shall be approved in writing

prior to accessing the Count room by the Tribal Gaming Commission and may require an escort by

a Tribal Gaming Inspector or Tribal Gaming Commissioner.

2. Items (e.g. bags, briefcases, etc.) brought by authorized individuals shall be subject to search by the

Tribal Gaming Inspector upon exit of the count rooms.

3. Count room access logs shall be maintained. All individuals not normally involved in the hard and

soft count procedures shall be required to sign the log unless it is a life threatening situation in

which case the log shall not be signed.

4. The count room logs shall be periodically sent to Income Control for auditing purposes as the pages

are completed.

5. The count room shall not serve as a coin room where the coin room inventory is not secured as to

preclude access by the count team. (NIGC§542.41(j)(1))

B. If counts from various revenue centers occur simultaneously in the count room, procedures shall be in

effect that prevent the commingling of funds from different revenue centers. (NIGC§542.41(i)(4);

(f)(3); (d)(3))

C. Surveillance shall be notified prior to entering the Count room for the start of the count and whenever

count room personnel exit or enter the count room during the count. (NIGC§542.41(c)(2))

D. Access to stored, full or empty, Table Game drop boxes is restricted to authorized members of the drop

and count teams. (NIGC§542.41(d)(15))

E. Access to stored bill acceptor canisters, full or empty, shall be restricted to:

1. Authorized members of the drop and count teams; and (NIGC§542.41(f)(11)(i))

2. Authorized personnel in an emergency for the resolution of a problem. (NIGC§542.41(f)(11)(ii))

VII. Hard Count/Drop Personnel

A. The weigh/count shall be performed by a minimum of three employees. (NIGC§542.41(h)(1))





B. At no time during the weigh/count shall there be fewer than three employees in the count room until the

drop proceeds have been accepted into cage/vault accountability. Surveillance shall be notified

whenever count room personnel exit or enter the count room during the count. (NIGC§542.41(h)(2))

C. If the gaming machine count is conducted with a continuous count meter that is not reset during the

count and is verified in writing by at least three employees at the start and end of each denomination

count, then one employee may perform the wrap. (NIGC§542.41(h)(2)(i))

D. Count team members shall be rotated on a routine basis such that the count team is not consistently the

same three persons more than four (4) days in a given week. This standard shall not apply to gaming

operations that utilize a count team of more than three persons per week. (NIGC§542.41(h)(3))

E. Hard count team personnel shall be independent of the transactions being reviewed and counted. The

hard count team shall be independent of the cage/vault departments, unless they are non-supervisory

gaming machine employees and perform the laborer function only. (A non-supervisory gaming

department employee is defined as a person below the level of gaming machine supervisor.) A cage

cashier may be used if this person is not allowed to perform the recording function. An accounting

representative may be used if there is an independent audit of all count documentation.

(NIGC§542.41(h)(4))

VIII. Equipment Standards for Gaming Machines

A. A weigh scale calibration module shall be secured so as to prevent unauthorized access (e.g., prenumbered

seal, lock and key, etc.). (NIGC§542.41(w)(1))

B. A person independent of the cage, vault, gaming machine, and count team functions shall be required to be

present whenever the calibration module is accessed. Such access shall be documented and maintained.

(NIGC§542.41(w)(2)) Documentation shall be accessible to the Gaming Commission.

C. Whenever the calibration module is accessed, the date, time, reason, and signatures of the individuals

present shall be documented on the "Scale Calibration Test Log" maintained by the Accounting

Department.

D. If a weigh scale interface is used, it shall be adequately restricted so as to prevent unauthorized access

(passwords, keys, etc.). (NIGC§542.41(w)(3))

E. The weigh scale and weigh scale interface (if applicable) shall be tested by a person or persons

independent of the cage, vault, and gaming machine departments and count team at least quarterly. At

least annually, this test shall be performed by internal audit in accordance with the internal audit

standards. The result of these tests shall be documented and signed by the person or persons performing

the test. (NIGC§542.41(w)(5))

F. Prior to the gaming machine count, at least two employees shall verify the accuracy of the weigh scale

with varying weights or with varying amounts of previously counted coin for each denomination to

ensure the scale is properly calibrated (varying weights/coin from drop to drop is acceptable).

(NIGC§542.41(w)(6)) Documentation evidencing the test of the weigh scale calibration shall be

forwarded to accounting/auditing.

G. If the weigh scale has a zero adjustment mechanism, it shall be physically limited to minor adjustments

(e.g., weight of a bucket) or physically situated such that any unnecessary adjustments to it during the

weigh process would be observed by other count team members. (NIGC§542.41(w)(4))

H. Individuals involved in the gaming machine drop and count shall wear pocket-less jumpsuits.





I. If a mechanical coin counter is used (instead of the weigh scale) during the count, the following shall

apply:

1. The Commission or the gaming operation as approved by the Commission shall establish and the

gaming operation shall comply with those procedures that are equivalent to those described in

paragraphs E, G, and H of this section; and (NIGC§542.41(w)(7)) (Reference also

NIGC§542.41(w)(4), (w)(5) and (w)(6))

2. The count team member shall record the machine number, denomination and number of coins in

ink on a source document, unless the meter machine automatically records such information.

(NIGC§542.41(w)(8))

J. A count team member shall test the coin meter count machine prior to the actual count to ascertain if the

metering device is functioning properly with a predetermined number of coins for each denomination.

(NIGC§542.41(w)(8)(i)) NOTE: (NIGC§542.41(w)(8)(ii) is reserved to NIGC.)

IX. Gaming Machine Coin Count and Wrap Standards

A. Coins shall include tokens. (NIGC§542.41(i)(1))

B. The gaming machine coin count and wrap shall be performed in the hard count room.

(NIGC§542.41(i)(2))

C. The following functions shall be performed in the counting of the gaming machine drop:

(NIGC§542.41(i)(5))

1. Recorder function, which involves the recording of the gaming machine count; and

(NIGC§542.41(i)(5)(i))

2. Hard count supervisor/lead or designee controls the gaming machine weigh and wrap process.

Hard count Supervisor/Lead or designee shall be precluded from recording the weigh/count.

(NIGC§542.41(i)(5)(ii))

D. Drop buckets shall be individually emptied into the weigh scale. The amount of the gaming machine

drop from each machine shall be mechanically printed by the weigh scale on the weigh scale tape. The

gaming machine drop amounts shall be also transferred via direct line to the computerized gaming

machine monitoring system. Empty buckets shall be shown to at least one other hard count team

member and shown to the surveillance camera to ensure all funds have been counted.

E. If applicable, the weight shall be converted to dollar amounts before the reconciliation of the weigh to

the wrap. (NIGC§542.41(i)(7)

F. The recorder, who records the buckets via the machine, and the hard count supervisor/lead or designee,

shall sign the weigh scale tape, attesting to the accuracy of the weigh/count. (NIGC§542.41(i)(9))

G. Any difficulties that arise during the counting and recording process shall be documented and shall be

prepared by the count room supervisor, or designee. Once completed, the documentation shall be

simultaneously (within the hour) sent to the count room supervisor, Casino Controller,

accounting/auditing personnel, Tribal Gaming Inspector, and the Tribal Gaming Commission for

review.

H. The gaming machine drop shall be immediately counted, wrapped, and reconciled in such a manner to

prevent the commingling of gaming machine drop coin with coin (for each denomination) from the next

gaming machine drop until the count of the gaming machine drop has been recorded.

(NIGC§542.41(i)(6))

1. The amount of the gaming machine drop from each machine shall be recorded in ink or other

permanent form of recordation on a gaming machine count document by the recorder or

mechanically printed by the weigh scale. (NIGC§542.41(i)(6)(i))





2. The weigh amount by denomination and in total shall be recorded on the summary report for

subsequent reconciliation to the wrap.

3. If a coin meter is used, a count team member shall convert the coin count for each denomination

into dollars and enter the results on a summary sheet. (NIGC§542.41(i)(8))

4. Corrections to information originally recorded by the count team on hard count documentation shall be

made by drawing a single line through the error, writing the correct figure above the original figure,

and then obtaining the initials of at least two hard count team members attesting to the accuracy of the

change. An employee independent of the gaming machine department and count team shall enter the

correct figure into the computer system prior to the generation of related gaming machine reports.

Known errors to information entered through the weigh scale interface on the scale printout shall be

documented on a variance form and signed by two hard count team members. The variance form shall

be sent to the Accounting Department where an accounting/auditing employee, independent of the hard

count team, shall enter the correct amount into the system prior to the generation of reports.

(NIGC§542.41(i)(6)(ii)(A))

I. Transfers out of the hard count room during any coin count and/or wrap process are permitted under the

internal control standards approved by the Commission. In such a case, surveillance and Tribal Gaming

Inspectors shall be notified prior to each partial transfer. Each transfer of coin shall be recorded by

Surveillance with enough clarity to facilitate investigation processes in the event a discrepancy is

disclosed in the reconciliation of the weigh to wrap counts. (NIGC§542.41(k)(1))

1. Each transfer shall be recorded on a separate multi-part form with a preprinted or concurrently-

printed form number used solely for gaming machine count transfers that shall be subsequently

reconciled by income control to ensure the accuracy of the reconciled gaming machine drop.

(NIGC§542.41(k)(2))

2. Each transfer shall be counted and signed for by at least two members of the count team and by a

cage cashier supervisor or designee, who is responsible for authorizing the transfer. A Tribal

Gaming Inspector shall verify such a transaction. (NIGC§542.41(k)(3))

J. After the completion of the count of the gaming machine drop, all of the following requirements shall

be completed, at the conclusion of the drop:

1. At least two members of the count/wrap team shall count the final wrapped gaming machine drop

(including emergency transfers) independently of each other. (NIGC§542.41(j)(2)(i))

2. The count shall be recorded on a summary report. (NIGC§542.41(j)(2)(ii))

3. The same count team members (or the accounting/auditing personnel) shall compare the final wrap

to the weigh/count, recording the comparison and noting any variances, which shall be documented

on the appropriate form. (NIGC§542.41(j)(2)(iii))

4. At the conclusion of the reconciliation, at least two count team members and the cage cashier

supervisor or designee who verifies the funds shall sign the summary report (or appropriate

documentation). (NIGC§542.41(i)(11); NIGC§542.41(j)(2)(iv))

5. All members of the hard count team shall sign the count document or a summary report to attest to

their participation in the count. (NIGC§542.41(i)(10))

K. All drop proceeds, tickets and cash equivalents that were counted shall be turned over to the cage or

vault casher (who shall be independent of the count team) or to an authorized person/employee

independent of the revenue generation and the count process for verification. Such person shall certify

by signature as to the accuracy of the drop proceeds delivered and received. (NIGC§542.41(i)(11);

NIGC§542.41(j)(2)(vi))

L. A designated count team member, who is not a member of the cashier's department, shall immediately

deliver all gaming machine count and wrap documentation, including any applicable computer storage

media, to the accounting/auditing department. Alternatively, this documentation may be adequately secured

(e.g., in a locked container to which only accounting/auditing can gain access) until retrieved by the

accounting/auditing department. (NIGC§542.41(i)(12))





M. If the coins are transported off the property, a second (alternative) count procedure shall be performed

before the coins leave the property. Any variances shall be documented. (NIGC§542.41(i)(13))

1. The Tribal Gaming Commission shall approve and provide written authorization for the removal of

funds from the Casino prior to the transportation of the funds.

2. A Trial Gaming Inspector shall verify the count and witness the removal of the funds.

X. Soft Count Room Characteristics

A. As part of the Gaming operation, there shall be a room specifically designated for counting the contents

of table game drop boxes and gaming machine drop boxes.

1. This room shall be known as the soft count room.

2. The soft count room shall be located adjacent to the Main Bank.

3. Drops for Poker, any other Electronic Devices, any other table games, and other revenue areas shall

also be counted in the soft count room.

B. The soft count room shall be designed to allow all areas of the soft count room to be totally visible from

the facility's Surveillance room. The count shall be viewed live or on video recording or digital record

reviewed by an employee independent of the count.

C. The soft count room also shall be designed and built to provide maximum security for the funds housed

therein and for the activities conducted therein to include, at a minimum, the following:

1. A door equipped with two separate locks securing the interior of the count room, the keys to which are

different from the keys to the locks securing the contents of the drop boxes. The Security Department

maintains and controls one key in a secure area, access to which may be allowed only by a designated

Security Department member. The second key is maintained and controlled by the Tribal Gaming

Inspector.

2. Keys shall be signed out, and subsequently signed in, on a Key Control Log.

3. An alarm device is connected to the entrance of the soft count room which signals the Surveillance

Room whenever the door to the count room is opened.

D. Equipment located within the soft count room shall include the following:

1. A count table constructed of a clear glass-like material for the emptying, counting, and recording of the

contents of Drop Boxes to be known as the "Count Table";

2. A closed-circuit television camera system with audio capability wired to the Surveillance Room that is

capable of, but not limited to, the following:

a. Effective, detailed video and audio monitoring of the entire count process;

b. Effective, detailed video monitoring of the interior of the soft count room, including Drop Box

storage racks; and

c. Audio-video taping of the entire count process and any other activities in the soft count room.

3. A computer terminal and printer;

4. An automated currency counting and verifying network, if applicable; and

5. A blind drop box used to secure all blind drops made throughout the day. The keys securing the blind

drop box shall be maintained and controlled by the cage.

E. Gaming equipment non-related to the soft count and hard count, or any other items non-related to the

soft count and hard count, shall not be allowed in the soft or hard count rooms without written approval

by the Tribal Gaming Commission.

XI. Soft Count Room Personnel

A. The table game soft count and the gaming machine bill validator count shall be performed by a

minimum of three soft count department employees. (NIGC§542.41(c)(1))

1. Count room personnel shall not be allowed to exit or enter the count room during the count except for

emergencies or scheduled breaks. (NIGC§542.41(c)(2))





2. At no time during the count, shall there be fewer than three employees in the count room, one of which

may be a Tribal Gaming Inspector, until all the drop proceeds have been accepted into cage/vault

accountability. (NIGC§542.41(c)(2))

3. Count team members shall be rotated on a routine basis such that the count team is not consistently the

same three persons more than four (4) days in a given week. This standard shall not apply to gaming

operations that utilize a count team of more than three persons. (NIGC§542.41(c)(3))

B. The soft count team shall be independent of transactions being reviewed and counted. The count team

shall be independent of the cage/vault departments; however, an accounting representative may be used

if there is an independent audit of all soft count documentation. (NIGC§542.41(c)(4))

XII. Table Games Drop and Bill Validator Drop Count Standards (soft count)

A. The soft count department shall ensure that the following standards are met:

1. The contents of the table game drop boxes and gaming machine bill validator boxes are counted and

recorded in the soft count room. (NIGC§542.41(d)(1); (f)(1))

2. The opening, counting and recording of the contents of the table drop boxes shall be performed once, at

the end of each shift, at time(s) submitted to the Tribal Gaming Commission. Prior to beginning this

process, casino management shall notify a Tribal Gaming Inspector instantly.

3. In the presence of a Tribal Gaming Inspector, the soft count supervisor shall notify the Security and

Surveillance Departments that the soft count is about to begin. The Surveillance Department shall

make a video-audio recording, with date and time inserted therein, of the entire count process. A

Tribal Gaming Inspector or Tribal Gaming Commissioner may be present at all times during the soft

count.

4. After entrance into the soft count room, and immediately prior to the opening of the drop box, the door

shall be securely locked, except as otherwise authorized by these standards.

5. If counts from various revenue centers occur simultaneously in the count room, procedures shall be in

effect that prevent the commingling of funds from different revenue centers. (NIGC§542.41(d)(3),

(f)(3), (i)(4))

6. Both gaming machine and table game drop boxes shall be individually emptied and counted in such a

manner to prevent the commingling of funds between boxes until the count of the box has been

recorded. (NIGC§542.41(d)(4), (f)(4))

a. The drop boxes, when empty shall be shown to another member of the count team and to

surveillance. (NIGC§542.41(d)(6), (f)(6))

b. The count of each box shall be recorded in ink or other permanent form of recordation.

(NIGC§542.41(d)(4)(i), (f)(4)(i))

c. A second count shall be performed by an employee on the count team who did not perform the

initial count. (NIGC§542.41(d)(4)(ii))

d. Corrections to information originally recorded by the count team on soft count documentation

shall be made by drawing a single line through the error, writing the correct figure above the

original figure, and then obtaining the initials of at least two hard count team members

attesting to the accuracy of the change. (NIGC§542.41(d)(4)(iii), (f)(4)(ii))

7. A count team member shall be able to observe the loading and unloading of all currency and tickets at

the currency counter, including rejected currency. (NIGC§542.41(d)(5), (f)(5))

8. A manual count shall be performed when the currency counter or ticket reader malfunctions and cannot

be repaired before the start of or at some point during the count. Manual count procedures shall require

two independent counts of each drop box contents. Counts are recorded in ink on currency count slips,

which are signed by the soft count team members performing the count and verification. All other

procedures are as described herein.

9. Chips and any mutilated currency or tickets shall be counted by a soft count representative and the

amount recorded. This count shall be verified by a second soft count representative.

10. At the end of the count, it is the responsibility of the count team to secure all Drop Box storage

rack/transportation carts containing empty Drop Boxes.





B. The count sheet shall be reconciled to the total drop by a count team member, who shall not function as a

sole recorder. (NIGC§542.41(f)(7),(d)(11))

C. The following additional procedures and requirements shall be required for conducting the table games

soft count:

1. Orders for fill/credit (if applicable) shall be matched to the fill/credit slips. Fills and credits shall be

traced to or recorded to the count sheet. (NIGC§542.41(d)(7))

2. The recorded and verified amount of currency shall be transmitted electronically or manually entered

into the computer system. An individual shall compare the forms, records, and documents to the

amounts on the preliminary Master Gaming Report, which was generated before beginning the count.

Any differences shall be highlighted for follow-up by accounting/auditing personnel. Soft count shall

not have access in the computer system to make corrections. Accounting/auditing personnel only shall

be authorized to make corrections in the system.

3. The table game opener/closer inventory forms shall be examined and traced to or recorded on the count

sheet. (NIGC§542.41(d)(10)(i))

4. The following forms, records, and documents of each table game drop box, shall be compared to the

data on the preliminary Master Gaming Report or equivalent (hereafter referred to as “Master Gaming

Report”) and examined for correctness:

a. Amount of the opener;

b. Amount of the closer;

c. The total amount of all fills and the serial number and amount of each fill; and

d. Serial number and amount of each credit.

5. Once all of the table game drop boxes for a shift have been counted and recorded, a final Master

Gaming Report shall be generated.

6. The report shall include the following information, at a minimum, for each table and in total:

a. Amount of opener;

b. Serial number and amount of each fill;

c. Total amount of fills;

d. Serial number and amount of each credit;

e. Total amount of credits;

f. Amount of closer;

g. Total amount of coin and currency; and

h. Win or Loss.

D. After completion and verification of the applicable soft count process, each member of the Count Team

shall sign the applicable soft count documentation attesting to their participation in the count.

(NIGC§542.41(d)(12); NIGC§542.41(f)(8))

1. A minimum of two (2) copies of the final Master Gaming Report shall be printed. One copy shall

be immediately sent to the Tribal Gaming Commission.

2. Accounting/auditing personnel shall run a tape to verify the total of all soft count receipts and

compare the information for agreement to the information on the last page of the final Master

Gaming Report. The Tribal Gaming Commission shall receive immediate written notification as to

any differences after the Master Gaming Report has been signed. Said differences shall be

resolved.

E. All drop proceeds and cash equivalents that are counted shall be turned over to a cage cashier

supervisor, or designee who is independent of the Count Team (hereafter referred to as “Cage Verifier”)

upon verification. (NIGC§542.41(d)(13), (f)(9))

1. For the table games soft count, prior to having access to any information on the Master Gaming

Report and in the presence of the soft count team and Tribal Gaming Inspector, the Cage Verifier

verifies the amount of currency and coin for the table games drop.

a. Once the verification is complete and the Cage Verifier agrees to the amount of currency and

coin, he/she shall sign the final Master Gaming Report verifying its accuracy.

(NIGC§542.41(d)(13))





b. After the Cage Verifier's independent verification, the Tribal Gaming Inspector shall sign the

final Master Gaming Report evidencing his/her presence during the sell and the fact both the

Cage Verifier and soft count team have agreed on the total amount of currency and coin

counted for the table game drop.

c. A copy of the Master Gaming Report containing all appropriate signatures, and the Requests

for Fills, the Fills, the Requests for Credits, the Credits, and the table inventory slips removed

from the drop box shall be transported directly to accounting/auditing personnel by a count

team member or a person independent of the cashier’s department or deposited in the

accounting drop box and shall not be available to any cashier cage personnel.

(NIGC§542.41(d)(14))

d. The Tribal Gaming Inspector shall receive and retain a duplicate copy of the Master Gaming

Report, but no other document referred to in this section whatsoever.

e. After the Tribal Gaming Inspector has signed the final Master Gaming Report, only

accounting/auditing shall make any changes to the Master Gaming Report, with prior written

approval of the Tribal Gaming Commission.

2. For the bill validator soft count, the Cage Verifier shall perform an independent count of the drop

funds and tickets and shall compare it to the Bill Validator Drop Report.

a. Variances discovered at this time shall be reported to the Tribal Gaming Inspector and

thoroughly investigated by the Cage Verifier and the soft count supervisor or designee. The

results of the investigation shall be documented and forwarded to the Tribal Gaming

Commission, accounting/auditing personnel and Casino Controller.

b. The Cage Verifier shall sign the Bill Validator Drop Report attesting to the accuracy of the

monies delivered and received. (NIGC§542.41(f)(9))

c. The Bill Validator Drop Report is a two-part count sheet, indicating the currency, tickets and

coin by denomination and in total.

d. The Cage Verifier shall retain one copy of the count sheet to reconcile the bank at the end of

the shift.

e. The duplicate shall be retained by the soft count team and subsequently transferred to

accounting/auditing personnel.

f. The bill validator drop report and all supporting documentation shall be forwarded directly to

accounting/auditing personnel or placed in a locked drop box by the soft count supervisor, or

designee. (NIGC§542.41(f)(10))

F. The Main Bank is located next to the soft count room. After the verification process is complete, the

Main Bank Cashier shall transport and have all funds secured within the Main Bank prior to the release

of the soft count team.

G. The gaming operation shall develop and the Tribal Gaming Commission shall approve procedures for

the drop, count and subsequent transfer of blind drop funds to the main bank.

H. The gaming operation shall develop and the Tribal Gaming Commission shall approve procedures for

manual counts of table game drop boxes and bill validator drop boxes for instances when the computer

systems and/or gaming machine monitoring systems are unavailable.

