STATE OF CALIFORNIA Budget Change Proposal - Cover …web1a.esd.dof.ca.gov/Documents/bcp/1617/FY1617_ORG... · 12/3/2015 · Filled Positions 143.0 131 ... Table 2 provides the sample

STATE OF CALIFORNIA B u d g e t C h a n g e P r o p o s a l - C o v e r Sheet DF-46 (REV08/15)

Fiscal Year Business Unit Department Priority No. 2016-17 0820 Justice 5

Budget Request Name 0820-005-BCP-BR-2016-GB

Program LAW ENFORCEMENT

Subprogram GAMBLING CONTROL

Budget Request Description New Bureau-wide Training Program

Budget Request Summary The Department of Justice's Bureau of Gambling Control (Bureau) requests to increase expenditure authority from the Gambling Control Fines and Penalties Account (0569) by $200,000 annually. The Bureau seeks to increase its authority and use the funds to develop an ongoing in-depth academy style training program, which would include courses in financial audits, investigative writing, fraud investigations, investigative trends, gaming related trends, and other courses related to the gaming industry. Courses would be geared towards all program and levels of employees (sworn and non-sworn), including licensing, enforcement, as well as audit and compact compliance.

Requires Legislation

• Yes M No

Code Section(s) to be Added/Amended/Repealed

Does this BCP contain information technology (IT) components? • Yes ^ No

If yes, departmental Chief Information Officer must sign.

Department CIO Date

For IT requests, specify the date a Special Project Report (SPR) or Feasibility Study Report (FSR) was approved by the Department of Technology, or previously by the Department of Finance.

• FSR • SPR Project No. Date:

If proposal affects another department, does other department concur with proposal? • Yes • No Attach comments of affected department, signed and dated by the department director or designee.

Prepared By Riann Kopchak, SSM 1

Date Reviewed By Nicole Dopp

Date 12/3/2015

Dedhrtment Director Date y Agency Secretary Date

Department of Fir lance Use Only

Additional Review: • Capital Outlay • ITCU • FSCU • OSAE • CALSTARS • Dept. of Technology

BCP Type: • Policy • Workload Budget per Government Code 13308.05

PPBA^^^^^^ Date submitted Jo the Legislature

BCP Fiscal Detail Sheet BCP Title: Establish new Bureau-wide Training Program DP Name: 0820-005-BCP-DP-2016-GB

Budget Request Summary FY16 CY BY BY+1 BY+2 BY+3 BY+4

Operating Expenses and Equipment 5322 - Training 0 200 200 200 200 200

Total Operating Expenses and Equipment $0 $200 $200 $200 $200 $200

Total Budget Request $0 $200 $200 $200 $200 $200

Fund Summary Fund Source - State Operations

0569 - Gambling Control Fines and Penalties 0 200 200 200 200 200

Total State Operations Expenditures $0 $200 $200 $200 $200 $200

Total All Funds $0 $200 $200 $200 $200 $200

Program Summary Program Funding

0440037 - Gambling 0 200 200 200 200 200 Total Ail Programs $0 $200 $200 $200 $200 $200

Analysis of Problem

A. Budget Request Summary The Department of Justice's (DOJ) Bureau of Gambling Control (Bureau) requests to increase expenditure authority from the Gambling Control Fines and Penalties Account (0569) by $200,000 annually. The Bureau seeks to increase its authority and use the funds to develop an ongoing, in-depth academy style training program which would include courses in financial audits, investigative writing, fraud investigations, investigative trends, gaming related trends, and other courses related to the gaming industry. Courses would be geared towards all programs and levels of employees (sworn and non-sworn), including licensing, enforcement, as well as audit and compact compliance.

B. Background/History The Bureau is the State law enforcement authority with special jurisdiction over gambling activities within the State of California. The Bureau regulates legal gambling activities in California to ensure that gambling is conducted honestly, competitively, and free from criminal and corrupt elements. The Bureau was created January 1, 1998, with the enactment of the Gambling