XIII. Additional Card Game Drop and Count Standards

Procedures for the Poker drop box removal, transfer of Poker drop boxes to the storage area, and Poker

count procedures shall be consistent with the handling of all gaming table drop boxes and comply with the

internal control standards applicable to the drop and count of the table game drop boxes in this section.

(NIGC§542.9(b))





XIV. Emergency Drop Procedures

A. Emergency drop procedures shall be developed by the Gaming Commission, or the gaming operation as

approved by the Gaming Commission. (NIGC§542.41(v))

B. Such approval shall be on file with the Gaming Commission.

C. Tribal Gaming Inspectors shall be notified of the following emergency drops by a Hard Count

Team/Drop Team Supervisor or Security:

1. Time the emergency drop is to be performed, and

2. Number of machines to be dropped during the emergency drop.



Section E CASINO CAGE


I. Computer applications

For any computer applications utilized, alternate documentation and/or procedures that provide at least the

level of control described by the standards in this section, as approved by the Tribal Gaming Commission,

shall be acceptable. (NIGC§542.14(a))

II. Physical Characteristics of Casino Cashier Locations

A. Coins shall include tokens.

B. The gaming operation shall maintain a Cashier's Cage on, or immediately adjacent to, the gaming floor

to house the cashiers and to serve as the central location for the following:

1. The approval of patron checks for the purpose of gaming in conformity with these standards;

2. The receipt, distribution, and redemption of gaming chips in conformity with these standards; and

3. Such other functions, forms and documents normally associated with the operation of a cage.

C. A room known as the 'Main Bank" shall be maintained in an area (not open to the public) to house Main

Bank Cashiers. The Main Bank shall serve as the central location for the following:

1. The custody of currency, coin, gaming chips, tickets and all completed forms, documents, and

records transferred in by the cashier cage and other casino operations departments;

2. The exchange of tickets, currency, coin, and gaming chips for supporting documentation;

3. The receipt of currency and coin and tickets from the soft count and hard count room;

4. The responsibility for overall reconciliation of documentation generated by casino operations daily;

and

5. All reserve cash bankrolls required to facilitate a smooth functioning cage operation, given

fluctuating business volumes.

D. The Cashier Cage and Chip Bank shall be designed and constructed to provide maximum security

including, at a minimum, the following:

1. A fully enclosed structure except for openings through which items such as gaming chips, checks,

cash, records, and documents can be passed to serve the public and gaming table;

2. Manually triggered silent alarm systems connected directly to the Surveillance monitoring room

with appropriate notification of department per established protocol;

3. Access shall be limited and restricted through a locked door. All personnel, excluding Casino Cage

Cashier employees and other authorized personnel shall be required to sign a cage access log as

they enter, unless it is a life threatening event, illness or injury; and

4. Closed-circuit television coverage shall be maintained and monitored by the Surveillance

Department.

E. Casino management shall place on file with the Tribal Gaming Commission the names of all persons

authorized to enter the cage, the names of all persons who possess the combination or the keys, or those

persons who control the mechanism to open the locks securing the entrance to the cage and the names

of all persons who possess the ability to operate the alarm systems.

III. Coupon Standards

Any program for exchanges of coupons for chips and/or tokens or other coupon program shall be approved

by the Commission prior to implementation. If approved, the gaming operation shall establish and comply

with procedures that account for and control of such programs. (NIGC§542.14(f))





IV. Casino Cashier Accounting Controls

A. The assets for which the Casino Cage Cashiers are held responsible shall be maintained on an imprest

basis and protected from unauthorized access.

B. Cashier functions shall be, but are not limited to, the following:

1. Redeem tickets from players;

2. Receive gaming chips from players in exchange for cash;

3. Receive traveler's checks and other cash equivalents from patrons in exchange for currency or coin;

4. Process patron credit/debit card transactions through the credit card network approved by the Tribal

Gaming Commission;

5. Exchange foreign currency received from patrons into U.S. dollars;

6. Receive cash, cash equivalents, gaming chips, and/or coin, tokens, from patrons as deposits;

7. Refund cash or cash equivalents to a patron that have been held on deposit;

8. Receive documentation with signature thereon, required to be prepared for the effective segregation

of functions in the cashier's cage;

9. Receive from Security Department Representatives gaming chips and/or coins removed from

gaming tables in exchange for the issuance of a Credit;

10. Receive from Security Department Representatives, Requests for Fills in exchange for the issuance

of a fill and the disbursal of gaming chips and/or coin;

11. Prepare the overall cage reconciliation and accounting records;

12. Perform such other functions as necessary to ensure proper accountability consistent with Internal

Control standards; and

13. Receive tickets, cash and coin from the count rooms and post to the cage accountability.

C. The gaming operation, in its discretion, may utilize the necessary number of independent cashiers to

ensure compliance with these standards.

D. Kiosks may be used for redemption of tickets and currency denomination changes.

V. Accountability for Funds

A. All transactions that flow through the Cage shall be summarized on a Cage Accountability Form on a

per shift basis and shall be supported by documentation. (NIGC§542.14(d)(1))

1. All imprest inventory of all Cashier Cages shall be recorded on the Main Bank Settlement Sheet.

2. At the end of each shift, the outgoing Main Bank Cashier shall prepare a Main Bank Settlement

Sheet listing all main bank items in inventory.

3. The Main Bank Settlement Sheet, when completed, shall be signed by the outgoing Main Bank

Cashier and the incoming Main Bank Cashier.

B. The cage and vault (including coin room) inventories shall be counted by the oncoming and outgoing

cashiers. These employees shall make individual counts for comparison and accuracy and maintenance

of individual accountability. Such counts shall be recorded at the end of each shift during which activity

took place. All discrepancies shall be noted and investigated. Unverified transfers of cash and/or cash

equivalents are prohibited. Such counts shall be recorded at the end of each shift. All discrepancies

shall be noted and investigated. (NIGC§542.14(d)(2))





C. The Commission or the gaming operation as approved by the Commission shall establish and the

gaming operation shall 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 customers as they are incurred.

(NIGC§542.14(d)(3)) Any variance in the reconciliation (over/short) shall be documented and

accounting/auditing personnel shall investigate variances in accordance with department procedures, as

necessary. The Tribal Gaming Commission shall be immediately notified of all variances over $100.00

in a timely manner. The Tribal Gaming Commission may conduct an investigation into these variances.

If a variance is over $500.00, the Cashier with responsibility for the funds shall remain at the gaming

operation until the variance is accounted for, or until the Cashier is excused from his/her shift by a

Tribal Gaming Inspector, who is aware of the variance in question.

D. Signatures attesting to the accuracy of the information contained on the Cashier Count Sheets, Chip

Bank Inventory Sheet, and Main Bank Settlement Sheet shall include, at a minimum, the Cashier

assigned to the outgoing shifts.

E. The gaming operation shall establish and implement procedures for the exchange of funds between

cashiers, upon approval of the Tribal Gaming Commission.

F. At least once a day, accounting/auditing personnel shall collect all Casino Cage Cashier paperwork and

documentation that have been deposited in the accounting box for audit and summarization.

VI. Procedures for Check Transactions in All Areas of the Casino

A. The gaming operation shall establish and comply with procedures for the acceptance of personal

checks. (NIGC§542.14(b)(2))

B. All personal checks sought to be exchanged for cash, tokens, coin, services, etc. in the tribal gaming

operation by a patron shall be:

1. Drawn on a bank and payable on demand;

2. Drawn for a specific amount;

3. Made payable to the “Gaming Operation Name” ; and

4. Currently dated (not post-dated).

C. When personal, third-party checks, or cashier’s checks are presented, the cashier shall:

(NIGC§542.14(b)(1))

1. Physically examine and record at least one form of valid patron photo identification, i.e. driver's

license, passport, state-issued identification card, military identification or Veteran's Administration

photo identification (cashiers are required to examine the identification after asking the patron to

remove it from their wallet, billfold, etc.);

2. Restrictively endorse the check "For Deposit Only" specifically to the gaming operation’s bank

account;

3. Place cashier’s first initial, last name and license number on the check;

4. Date and time stamp the check except guaranteed checks;

5. Immediately exchange the check for currency and/or coin, token or services in an amount equal to

the amount for which the check was drawn;

6. Forward all patron checks to the Main Bank Cashier at the end of the shift for deposit to the

gaming operation bank account; and

7. Perform any other procedures, which the electronic check cashing service requires.

D. Personal checks presented to the Casino Cage Cashier shall be verified through an electronic check

cashing service.





E. Prior to acceptance of a traveler’s check or the guaranteed drafts, such as cashier’s check, are presented,

the cashier shall comply with the examination and documentation procedures as required by the issuer.

The Cashier shall also perform the following to verify its validity by: (NIGC§542.14(b)(4))

1. Requiring the patron to countersign the traveler’s check in his/her presence;

2. Comparing the countersignature with the original signature on the travelers check;

3. Examining the traveler’s check for any other signs of tampering, forgery, or alteration; and

4. Performing any other procedures, which the issuer of the traveler’s check requires.

F. Prior to the tribal gaming operation accepting any check from a patron, a Cashier shall examine and

record one form of patron photo identification to verify the patron's identification and shall maintain

documentation supporting that examination.

G. When counter checks are issued, the following shall be included on the check: (NIGC§542.14(b)(3))

1. The patron’s name and signature; (NIGC§542.14(b)(3)(i))

2. The dollar amount of the countercheck (both alpha and numeric); (NIGC§542.14(b)(3)(ii))

3. Customer’s bank name and bank account number; (NIGC§542.14(b)(3)(iii))

4. Date of issuance; and (NIGC 542.14(b)(3)(iv))

5. Signature of first initial, last name, and gaming license number of the individual approving the

counter check. (NIGC§542.14(b)(3)(v))

H. Ticket redemption standards are included in the Technical Standards.

I. No Person acting on behalf of or under any arrangement with the tribal gaming operation and no person

acting on behalf of or under any arrangement with the Tribal Gaming Commission shall make any loan,

or otherwise provide or allow to any person any credit or advance of anything of value, or which

represents value to enable any person to take part in gaming activity as a player provided, that nothing

in these standards shall restrict the use of any automatic device for providing cash advances on patron’s

credit card or bank cards in accordance with normal commercial practices provided, further, that

nothing in these standards shall restrict the use of patron checks within utilized in accordance with these

standards. (Compact, Appendix A§13(a))

VII. Deposit of Funds Received: Procedure for Depositing Checks Received From Gaming Patrons

A. All checks received by the gaming operation, in conformity with these standards, shall be forwarded to

the Main Bank for deposit. All checks shall be processed through the approved electronic check

cashing service and shall be deposited into the tribal gaming operation bank account in accordance with

the tribal gaming operations. Normal business practice shall provide for the deposit of all checks

received within seven (7) days after receipt.

B. In computing the time period for deposits, the last day of the period shall be included unless it is a

Saturday, Sunday, or a state or federal holiday, in which event the time period shall run until the next

business day.

C. Any check deposited into a bank shall not be considered clear until a reasonable time has been allowed

for such check to clear the banking system. (See also Compact Appendix A §14, 15)

VIII. Collection and Recording of Returned Checks After Deposit

A. All dishonored checks returned by a bank ("returned checks") after deposit, which includes re-deposit

procedures, shall be returned directly to, and controlled by, accounting department employees that do

not have incompatible responsibilities. Procedures shall provide for notification of cage check cashing

and custodian of returned checks. (NIGC§542.14(b)(2))





B. A reasonable effort shall be made to collect on all returned checks. No person other than an accounting

department employee, who has no incompatible functions, may engage in efforts to collect returned

checks, except that a collection company or an attorney-at-law representing the company may bring

action for such collection.

C. All checks processed through the electronic check cashing service shall be turned over to that company

for collection. The gaming operation shall be paid by the check cashing services company for the face

value of the check. No collection efforts shall be required by the gaming operation.

D. A continuous record of all returned checks shall be maintained by accounting department personnel.

Such records shall include, at a minimum, the following:

1. The original date of the check;

2. The name and address of the drawer of the check;

3. The check number;

4. The amount of the check;

5. The date(s) the check was dishonored; and

6. The date(s) and amount(s) of any collections received on the check after being returned by a bank.

E. A check dishonored by a bank may be immediately re-deposited if there is sufficient reason to believe the

check will be honored the second time.

F. If a check is dishonored a second time upon redeposit, the name of the person who submitted the check

shall be kept in a log, which is available to cashier personnel. Such person shall be prohibited from

submitting a future check until the amount is paid in full.

G. Statements shall be sent to patrons immediately upon receipt of returned checks or immediately upon

receipt of a check returned for a second time, if the check was immediately re-deposited as described

above, and on a period basis (at least quarterly) thereafter until collection efforts are discontinued.

H. After all reasonable collection efforts have been made, returned checks shall be considered uncollectible

for accounting purposes and charged the gaming operation allowance for uncollectible patron checks

after the following information has been included in the patron's file: (NIGC§542.14(b)(2))

1. Documentation by the accounting department employees evidencing independent efforts to collect

the patron's outstanding check(s) and the reason why such collection efforts were unsuccessful.

2. The listing of uncollectible checks shall be approved in writing by, at a minimum, Vice President

and General Manager, Director of Finance and Administration and a designated Accounting

Department Supervisor. Any subsequent payments shall be noted and adjusted on the listing. This

updated listing shall be provided, in writing, to the Tribal Gaming Commission on a monthly basis.

(See also Compact Appendix A § 14, 15)

3. The gaming operation shall develop procedures for approval by the Tribal Gaming Commission

regarding checks dishonored by the banking system. The process shall include procedures for both

the criteria for writing-off checks in general and for individual checks specifically.

(NIGC§542.14(b)(2))

IX. Procedures for Credit/Debit Card Transactions

A. A patron may obtain cash at the Cashier's Cage to be used for gaming purposes by presenting a

recognized credit/debit card to a Casino Cage Cashier. The casino shall utilize an approved credit/debit

card network to process these cash advance transactions.

B. Prior to the issuance of cash to the individual, the Casino Cage Cashier shall:

1. Obtain the patron's credit/debit card and examine the expiration date, patron's name, and patron's

signature. In addition, one form of photo identification shall be obtained for verification, e.g.

driver's license, military identification, passport, state-issued identification card;





2. Request the dollar amount of the transaction to be processed from the patron and verify with the

electronic funds transfer company.

C. The gaming operation shall develop procedures for the acceptance and processing of credit/debit

transactions that are in accordance with these standards for approval by the Tribal Gaming Commission.

X. Foreign Currency Exchange

A. All foreign currency exchanges shall be completed at the Casino Cashier's Cage by a Casino Cashier.

The Casino Cashier shall calculate the exchange rate.

B. All foreign currency shall be transferred to the Main Bank by the end of the shift for deposit.

XI. Customer Deposits/Safekeeping Deposits

A. Only cash, cash equivalents, gaming chips, and tokens shall be accepted from customers for the purpose

of a customer deposit. (NIGC§542.14(c)(6))

B. Tickets shall be redeemed prior to acceptance from a customer for a deposit. (Technical Standards)

C. A file for customers shall be prepared prior to acceptance of a deposit. (NIGC§542.14(c)(8))

D. Casino management, approved by the Tribal Gaming Commission, shall establish and comply with

procedures that: (NIGC§542.14(c)(3))

1. Maintain a detailed record by customer name and date of all funds on deposit;

(NIGC§542.14(c)(3)(i))

2. Maintain a current balance of all customer cash deposits, which are in the cage/vault inventory of

accountability; (NIGC§542.14(c)(3)(ii))

3. Reconcile this current balance with the deposits and withdrawals at least once daily.

(NIGC§542.14(c)(3)(iii))

4. Provide adequate controls for the acceptance of deposits and refunds (withdrawals) to patrons,

including refunds to patrons who have lost their copies of the deposit receipt.

E. The gaming operation as approved by the Commission shall describe the sequence of the required

signatures attesting to the accuracy of the information contained on the customer deposit or withdrawal

form ensuring that the form is signed by the cashier. (NIGC§542.14(c)(4))

F. At least a two-part deposit form shall evidence the receipt or withdrawal (refund) of customer funds.

One copy shall be provided to the patron, and one copy shall be maintained in the cage file.

(NIGC§542.14(c)(1))

G. The Casino Cage Cashier shall accept and record deposits in the following manner:

1. The following information is obtained and recorded on at least a two-part Deposit Receipt:

(NIGC§542.14(c)(2)(i-vi))

a. Same receipt number on all copies; (NIGC§542.14(c)(2)(i))

b. Customer Name and signature; (NIGC§542.14(c)(2)(ii))

c. Current Date (Gaming Day) of receipt and withdrawal; (NIGC§542.14(c)(2)(iii))

d. Dollar amount deposited/withdrawal (written and numeric); (NIGC§542.14(c)(2)(iv))

e. Nature of deposit by denomination and type (cash, cash equivalent, chips and tokens); and

(NIGC§542.14(c)(2)(v))

f. The signature (first initial, last name, and Tribal Gaming Commission license number) of the

Casino Cage Cashier accepting the deposit.

g. Provided all of the information in XI.G.1.A. through F is available, the only required

information for all copies of the receipt is the receipt number. (NIGC§542.14(c)(2)(vi))





H. All customer deposits and withdrawal transactions at the cage shall be recorded on a cage accountability

form on a per-shift basis. (NIGC§542.14(c)(5))

I. All voided Deposit Receipts shall contain the Casino Cage Cashier, Cashier Cage Supervisor or Cage

Shift Manager signatures and a brief explanation of why the document was voided. All parts of the

voided form shall be marked "VOID", time and date stamped and then forwarded to

accounting/auditing personnel at the end of the shift.

J. The gaming operation as approved by the Commission shall establish and comply with procedures that

verify the customer’s identity, including photo identification. (NIGC§542.14(c)(7))

K. All transactions that flow through the cage shall be supported by documentation. (NIGC§542.14(c)(8))

XII. Ticket In/Ticket Out Transactions

The gaming operation shall develop and present to the Commission for approval procedures and policies

regarding the handling of tickets within the framework of the Technical Standards and these TC3MICs.

Such procedures shall include redemption, outstanding ticket liability and mutilated tickets and meet

requirements set forth by NIGC for cash-out tickets.

XIII. Extraneous Items

The gaming operation, as approved by the Commission, shall establish and comply with procedures to

address the transporting of extraneous items, such as coats, purses, and/or boxes, into and out of the cage,

coin room, count room, and/or vault. These procedures shall be documented in the Casino internal control

standards. (NIGC§542.14(h))



Section F

ACCOUNTING


I. Accounting Standards

A. The Cage accountability shall be reconciled to the general ledger at least monthly.

(NIGC§542.14(g)(1))

B. A trial balance of gaming operation accounts receivable, including the name of the customer and

current balance, shall be prepared at least monthly for active, inactive, settled or written-off accounts.

Reconciliation and any follow-up performed shall be documented and retained. (NIGC§542.14(g)(2))

C. The trial balance of gaming operation accounts receivable shall be reconciled to the general ledger each

month. The reconciliation and any follow-up performed shall be documented, maintained for

inspection, and provided to the Commission upon request. (NIGC§542.14(g)(3))

D. On a monthly basis, an evaluation of the collection percentage of check cashing shall be used to identify

unusual trends shall be documented and maintained for inspection and provided to the Tribal Gaming

Commission upon request. (NIGC§542.14(g)(4))

E. All Cage and accounting procedures and any follow-up performed shall be documented, maintained for

inspection, and provided to the Commission upon request. (NIGC§542.14(g)(5))

F. An individual independent of the cage, check cashing, and collection functions shall perform all of the

following at least three times per year: (NIGC§542.15(h)(i-iv))

1. Ascertain compliance with check cashing limits and other established check cashing issuance

procedures; (NIGC§542.15(h)(i))

2. Randomly reconcile outstanding balances at both active and inactive accounts on the accounts

receivable listing to individual check cashing records and physical instruments;

(NIGC§542.15(h)(ii))

3. Examine check cashing records to determine that appropriate collection efforts are being made and

payments are being properly recorded; and (NIGC§542.15(h)(iii))

4. For a minimum of five (5) days per month, partial payment receipts shall be subsequently

reconciled to the total payments recorded by the cage for the day and shall be numerically

accounted for. (NIGC§542.15(h)(iv))

II. Minimum Bankroll

For minimum bankroll requirements, see Section E Casino Cage V. C.

III. Accounting Control Structure

A. The gaming operation’s accounting department, supervised by the Director of Finance, shall be

responsible for, but not limited to, the following:

1. The accounting and internal controls.

2. The preparation and control of records and data required by these standards.

3. The control of stored data, the supply of unused forms, the accounting for and comparing of forms

used in the gaming operation as required by these standards.

4. The preparation of timely financial statements meeting the standards of generally accepted

accounting principles used in the United States of America.

5. The preparation and submission to the Commission other reports as required.

IV. Minimum Internal Control Standards for Accounting

A. Each gaming operation shall prepare accurate, complete, legible, and permanent records of all

transactions pertaining to revenue and gaming activities. (NIGC§542.19(a))



Section F

ACCOUNTING


B. Each gaming operation shall prepare general accounting records according to Generally Accepted

Accounting Principles as used in the United States on a double-entry system of accounting, maintaining

detailed, supporting, subsidiary records including, but not limited to: (NIGC§542.19(b))

1. Detailed records identifying revenues, expenses, assets, liabilities and equity for each gaming

operation; (NIGC§542.19(b)(1))

2. Detailed records of returned checks; (NIGC§542.19(b)(2))

3. Individual and statistical game records to reflect statistical drop, statistical win, and the percentage

statistical win to statistical drop by each table game, and to reflect statistical drop, statistical win,

and the percentage of statistical win to statistical drop for each type of table game by shift, by day,

cumulative month-to-date and year-to-date, and individual and statistical game records reflecting

similar information for all other games. (NIGC§542.19(b)(3))

4. Gaming machine analysis reports, which by each machine, compare actual hold percentages to

theoretical hold percentages; (NIGC§542.19(b)(4))

5. The records required by this part and by the TC3MICS; (NIGC§542.19(b)(5))

6. Journal entries prepared by the gaming operation and by its independent accountants; and

(NIGC§542.19(b)(6))

7. Any other records specifically required to be maintained. (NIGC§542.19(b)(7))

C. Each gaming operation shall establish administrative and accounting procedures for the purpose of

determining effective control over a gaming operation’s fiscal affairs. The procedures shall be designed

to reasonably ensure that: (NIGC§542.19(c))

1. Assets are safeguarded; (NIGC§542.19(c)(1))

2. Financial records are accurate and reliable; (NIGC§542.19(c)(2))

3. Transactions are performed only in accordance with management’s general and specific

authorization; (NIGC§542.19(c)(3))

4. Transactions are recorded adequately to permit proper reporting of gaming revenue and of fees and

taxes and to maintain accountability of assets; (NIGC§542.19(c)(4))

5. Recorded accountability for assets is compared with the actual assets at reasonable intervals, and

appropriate action is taken with respect to any discrepancies; and (NIGC§542.19(c)(5))

6. Functions, duties, and responsibilities are appropriately segregated in accordance with sound

business practices. (NIGC§542.19(c)(6))

D. Gross gaming revenue computation: (NIGC§542.19(d))

1. For table games, gross revenue equals the closing table bankroll, plus credit slips for chips, tokens

or personal/payroll checks returned to the cage, plus drop, less opening table bankroll and fills to

the table. (NIGC§542.19(d)(1))

2. For gaming machines, gross revenue equals drop, less fills, jackpot payouts and personal property

awarded to patrons as gaming winnings. Additionally, the initial hopper load is not a fill and does

not affect gross revenue. The difference between the initial hopper load and the total amount that is

in the hopper at the end of the gaming operation’s fiscal year should be adjusted accordingly as an

addition to or subtraction from the drop for the year. (NIGC§542.19(d)(2))

3. Counter games are not offered. (NIGC§542.19(d)(3))

4. For any card game and any other game in which the gaming operation is not a party to a wager,

gross revenue equals all money received by the operation as compensations for conducting the

game. (NIGC§542.19(d)(4))

a. A gaming operation shall not include either shill win or loss in gross revenue computations.

(NIGC§542.19(d)(4)(i))

b. In computing gross revenue for gaming machines, the actual cost to the gaming operation of

any personal property distributed as losses to patrons may be deducted from winnings (other

than costs of travel, lodging, services, food, and beverages) if the gaming operation maintains

detailed documents supporting the deduction. (NIGC§542.19(d)(4)(ii))



Section F

ACCOUNTING


E. Each gaming operation shall establish internal control systems sufficient to ensure that currency (other

than tips or gratuities) received from a patron in the gaming areas is promptly placed in a locked box in

the table or, in the case of a cashier, in the appropriate place in the cashier’s cage, or on those games

which do not have a locked drop box, or on a card game table in a appropriate place on the table, in the

cash register or in another approved repository. (NIGC§542.19(e))

F. If the gaming operation provides periodic payments to satisfy a payout resulting from a wager, the

initial installment payment, when paid, and the actual cost of a payment plan, which is funded by the

gaming operation, may be deducted from winnings. The gaming operation is required to obtain the

payment plans from the Gaming Commission. For any funding method, which merely guarantees the

gaming operation’s performance and under which the gaming operation makes payments out of cash

flow (e.g., irrevocable letters of credits, surety, bonds, or other similar methods), the gaming operation

may only deduct such payments when paid to the patron. (NIGC§542.19(f))

G. For payouts by wide-area progressive gaming machine systems, the gaming operation may deduct from

winnings only its pro rata share of a wide-area gaming machines system payout. (NIGC§542.19(g))

H. Cash-out tickets issued at a gaming machine or gaming device shall be deducted from gross revenue as

jackpot payouts in the month the tickets are issued by the gaming machine or gaming device. Tickets

deducted from gross revenue that are not redeemed within a period, not to exceed 180 days of issuance,

shall be included in gross revenue. An unredeemed ticket previously included in gross revenue may be

deducted from gross revenue in the month redeemed. (NIGC§542.19(h))

I. Credit instruments are not offered in Kansas. (NIGC§542.19(i); NIGC§542.19(j)(1),(2),(3),(4),(5),(6)

and (7))

J. Maintenance and preservation of books, record and documents. (NIGC§542.19(k))

1. All original books, records and documents pertaining to the conduct of wagering activities shall be

retained by a gaming operation in accordance with the following schedule. A record summarizing

gaming transactions is sufficient, provided that all documents containing an original signature(s)

attesting to the accuracy of a gaming related transaction are independently preserved. Original

books, records or documents shall not include copies of originals, except for copies that contain

original comments or notations on parts of multi-part forms. The following original books, records

and documents shall be retained by a gaming operation for a minimum of five (5) years:

(NIGC§542.19(k)(1))

a. Casino cage documents; (NIGC§542.19(k)(1)(i))

b. Documentation supporting the calculation of table game win; (NIGC§542.19(k)(1)(ii))

c. Documentation supporting the calculation of gaming machine win; (NIGC§542.19(k)(1)(iii))

d. Documentation supporting the calculation of revenue received from card games and all other

gaming activities offered by the gaming operation; (NIGC§542.19(k)(1)(iv))

e. Table games statistical reports; (NIGC§542.19(k)(1)(v))

f. Gaming machine statistical analysis reports; (NIGC§542.19(k)(1)(vi))

g. Not relevant to Kansas; (NIGC§542.19(k)(1)(vii))

h. Internal audit documentation and reports; (NIGC§542.19(k)(1)(viii))

i. Not relevant in Kansas; and (NIGC§542.19(k)(1)(xi))

j. All other books, records and documents pertaining to the conduct of wagering activities that

contain original signature(s) attesting to the accuracy of the gaming related transaction.

(NIGC§542.19(k)(1)(x))

K. Unless otherwise specified in this part, all other books records, and documents shall be retained until

such time as the accounting records of the operation have been audited by the Gaming Commission’s

independent certified public accountants. (NIGC§542.19(k)(2))



Section F

ACCOUNTING


L. The above definition shall apply without regard to the medium by which the book, record or document

is generated or maintained (paper, computer-generated, magnetic media, etc.). (NIGC§542.19(k)(3))

V. Accounting Records

A. The Casino shall maintain complete, accurate, and legible records of all transactions relating to the

revenues, costs, assets and liabilities and equity of the gaming operation. All records and documents of

the Casino shall be maintained on the Reservation.

B. All pertinent accounting records shall be maintained for a period of time not less than the time frame

established in Title 12 of the Potawatomi Law and Order Code or as required by any other applicable

law or the Compact, whichever is greater.

C. General accounting records will be maintained on a double entry system of accounting with transactions

recorded on the accrual basis using generally accepted accounting principles, and detailed, supporting

subsidiary records, sufficient to meet the requirements of sub-section E. below.

D. The forms or chart of accounts adopted shall be of a standard which ensures consistency, comparability,

and effective disclosure of financial information. Changes in the forms or chart of accounts shall follow

the procedures outlined for changes to the TC3MICS.

E. The detailed, accounting and subsidiary records shall include, but not be limited to (See also Compact

Appendix A):

1. Records of all patrons' checks initially accepted, deposited, and returned as "uncollected" and

ultimately written off as "uncollectible";

2. For each gaming shift (24-hour), statistical game records to reflect drop and win amounts for each

table and for each game type;

3. Records of investments in property and services, including equipment used directly in connection

with the operation of Class III gaming;

4. Records of amounts payable;

5. Records, which identify the purchase, receipt, and destruction of gaming chips used in wagering;

6. Revenues, expenses, assets, liabilities and equity for each facility at which any component of each

gaming activity or operation is conducted;

7. Daily cash transactions for each game at each facility at which any gaming activity or operation is

conducted, including, but not limited to, transactions relating to each gaming table bank, game drop

box and gaming room bank;

8. Individual and statistical game records to reflect statistical drop, statistical win, statistical drop by

table for each game, and individual and statistical game records reflecting similar information for

all other games;

9. For gaming machines, analytic reports, which by each machine, compare actual hold percentages to

theoretical hold percentages;

10. All audit reports prepared by or for the Tribe; and

11. Records required from other Sections of the ICS are to be incorporated into the system.



Section G

INCOME CONTROL


I. Income Control shall meet all applicable standards as described in each section of these Tribal

Minimum Internal Control Standards

II. Table Games Accounting/Auditing Standards

A. The accounting and auditing procedures shall be performed by personnel who are independent of the

transaction being audited/accounted for. (NIGC§542.12(j)(1))

B. If a table game has the capability to determine drop (e.g., bill-in/coin-drop meters, bill validator,

computerized record, etc.) the dollar amount of the drop shall be reconciled to the actual drop by shift.

(NIGC§542.12(j)(2))

C. Accounting/auditing employees shall review exception reports for all computerized table games

systems at least monthly for propriety of transactions and unusual occurrences. (NIGC§542.12(j)(3))

D. All noted improper transactions or unusual occurrences shall be investigated with the results

documented. (NIGC§542.12(j)(4))

E. All evidence of table games auditing procedures and any follow-up performed shall be documented,

maintained and made available to the Tribal Gaming Commission upon request. (NIGC§542.12(j)(5))

F. A daily recap shall be prepared for the day, month-to-date, and year-to-date which shall include the

following information: (NIGC§542.12(j)(6))

1. Drop; (NIGC§542.12(j)(6)(i))

2. Win; and (NIGC§542.12(j)(6)(ii))

3. Gross Revenue. (NIGC§542.12(j)(6)(iii))

III. Audit of Master Gaming Report

A. The Master Gaming Report and supporting documentation shall be audited by an accounting/auditing

employee who has no incompatible functions.

B. Steps to be performed as part of the Table Games Audit shall include, but are not limited to:

1. Comparison of original documents and copies to stored data for agreement on a test basis.

2. Review, on a test basis, for the appropriate number and propriety of signatures.

3. Account for numerical series of applicable forms.

4. Test for proper calculation, summarization, and recording.

5. Record the activity in the books and records of the gaming operation.

6. Maintain and control the documents as part of the permanent accounting records.

C. The audit shall be performed by an accounting/auditing employee and reviewed by the designated

accounting/auditing Supervisor. The accounting/auditing employee shall sign the work indicating the

audit has been completed satisfactorily.

D. The accounting/auditing employee shall sign-off on the final Master Gaming Report. After the Tribal

Gaming Inspector has signed the final Master Gaming Report, only accounting/auditing shall make any

changes to the Master Gaming Report, with prior written approval of the Tribal Gaming Commission.

IV. Gaming Machine Accounting/Auditing Standards

A. Gaming machine accounting/audit procedures shall be performed by employees who are independent of the

transactions being reviewed. (NIGC§542.13(m)(1))

B. Large (i.e., large by denomination, either $500 or 2% of the drop, whichever is less) or unusual (e.g., zero

for weigh count or patterned for all counts) variances between the weigh/count and wrap shall be

investigated by management personnel independent of the gaming machine department, count team and the

cage/vault functions on a timely basis. The results of such investigation shall be documented and retained

with a copy being forwarded to the Tribal Gaming Commission. (NIGC§542.41(i)(14))



Section G

INCOME CONTROL


C. For computerized gaming machine monitoring systems and multi-game machines, procedures shall be

performed monthly by an employee or department independent of the gaming machine department to

verify that the system is transmitting and receiving data to the gaming machines properly and to verify

the continuing accuracy of the coin-in meter readings as recorded in the gaming machine statistical

report. (NIGC§542.13(m)(2))

D. For each drop period, accounting/auditing employees shall compare the bill-in meter reading to the total

bill acceptor drop amount for the period. Discrepancies shall be resolved before the

generation/distribution of gaming machine statistical reports. (NIGC§542.13(m)(6))

E. Follow up shall be performed for any one machine having an unresolved variance between actual currency

drop and bill-in meter reading in excess of an amount that is both more than $25 and at least three percent

(3%) of the actual currency drop. The follow-up performed and results of the investigation shall be

documented, maintained for inspection, and provided to the Tribal Gaming Commission upon request.

(NIGC§542.13(m)(7))

F. Accounting/auditing personnel shall review exception reports for all computerized gaming machine

systems on a daily basis for propriety of transactions and unusual occurrences. The Tribal Gaming

Commission shall receive timely notification of any unusual occurrences. (NIGC§542.13(m)(9))

G. All gaming machine auditing procedures and any follow-up performed shall be documented and

retained for at least five years for inspection, with a copy being forwarded to the Tribal Gaming

Commission upon request. Oversight reports shall be forwarded bi-monthly to the Tribal Gaming

Commission. (NIGC§542.13(m)(10))

H. At least annually, accounting/auditing personnel shall randomly verify that EPROM changes are

properly reflected in the gaming machine analysis reports. (NIGC§542.13(m)(8))

I. For weigh scale, ticket validation systems and currency interface systems, for at least one drop period

per month accounting/auditing employees shall make such comparisons as necessary to the system

generated count as recorded in the gaming machines statistical report. Discrepancies shall be resolved

prior to generation/distribution of gaming machine reports. (NIGC§542.13(m)(3))

J. For each drop period, accounting/auditing personnel shall compare the "coin-to-drop" meter reading to

the actual drop amount. Discrepancies shall be resolved prior to generation/distribution of gaming

machine statistical reports. (NIGC§542.13(m)(4))

1. The Tribal Gaming Commission shall receive timely notification of any discrepancies prior to the

distribution of said gaming machine reports.

2. Follow-up shall be performed for any one machine having an unresolved variance between actual

drop and coin-to-drop meter reading in excess of 3% and over $25.00. The follow-up performed

and results of the investigation shall be documented and retained with a copy being forwarded to

the Tribal Gaming Commission upon request. (NIGC§542.13(m)(5))

V. Audit of Casino Cashier Reports

A. All reports and supporting documentation relating to Casino Cashier areas shall be audited by an

accounting/auditing representative who has no incompatible functions.

B. The audit steps performed shall include agreement of opening and closing inventories; agreement

between forms, records, and documents; and summarization and recording of transactions, at a

minimum.

C. Upon completion of the shift's work, the accounting/auditing employee shall sign the work indicating

the audit has been completed satisfactorily.



Section G

INCOME CONTROL


VI. Audit of Outstanding Checks and Deposits

A. At least once a week, a continuous record of all returned checks shall be maintained by the Accounting

Department. This list shall include the following information:

1. Name and address of the drawer of the check;

2. Date of check;

3. Date of return of the check,

4. Date(s) the check was dishonored;

5. Amount of the returned check; and

6. The date(s) and amount(s) of any collection received on the check after being returned.

B. A copy of the returned check listing shall be forwarded weekly to the Casino Cashier's Cage for review

when patrons submit a check to be cashed. A copy of the returned check listing shall be delivered to the

Tribal Gaming Commission on a monthly basis.

C. Accounting/auditing personnel shall perform a reconciliation of the cage file of customer deposits to the

amounts listed in the computer system and the general ledger.

VII. Control Over Dispenser Machines

A. Dispensers shall be used to control Manual Fill Slips and Manual Credit Slips.

B. The accounting/auditing department shall be responsible for the loading and unloading of all locking

dispenser machines located in the Cashier's Cage. The last copy shall remain in a continuous, unbroken

form in the dispenser until removed by accounting/auditing personnel.

C. The keys providing access to these machines shall be at all times maintained and controlled by

representatives of the accounting/auditing department.

1. No individual in any other department is authorized to have access to these keys, except for the

Tribal Gaming Commission and the State Gaming Agency.

2. However, the Security Department shall maintain a key to the 'forms dispenser' only if

accounting/auditing personnel are unavailable to clear a jammed machine.

3. Access to any forms dispenser by a Security Department Representative shall be observed by a

Cashier's Cage Supervisor.

D. All dispensers shall be inspected periodically. Any used dispenser copies shall be removed by the

accounting/auditing representatives and maintained by the accounting department. Any machines

needing refills shall be loaded at this time.

VIII. Storage of Unused Forms

A. All unused pre-numbered forms that shall be used in the Casino are controlled, prior to use, by the

accounting/auditing department. Blank forms shall be secured in a restricted access storage area.

B. The receipt and issuance of pre-numbered forms shall be done by an accounting/auditing Representative

through the use of perpetual inventory records. All receipts or issuance shall be documented with the

following information:

1. Type of Form;

2. Initials of accounting/auditing Representatives and date; and

3. Quantity received or issued.

C. Periodically an inventory of all pre-numbered Casino Forms shall be performed. The following parties

shall receive instant, written notification if there are any deviations from the perpetual records: the

Tribal Gaming Commission and the General Manager.



Section G

INCOME CONTROL


D. Any forms that are not required to be controlled by accounting may be maintained and controlled by the

applicable department manager.

IX. Numerical Sequence Control of Computer-Generated Documents

A. The computer shall generate a control number for the following transactions: Fill Slips and Credit Slips.

The control number generated by the system shall be numerically sequenced by type of form.

B. The numerical sequence shall be generated by the computer only upon receipt of valid requests for a

transaction. All computer generated reports that are issued for control purposes shall list the individual

transaction type in numerical sequence, identifying any skips in sequence of voided transactions.

C. Any exceptions, or skips in numerical sequence, shall be researched by accounting/auditing

representatives. The Tribal Gaming Commission shall receive immediate written notification if there

are any such exceptions, or skips in numerical sequence.

X. Signature Records

A. Dated signature cards shall be maintained in a secured area by the Accounting/auditing Department for

each employee who is required to sign Company documents.

B. The signature cards shall be updated on a continuous basis to reflect changes in personnel. The date the

change became effective shall be recorded on the signature card.

XI. Sensitive Key Logs

A. All completed manual Key Control Logs shall be forwarded to accounting/auditing personnel on a

weekly basis, at a minimum, for review and retention.

B. Accounting/auditing personnel shall, on a test basis, audit the Key Control Logs for proper completion

and compliance with sensitive key access.

C. Any instances of non-compliance shall be recorded on an exception report and issued to the appropriate

department manager for review.

XII. Exception Reporting

A. Accounting/auditing personnel shall complete exception reports as deemed necessary for exceptions

noted or issues of non-compliance with the approved Internal Control submission.

B. All exception reports shall be forwarded to the appropriate department manager for notification and

appropriate follow-up, if necessary, and immediately submitted in writing to the Tribal Gaming

Commission.



Section H SURVEILLANCE DEPARTMENT


I. General Responsibilities

A. The management contractor or operator shall establish and maintain:

1. A surveillance department supervised by a Director, which reports directly to the Tribal Council.

(Compact, Appendix A, Sec 6 (c) (ii))

2. Instant access for Commissioners, Inspectors and Officers of the State Gaming Agency to the

Surveillance Department and any and all information requested from the surveillance department.

3. That the surveillance manager shall have open and direct communication with the Tribal Gaming

Commission.

B. No present or former employee of the surveillance department may be employed in any other capacity

in the gaming operation unless the Tribal Gaming Commission, upon petition, approves such

employment in a particular capacity upon finding that:

1. One year has passed since the present or former surveillance department employee worked in the

surveillance department;

2. Surveillance and security systems will not be jeopardized or compromised in the proposed

employment of the former surveillance department employee in the capacity proposed; and

3. Errors, irregularities or illegal acts cannot be perpetuated and concealed by the former surveillance

system in the capacity in which the former surveillance department employee will be employed.

(Compact, Appendix A, Sec 6 (c) (ii) (7))

C. Surveillance shall record in a proper log or journal in a legible manner any exceptions or variations to

established procedures observed during the drop. Such log or journal shall be made available for

review to only those persons who have written authorization from the Tribal Gaming Commission. The

Kansas State Gaming Agency is hereby authorized to view for inspection such logs.

D. The surveillance room shall be staffed for all shifts and activities by personnel trained in the use of the

equipment, knowledge of the games and house rules. (NIGC§542.43 (g))

E. The surveillance manager shall have overall responsibility for the surveillance department.

F. The surveillance department shall be responsible for, but not limited to the following:

1. The clandestine surveillance of the operation and conduct of the gaming activities;

2. The clandestine surveillance of the operation of the cashier's cage;

3. The audio-video taping of activities in the count rooms;

4. The detection of cheating, theft, embezzlement, and other illegal activities in the gaming operation,

count rooms, and cashier's cage;

5. The videotaping of illegal and unusual activities monitored; and

6. The notification of appropriate gaming operation supervisors and the Tribal Gaming Commission

upon the detection or taping of cheating, theft, embezzlement, other illegal activities, or law

enforcement activities.

G. The Surveillance department shall notify the Tribal Gaming Commission of the following:

1. Gaming Machine monitoring system malfunctions,

2. Gaming Machines that are down,

3. Injuries occurring on the premises,

4. Criminal activity,

5. Presence of law enforcement personnel for criminal or civil activity, and/or

6. Tape/Recordable Media review.





II. Surveillance Room and Access

A. A monitoring room shall be established which shall be used by the employees of the surveillance

department assigned to monitor the activities in the Casino and all the gaming areas. This monitoring

room may be accessed and used, at any time, by Tribal Gaming Commissioners and Inspectors and

Officers of the State Gaming Agency. All Surveillance Department employees shall cooperate fully

with Commissioners, Inspectors and State Gaming Agency Officers at all times. (Compact Appendix A,

NIGC§542.43(a))

B. The interior of and entrance(s) to the Surveillance Room shall not be visible to the public and shall not

be visible from the area of the casino where gaming is conducted. Also, the entrance shall not be

readily accessible to employees who work primarily on the casino floor. (NIGC§542.43(b))

C. Access to the surveillance room is restricted to surveillance, State Gaming Agency and Tribal Gaming

Commission personnel. If any other person wants to access the surveillance room, they shall obtain

prior, written permission of the Tribal Gaming Commission. (NIGC§542.43(c))

D. All ingress and egress of the surveillance room shall be recorded in a surveillance access log.

(NIGC§542.43(c))

E. The Tribal Gaming Commission shall authorize only those individuals who are requesting access for a

legitimate and appropriate business reason. Such access shall require the individual to record ingress

and egress in the surveillance access log. (NIGC§542.43(c))

III. Surveillance Equipment

A. A closed-circuit television system shall be installed in accordance with the equipment specifications

outlined by the Tribal Gaming Commission, which shall be operational twenty-four (24) hours per day,

seven (7) days per week.

1. The closed-circuit television system shall include, but not be limited to, the following:

a. Light sensitive cameras, some with fixed and/or pan, zoom, and tilt cameras capable of

effectively and clandestinely monitoring in detail and from various vantage points the

following:

i. The gaming conducted at each gaming table in the Casino and the activities in the

pit areas and electronic gaming equipment.

ii. The operations conducted at and in the Cashier's Cage, Chip Bank, Change Bin,

and Main Bank;

iii. The count processes conducted in the count rooms and vault;

iv. The movement of cash, cash equivalents, coin, gaming chips, and drop boxes and

drop buckets throughout the Casino;

v. The entrances and exits to the Casino, count rooms, and vault room;

vi. The security detention room;

vii. EPROM Duplication Machine; and

viii. Such other areas as the Tribal Gaming Commission designates.

b. In the event of a power loss, an auxiliary or backup power source shall be available and

capable of providing immediate restoration of power to the Surveillance System that enables

surveillance personnel to observe the table games remaining open for play (if applicable) and

all areas covered by dedicated cameras. Auxiliary or back up power sources such as an UPS

system, backup generator, or an alternate utility supplier, satisfy this requirement;

(NIGC§542.43(e))

c. The surveillance system shall include date and time generators, which possess the capability to

display the date and time of recorded events on video and/or digital recordings. The displayed

date and time shall not significantly obstruct the recorded view; and (NIGC§542.43(f))

d. Audio capability in the soft count room and Security Detention Room. (NIGC§542.43(u)(2))





2. Adequate lighting in all areas of the Casino, including gaming tables and pit areas where closed-

circuit camera coverage shall be required.

3. Each video camera required by the standards in this section shall possess the capability of having

its picture displayed on a video monitor and recorded. The surveillance system shall include

sufficient numbers of monitors and recorders to simultaneously display and record multiple gaming

and count room activities and record the views of all dedicated cameras and motion activated

dedicated cameras. (NIGC§542.43(i))

4. Surveillance room equipment shall have total override capability over all other Satellite

surveillance equipment located outside the surveillance room. (NIGC§542.43(d))

5. Each video camera required by these standards shall be installed in a manner that shall prevent it

from being readily obstructed, tampered with, or disabled by patrons or employees.

(NIGC§542.43(h))

B. The Surveillance Department shall check and maintain all equipment on a routine basis:

1. Reasonable effort shall be made to repair each malfunction of the surveillance system equipment

required by the standards in this section within seventy-two (72) hours after the malfunction is

discovered. The Tribal Gaming Commission shall be notified of any camera(s) that has

malfunctioned for more than twenty-four (24) hours. (NIGC§542.43(j))

2. In the event of a dedicated camera malfunction, the gaming operation and/or surveillance

department shall immediately provide alternative camera coverage or other security measures, such

as additional supervisory or security personnel, to protect the subject activity.

(NIGC§542.43(j)(1))

3. The Surveillance Department shall maintain a log that documents each malfunction and repair of

the surveillance system as defined in this section. The log shall state the time, date, and nature of

each malfunction, the efforts expended to repair the malfunction, and the date of each effort, the

reasons for any delays in repairing the malfunction, the date the malfunction is repaired, and where

applicable, any alternative security measures that were taken. (NIGC§542.43(y)(1), (y)(2))

IV. Surveillance Daily Logs and Incident Reports

A. A surveillance log of all surveillance activities in the Surveillance Room shall be maintained for a

period of at least five (5) years and shall be stored in a secured location within the Surveillance

Department. The log shall be prepared by Surveillance Department personnel and include, at a

minimum, the following: (NIGC§542.43(z)(1), (z)(2), (z)(3))

1. Date; (NIGC§542.43(z)(3)(i))

2. The times at which each video or audio recordable media recording is commenced and terminated;

(NIGC§542.43(z)(3)(ii))

3. Name and license number of each person initiating the surveillance; (NIGC§542.43§(z)(3)(iv))

4. Activity observed or performed. Reason for specific surveillance, including the name, if known,

alias or description of each individual being monitored, and a brief description of the activity in

which the person being monitored is engaging; (NIGC§542.43(z)(3)(iii))

5. The time at which each suspected criminal offense is observed, along with a notation of the reading

on the meter/counter that identifies the point on the video recordable media at which such offense

was recorded; (i.e., time and date insertion capabilities)

6. Summary of the results of the surveillance of any suspicious activity. This summary may be

maintained in a separate log; and (NIGC§542.43(z)(4))

7. A record/written notification of any equipment or camera malfunctions.

B. The surveillance log shall be available for inspection at any time by Inspectors of the Tribal Gaming

Commission and Officers of the State Gaming Agency.

C. Surveillance daily logs and incident reports shall be forwarded to the Commission on a daily basis via

facsimile.





V. Video Recording and/or Digital Record Retention/Video Library Log

A. All video recordings and/or digital records shall be retained for a minimum of seven (7) days.

(NIGC§542.43(w)(1))

B. Recordings involving suspected or confirmed gaming crimes, unlawful activity, or detentions by

security personnel shall be retained for a minimum of thirty days, or for such longer period as the Tribal

Gaming Commission or the State Gaming Agency may require. (NIGC§542.43(w)(2)) Recordings of

all linked systems (gaming machines, etc.) shall be maintained for at least 30 days.

C. A video library log shall be maintained to demonstrate the storage, identification, and retention standards

required have been complied with. (NIGC§542.43(x))

D. The Surveillance Department shall maintain a Surveillance Tape/Recordable Media Release Log to

document the release of video recordable media. Whenever a Surveillance recordable media is released

from the Surveillance Department, it shall be noted on the Surveillance Recordable Media Release Log.

Recordable Media shall only be released to authorized individuals upon prior, written approval of the Tribal

Gaming Commission. This shall not limit access to any authorized gaming regulatory entity, which

requests to view and/or obtain the original or dubbed copy of surveillance recordable media.

E. Duly authenticated copies of video recordings, recordable media and/or digital records shall be

provided to the Commission upon request. (NIGC§542.43(w)(3))

VI. Surveillance Coverage of Gaming Floor

A. Except as otherwise provided in paragraphs VI.C. and D. of this section, gaming machines offering a

payout of more than $250,000 shall be monitored by a dedicated camera(s) to provide coverage of:

(NIGC§542.43(r))

1. All patrons and employees at the gaming machine, and (NIGC§542.43(r)(i))

2. The face of the gaming machine, with sufficient clarity to identify the payout line(s) of the gaming

machine. (NIGC§542.43(r)(ii))

B. Notwithstanding paragraph VI.A. if the gaming machine is a multi-game machine, the gaming

operation, with the approval of the Tribal Gaming Commission, may develop and implement alternative

procedures to verify payouts. (NIGC§542.43(r)(4))

C. In-house progressive gaming machines offering a base payout amount (jackpot reset amount) of more

than $100,000 shall be monitored and recorded by a dedicated camera(s) to provide coverage of:

(NIGC§542.43(r)(2))

1. All customers and employees on the gaming machine; and (NIGC§542.43(r)(2)(i))

2. The face of the gaming machine, with sufficient clarity to identify the payout line(s) of the gaming

machine. (NIGC§542.43(r)(2)(ii))

D. Wide-area progressive machines: Wide-area progressive gaming machines offering a base payout

amount of $1 million or more and monitored by an independent vendor utilizing an on-line progressive

computer system shall be recorded by a dedicated camera(s) to provide coverage of:

(NIGC§542.43(r)(3))

1. All customers and employees at the gaming machine; and (NIGC§542.43(r)(3)(i))

2. The face of the gaming machine with sufficient clarity to identify the payout line(s) of the gaming

machine. (NIGC§542.43(r)(3)(ii))





E. The surveillance system of gaming operations operating four (4) or more table games shall provide at a

minimum one pan-tilt-zoom camera per two tables and surveillance shall be capable of taping (except

as otherwise provided in this section): (NIGC§542.43(p)(1))

1. With sufficient clarity to identify patrons and dealers; and (NIGC§542.43(p)(1)(i))

2. With sufficient coverage and clarity to simultaneously view the table bank and determine the

configuration of wagers, card values and game outcome. (NIGC§542.43(p)(1)(ii))

3. One (1) dedicated camera per table and one (1) pan tilt-zoom camera per four (4) tables may be an

acceptable alternative procedure to satisfy the requirements of this paragraph.

(NIGC§542.43(p)(1)(iii))

F. All craps tables shall have two stationary cross view cameras covering both ends of the tables. All

roulette areas shall have one overhead stationary camera covering the roulette wheel and shall also have

one stationary overview of the play of the table. All big wheel games shall have one stationary camera

viewing the wheel. (NIGC§542.43(p)(3), (p)(4), (p)(5))

G. The surveillance system shall monitor and record general activities in each card room with sufficient

clarity to identify the employees performing the different functions. (NIGC§542.43(l))

H. Each progressive table (card) game with a potential progressive jackpot of $25,000 or more shall be

recorded and monitored by dedicated cameras that provide coverage of: (NIGC§542.43(q)(1), (m)(1))

1. The table surface, sufficient that the card values and card suits can be clearly identified;

(NIGC§542.43(q)(1)(i), (m)(1)(i))

2. An overall view of the entire table with sufficient clarity to identify patrons and dealer; and

(NIGC§542.43(q)(1)(ii), (m)(1)(ii))

3. A view of the progressive meter jackpot amount. If several tables are linked to the same

progressive jackpot meter, only one meter need be recorded. (NIGC§542.43(q)(1)(iii), (m)(1)(iii))

I. The gaming operation shall provide the State Gaming Agency with copies of its floor plan and closed

circuit television system and any modifications thereof for review by the State Gaming Agency.

VII. Surveillance Coverage of Cage and Vault

A. The surveillance system shall monitor and record a general overview of activities occurring in each

cage and vault area with sufficient clarity to identify employees within the cage and patrons and

employees at the counter areas. (NIGC§542.43(s)(1))

B. Each cashier station shall be equipped with one (1) stationary overhead camera covering the transaction

area. (NIGC§542.43(s)(2))

C. The surveillance system shall be used as an overview for cash transactions. This overview should

include the customer, the employee and the surrounding area. (NIGC§542.43(s)(3))

VIII. Fills and credits

A. The cage or vault area in which fills and credits are transacted shall be monitored and recorded by a

dedicated camera or motion activated dedicated camera that provides coverage with sufficient clarity to

identify the chip values and the amounts on the fill and credit slips. (NIGC§542.43(t)(1))

B. Controls provided by a computerized fill and credit system may be deemed an adequate alternative to

viewing the fill and credit slips. (NIGC§542.43(t)(2))





IX. Currency and Coin

A. The surveillance system shall monitor and record all areas where currency, tickets or coin may be stored

or counted, including the soft and hard count rooms, all doors to the soft and hard count rooms, all

scales and wrapping machines and all areas where uncounted currency and coin may be stored during

the drop and count process. (NIGC§542.43(u)(1))

B. The gaming operation shall maintain audio capability of the soft count room. (NIGC§542.43(u)(2))

C. The surveillance system shall provide for: (NIGC§542.43(u)(3))

1. Coverage of scales shall be sufficiently clear to view any attempted manipulation of the recorded

data. (NIGC§542.43(u)(3)(i))

2. Monitoring and recording of the table games drop box storage rack or area by either a dedicated

camera or a motion-detector activated camera. (NIGC§542.43(u)(3)(ii))

3. Monitoring and recording of all areas where coin may be stored or counted, including the hard

count room, all doors to the hard count room, all scales and wrapping machines and all areas where

uncounted coin may be stored during the drop and count process. (NIGC§542.43(u)(3)(iii))

4. Monitoring and recording of soft count room, including all doors to the room, all drop boxes, safes,

and counting surfaces, and all count team personnel. The counting surface area shall be

continuously monitored by a dedicated camera during the soft count. (NIGC§542.43(u)(3)(iv))

5. Monitoring and recording of all areas where currency is sorted, stacked, counted, verified or stored

during the soft count process. (NIGC§542.43(u)(3)(v))

X. Change booths

The surveillance system shall monitor and record a general overview of the activities occurring in each of

the gaming machine change booths. (NIGC§542.43(v)) The surveillance system shall monitor and record a

general overview of the activities occurring with kiosks.



Section I

SECURITY DEPARTMENT


I. General Responsibilities

A. The gaming operation’s Security Department shall be responsible for ensuring a secure environment in

the Casino and support facilities.

B. The Chief of Security, who reports to the Vice President and General Manager, shall have overall

responsibility for the Security Department.

II. Incident Reporting

A. The Security Department shall prepare incident reports in all unusual occurrences where the assignment

of a security department representative is requested. The Security Department shall maintain a security

log, in either a written or computerized form, documenting all incident reports. Incident reports shall be

assigned a numerical designator. Access to this log shall be made available for instant inspection by the

State Gaming Agency or the Tribal Gaming Commission. (Compact§7B(1))

B. The Security Supervisor shall ensure that reports are submitted to the Tribal Gaming Commission in a

timely manner and are accurately reported.

C. The Tribal Gaming Inspector shall be instantly notified of any criminal activities or of any injuries.

III. Funds Transfer Control

A. Internal fund transfers shall be monitored by either surveillance or security to ensure security of the

funds.

B. The gaming operation shall disseminate appropriate procedures to the respecting cash handling

departments.

IV. Power Failure/Camera Outage

A. In the event a situation arises whereby the facility experiences a power loss, which results in a camera

outage, Security Department Representatives shall position themselves in areas designated by Security

Department procedures to assist each department in the safeguarding of assets.

B. A Security Department Representative shall be immediately dispatched to monitor the public exit(s) of

the facility. The Security Supervisor shall assign/reassign personnel as deemed appropriate by the

situation.

V. Gaming Restrictions

A. The Security Department shall provide enforcement support regarding the prohibition of minors gaming

in the state of Kansas. No patron under the age of twenty-one (21) years shall be permitted on the

gaming floor except while going to/from the hotel and designated eating areas.

B. All employees shall be responsible for checking IDs to assure compliance.

VI. Firearm Prohibition

A. No person shall be permitted to bring firearms of any kind into the gaming facility except for members

of any State or federal law enforcement agency and the Tribal law enforcement agency.

B. The gaming operation shall post a notice near the entrance of the facility regarding the prohibition of

firearms.



Section I SECURITY DEPARTMENT


VII. Disruptive Patrons

A. The gaming operation shall establish policies regarding the eviction of guest(s) and employee(s).



Section J FEDERAL TAX REQUIREMENTS

STATE TAX REQUIREMENTS


THIS SECTION SHALL BE SUBJECT TO CHANGE ACCORDING TO FEDERAL

REQUIREMENTS. CHANGES SHALL BE MADE INSTANTLY OR AS DIRECTED BY THE

UNITED STATES GOVERNMENT.

I. Federal Tax Reporting

A. Winnings, which meet or exceed a specified level as outlined below, shall be required to be reported

to the Internal Revenue Service on the appropriate form.

1. Electronic Gaming Device: Winning prize of $1200.00 or more.

2. Table Games:

a. Winnings of at least 300 times the original bet and greater than $600.00 in Caribbean

Stud and

b. $600.00 or more Bad Beat Jackpot in Poker.

B. Winnings shall generally be reported on Form W-2G (winner is a U.S. Citizen), which requires the

following information:

1. Name and address of winner;

2. Winner's date of birth;

3. Winner's Social Security Number;

4. Date;

5. Amount won;

6. Location of payout;

7. Initials of preparer; and

8. Description of identification provided.

C. Upon completion of the form, the individual shall sign and date the form in the appropriate space.

All Form W-2Gs shall be forwarded to the Main Bank and subsequently to accounting/auditing

personnel for review and filing.

D. Winnings paid to Non-Residents shall be reported on a Form 1042-S. Federal tax withholdings shall

be required in an amount equal to thirty percent (30%) of winnings. The Form 1042-S shall be

prepared in lieu of a Form W-2G.

E. A Miscellaneous 1099 form shall be prepared for all prizes and giveaways whose value is $600.00 or

more.

II. Currency Transaction Reporting Guidelines

A. The gaming operation shall comply fully with all aspects of the United States Currency Transaction

Reporting laws ("CTR Laws"), which apply to the casino, including all Suspicious Activity

Reporting laws (SAR).

1. Casino employees shall comply with the CTR Laws.

2. Failure of employees to comply with CTR Laws shall result in disciplinary actions, which may

include termination of employment and may subject the employee to civil and criminal fines or

imprisonment.

3. The gaming operation shall establish and implement a written Title 31 compliance program

reasonably designed to assure and monitor compliance with the applicable requirements set

forth in Title 31 of the Code of Federal Regulations (Title 31). The compliance program shall

provide for at least the following:

a. A system of internal controls to assure on-going compliance,

b. Internal and/or external independent testing for compliance,

c. Training of gaming operation personnel, including training in the identification of

unusual or suspicious transactions,






d. An individual or individuals to assure day-to-day compliance, and

e. Procedures for the determination of the following:

i. Name, address, social security number, and other information, and verification of the

same, of a person;

ii. The occurrence of unusual or suspicious transactions; and

iii. Retention of any applicable records as detailed in Title 31.

4. Persons responsible for compliance with the CTR Laws (recording and reporting) include, but

are not limited to, Director of Table Games, Director of Finance, Casino Managers, Games

Managers, Casino Supervisors, Cashier Cage Manager, Cashier Cage Supervisors, Casino

Cashiers, Regulatory Compliance Officer, and all personnel who have knowledge of currency

transactions meeting the reporting threshold.

B. The gaming operation shall be required by Title 31 to file a Currency Transaction Report for Casinos

(CTRC) identifying any patron who performs any transaction, or series of transactions, conducted in

a single gaming day, involving the receipt or disbursement of currency of more than $10,000.

1. Multiple Currency Transactions shall be aggregated and treated as a Single Transaction if the

casino has knowledge that they are by or on behalf of any person and result in either cash in or

out totaling more than $10,000 during a gaming day.

2. The gaming operation shall ensure that cash-in transactions shall be aggregated separately from

cash-out transactions.

C. For the purpose of CTR Reporting, the following transactions shall be considered reportable when

the sum of cash-in transactions or the sum of cash-out transactions exceed $10,000:

1. Purchase of chips or tokens;

2. Bets of currency;

3. Cash Buy-Ins (single or multiple) at the gaming tables;

4. Purchases of casino checks;

5. Exchanges of currency for currency, including foreign currency;

6. Customer safekeeping deposits or refunds;

7. Jackpots payouts in cash;

8. Payments on bets in cash;

9. Payments by a casino to a customer based on receipt of funds through wire transfer for credit to

a customer;

10. Chip, ticket and token redemptions;

11. Cashier Cage cash disbursements;

12. Safekeeping withdrawals;

13. Cashing of checks or other negotiable instruments;

14. Reimbursements for customer travel and entertainment expenses by the gaming operation;

15. Any other cash transaction in excess of $10,000; and

16. Any combination of the transactions noted above that would cause cash in or cash out to exceed

$10,000.

D. “Actual Knowledge”: If casino personnel suspect a patron may be structuring transactions in order

to avoid the casino with sufficient information to fill out a CTR and if any employee deliberately

refuses to ask for name, address and social security number because he/she wishes to remain

ignorant, that employee may be deemed by the IRS (Internal Revenue Service) to have "Actual

Knowledge" and may be found liable for Civil and Criminal Penalties including monetary fines and

imprisonment.

E. Procedures shall be developed to ensure compliance with Title 31 with regards to customer deposits

in the gaming operation.






F. Identification

1. For each customer deposit, casino personnel shall, at the time the funds are deposited, secure

and maintain a record of each patron's name, address, and social security number.

2. Once “Actual Knowledge” that a single or multiple transactions in excess of $10,000 occurs,

the information necessary for a CTR to be completed shall be obtained prior to completion of

the transaction. Casino personnel shall do the following:

a. Verify patron name and address by examination of one of the following forms of photo

identification:

i. Driver's License

ii. Passport

iii. Military I.D.

iv. Alien I.D.

v. State issued non-driver's identification

vi. Veteran's Administration identification

b. The type of document examined shall be recorded on the CTR, along with pertinent I.D.

information, such as document number and issuing jurisdiction. Identification provided is

acceptable even though it may be expired.

c. Casino personnel shall obtain the patron's social security number.

G. No single cash Transaction in excess of $10,000 shall be allowed unless the patron provides his/her

social security number and an acceptable form of identification as a means of verification for his/her

name and address.

H. Cumulative (Multiple Transactions)

1. Multiple Transaction Logs (MTLs) shall be kept for all cash transactions of $3,000 or more.

The log shall include date and time of transaction(s), patron information including physical

description if ID is not available, location and type of transaction, and employee signature/ID

number of employee preparing the log.

2. The Accounting Department shall combine all such recorded transactions and complete the

necessary CTR based on available information at the end of the gaming day. Knowledge that

some transactions shall be recorded by the Accounting Department does not discharge gaming

floor employees of the obligation to obtain necessary information from a patron.

3. In the event that gaming operation employees are aware that two or more persons are

conducting gaming activities as if they are one party, the activity shall be treated as though the

funds are from a Common Bankroll, e.g. if a husband and wife are playing together with a

Common Bankroll and Cash Buy-In exceeds $10,000, a CTR shall be completed for at least one

of the individuals.

I. Gaming employees shall not assist any patron on the circumvention of CTR Reporting requirements.

1. Gaming employees shall be considered circumventing the CTR laws if the employee advises

any patron(s) on how to avoid the CTR Reporting Requirements or engage in "What if"

discussions.

2. Employees shall be responsible for preventing a patron from circumventing the reporting

requirements if the employee has knowledge, or through reasonable diligence in performing

their duties should have knowledge, of the patron's attempt.

J. Gaming Operation Disciplinary Policy

1. Any employee who unintentionally or negligently violates these guidelines and/or the CTR

laws shall be subject to the progressive discipline policy established by the CTR Compliance

Committee.

2. An employee, who intentionally violates the Company guidelines and/or the CTR laws,

including assisting patrons to circumvent the CTR laws, shall be immediately terminated.






3. Disciplinary action shall be progressively applied. Progression is applicable for one year from

any policy violation.

K. Filing of Currency Transaction Reports by Casinos (CTRC)

1. The gaming operation shall file CTRCs within fifteen (15) days following the day on which the

reportable transaction occurred with the Internal Revenue Service (IRS).

2. A copy of each CTRC filed with the IRS shall be retained by the gaming operation for a period

of five years from the date of the report.

III. Monetary Instrument Log

A. The gaming operation shall maintain a listing of each transaction involving the following instruments

having a face value of $3,000 or more:

1. Personal checks;

2. Business checks;

3. Casino Cage checks;

4. Official bank checks;

5. Cashier's checks;

6. Third-party checks (including debit/credit card checks);

7. Traveler's checks;

8. Money orders; and

9. Tickets.

B. The listing shall include the following specific information:

1. Time, date, and amount of the transaction;

2. Name and permanent address of the patron;

3. Type of instrument;

4. Name of the drawee or issuer of the instrument;

5. All instrument reference numbers (bank account number, check number);

6. Individual's casino account number; and

7. Name and casino license number of the employee who conducted the transaction.

C. Applicable transactions shall be placed on the list in the chronological order in which they occur.

IV. State Tax Requirements

A. Nothing in the Compact is deemed to authorize the State to impose any tax, fee, charge or assessment

upon the Tribe, any management contractor or any gaming activity or operation except for the

reimbursement of expenses expressly authorized pursuant to Section 25 of the Compact, nor to

diminish the State's right to tax as provided by applicable federal and state law.

B. However, to the extent that the Tribe is required under federal law to withhold federal income tax

from gaming winnings, the Tribe agrees to withhold state individual income tax from gaming

winnings of non-Indians in the amounts set forth in applicable Kansas law and to furnish the State

with copies of all reports of gaming winnings, which the Tribe is required by federal law to furnish to

the Internal Revenue Service.



Section K

INFORMATION TECHNOLOGY


I. General Controls For Gaming Hardware And Software

A. Management shall take an active role in making sure physical and logical security measures are

implemented, maintained, and adhered to by personnel to prevent unauthorized access that could

cause errors or compromise data or processing integrity. (NIGC§542.16(a)(1))

1. Management shall ensure that all new gaming vendor hardware and software agreements and

contracts shall contain language requiring the vendor to adhere to the Commission Minimum

Internal Control Standards applicable to the goods and services the vendor is providing.

(NIGC§542.16(a)(1)(i))

2. Physical security measures shall be in place over computers, computer terminals, and storage

media to prevent unauthorized access and loss of integrity of data and processing.

(NIGC§542.16(a)(1)(ii))

3. Access to system software and applications programs shall be limited to authorized personnel.

(NIGC§542.16(a)(1)(iii))

4. Access to computer data shall be limited to authorized personnel. (NIGC§542.16(a)(1)(iv))

5. Access to computer communications facilities, or the computer system, and information

transmissions shall be limited to authorized personnel. (NIGC§542.16(a)(1)(v))

6. The standard in paragraph I.A. of this section shall apply to each applicable department within

the gaming operation. (NIGC§542.16(a)(1)(vi))

7. Incompatible duties shall be adequately segregated and monitored to prevent error in general

information technology procedures to go undetected or fraud to be concealed.

(NIGC§542.16(a)(4))

8. The computer systems, including application software, shall be secured through the use of

passwords or other approved means where applicable. Management personnel or persons

independent of the department being controlled shall assign and control access to system

functions. (NIGC§542.16(a)(6))

9. Passwords shall be controlled as follows unless otherwise addressed in the standards in this

section. (NIGC§542.16(a)(7))

a. Each user shall have their own individual password; and (NIGC§542.16(a)(7)(i))

b. Passwords shall be changed at least quarterly with changes documented.

(NIGC§542.16(a)(7)(ii))

c. For computer systems that automatically force a password change on a quarterly basis,

documentation shall be maintained listing the systems and the date the user was given

access. (NIGC§542.16(a)(7)(iii))

B. The main computers (i.e. hardware, software and data files) for each gaming application (e.g. gaming

machines and all other applications used by the gaming operation, etc.) shall be in a secured area

with access restricted to authorized persons, including vendors. (NIGC§542.16(a)(2))

C. Access to computer operations shall be restricted to authorized personnel to reduce the risk of loss of

integrity of data or processing. (NIGC§542.16(a)(3))

D. Non-information technology personnel shall be precluded from having unrestricted access to the

secured computer areas. (NIGC§542.16(a)(5))

E. Adequate backup and recovery procedures shall be in place, that include: (NIGC§542.16(a)(8))

1. Frequent backup of data files; (NIGC§542.16(a)(8)(i))

2. Backup of all programs; (NIGC§542.16(a)(8)(ii))

3. Secured off-site storage of all data files and programs or other adequate protection; and

(NIGC§542.16(a)(8)(iii))

4. Recovery procedures, which are tested on a sample basis at least annually with documentation

of results. (NIGC§542.16(a)(8)(iv))



Section K INFORMATION TECHNOLOGY


F. Adequate information system documentation shall be maintained including descriptions of the

hardware and software operator manual, etc. (NIGC§542.16(a)(9))

G. The information technology personnel shall be independent of the gaming areas (e.g. pit, cage, count

rooms, etc.). The information technology personnel procedures and controls should be documented

and responsibilities communicated. (NIGC§542.16(b)(1))

H. Information technology personnel shall be precluded from having unauthorized access to:

(NIGC§542.16(b)(2))

1. Computers and terminals located in the gaming areas; (NIGC§542.16(b)(2)(i))

2. Source documents; and (NIGC§542.16(b)(2)(ii))

3. Live data files (not test data). (NIGC§542.16(b)(2)(iii))

I. Information technology personnel shall be restricted from: (NIGC§542.16(b)(3))

1. Having unauthorized access to cash or other liquid assets; and (NIGC§542.16(b)(3)(i))

2. Initiating general or subsidiary ledger entries. (NIGC§542.16(b)(3)(ii))

J. When remote dial-up to any equipment is allowed for software support, a log shall be maintained

which includes: (NIGC§542.16(e)(1))

1. Name of employee authorizing modem access; (NIGC§542.16(e)(1)(i))

2. Name of authorized programmer or manufacturer representative; (NIGC§542.16(e)(1)(ii))

3. Reason for modem access; (NIGC§542.16(e)(1)(iii))

4. Description of work performed; and (NIGC§542.16(e)(1)(iv))

5. Date, time and duration of access. (NIGC§542.16(e)(1)(v))

K. The modem for dial-up support shall be powered off while not in use to prevent unauthorized access.

Modem support shall be authorized by Information Technology supervisory personnel.

L. A unique and confidential password shall be maintained for vendor use in providing system support.

This password shall be communicated to vendor representatives immediately prior to performance of

system support work. The password shall then be changed within 24 hours of the completion of

support work.

M. Computer security logs, if generated by the system, shall be reviewed by Information Technology

supervisory personnel for evidence of: (NIGC§542.16(d)(1))

1. Multiple attempts to log-on, or alternatively, the system shall deny user access after three

attempts to log-on; (NIGC§542.16(d)(1)(i))

2. Unauthorized changes to live data files; (NIGC§542.16(d)(1)(ii))

3. Any other unusual transactions; and (NIGC§542.16(d)(1)(iii))

4. This paragraph shall not apply to personal computers not connected to the system.

(NIGC§542.16(d)(2))

II. Manager/Operator Information Technology Responsibilities

A. Gaming program and other program changes for in-house developed systems shall be documented as

follows: (NIGC§542.16(c)(1))

1. Requests for new programs or program changes shall be reviewed by the Information

Technology supervisor. Approvals to begin work on the program shall be documented;

(NIGC§542.16(c)(1)(i))

2. A written plan of implementation for new and modified programs shall be maintained and shall

include, at a minimum, the date the program is to be placed into service, the nature of the

change, a description of procedures required in order to bring the new or modified program into

service (conversion or input of data, installation procedures, etc.), and an indication of who is to

perform all such procedures; (NIGC§542.16(c)(1)(ii))





3. Testing of new and modified programs shall be performed and documented prior to

implementation; and (NIGC§542.16(c)(1)(iii))

4. A record of the final program or program changes, including evidence of user acceptance, date

in service, programmer, and reason for changes, shall be documented and maintained.

(NIGC§542.16(c)(1)(iv))

III. Document Storage

A. Documents may be scanned or directly stored to an unalterable storage medium under the following

conditions: (NIGC§542.16(f)(1))

1. The storage medium shall contain the exact duplicate of the original document.

(NIGC§542.16(f)(1)(i))

2. All documents stored on the storage medium shall be maintained with a detailed index

containing the gaming operation department and date. This index shall be made available to

NIGC upon request. (NIGC§542.16(f)(1)(ii))

3. Upon request and adequate notice by the NIGC, hardware (terminal, printer, etc.) shall be made

available in order to perform auditing procedures. (NIGC§542.16(f)(1)(iii))

4. Controls shall exist to ensure the accurate reproduction of records up to and including the

printing of stored documents used for auditing purposes. (NIGC§542.16(f)(1)(iv))

5. The storage medium shall be retained for a minimum of five (5) years. (NIGC§542.16(f)(1)(v))

6. Original documents shall be retained until the books and records have been audited by an

independent certified public accountant. (NIGC§542.16(f)(1)(vi))

IV. Remote Access to Information Technology

A. If remote dial up is allowed to any associated equipment for software support, the gaming operation

shall maintain a log that includes: (NIGC§542.16(e))

1. Name of employee authorizing modem access, (NIGC§542.16(e)(i))

2. Name of authorized programmer or manufacturer representative, (NIGC§542.16(e)(ii))

3. Reason for access, (NIGC§542.16(e)(iii))

4. Description of work performed, and (NIGC§542.16(e)(iv))

5. Date and duration of access. (NIGC§542.16(e)(v))

V. Information Technology Systems – On and Off-Site

A. The ICS shall include a description of all Casino gaming computer systems used and all computer

systems, on or offsite, that interface with gaming computer systems that track, control, monitor or

account for gaming operation activities, including microcomputer data input templates developed

from applications such as Microsoft Word and Excel. (See gaming machine section for additional

Computer Activities) (Compact §5 (F))

B. The gaming operation shall ensure that procedures are established to:

1. Notify and obtain prior approval of the Tribal Gaming Commission for proposed changes to the

computer monitoring system using the procedures outlined for changes in ICS;

2. Update or change information (passwords, etc.);

3. Establish back-up files;

4. Protect files (off-site storage of back-up files);

5. Limit access to computer software and equipment (restricted access, locked doors);

6. Provide the Tribal Gaming Commission timely lists of authorized access personnel;

7. Test program changes or implementation of new or upgraded hardware and software;

8. Control the ability to access computer programs and equipment at each level (key access, time-

out restrictions, passwords);

9. Compare computer generated information affecting gaming revenues through physical count,

management analysis, and other methods;





10. Ensure that a department independent of the gaming machine department performs maintenance

of the computerized gaming machine monitoring system data files; alternatively, maintenance

may be performed by gaming machine supervisory employees if sufficient documentation is

generated, and it is randomly verified by employees independent of the gaming machine

department on a monthly basis; (NIGC §542.13(h)(20))

11. Ensure updates to the computerized gaming monitoring system to reflect additions, deletions or

movements of gaming machine machines are made at least weekly prior to in-meter readings

and the weigh process; (NIGC §542.13(h)(21))

12. Provide documentation regarding each change to the information technology system in the

same manner as changes to the ICS are requested;

13. Ensure follow-up communication between individual machine(s) and the central computer after

communication problems;

14. Provide records for review immediately upon request from the Tribal Gaming Commission;

15. Ensure that a department independent of the gaming machine departments verifies that the on-

line gaming machine monitoring system is transmitting and receiving data from the gaming

machines properly at least monthly; and (NIGC §542.13(m)(2))

16. Verify the continuing accuracy of coin-in meter readings as recorded on the gaming machine

statistical report. (NIGC §542.13(m)(2))

C. Instant access to computer-contained information shall be furnished to Commissioners, Inspectors,

State Gaming Officers, NIGC Officials and other Tribal Gaming Commission and State Gaming

Agency Executive Director authorized individuals. (Compact §10A, 11A, 12A)



Section L

COMPLIMENTARY SERVICES AND ITEMS


I. Guidelines for Discretionary Complimentaries

A. Complimentary means a service or item provided at no cost, or at a reduced cost, to a customer.

B. Discretionary complimentaries are guest rewards based on level of play, which are beyond Reward

Credits. All complimentaries shall be granted for patrons or players at or in active play at the tribal

gaming operation. Administrative complimentaries may be issued to business associates in

conjunction with business related meetings.

C. The gaming operation shall establish as approved by the Commission, and the gaming operation shall

comply with procedures for the authorization, issuance, and tracking of complimentary services and

items, including cash and non-cash gifts. Such procedures as approved by the Commission shall

include, but not be limited to, the procedures by which the gaming operation delegates to its

employees the authority to approve the issuance of complimentary services and items and the

procedures, which conditions or limits, if any, which may apply to such authority are established and

modified, including limits based on relationships between the authorizer and recipient and shall

further include effective provisions for audit. (NIGC§542.17(a)) Employees are prohibited from

giving complimentaries to relatives.

1. Vice President and General Manager: Limit $10,000 per person, per day, Outlet - Hotel, food

venues within the operation, gift shop, tribal entities and only those other items that are approved

in writing by the Tribal Gaming Commission.

2. Assistant General Manager: Limit $2,500 per person, per day, Outlet - Hotel, food venues within

the operation, gift shop, tribal entities, and only those other items that are approved in writing by

the Tribal Gaming Commission.

3. Direct Reports to General Manager: Limit $1,500 per person, per day, Outlet - Hotel, food

venues within the operation, tribal entities, and only those other items that are approved in

writing by the Tribal Gaming Commission.

4. Manager on Duty: Limit $500 per person, per day, Outlet – Hotel, food venues within the

operation, gift shop, tribal entities, and only those other items that are approved in writing by the

Tribal Gaming Commission.

5. Gaming Machine Shift Managers: Limit $500 per person, per day, Outlet - Hotel, food venues

within the operation, gift shop, tribal entities, and only those other items that are approved in


6. Gaming Machine Supervisors: Limit $100 per person, per day, Outlet - Hotel, food venues



7. Hotel/Guest Services Manager: Limit $500 per person, per day, Outlet - Hotel, food venues



8. Games Shift Managers: Limit $500 per person, per day, Outlet - Hotel, food venues within the



9. Senior Games Supervisors: Limit $250 per person, per day, Outlet - Hotel, and food venues

within the operation, gift shop, and only those other items that are approved in writing by the


10. Gaming Supervisors: Limit $100 per person, per day, Outlet - Hotel, and food venues within the

operation, gift shop, and only those other items that are approved in writing by the Tribal

Gaming Commission.

11. Marketing Services Manager: Limit $100 per person, per day, Outlet - Hotel, food venues within



12. Manager/Sales/Events/Promotions: Limit $100 per person, per day, Outlet - Hotel, food venues





Section L COMPLIMENTARY SERVICES AND ITEMS


13. Public Relations Manager: Limit $100 per person, per day, Outlet - Hotel, food venues within



14. Casino Hosts: Limit $250 per person, per day, Outlet - Hotel, food venues within the operation,

gift shop, tribal entities, and only those other items that are approved in writing by the Tribal

Gaming Commission.

15. Manager Player Data: Limit $100 per person, per day, Outlet - Hotel, food venues within the



16. Player Data Card Supervisors: Limit $100 per person, per day, Outlet - Hotel, food venues

within the operation, gift shop, tribal entities, valet and only those other items that are approved

in writing by the Tribal Gaming Commission.

17. Player Data Card Leads: Limit $100 per person, per day, Outlet - Hotel, food venues within the

operation, gift shop, tribal entities, valet and only those other items that are approved in writing

by the Tribal Gaming Commission.

18. Player Data Card Representatives: Are not allowed to do any discretionary comping.

19. Assistant Food & Beverage Manager: Limit $500 per person, per day, Outlet - Food venues

within the operation, gift shop, tribal entities and only those other items that are approved in


D. The staff, employees, and agents of the gaming operation shall be strictly prohibited from offering,

providing, or attempting to provide complimentaries, in any form, to any members of the Tribal

Council, Tribal Gaming Commission, Management Committee members, or Tribal Gaming

Commission Inspectors subject to the exceptions in subsection F of this section.

E. Officers, directors, agents, or employees of a management contractor or operator or any of its

subsidiaries, are also strictly prohibited from offering, providing, or attempting to provide

complimentaries, in any form, to any members of the Tribal Council, Tribal Gaming Commission,

Management Committee, or Tribal Gaming Commission Inspectors subject to the exceptions in

subsection F of this section.

F. Members of the Tribal Council, Tribal Gaming Commission, Management Committee, and other

designees of the Tribal Council and Tribal Gaming Commission, may have their travel costs, food

and beverage costs, lodging expenses, and incidental expenses paid as operating expenses of the

gaming operation for any business-related meeting or business-related travel only if the Tribal

Council approves such expenditure via written consensus. At its discretion, the Tribal Gaming

Commission may submit payment in order to maintain independence from the operation.

G. The staff, employees, and agents of the gaming operation, or any officer, director, agent or employee

of the management contractor, or its subsidiaries are strictly prohibited from using, or attempting to

use, any revenues, monies, or property of the gaming operation to pay for travel expenses of any

patron, guest, or person traveling, or intending to travel, to another casino property owned or

managed by the management contractor or operator or any of its subsidiaries unless such programs

are approved in writing by the Tribal Gaming Commission prior to implementation. The

Commission reserves the right to withdraw this type of complimentary at any time. Should a

licensee not obtain such approval from the Tribal Gaming Commission, such action shall be cause

for immediate revocation and/or suspension of an employee’s gaming license, and shall subject that

individual to all civil causes of action and criminal penalties afforded by any local, state, federal, or

tribal laws. “Travel Expenses” include, but are not limited to, airfare costs, ground transportation

costs, lodging expenses, or per diem costs associated with travel of any kind.





H. The staff, employees, agents of the gaming operation, and officers, directors, agents and employees

of the management contractor or operator or any of its subsidiaries are strictly prohibited from using,

or attempting to use, any revenues, monies, or property of the gaming operation to pay for goods or

services or to provide complimentaries for guests, patrons, employees, or any person unless such

programs are approved in writing by the Tribal Gaming Commission prior to implementation. The

Commission reserves the right to withdraw this type of program at any time. Should a licensee not

obtain such approval from the Tribal Gaming Commission, such action shall be cause for immediate

revocation and/or suspension of an employee's gaming license, and shall subject that individual to all

civil causes of action and criminal penalties afforded by any local, state, federal, or tribal laws.

II. Report Generating

A. At least monthly, accounting, information technology, or audit personnel that cannot grant or receive

complimentary privileges shall prepare reports that include the following information for

complimentary items and services, equal to or exceeding $100 or an amount by the established

Commission, which shall not exceed $100. (NIGC§542.17(b)) The monthly report shall include at

least the following:

1. Name of customer who received the complimentary service or item; (NIGC§542.17(b)(1))

2. Name(s) of authorized issuer of the complimentary service or item; (NIGC§542.17(b)(2))

3. The actual cash value of the complimentary service or item; (NIGC§542.17(b)(3))

4. The type of complimentary service or item (i.e., food, beverage, etc.); and (NIGC§542.17(b)(4))

5. Date the complimentary service or item was issued. (NIGC§542.17(b)(5))

B. The Tribe shall maintain a record of all complimentary services provided to patrons of its gaming

operation, including either the full retail price of such service or item if the same service or item is

normally offered for sale to patrons in the ordinary course of business at the gaming operation, or the

cost of service or items to the Tribe if not offered for sale to patrons in the ordinary course of

business.

C. If the complimentary service or item is provided to a patron by a third party on behalf of the Tribe,

such service or item shall be recorded at the actual cost to the Tribe of having the third party provide

such service or item.

D. A log recording all such complimentary services shall be available for inspection by the State

Gaming Agency in accordance with the Kansas State Compact.

III. Audit Standards for Complimentary Services

The internal audit or accounting departments shall review the reports required in paragraph II.A. of this

section at least monthly. These reports shall be made available to the Tribal Gaming Commission upon

request. (NIGC§542.17(c))

IV. Player Tracking Standards

A. The player tracking system shall be secured so as to prevent unauthorized access (e.g., changing

passwords at least quarterly and physical access to computer hardware, etc.). (NIGC§542.13(j)(1)(i))

B. The addition of points to member’s accounts other than through actual gaming machine play shall be

sufficiently documented (including substantiation of reasons for increases) and shall be authorized by

a department independent of the player tracking and gaming machines. Alternatively, addition of

points to member's accounts may be authorized by gaming machine supervisory employees if

sufficient documentation is generated, and it is randomly verified by employees independent of the

gaming machine department on a quarterly basis. (NIGC§542.13(j)(1)(ii))





C. Booth employees who redeem points for members shall be allowed to receive lost players club cards,

provided that they are immediately deposited into a secured container for retrieval by independent

personnel. (NIGC§542.13(j)(1)(iii))

D. Changes to the player tracking system parameters, such as point structures and employee access,

shall be performed by supervisory employees independent of the gaming machine department.

Alternatively, changes to player tracking system parameters may be performed by gaming machine

supervisory employees if sufficient documentation is generated, and it is randomly verified by

supervisory employees independent of the gaming machine department on a monthly basis.

(NIGC§542.13(j)(1)(iv))

E. All other changes to the player tracking system shall be appropriately documented.

(NIGC§542.13(j)(1)(v))



Section M INTERNAL AUDIT STANDARDS


I. Internal Audit Standards

A. All internal auditors shall report directly to the Tribal Gaming Commission.

B. All internal auditors shall be subject to the standards set forth in this section, as applicable.

C. “Internal auditor” means individuals or organizations that perform an audit function of a gaming

operation for the tribe that are independent of the operation subject to audit. (NIGC§542.42(a)(1))

The internal auditor shall report directly to the Tribal Gaming Commission, in accordance with the

internal audit definition of these standards. (NIGC§542.42 (a)(2))

D. The Tribal Gaming Commission shall, at the expense of the gaming operation, cause each gaming

operation to be subject to external and internal audits.

E. Whenever possible, the observations shall be unannounced and shall not be performed at a consistent

time of day or day of the month.

F. Results of audits shall be communicated to Tribal Gaming Commission and management of the

gaming operation. Audit exceptions shall require management follow-up.

G. A schedule of regular internal audits shall be approved by the Tribal Gaming Commission.

H. In addition to the annual audit required pursuant to the IGRA, the State shall have the right to

conduct a separate annual audit at its own expense, provided that such audit shall be reasonably

conducted so as not to interrupt normal business practices of the Tribe. (Compact§23)

II. Internal Audit Documentation

A. Documentation (e.g. checklists, programs, reports, etc.) shall be prepared to evidence all internal

audit work performed as it relates to the requirements in this section. (NIGC§542.42(c)(1))

B. The internal audit personnel shall operate with audit programs, which, at a minimum, address the

Tribal Minimum Internal Controls and the Compact. Additionally, the department shall properly

document the work performed, the conclusions reached, and the resolution of all exceptions.

(NIGC§542.42(c)(2))

III. Internal Audit Reports

A. Written reports shall be rendered on each audit performed. These reports shall include the scope of

work performed, audit issues, corrective actions required, if necessary, and suggestions for

improvement. All reports shall be reviewed, approved, and signed by the Internal Audit Director or

proper signatory individual with copies sent to the Tribal Gaming Commission in a reasonable

manner. All material exceptions resulting from Internal Audit work shall be investigated and

resolved to the satisfaction of the Tribal Gaming Commission. Such documentation shall be retained

for five (5) years. (NIGC§542.42(c)(1))

B. Copies of all audit reports shall be provided to the Tribal Gaming Commission, as well as the

management contractor’s senior management, property management, and Tribal Gaming

Commission engaged independent public accountants. The Tribal Gaming Commission reserves the

right to request copies of all audit work papers upon review of the report. (NIGC§542.42(d)(1))





C. Such audit reports shall include the following information: (NIGC§542.42(d)(2))

1. Audit objective; (NIGC§542.42(d)(2)(i))

2. Audit procedures and scope; (NIGC§542.42(d)(2)(ii))

3. Findings and conclusions; (NIGC§542.42(d)(2)(iii))

4. Recommendations, if applicable; and (NIGC§542.42(d)(2)(iv))

5. Management response. (NIGC§542.42(d)(2)(v))

IV. Material Exceptions

All material exceptions resulting from internal audit work shall be investigated and resolved with the

results of such being documented and retained for five (5) years. (NIGC§542.42(e))

V. Role of Management

A. Internal audit findings shall be reported to management and the Tribal Gaming Commission. All

instances of non-compliance that come to its attention during the course of testing compliance with

the standards in this part shall be reported to both management and the Tribal Gaming Commission.

(NIGC§542.42(f)(1))

B. Management shall be required to respond to internal audit findings stating corrective measures to be

taken to avoid recurrence of the audit exception. (NIGC§542.42(f)(2))

C. Such management responses shall be included in the internal audit report delivered to management,

the Commission and State Gaming Agency. (Compact)(NIGC§542.42(f)(3))

VI. Internal Audit Requirements

A. The following gaming areas of operation shall be reviewed at least annually by internal audit:

(NIGC§542.42(b)(1))

1. Federal Currency Transaction Reporting (Title 31).

2. Table games, including, but not limited to, the following:

a. Fill and credit procedures,

b. Soft drop/count procedures and the subsequent transfer of funds,

c. Unannounced testing of count room currency counters, ticket readers and/or currency

interface,

d. Location and control over sensitive keys,

e. The tracing of source documents to summarized documentation and accounting records,

and

f. Reconciliation to restricted copies. (NIGC§542.42(b)(1)(vi))

3. Gaming machines, including, but not limited to, the following:

a. Jackpot payout and gaming machine fill procedures,

b. Gaming machine drop/count and bill validator drop/count and subsequent transfer of

funds,

c. Unannounced testing of weigh scale and weigh scale interface,

d. Currency counters, ticket readers and/or currency interface,

e. Gaming machine drop cabinet access,

f. Tracing of source documents to summarized documentation and accounting records,

g. Reconciliation to restricted copies,

h. Location and control over sensitive keys,

i. Compliance with EPROM duplication procedures, and

j. Compliance with TC3MICS procedures for gaming machines that accept currency or

coin(s). (NIGC§542.42(b)(1)(vii))

4. Cage and credit procedures including, but not limited to, the following:

a. All cage, credit, and collection procedures,





b. Reconciliation of trial balances to physical instruments on a sample basis, and

c. Cage accountability shall be reconciled to the general ledger. (NIGC§542.42(b)(1)(viii))

5. Card games, including, but not limited to, the following:

a. Card game operation;

b. Monetary exchange procedures; and

c. Count procedures. (NIGC§542.42(b)(1)(iii))

6. Complimentary Service or items, including, but not limited to, the following:

a. Procedures whereby complimentary service items are issued,

b. Procedures whereby complimentary service items are authorized, and

c. Procedures whereby complimentary service items are redeemed. (NIGC§542.42(b)(1)(x))

7. Information technology functions, including, but not limited to: review for compliance with

information technology standards. (NIGC§542.42(b)(1)(ix))

8. Any other internal audits as required by the Tribe, Tribal Gaming Commission, or other entity

designated by the Tribe. (NIGC§542.42(b)(1)(xi))

B. In addition to the observation and examination performed, follow-up observations and examinations

shall be performed to verify that corrective action has been taken regarding all instances of

noncompliance cited by internal audit. The verification shall be performed within six (6) months

following the date of notification. (NIGC§542.42(b)(2))

C. Whenever possible, internal audit observations shall be performed on an unannounced basis (i.e.,

without the employees being forewarned that their activities shall be observed). Additionally, if the

independent accountant also performs the internal audit function, the accountant shall perform

separate observations of the table games/gaming machine drops and counts to satisfy the internal

audit observation requirements and independent accountant tests of controls as required by the

AICPA (American Institute of Certified Public Accountants) Guide. (NIGC§542.42(b)(3))

D. Compliance with other regulatory requirements may be tested periodically based on risk assessment.

E. Non-gaming areas shall periodically be reviewed for appropriate controls and adherence to such

controls. These areas shall include, but not be limited to the following:

1. Food & Beverage,

2. Hotel,

3. Events,

4. Entertainment,

5. Retail shops,

6. General Ledger,

7. Accounts payable,

8. Payroll,

9. Procurement & Construction,

10. Contract Administration,

11. Centralized Services, and

12. All other profit centers affiliated with the gaming operation.

F. Internal auditors of the management contractor or operator itself shall identify themselves to the

Tribal Gaming Commission and provide the Tribal Gaming Commission the scope of the work

intended at the current visit.

1. Internal audits done by the management contractor’s or operator’s internal audit staff for itself

shall be presented to the Tribal Gaming Commission and retained in the management

contractor’s or operator’s departmental files for a minimum of two (2) years.

2. The management contractor’s or operator’s internal audit staff shall notify and include the

Tribal Gaming Commission in all exit interviews regarding audit findings at the Casino.

3. Copies of all audit reports shall be distributed to the Commission simultaneously with

distribution to the management contractor or operator and the State Gaming Agency.





VII. Internal Audit Reporting Guidelines

A. Reports shall be required for all internal audits performed and shall be submitted to the Tribal

Gaming Commission upon completion. Oral exit interviews shall be given to the Tribal Gaming

Commission upon completion of the reports.

B. The Audit Report shall include the following information in addition to requirements listed in the

General Provisions Section A:

1. A title page containing the name of the gaming operation, the name of the report, and the report

number.

2. Each audit shall be subdivided into the following sections:

a. Audit objectives,

b. Audit procedures and scope,

c. Findings and conclusions,

d. Recommendations, if applicable, and

e. Management's response. (NIGC§542.42 (d)(2))

C. The internal auditor shall meet with the Tribal Gaming Commission to assess continued compliance

with the NIGC requirements in the final quarter of the fiscal year.

D. Nine copies of the Internal Audit Report shall be sent to the Tribal Gaming Commission

E. Internal auditors shall immediately notify the Tribal Gaming Commission in writing of any material

weaknesses noted in any audit.

VIII. Review of Changes to the ICS

An independent accountant shall review changes to the gaming operator’s ICS for ongoing compliance

with the TC3MICS prior to final approval by the Tribal Gaming Commission and shall submit a report

stating that the principles of internal control required by these standards have been complied with. The

Commission shall then forward a copy to the State Gaming Agency.

IX. NIGC Internal Audit Guidelines

In connection with the internal audit testing pursuant to paragraph VI.A. of this section, the NIGC shall

develop recommended Internal Audit Guidelines, which shall be available upon request. (NIGC§542.42(g))



Section N EXTERNAL AUDIT STANDARDS


I. General External Audit Standards

A. External auditors shall report directly to the Tribal Gaming Commission.

B. External audits are subject to the standards set forth in this section, as applicable.

I. External Audit Standards

A. The Tribal Gaming Commission shall, at the expense of the gaming operation, because each gaming

operation's annual financial statements to be audited by an independent accountant in accordance

with generally accepted auditing standards used in the United States of America by an independent

accountant of the Tribal Gaming Commission's choice.

B. The annual financial statements shall be prepared on a comparative basis to the prior year (after the

first year and other available years). The statements shall present the financial position and results of

operations in conformity with generally accepted accounting principles used in the United States of

America.

C. Twenty-five copies of the audited financial statements, together with all reports prepared thereon of

the independent accountant shall be filed by the independent accountant with the Tribal Gaming

Commission, who will then forward copies to the State Gaming Agency and NIGC not later than 120

days following the end of the calendar or fiscal year. The Tribal Gaming Commission in extenuating

circumstances may grant extensions.

D. In addition to the annual audit required pursuant to the IGRA, the State shall have the right to

conduct a separate annual audit at its own expense, provided that such audit shall be reasonably

conducted so as not to interrupt normal business practices of the Tribe. (Compact§23)

II. CPA Testing of These TC3MICS/Agreed Upon Procedures

A. Testing:

1. An independent Certified Public Accountant shall be engaged to perform procedures to verify,

on a test basis, that the gaming operation is in material compliance with the TC3MICS or a

tribally approved variance that has received NIGC concurrence. The procedures may be

performed in conjunction with the annual audit. The CPA shall report its findings to the Tribe,

Tribal Gaming Commission and management. (NIGC§542.3(c)) A copy of such audit shall be

furnished to the State Gaming Agency. (Compact §23) (NIGC 542.3 (g))

B. Agreed Upon Procedures CPA Testing (NIGC 542.3(f))

C. An independent certified public accountant (CPA) shall be engaged to perform “Agreed-upon

procedures” to verify that the gaming operation is in compliance with the minimum internal control

standards (MICS) set forth in this part or a Tribal Gaming Commission approved variance thereto

that has received NIGC concurrence. The CPA shall report each event and procedure discovered by

or brought to the CPA’s attention that the CPA believes does not satisfy the minimum standards or

Tribal Gaming Commission approved variance that has received NIGC concurrence. The “Agreed-

upon-procedures” may be performed in conjunction with the annual audit. The CPA shall report its

findings to the Tribe, Tribal Gaming Commission and management. The Tribe shall submit two

copies of the report to the NIGC within 120 days of the gaming operation’s fiscal year end. This

regulation is intended to communicate the Tribal Gaming Commission’s position on the minimum

agreed-upon procedures to be performed by the CPA. Throughout these regulations, the CPA’s

engagement and reporting are based on Statements on Standards for Attestation Engagements

(SSAEs) in effect as of December 31, 2003, specifically SSAE 10 (“Revisions and Recodification

Agreed-Upon-Procedures Engagements”). If future revisions are made to the SSAEs or new SSAEs





are adopted that are applicable to this type of engagement, the CPA is to comply with any new or

revised professional standards in conducting engagements pursuant to the regulations and the

issuance of the agreed-upon procedures report. The CPA shall perform the “Agreed-Upon

Procedures” in accordance with the following: (NIGC§542.3(f)(1)) Reports shall be made available

to the State Gaming Agency upon request. (Compact §23)

1. As a prerequisite to the evaluation of the gaming operation’s internal control systems, it is

recommended that the CPA obtain and review an organizational chart depicting segregation of

functions and responsibilities, a description of the duties and responsibilities of each position

shown on the organization’s chart, and an accurate, detailed narrative description of the gaming

operation’s procedures in effect that demonstrate compliance. (NIGC§542.3(f)(1)(i))

2. Complete the CPA NIGC MICS Compliance checklists or other comparable testing procedures.

The checklists should measure compliance on a sampling basis by performing walk-through,

observations and substantive testing. The CPA shall complete separate checklists for each

gaming revenue center, cage, internal audit, surveillance, information technology and

complimentary services or items. All questions on each applicable checklist should be

completed. Work-paper references are suggested for all “no” responses for the results obtained

during the testing (unless a note “W/P Ref” can explain the exception). (NIGC§542.3(f)(1)(ii))

3. The CPA shall perform, at a minimum, the following procedures in conjunction with the

completion of the checklists: (NIGC§542.3(f)(1)(iii))

a. At least on unannounced observation of each of the following: Gaming machine coin

drop, gaming machine currency acceptor drop, table games drop, gaming machine coin

count, gaming machine currency acceptor count, and table games count. The AICPA’s

Audits of Casinos’ Audit and Accounting Guide states that “observations of operations in

the casino cage and count room should not be announced in advance for purposes of these

procedures. For purposes of these procedures “unannounced” means that no officers,

directors, or employees are given advance information regarding the dates or times of such

observations. The independent accountant should make arrangements with the gaming

operation and Tribal Gaming Commission to ensure proper identification of the CPA’s

personnel and to provide for their prompt access to the count rooms.

(NIGC§542.3(f)(1)(iii)(A))

i. The gaming machine coin count observation would include a weigh scale test of all

denominations using pre-counted coin. The count would be in process when these

tests are performed and would be conducted prior to the commencement of any other

walk-through procedures. For computerized weigh scales, the test can be conducted

at the conclusion of the count, but before the final totals are generated.

(NIGC§542.3(f)(1)(iii)(A)(1))

ii. The checklists should provide for drop/count, soft drop/count and currency acceptor

drop/count. The count room would not be entered until the count is in process, and

the CPA would not leave the room until the monies have been counted and verified

to the count sheet by the CPA and accepted into accountability. If the drop teams are

unaware of the drop observations and the count observations would be unexpected,

the hard count and soft count rooms may be entered simultaneously. Additionally, if

the gaming machine currency acceptor count begins immediately after the table

games count in the same location, by the same count team, and using the same

equipment, the currency acceptor count observation can be conducted on the same

day as the table games count observations, provided the CPA remains until monies

are transferred to the vault/cashier. (NIGC§542.3(f)(1)(iii)(A)(2))

iii. Observations of the gaming operation’s employees as they perform their duties.

(NIGC§542.3(f)(1)(iii)(B))

iv. Interviews with the gaming operation’s employees who perform the relevant

procedures. (NIGC§542.3(f)(1)(iii)(C))





v. Compliance testing of various documents relevant to the procedures. The scope of

such testing should be indicated on the checklist where applicable.

(NIGC§542.3(f)(1)(iii)(D))

vi. For each new gaming operation that has been in operation for three months or less at

the end of its business year, performance of this regulation sections 542.3(f) is not

required for the partial year. (NIGC§542.3(f)(1)(iii)(E))

D. Alternatively, at the discretion of the Tribe, the Tribe may engage an independent certified public

accountant (CPA) to perform the testing observations and procedures reflected in paragraphs III.C.1.,

2. and 3. of this section, utilizing the TC3MICS adopted by the Tribal Gaming Commission or

tribally approved variance that has received NIGC concurrence. Accordingly, the CPA will verify

compliance by the gaming operation with the TC3MICS. Should the Tribe elect this alternative, as a

prerequisite, the CPA will perform the following: (NIGC§542.3(f)(2))

1. The CPA shall compare the TC3MICS to the NIGC MICS to ascertain whether the criteria set

forth in the NIGC MICS or NIGC approved variances are adequately addressed.

(NIGC§542.3(f)(2)(i))

2. The CPA may utilize personnel of the Tribal Gaming Commission to cross-reference the

TC3MICS to their NIGC MICS, provided the CPA performs a review of the Tribal Gaming

Commission personnel’s work and assumes complete responsibility for the completion of the

work product. (NIGC§542.3(f)(2)(ii))

3. The CPA shall report each procedure discovered by or brought to the CPA’s attention that the

CPA believes does not satisfy paragraph III.D.I of this section. (NIGC§542.3(f)(2)(iii))

E. Reliance on internal auditors (NIGC§542.3(f)(3))

1. The CPA may rely on the work of an internal auditor, to the extent allowed by the professional

standards, for the performance of the recommended procedures specified in paragraphs III.C.3.

of this section, and for the completion of the checklists as they relate to the procedures covered

therein, provided that the internal audit department can demonstrate to the satisfaction of the

CPA that the requirements contained within § 542.42 have been satisfied.

(NIGC§542.3(f)(3)(i))

2. Agreed-upon procedures are to be performed by the CPA to determine that the internal audit

procedures performed for a past 12-month period (includes two 6-month periods) encompassing

a portion or all of the most recent business year has been properly completed. The CPA will

apply the following Agreed-upon procedures to the gaming operation’s written assertion:

(NIGC§542.3(f)(3)(ii))

a. Obtain internal audit department work-papers completed for a 12-month period (includes

two 6-month periods) encompassing a portion or all of the most recent business year and

determine whether the CPA NIGC checklists or other comparable testing procedures were

included in the internal audit work-papers and all steps described in the checklists were

initialed or signed by an internal audit representative. (NIGC§542.3(f)(3)(ii)(A))

b. For the internal audit work-papers obtained in paragraph III.E.2.a. of this section, on a

sample basis, re-perform the procedures included in CPA NIGC MICS compliance

checklists or other comparable testing procedures prepared by internal audit and determine

if all instances of noncompliance noted in the sample were documented as such by the

internal audit. The CPA NIGC MICS comparable testing procedures of the applicable

Drop and Count procedures are not included in the sample re-performance of procedures

because the CPA is required to perform the drop and count observations as required under

paragraph III.C.3.a. this section of the Agreed-Upon Procedures. The CPA’s sample

should comprise a minimum of 3 percent of the procedures required in each CPA NIGC

MICS Compliance Checklist or other comparable testing procedures for the gaming

machine and table game departments and 5 percent for the other departments completed





by internal audit in compliance with the internal audit MICS. The re-performance of

procedures is performed as follows: (NIGC§542.3(f)(3)(ii)(B))

i. For inquiries, the CPA should either speak with the same individual or an individual

of the same job position as the internal auditor did for the procedure indicated in

their checklist. (NIGC§542.3(f)(3)(ii)(B)(1))

ii. For observations, the CPA should observe the same process as the internal auditor

did for the procedure as indicated in their checklist. (NIGC§542.3(f)(3)(ii)(B)(2))

iii. For document testing, the CPA should look at the same original document as tested

by the internal auditor for the procedure as indicated in their checklist. The CPA

need only re-test the minimum sample size required in the check list.

(NIGC§542.3(f)(3)(ii)(B)(3))

3. The CPA is to investigate and resolve any differences between their re-performance results and

the internal audit results. (NIGC§542.3(f)(3)(ii)(C))

4. Documentation shall be maintained for 5 years by the CPA indicating the procedures re-

performed along with the results. (NIGC§542.3(f)(3)(ii)(D))

5. When performing the procedures for paragraph III.E.2.b of this section in subsequent years, the

CPA must select a different sample so that the CPA will re-perform substantially all of the

procedures after several years. (NIGC§542.3(f)(3)(ii)(E))

6. Any additional procedures performed at the request of the NIGC, the Tribal Gaming

Commission or Management should be included in the Agreed-Upon Procedures report

transmitted to the NIGC. (NIGC§542.3(f)(3)(ii)(F))

F. Report Format (NIGC§542.3(f)(4))

1. The NIGC has concluded that the performance of these procedures is an attestation engagement

in which the CPA applies such Agree-Upon Procedures to the gaming operation’s assertion that

it is in compliance with the NIGC and TC3MICS and, if applicable under paragraph III.D. of

this section, the TC3MICS and approved variances provide a level of control that equals or

exceeds that of the NIGC MICS. Accordingly, the Statements on Standards for Attestation

Engagements (SSAE’s), specifically SSAE 10, issued by the Auditing Standards Board is

currently applicable. SSAE 10 provides current, pertinent guidance regarding agreed upon

procedure engagements, and the sample report formats included within those standards should

be used, as appropriate, in the preparation of the CPA’s agreed-upon procedures report. If future

revisions are made to this standard or new SSAEs are adopted that are applicable to this type of

engagement, the CPA is to comply with any revised professional standards in issuing their

agreed upon procedures report.

2. The NIGC will provide an Example Report and Letter Formats upon request that may be used

and contain all of the information discussed below: (NIGC§542.3(f)(4)(A))

a. The report must describe all instances of procedural noncompliance (regardless of

materiality) with the NIGC MICS and TC3MICS or approved variations, and all instances

where the TC3MICS do not comply with the NIGC MICS. When describing the agreed-

upon procedures performed, the CPA should also indicate whether procedures performed

by other individuals were utilized to substitute for the procedures required to be performed

by the CPA.

b. For each instance of noncompliance noted in the CPA’s agreed-upon procedures report,

the following information must be included:

i. The citation of the applicable NIGC MICS or TC3MICS for which the instance of

noncompliance was noted. (NIGC§542.3(f)(4)(A)(1))

ii. A narrative description of the noncompliance, including the number of exceptions

and sample size tested. (NIGC§542.3(f)(4)(A)(2))





G. Report Submission Requirements (NIGC§542.3(f)(5))

1. The CPA shall prepare a report of the findings for the Tribal Gaming Commission and

management. The Tribal Gaming Commission shall submit 2 copies of the report to the NIGC

no later than 120 days after the gaming operation’s business year. This report should be

provided in addition to any other reports required to be submitted to the NIGC.

(NIGC§542.3(f)(5)(i))

2. The CPA should maintain the work-papers supporting the report for a minimum of five years.

Digital storage is acceptable. The NIGC may request access to the work-papers through the

Tribal Gaming Commission. (NIGC§542.3(f)(5)(ii))

H. CPA NIGC MICS Compliance Checklists: In connection with the CPA testing pursuant to this

section and as referenced therein, the NIGC will provide CPA NIGC MICS Compliance Checklists

upon request. (NIGC§542.3(f)(6))



Section O

KEY CONTROL STANDARDS


I. General Key Control Standards

A. The Security Department shall be responsible for maintaining certain keys which provide access to

areas of the Casino designated as sensitive areas.

B. All sensitive keys assigned to security responsibility shall be maintained in a secure area, e.g. locked

key box or electronic key lock box, with limited access to designated personnel.

II. Sensitive Keys

A. Sensitive keys are those keys that the Tribal Gaming Commission considers sensitive to the Casino's

operation and, therefore, require strict control over custody and issuance. Computer technology logs

and technology controls shall substitute for mechanical controls where computer systems are used.

B. The ICS shall include:

1. Location of all sensitive key boxes, devices or pads and whether any of these are portable or

controlled by dual locks.

2. Personnel positions which have authorized access to the sensitive key box keys, devices or pads

and how the keys, devices or pads to the sensitive key boxes are issued and controlled.

3. Sensitive key name, location, custodian and job titles authorized to sign out each sensitive key.

4. Location and custodian of duplicate sensitive keys.

C. Each sensitive key box custodian shall be issued a sensitive key access list noting authorized job

titles that may access each sensitive key. (NIGC§542.41(m)(6))

D. Whenever two (2) sensitive keys are required to access a controlled area, the keys shall be issued to

different employees, and each key shall be independently signed out.

E. Sensitive keys, which require issuance under security, management and/or Tribal Gaming

Commission escort, shall be identified as such in the sensitive key access list.

F. The ICS shall indicate which management employee or designee has the authority to make changes,

deletions and/or additions to the sensitive key access list.

G. A sensitive key access list shall be maintained at each sensitive key box and a current copy shall be

given immediately at the time any changes are made to the Tribal Gaming Commission and shall

include:

1. Name of sensitive key;

2. Location of sensitive key;

3. Custodian of sensitive key;

4. Quantity of sensitive key(s);

5. Job titles authorized to sign out sensitive key and, if applicable, escort requirements and

specific limitations; and

6. Custodian/location of duplicate keys.

H. All sensitive keys and duplicate keys shall be issued after proper completion of a sensitive key log,

which shall include:

1. Key number;

2. Key name;

3. Signature of individual giving out key;

4. Signature of individual receiving key;

5. Signature of individual witnessing giving of the key;

6. Date;

7. Time key signed out;



Section O KEY CONTROL STANDARDS


8. Upon return, time key signed in;

9. Signature of individual receiving returned key;

10. Signature of individual returning key; and

11. Signature of individual witnessing receiving of the key.

I. Sensitive keys shall be returned to custody and signed in by the same employee to whom they were

issued. If keys must be passed on at shift change, the ICS should identify these keys and indicate the

procedural controls over their transfer.

J. Completed sensitive key logs shall be forwarded at specified intervals to the accounting department

with simultaneous (within the hour) copies to the Tribal Gaming Commission where they shall be

reviewed and retained.

III. Broken, Lost or Missing Keys

A. The ICS shall identify those critical sensitive keys, which if lost, missing, or taken from the premises

require immediate changing of the locks.

B. If a sensitive key is broken, the ICS should include procedures as to which employee shall receive

and replace the broken key and the disposition of the broken key.

C. The ICS should include procedures to be followed when a sensitive key is lost, missing, or taken

from the premises.

D. The ICS should include procedures for investigating and instantly reporting missing sensitive keys to


E. The ICS should include name of the individual authorized to order and separate individual to receive

replacement/new keys or locks and name of the bonded vendor.

IV. Duplicate Keys

All duplicate keys shall be maintained in a manner that provides the same degree of control as required for

the original keys. Records shall be maintained for each key duplicated that indicate the number of keys

made and destroyed. (NIGC§542.41(m)(5))

V. Key Control Standards

A. Access to the sensitive keys addressed in this section shall be documented on key access logs. The

following information shall be contained on the logs:

1. Date and time of issuance;

2. Key issued;

3. Signature and ID of issuing employee;

4. Signature and ID of authorized recipient;

5. Date and time of key return;

6. Reason for access; and

7. The initials of a witness who verifies to whom the key is being issued and the return of the key.

8. Computer logs shall substitute where PINs or other personalized techniques such as a

fingerprint are used and such logs shall be maintained.





VI. Gaming Machine Door Key Controls

Gaming machine door keys shall be maintained on Gaming Machine Department key rings in a locked key

box located in the Gaming Machine Department. Gaming Machine Supervisors and Shift Managers shall

have access to the key rings on their assigned shifts.

VII. Gaming Machine Drop Cabinet Key Controls

A. Gaming machine drop cabinet keys, including duplicates, shall be maintained in the Cage or other

secure location as approved by the Tribal Gaming Commission. (NIGC§542.41(l)(1))

B. The physical custody of the keys needed to access the gaming machine coin drop cabinets, including

duplicates, shall require the involvement of a representative from the Security Department and Cage.

(NIGC§542.41(l)(2))

C. When it is necessary to access the drop cabinet at other than scheduled drop times (i.e., emergency

drop, machine movement, etc.), three employees (one Security, one gaming machine department

employee and one Tribal Gaming Inspector) shall be required to accompany the drop cabinet keys

while checked out and observe each time gaming machine drop cabinets are accessed.

D. Two employees (separate from the key custodian) shall be required to accompany such keys while

checked out and observe each time gaming machine drop cabinets are accessed, unless surveillance is

notified each time keys are checked out and surveillance observes the person throughout the period

the keys are checked out. (NIGC§542.41(l)(3))

E. The involvement of at least two individuals independent of the cage department (Tribal Gaming

Inspector and Security) shall be required to access stored, empty drop boxes.

VIII. Bill Validator Drop Box Release Key

A. Bill validator drop box release keys shall be maintained by the Cage. (NIGC§542.41(o)(1))

B. Access to the release keys shall be restricted to drop team personnel authorized to remove drop boxes

from the gaming machines. A Gaming Machine Supervisor or other gaming machine management

may have access to the keys during emergency situations, such as bill or ticket jams. Security and a

Tribal Gaming Inspector shall be required to be present and shall observe each time the drop boxes

are accessed. (NIGC§542.41(o)(2))

C. Persons authorized to remove the bill validator drop boxes shall be precluded from having

simultaneous access to the bill validator contents keys and release keys. (NIGC§542.41(o)(3))

D. For situations requiring access to a bill validator box at a time other than the scheduled drop, the

date, time and signature of employee signing out/in the release key shall be documented on the key

log. (NIGC§542.41(o)(4))





IX. Bill Validator Drop Box Storage Rack Key

A. A representative from the security department shall be required to accompany the bill validator

storage rack keys and observe each time drop boxes are removed from or placed in storage racks.

(NIGC§542.41(q)(1))

B. Persons authorized to obtain bill validator storage rack keys shall be precluded from having

simultaneous access to bill validator drop box contents keys with the exception of soft count.

(NIGC§542.41(q)(2))

C. Access to the storage rack keys shall be restricted to Security Officers, who observe each time drop

boxes are removed from or placed in storage racks and to Soft Count during the count process.

X. Bill Validator Drop Box Contents Key

A. Drop box contents keys shall be maintained in a dual locked box in the Cage. One key to the dual

lock box shall be maintained by the Cashiers while the other key shall be maintained by Security in a

locked key box within the Security Department. (NIGC§542.41(s)(1))

B. Only soft count personnel shall be allowed access to bill acceptor drop box contents keys during the

count process. (NIGC §542.41(s)(3))

NOTE: This standard is not applicable to emergency situations, which require drop box access at other

than scheduled count times. The Gaming Machine Technician, accompanied by Security, participates in

these situations. A Gaming Inspector shall be notified by radio and be present. The reason for access shall

be documented with the signature of all active participants on the key log. (NIGC§542.41(s)(2))

C. If the reason for access is to clear a bill or ticket acceptor jam or other malfunction, Security, a

Gaming Machine Technician and a Tribal Gaming Inspector shall participate in accessing the bill or

ticket acceptor after providing instant notification to a Tribal Gaming Inspector. Surveillance is

notified prior to accessing the drop box. The reason for access shall be documented on the machine

door open report and signed by the individuals involved.

D. Hard count personnel and gaming machine technicians are precluded from having access to drop box

contents keys.

XI. Table Game Drop Box Key Control Standards

A. Procedures shall be developed and implemented to ensure that unauthorized access to empty table

game drop boxes shall not occur from the time the boxes leave the storage racks until they are placed

on the tables. (NIGC§542.41(m)(1))

B. The involvement of at least two persons independent of the cage department shall be required to

access stored empty table game drop boxes. (NIGC§542.41(m)(2))

C. The release keys shall be separately keyed from the contents key. (NIGC§542.41(m)(3))

XII. Table Game Drop Box Release Key

A. The table game drop box release keys shall be maintained in a dual lock key box located in the Cage.

(NIGC§542.41(n)(1)) One key to the dual lock key box shall be maintained by the Security

Department, and the second shall be maintained by the Tribal Gaming Inspector.





B. Only the person(s) authorized to remove the table game drop boxes from the tables shall be allowed

access to the table game drop box release keys; however, the count team members may have access to

the release keys during the soft count in order to reset the table game drop boxes. (NIGC§542.41(n)(2))

C. Situations that require access to a table game drop box at a time other than the scheduled drop shall

require at a minimum a security officer and a Tribal Gaming Inspector. The date, time, and signature of

the employee signing out/in the release key shall be documented. (NIGC§542.41(n)(4))

D. During an emergency drop of a table game, a security employee and a Tribal Gaming Inspector shall be

involved in securing the keys, accessing the appropriate empty table game drop box in soft count,

removing the full drop box at the table, escorting and securing the full box in the soft count room, and

returning the keys back to the cage.

E. Persons authorized to remove the table game drop boxes shall be precluded from having simultaneous

access to the table game drop box contents keys and release keys. (NIGC§542.41(n)(3))

F. The storage rack/transportation cart shall be secured by a separately keyed, dual-locking system. The

key to one lock shall be maintained and controlled by the Security Department, and the key to the

second lock shall be maintained and controlled by the Tribal Gaming Inspector.

XIII. Table Game Drop Box Storage Rack Key

A. A person independent of the table games department shall be required to accompany the table game drop

box storage rack keys and observe each time the table game drop boxes are removed or placed in the

storage racks. (NIGC§542.41(p)(1))

B. Persons authorized to obtain table game drop box storage rack keys shall be precluded from having

simultaneous access to table game drop box contents keys with the exception of the soft count team.

(NIGC§542.41(p)(2))

XIV. Table Game Drop Box Contents Key

A. The physical custody of the keys needed for accessing stored, full table game drop box contents shall

require the involvement of at least a security officer and a Tribal Gaming Inspector. Security performing

the drop shall not have access to Table Games Drop Box contents keys. (NIGC§542.41(r)(1))

B. Access to the table game drop box contents key at other than scheduled count times shall require the

involvement of a security employee, a Tribal Gaming Inspector and a Table Games Shift Manager. The

reason for access shall be documented with signatures of all participants and observers on the key control

log. (NIGC§542.41(r)(2))

C. The reason for access shall be documented with the signature of all participants and observers.

D. Only soft count team members shall be allowed access to table game drop box contents keys during the

count process. (NIGC§542.41(r)(3))

XV. Count Room Keys

A. Soft Count: At least three Soft Count Team members shall be required to be present at the time the count

room and other count keys are issued for the count. (NIGC§542.41(m)(4)) The keys used in the

performance of the Soft Count shall be maintained in a sensitive key locked box in the Cage.





B. Hard Count: At least three hard count team members shall be required to be present at the time the count

room and other count keys are issued for the drop and count. The hard count room keys shall be

maintained in a sensitive key locked box in the Cage.

C. Soft Count Room Door Keys: A dual door lock shall secure the soft count room. Soft count room door

keys shall be permanently controlled and maintained by Security and the Tribal Gaming Inspectors. The

Security Department shall maintain the dead bolt lock key and the Tribal Gaming Inspectors will

maintain the door lock key.

D. Hard Count Room Door Keys: A dual door lock shall secure the hard count room. Hard count room

door keys shall be permanently controlled and maintained by Security and the Tribal Gaming Inspectors.

The Security Department shall maintain the dead bolt lock key and the Tribal Gaming Inspectors shall

maintain the door lock key.

E. Duplicate keys: Duplicate key controls shall require the involvement of Security, the manager on duty

and the Tribal Gaming Inspector. All duplicate keys shall be maintained in a separate triple lock cabinet

in the Security office. Records shall be maintained for each key duplicated, which indicate the number

of keys made and number of keys given to the Tribal Gaming Inspector for destruction.

XVI. Gaming Machine Computerized Key Security Systems

A. Computerized key security systems which restrict access to the gaming machine drop and count keys

through use of passwords, keys or other means, other than a key custodian, must provide the same

degree of control as indicated in the aforementioned key control standards; refer to paragraphs VII.,

VIII., IX., and X. of this section. Note: This standard does not apply to the system administrator. The

system administrator is defined in paragraph XVI.B.I. of this section. (NIGC§542.41(t)(1))

B. For computerized key security systems, the following additions to gaming machine key control

procedures apply:

1. Management personnel independent of the gaming machine department assign and control user

access to keys in the computerized key security system (i.e., system administrator) to ensure

that gaming machine drop and count keys are restricted to authorized employees.

(NIGC§542.41(t)(2)(i))

2. In the event of an emergency or the key box is inoperable, access to the emergency manual

key(s) (a.k.a. override key), used to access the box containing the gaming machine drop and

count keys, and requires the physical involvement of at least three persons from separate

departments, including management. The date, time and reason for access, must be documented

with signatures for all participating employees signing out/in the emergency manual key(s).

(NIGC§542.41(t)(2)(ii))

3. The custody of the keys issued pursuant to paragraph XVI.B.2. this section requires the

presence of two persons from separate departments from the time of their issuance until the

time of their return. (NIGC§542.41(t)(2)(iii))

4. Routine physical maintenance that requires accessing the emergency manual key(s) (override

key(s)) and does not involve the accessing of the gaming machine drop and count keys, only

requires the presence of two persons from separate departments. The date, time and reason for

access must be documented with the signatures of all participating employees signing out/in the

emergency manual key(s). (NIGC§542.41(t)(2)(iv))

C. For computerized key security systems controlling access to gaming machine drop and count keys,

accounting/audit personnel, independent of the system administrator, will perform the following

procedures: (NIGC§542.41(t)(3))

1. Daily, review the report generated by the computerized key security system indicating the

transactions performed by the individual(s) that adds, deletes, and changes user’s access within

the system (i.e. system administrator). Determine whether the transactions completed by the





system administrator provide an adequate control over the access to the gaming machine drop

and count keys. Also determine whether any gaming machine drop and count key(s) removed or

returned to the key cabinet by the system administrator was properly authorized.

(NIGC§542.41(t)(3)(i))

2. For at least one day each month, review the report generated by the computerized key security

system indicating all transactions performed to determine whether any unusual gaming machine

drop and count key removals or key returns occurred. (NIGC§542.41(t)(3)(ii))

3. At least quarterly, review a sample of users that are assigned access to the gaming machine drop

and count keys to determine that their access to the assigned keys is adequate relative to their

job position. (NIGC§542.41(t)(3)(iii))

4. All noted improper transactions or unusual occurrences are investigated with the results

documented. (NIGC§542.41(t)(3)(iv)) Documentation shall be made available to the Gaming

Commission upon request.

D. Quarterly, an inventory of all count room, drop box release, storage rack and contents keys is

performed, and reconciled to records of keys made, issued, and destroyed. Investigations are

performed for all keys unaccounted for, with the investigation being documented.

(NIGC§542.41(t)(4)) Documentation shall be made available to the Gaming Commission upon

request

XVII. Table Games Computerized Key Security Systems

A. Computerized key security systems which restrict access to the table game drop and count keys

through the use of passwords, keys or other means, other than a key custodian, must provide the

same degree of control as indicated in the aforementioned key control standards; refer to paragraphs

XI., XII, XIII., and XIV. of this section. (NIGC§542.41(u)(1))

B. For computerized key security systems, the following additional table game key control procedures

apply: (NIGC§542.41(u)(2))

1. Management personnel independent of the table games department assign and control user

access to keys in the computerized key security system (i.e. system administrator) to ensure that

table game drop and count keys are restricted to authorized employees.

(NIGC§542.41(u)(2)(i))

2. In the event of an emergency or the key box is inoperable, access to the emergency manual

key(s) (a.k.a. override key), used to access the box containing the table game drop and count

keys, requires the physical involvement of at least three persons from separate departments,

including management. The date, time and reason for access must be documented with the

signatures of all participating employees signing out/in the emergency manual key(s).

(NIGC§542.41(u)(2)(ii))

3. The custody of the keys issued pursuant to paragraph XVII.B.I of this section requires the

presence of two persons from separate departments from the time of their issuance until the

time of their return. (NIGC§542.41(u)(2)(iii))

4. Routine physical maintenance that requires accessing the emergency manual key(s) (override

key) and does not involve the accessing of the table games drop and count keys, only requires

the presence of two persons from separate departments. The date, time and reason for access

must be documented with the signatures of all participating employees signing out/in the

emergency manual key(s). The custody of the keys issued pursuant to paragraph XVII.B.2 of

this section requires the presence of two persons from separate departments from the time of

their issuance until the time of their return. (NIGC§542.41(u)(2)(iv))

C. For computerized key security systems controlling access to table games drop and count keys,

accounting/audit personnel, independent of the system administrator, will perform the following

procedures: The custody of the keys issued pursuant to paragraph XVII.B.2 of this section requires





the presence of two persons from separate departments from the time of their issuance until the time

of their return. (NIGC§542.41(u)(3))

1. Daily, review the report generated by the computerized key security system indicating the

transactions performed by the individual(s) that adds, deletes, and changes user’s access within

the system (i.e., system administrator). Determine whether the transactions completed by the

system administrator provide an adequate control over access to the table games drop and count

keys. Also, determine whether any table games drop and count key(s) removed or returned to

the key cabinet by the system administrator was properly authorized. (NIGC§542.41(u)(3)(i))

2. For at least one day each month, review the report generated by the computerized key security

system indicating all transactions performed to determine whether any unusual table games

drop and count key removals or key returns occurred. (NIGC§542.41(u)(3)(ii))

3. At least quarterly, review a sample of users that are assigned access to the table games drop and

count keys to determine that their access to the assigned keys is adequate relative to their job

position. (NIGC§542.41(u)(3)(iii)) Review documentation shall be made available to the

Gaming Commission.

D. Quarterly, an inventory of all count room, table game drop box release, storage rack and contents

keys is performed and reconciled to records of keys made, issued and destroyed. Investigations are

performed for all keys unaccounted for, with the investigations being documented.

(NIGC§542.41(u)(3)(iv))



TECHNICAL STANDARDS WITH

ATTACHMENTS A AND B


TECHNICAL STANDARDS FOR OPERATION, CONSTRUCTION AND TESTING

OF ELECTRONIC

GAMING DEVICES (EGDs)

The Technical Standards for Electronic Gaming Devices (EGDs) shall control the operation, construction, and

testing of EGDs in casinos in Kansas. These standards are to remain in effect until the Tribes and the State

Gaming Agency approve changes. Requests for alterations of these Technical Standards shall be made with

specificity and submitted to the State Gaming Agency for review. The State Gaming Agency has 60 days from

receipt of the submitted alteration request in which to review the requested proposals. The State Gaming

Agency objections to specified changes requested by the Tribes must be stated specifically for each item

proposed. The State Gaming Agency may propose changes to these Technical Standards in the same manner by

submission to the Tribal Gaming Commission. Any objections to changes proposed by the State Gaming

Agency must be submitted within 60 days from receipt of the proposed changes and must be stated specifically

for each item proposed. If no agreement is reached, an attempt at good faith negotiations between the parties

shall occur prior to seeking relief under Section 31 of the Tribal State Compact.

I. DEFINITIONS

A. Article I Definitions

1. Approved: a process of acceptance of any component of the system that would have an affect

on the integrity of any game and/or the system.

2. Cash Out: the process by which a patron elects to and does receive coin, tokens, tickets or a

combination thereof in payment for game credits remaining on an electronic gaming device

(EGD) and the simultaneous reduction of credits shown on the EGD to zero.

3. Communication Connection: means a physical hardware connection and does not include

wireless or infrared communication equipment.

4. Computerized Ticket Validation System: a hardware and software system, physically located

within the gaming facility that maintains a ticket database for validation when tickets are

presented for payment or for game credits. Each component of the computerized ticket

validation system shall function as indicated by the communication protocol implemented.

5. Coupon: a paper message purporting to entitle the holder to cash, something of value or game

credits. The paper message may be from any source and may be printed by a ticket printer.

6. Program Storage Media: the device in which the game program resides as defined in

Attachment A and whose operation is described in Attachment A.

7. Distributor: means a person or business entity who obtains an electronic gaming device from a

manufacturer and who intends to furnish it to the Tribe.

8. Electronic Gaming Device (EGD): means gaming equipment which is electric, electronic or

mechanical, or a combination thereof, which plays a game which involves an element of prize,

chance and consideration, and which is linked to a central computer for purposes of security,

monitoring, and auditing. The EGD shall function as indicated by the communication protocol

that is implemented.

9. Game Credit: means the smallest unit of value that may be used to play a game on an EGD or

that may be cashed out in US coin, ticket, or approved tokens.

10. Kiosk: means a self-service device located on the gaming floor that provides a means for

payment of a ticket that has been validated and redeemed by the computer ticket validation

system or provides a means for printing a ticket

11. Manufacturer: means a person or business entity who manufactures, produces, or assembles an

EGD or a TITO system or any component thereof, and who intends to furnish it to a distributor

or the Tribe

12. Redemption: means the process by which a ticket is presented by a patron for payment at a

casino cage, or inserted into a kiosk or bill validator of an EGD, recognized by the computer


MINIMUM INTERNAL CONTROLS (TC3MICS))


ATTACHMENTS A AND B


ticket validation system as valid and the patron is paid in US currency and coin or by check the

amount printed on the ticket, or, in the case of acceptance of the ticket in an EGD, game credits

plus any residual in an amount equivalent to the amount printed on the ticket. The redemption

process must be completed entirely prior to the award of a merchandise prize.

13. Residual: means the value in dollars and cents remaining after an EGD registers the maximum

game credits possible following insertion and redemption of a ticket, token(s) or US currency

and/or coin.

14. Residual Ticket: a ticket printed in an amount remaining following the insertion and

redemption of a ticket or the insertion and acceptance of US currency and/or coin or approved

token into an EGD.

15. Ticket: an approved paper token printed by a ticket printer, in an EGD with a game and

containing that printer or a kiosk containing that printer, immediately following the insertion of

US currency and/or coin, approved token or valid ticket into the EGD in the case of a residual or

following the patron activation of the cash out selection on the EGD. A ticket shall record the

value of game credits at cash-out or residual in dollars and cents in numerical form, the time of

day it was printed, the date of printing showing the month, day and year, a gaming device

number identifying the EGD or kiosk in which the ticket is printed, a unique validation number

or barcode capable of being read by a ticket reader, and an identifier unique to the gaming

facility such as a logo or name. Tickets will expire a maximum of 45 days from the date and

time of issue and tickets shall state the length of time until expiration or the expiration time and

date.

16. Ticket Reader: an optical device in an EGD or kiosk or at the cage capable of reading tickets

and sending information to the computerized ticket validation system. Bill validators may

incorporate this technology.

17. Ticket Printer: a device in an EGD or kiosk that is capable of printing an approved ticket based

on instructions received from the EGD or kiosk which has received data from the computerized

ticket validation system.

18. Ticket In/Ticket Out (TITO): a process by which an EGD has the ability to accept or dispense

tickets as a means for payment of game credits or residuals and communicates with a

computerized ticket validation system.

19. Token: means an object of a design and substance approved in writing by the Tribal Gaming

Commission. The object shall represent a value shown on the object and be capable of being

inserted into an EGD which causes the appropriate number of game credits to register.

20. Valid: means a ticket that has not been previously redeemed, has not expired, has not been

voided and is not in an unredeemable state as determined by the computerized ticket validation

system.

21. Validation: The process that is used to verify the validity of a ticket that is presented for game

credits or payment. When presented for game credits or payment, the ticket information is

compared to the data stored on the computerized ticket validation system, based on the unique

identifying number, for validation prior to registration of game credits or payment.

II. Hardware Requirements Electronic Gaming Devices

A. Gaming Devices

1. Physical Hazard: Electronic and mechanical parts and design principles of the electronic game

of chance must not subject a player to physical hazards.

2. Surge Protector: A surge protector must be installed on the line that feeds power to the EGD

or the main electrical control panel box that supplies electrical current to an EGD.

3. Power Interrupt Device: A battery backup or an equivalent shall be installed on the EGD for

the electronic meters and must be capable of maintaining the accuracy of all information

required by this Compact for 90 days after power is discontinued from the machine. The

backup device shall be kept within the locked microprocessor compartment.




ATTACHMENTS A AND B


4. On/Off Switch: An on/off switch that controls the electric current used in the operation of an

electronic game of chance and any associated equipment must be located in a place which is

readily accessible within the interior of the machine.

5. Static Discharge: The operation of each EGD must not be adversely affected by a static

discharge or other electromagnetic interference.

6. Approved Coin and Bill Acceptors: At least one electronic coin and/or bill acceptor (bill

validator) must be installed in or on each EGD. The bill acceptors shall accept denominations

determined by the Tribe, and may also accept tickets and must reject coupons. Prior to

operation, all models of coin and bill acceptors installed must have been tested and approved in

writing by a gaming test laboratory as provided in Section H.

B. Ticket in/Ticket out(TITO)

1. A TITO system shall consist of a computerized ticket validation system located in the gaming

facility and ticket readers and ticket printers, each of which has a bi-directional communication

connection to the computerized ticket validation system. An EGD must be equipped with a

ticket reader and ticket printer to be part of a ticket in/ticket out system. The TITO system shall:

a. Not be permitted to instruct the ticket printer to print a ticket under circumstances which

would require the completion of IRS form W2G.

b. Be capable of determining that a ticket is valid prior to acceptance and registering the

appropriate game credits on an EGD or issuing cash or tokens.

c. Reject and return tickets that are not valid without registering game credits on an EGD or

dispensing cash or tokens.

d. Generate a unique validation number, or authorize a unique validation number generated

by an EGD, for each ticket issued.

e. Accept only tickets printed within the gaming facility by ticket printers and reject and

return immediately any ticket inserted that is not affirmatively validated or any other

coupon inserted without registering game credits on an EGD or dispensing cash or tokens.

f. On redemption of a valid ticket, the computerized ticket validation system must

immediately mark the ticket’s unique validation number as redeemed.

g. Not print a ticket without first issuing a unique validation number or issuing authorization

for a generated validation number.

h. Print a ticket in the amount of the residual prior to permitting first play after a ticket,

token(s) or cash is inserted in an EGD but after or contemporaneously with the registration

of the maximum number of game credits possible, or print a ticket in the amount of the

residual as a result of a patron’s selection of cash out.

i. Maintain a communication connection with the central monitoring computer system such

that tracking and auditing is done in the same manner as when a patron plays an EGD

using cash.

j. Have all of the information required to be associated with a ticket recorded and stored by

the computer ticket validation system.

k. Locate ticket readers and ticket printers in a locked area of the EGD or kiosk separated

from the logic area and the drop box.

l. Provide that ticket printers have software mechanisms to interpret and act upon the

following conditions:

i. Out of paper or paper low

ii. Printer jam/ failure

m. Allow payment of tickets only at the cage or kiosks.

2. The TITO system shall ensure that the information being communicated is accurate using

industry appropriate security and verification methods.

3. If validation is not possible through the computerized ticket validation system, human

intervention using the issuing EGDs ticket history to validate the ticket is required.

4. The TITO system shall maintain a history log of the last 35 tickets printed on each EGD.

5. The computerized ticket validation system can be a separate computer from or a part of the

Central Monitoring Computer System.




ATTACHMENTS A AND B


6. Kiosks may or may not be used with TITO. Kiosks shall have local light or sound alarms that

indicate malfunctioning ticket readers/bill validators or bill or coin dispensers and/or loss of

communication with the computerized ticket validation system. A trouble alert signal must also

be sent to Surveillance in the event of malfunctions or security events. The redemption

function of the kiosk shall be disabled during any time communication is lost between the kiosk

and the computerized ticket validation system.

7. Prior to redemption, the EGD shall reject and return tickets inserted during any time in which

the EGD is not communicating with the computerized ticket validation system.

C. Central Monitoring Computer System

1. EGDs and kiosks shall be monitored by an on-line electronic game management/reporting

system (Central Monitoring Computer System) which has been approved by the independent

gaming test laboratory. Each EGD and kiosk must be linked by a communication connection to

a central computer system (Central Monitoring Computer System)with information contained

therein accessible to the Tribal Gaming Commission personnel and the State Gaming Agency

personnel for information and control programs related to security, monitoring and auditing.

The central monitoring computer system shall function as indicated by the communication

protocol that is implemented. The central computer system (Central Monitoring Computer

System) shall compile and record, among other things, the following information in a form

accessible for reports in aggregate as well as for each individual EGD:

a. Total Drop - Amount deposited in the coin drop area and bill acceptor stack area as well as

the amounts of tickets accepted, if applicable;

b. amounts won

c. amounts wagered

d. Value of the game credits hand paid in dollars and cents by the attendant

e. Value of tickets printed including those for residuals

f. Value of machine fills from the cage

g. Amount of net revenue to the machine

h. The online system (Central Monitoring Computer System) shall accurately indicate the

time of day and the date of all security events and other accounting messages/events

i. Machine serial number as affixed by the manufacturer

j. Terminal number as designated by the gaming operation

k. The program name and version, which may be input manually

l. Number of times the coin/cash/ticket compartments have been opened, including the date

and time

m. Number of times the cabinet has been opened, including date and time.

n. EGDs utilizing coin drop hoppers must detect and the central monitoring computer system

must record:

i. Hopper empty or low

ii. Hopper jam

iii. Hopper runaway/malfunction

D. Cabinet Security for EGDS and KIOSKS

1. Surveillance Notification: The surveillance department shall be notified prior to opening the

cash or ticket compartments of EGDs or redemption kiosks.

2. Locks: The cabinet or interior area of the EGD or redemption kiosk shall be locked and not

readily accessible.

3. Repairs and Service: An authorized agent or employee of the Tribe may open the gaming

cabinet to effect repairs and service.

4. Secure Electronic Components:

a. Logic Boards and program storage media and other logic control components, which

directly affect the outcome of the game, shall be located in a separate compartment within

the EGD and that compartment shall be locked and sealed with serialized security tape and

with a different key or combination than that used for the main cabinet door and cash




ATTACHMENTS A AND B


compartment. The Tribal Gaming Commission shall control this key. The compartment

may only be opened in the presence of a Tribal Gaming Commissioner or Inspector.

b. After software verification and upon installation of program storage media in the

appropriate component in an EGD, a Tribal Gaming Commissioner or Inspector shall affix

or cause to be affixed to said appropriate component of each EGD a strip of serialized

security tape, capable of evidencing the removal of the program storage media if the

program storage media is removed from the original location in the EGD. The security

tape shall be secured and available only to the Tribal Gaming Commissioners and

Inspectors. The Tribal Gaming Commission shall maintain accurate and complete records

of the identification number of each program storage media installed in each EGD.

c. Serialized security tape shall be identifiable to the Tribal Gaming Commission and

available only to Tribal Gaming Commissioners or Inspectors.

5. Machine Records: The Tribal Gaming Commission shall maintain an accurate and complete

record of each EGD including the identification number of the EGD and the identification

number of each piece of program storage media when installed to the logic board witnessed by

Tribal Gaming Commissioners or Inspectors.

6. Meal Cards: For all entries into the EGDs and redemption kiosks as set forth in paragraphs 3,

4,and 7, a written record must be made on a machine entry authorization log (MEAL) card

indicating the time, date and purpose for entering said machine and identifying the person

entering the machine using a legible approved signature.

7. Secure Cash Compartment: The coins and currency compartment as well as the compartment

in which tickets are collected shall be locked separately from the main cabinet area, and secured

with a different key or combination than that used for the main cabinet door, except that a

separate cash compartment shall not be required for coins or tokens necessary to pay prizes in a

machine which pays prizes through a drop hopper as permitted in this section. Keys to gain

access to drop the acceptor compartment must be different from those to gain access to the

contents of the acceptor compartment. Coin drop, bill acceptor and ticket compartment keys

must be kept in a secure location. Except as provided in this section, the compartment in which

the inserted coins, tokens, bills, and tickets are deposited shall be locked at all times. The

Tribal Gaming Commissioner or Inspector must be present when the coin drop, bill acceptor,

and ticket compartments in the gaming cabinet are opened for the purpose of collecting the

accumulated cash and tickets.

8. Configuration Setting: It shall not be possible to change a configuration setting that causes an

obstruction to the electronic accounting meters without a RAM clear. Clearing non-volatile

memory shall only be able to be undertaken by accessing the locked logic area. Any change to

the denomination must be done by a secure means, which includes access to the locked logic

area. A Tribal Gaming Commissioner or Inspector shall monitor denomination changes.

9. Machine Identification: A non-removable plate shall be affixed to each EGD and redemption

kiosk. This plate shall have at a minimum inscribed upon it the machine’s serial number, model

number, and the name of the manufacturer. All EGDs and redemption kiosks shall also have a

label with a location/asset number prominently displayed unique to the gaming location. The

Tribal Gaming Commission may require affixing other certificate plates, tags or decals.

E. Network

1. Operation as Part of a Network: The hardware requirements of the Technical Standards shall

not be construed to prevent the operation of the EGD as part of a network with an aggregate

prize or prizes, provided:

a. An EGD capable of bi-directional communication with internal or external associated

equipment must utilize communication protocol which insures that erroneous data or

signals will not adversely affect the operation of the game. The operation of the local

network must be approved by the independent gaming test laboratory, and

b. Where the network links the Tribe’s EGDs to tribal games of chance on other Indian

reservations within the State of Kansas or outside the State of Kansas, each Tribe

participating in the network shall have in force a Class III gaming compact in the state in




ATTACHMENTS A AND B


which participating EGDs are located authorizing such gaming as part of a network. All

gaming activities shall occur on authorized gaming floors at said reservations.

F. Software requirements for electronic gaming devices

1. Randomness Testing: Each EGD must have a microprocessor based random number generator

that will determine the occurrence of the specific card, symbol, number, or stop position to be

displayed. A selection process will be considered random if it meets all the following

requirements:

a. Chi-square Analysis: Each card, symbol, number or stop position which is wholly or

partially determinative of the outcome of the game satisfies the 99 percent confidence

limit using the standard chi-square analysis.

b. Runs Test: Each card, symbol, number or stop position does not as a significant statistic

produce predictable patterns of game elements or occurrences. Each card, symbol,

number or stop position will be considered random if it meets the 99 percent confidence

level with regard to the “runs test” or any generally accepted pattern testing statistic.

c. Correlation Analysis: Each card, symbol, number or stop position is independently

chosen without regard to any other card, symbol, number or stop position, drawn within

that game play. Each card, symbol, number or stop position is considered random if it

meets the 99 percent confidence level using standard correlation analysis.

d. Serial Correlation Analysis: Each card, symbol, number or stop position is

independently chosen without reference to the same card, symbol, number or stop

position, in the previous game. Each card, symbol, number or stop position is considered

random if it meets the 99 percent confidence level using standard serial correlation

analysis.

e. Live Game Correlation: EGDs that are representative of live gambling games must fairly

and accurately depict the play of the live game.

G. Software Requirements for Percentage Payout: Each EGD must meet the following minimum

theoretical percentage payout during the expected lifetime of the game:

1. EGDs shall pay out a minimum of 80 percent of the amount wagered. The theoretical payout

percentage will be determined using standard methods of probability theory.

2. Merchandise Prizes: The cash value of a ticket redeemed to claim a merchandise prize shall

be included in computing the minimum theoretical percentage payout and in computing

theoretical and actual hold percentage. No merchandise prize may be awarded without first

offering the patron, the cash value of the ticket redeemed, or the value of the jackpot in cash

and receiving a written declination of the offer or, in the alternative, using plain signage to

inform patrons whether cash is available in lieu of a merchandise prize and, if so, the amount of

cash available in lieu of a merchandise prize at the option of the patron.

3. Each EGD must have a probability of obtaining the maximum payout, of the highest advertised

award, which is greater than 1 in 50,000,000 for each play.

4. EGDs and kiosks must not be operated in any mode which would violate any provisions of

these Technical Standards.

H. Software Requirements for continuation after game malfunction: Each game must be capable

of continuing the current game with all current game features after a game malfunction is cleared.

This provision does not apply if the game is rendered totally inoperable; however, the current game

credits wagered and all player remaining game credits active prior to the malfunction must be

returned to the player.

I. Metering: An EGD must have electronic meters. The EGD accounting meters shall be at least

eight digits in length. If the meter is being used in dollars and cents, at least eight digits must be used

for the dollar amount. The meter must roll over to zero upon the next occurrence, any time the meter

is eight digits or higher and after 99,999,999 has been reached or any other value that is logical.




ATTACHMENTS A AND B


The EGD control program must provide the means for on-demand display of the electronic meters

via a key switch on the exterior of the machine. The required electronic meters are as follows:

1. Amounts Wagered the total wagered expressed in US dollars and cents.

2. Amounts Won – total won expressed in US dollars and cents.

3. Total Dropped the total of all coins and tokens diverted to the drop plus all bills and tickets

inserted into and accepted by the bill validator.

4. Jackpot Meter - The total amount paid out by an attendant from redeemed awards, cash or cash

value of merchandise from a single event.

5. Canceled Credit Meter - - Cumulative amounts paid by an attendant following the removal of

registered game credits on an EGD exclusive of amounts required to be recorded by the Jackpot

Meter in these standards.

6. Bills In (total monetary value of all bills accepted)

7. Items In (total value of all items accepted to include currency, coin, tokens, tickets)

8. Individual Bill Meters (total number of each bill accepted per denomination)

9. The number of games played.

10. The number of times the front cabinet door was opened.

11. The number of times the drop door was opened, including the mechanism which holds the

currency and/or tickets within the machine.

J. No Automatic Clearing of Accounting Meters: No game may have a mechanism by which an error

will cause the electronic accounting meters to automatically clear. All meter readings must be

recorded and dated in the presence of a Tribal Gaming Commissioner or Inspector both before and

after the electronic accounting meter is cleared.

K. Display of Information: The required game display information shall be kept under glass, another

transparent substance or generated video medium and at no time may stickers or other removable

devices be placed in any manner anywhere on the machine’s face.

L. Rules Display: Each EGD shall have the following information displayed on the video screen

and/or permanently affixed on the game itself in a location conspicuous to the player:

1. The rules of the game prior to each game being played;

2. The maximum and minimum wagers, amount of game credits which may be won for each

winning hand or combination of numbers or symbols and;

3. The game credits the player has accumulated for additional play or redemption.

M. Last Play Recall: Last play information shall provide all information required to fully reconstruct

the last five plays and shall reflect bonus rounds. Each EGD shall record the denominations of the

last five bills accepted.

N. Software Verification: The device shall have the ability to allow for an independent integrity check

of the device’s software from an outside source. This must be accomplished by being authenticated

by a third-party device, which may be embedded within the game software (see NOTE) or having an

interface port for a third-party device to authenticate the media. This integrity check will provide a

means for field testing the software to identify and validate the program. The test laboratory, prior to

device approval, shall approve the integrity check method.

NOTE: If the authentication program is contained within the game software, the manufacturer must receive

written approval from the test laboratory prior to submission.

III. Testing of Electronic Gaming Devices

A. Testing and Approval of Electronic Gaming Devices: No EGDs or kiosks shall be purchased,

leased or otherwise acquired by the gaming operation unless:




ATTACHMENTS A AND B


1. The EGD or kiosk, or a prototype thereof, has been tested, approved, or certified by a gaming test

laboratory as meeting the requirements and standards as set forth herein and of the Compact. For

purposes of these standards and the Compact, a gaming test laboratory is a laboratory agreed to

and designated in writing by the Tribe and State Gaming Agency as competent and qualified to

conduct scientific tests and evaluations of EGDs and related equipment. A laboratory operated by

or under contract with the states of New Jersey, South Dakota or Colorado constitutes a designated

gaming test laboratory.

B. Testing of EGDs: If required by the gaming test laboratory, the Tribe shall require the manufacturer

or distributor to transport not more than two working models of the EGDs or kiosks and related

equipment to a location designated by the laboratory for testing, examination, and analysis. In

addition, the manufacturer or distributor shall supply copies of EGD illustrations, schematics, block

diagrams, circuit analyses, technical and operation manuals, program object and source codes,

hexadecimal dumps (the compiled computer program represented in base-16 format), and any other

information requested by the gaming laboratory. The gaming operation shall require the

manufacturer or distributor to pay for any and all costs for the transportation, testing, examination,

and analysis. The testing, examination, and analysis may include the entire dismantling of the EGD

and related equipment and some tests may result in damage or destruction to one or more electronic

components of the devices. If required by the laboratory, the gaming operation must require the

manufacturer to provide specialized equipment or the services of an independent technical expert to

assist the testing, examination and analysis.

C. Report of Test Results: At the conclusion of each test, the laboratory shall provide to the Tribe and

the State Gaming Agency, a report that contains findings, conclusions, and a determination that the

EGD or kiosk and related equipment conforms or fails to conform to the hardware and software

requirements of these standards and standards of the Compact. If modifications can be made which

would bring the EGD or kiosk or related equipment into compliance, the report may contain

recommendations for such modifications. A report from the laboratory stating that the machine is an

eligible electronic gaming device under the terms of the Compact and that it meets the technical

standards defined herein shall constitute authority for the machine to be shipped to the gaming

operation’s Class III gaming facility.

D. Modifications of Approved Electronic Gaming Devices: No modification to the assembly or

operational functions of any EGD or kiosk or related equipment may be made after testing and

installation unless a gaming test laboratory certifies to the Tribal Gaming Commission and the State

Gaming Agency that the modified EGD conforms to the standards of the Compact and these

standards. Any proposed modifications shall be subject to the requirements of the paragraphs above,

before the modification may be implemented.

IV. CONFORMITY TO TECHNICAL STANDARDS

A. The Tribal Gaming Commission shall require the manufacturer or distributor to certify, in writing,

that, upon installation, each EGD or kiosk:

1. Conforms precisely to the exact specifications of the EGD or kiosk or prototypes tested and

approved by the gaming test laboratory.

2. Operates and plays in accordance with the technical standards set forth in these provisions




ATTACHMENTS A AND B


ATTACHMENT A

Program Storage Media

I. Program Storage Device Requirements

A. Requirements for Program Storage Devices: All Program Storage Devices, including EPROMs,

DVD, CD-ROM, Compact Flash and any other type of Program Storage Devices shall:

1. Be clearly marked with sufficient information to identify the software and revision level of the

information stored in the devices and shall only be accessible with access to the locked logic

department.

2. Perform an integrity check (authentication) of the Critical Files or Program Code that operate

the Player Terminal during:

a. Any power-up; and

b. The first time the files or program code is loaded for use (even if only partially loaded).

NOTE: RAM and PSD space that is not critical to machine security (e.g., video or sound ROM) are not

required to be validated, although GLI recommends a method be in place for the files to be tested for

corruption. If any of the video or sound filed contain payout amounts or other information needed by the

player, the files or program storage must have a secure method of verification, see also software

verification.

c. The program residing in the Player Terminal shall be contained in a storage medium that

cannot be altered through use of the circuitry or programming of the Player Terminal

itself.

d. Is housed within a locked logic compartment; and

e. Meets the Software Verification requirements of Attachment “B”

B. Write Once (Non-Writeable) Program Storage: For Program Storage Devices that is written to

once (i.e. EPROM, CD), the following rules shall be met:

1. CD-ROM specific based Program Storage shall:

a. Not be a re-writeable disk; and

b. The “Session” shall be closed to prevent any further writing.

2. Non-EPROM specific (including CD-ROM) Program Storage shall meet the following rules;

a. The Control Program shall authenticate all (Critical Files by employing a hashing

algorithm which produces a “Message Digest” output of at least 128 bits at a minimum as

certified by the test laboratory and agreed upon by the jurisdiction. The Message

Digest(s) shall be stored on a memory device (ROM based or other medium) within the

Player Terminal. Message Digests which reside on any other medium shall be encrypted,

using a public/private key algorithm with a minimum of a 512-bit key. However, a 768-

bit key is recommended, or an equivalent encryption algorithm with a similar security

certified by the test laboratory and agreed upon by the jurisdiction.

b. The Player Terminal shall authenticate all Critical Files against the Stored Message

Digest(s), as required in (i) above. In the event of a failed authentication, after the

condition with the appropriate tower light signal and record the details including the clear.

The game shall display specific error information and shall not clear until the file

authenticates properly, following the operation intervention or the medium is replaced or

corrected, and the device’s memory is cleared, the game restarted and, all files

authenticate correctly.

NOTE: the values in (i) and (ii) above, above will constantly be re-evaluated based on technology

advancements and new security methods available.




ATTACHMENTS A AND B


C. Writeable Program Storage: The program residing in the Player Terminal that is capable of being

erased and reprogrammed without being removed from the Player Terminal, bill changer or other

equipment related device shall meet the below requirements.

1. Re-programmable Program Storage shall only write to alterable storage media containing data

files, and programs that are not critical to the basic operation of the game, such as marketing

information. Notwithstanding the foregoing, such device may write to media containing critical

data files, and programs provided the gaming equipment:

a. logs all information that is added, deleted or modified be stored on the media,

b. verifies the validity of all data, files, and programs which reside on the media,

c. contains appropriate security to prevent unauthorized modifications; and

d. does not allow game play while the media containing the critical data, files, and programs

are in a modifiable state.

NOTE: If the program storage does not comply with any of the above requirements and is a Hard Disk, the

media is permissible provided a write-protected drive is used. SCSI Devices are preferred as they provide

a write protect jumper which can be sealed in place by the regulating body. Any other type of drive will

have the write line cut and verified in the field and any other means of write protection will be examined on

a case-by-case basis.

II. Critical RAM Requirements

A. Comprehensive Memory Checks: comprehensive checks of Critical Memory shall be made during

each Player Terminal restart (e.g. power-up cycle). The Player Terminal Control Programs shall test

for possible corruption of Critical Memory. Test methodology shall detect 99.99 percent of all

possible failures.

B. Unrecoverable Critical Memory: an uncorrectable corruption of RAM shall result in a RAM error.

The RAM should not be cleared automatically, but shall require a full RAM clear (RAM Reset)

performed by an authorized person.

C. Function of RAM Reset: following the initiation of a RAM reset procedure (utilizing a certified

RAM clear method); each bit in RAM must be set to the default state. For games that allow for

partial RAM clears, the methodology in doing so must be accurate and the game must validate the

un-cleared portions of RAM.




ATTACHMENTS A AND B


ATTACHMENT B

Software Verification

I. Software Verification

The device shall have the ability to allow for an independent integrity check of the device’s software from

an outside source. This must be accomplished by being authenticated by a third- party device which may

be embedded within the game software or having an interface port for third party devices to authenticate

the media. This integrity check will provide a means for field- testing the software to identify and validate

the program. The test laboratory, prior to device approval, shall approve the integrity check method.

NOTE: If the authentication program is contained within the game software, the manufacturer must

receive written approval from the test laboratory prior to submission.

NOTE: See GLI Standards for definitions of terms found in Attachments A and B.

APPROVED:

__________________________ Date:________________

John E. McElroy,

Kansas State Gaming Agency

__________________________ Date:________________

Gary Mitchell, Chairman

Potawatomi Tribal Gaming Commission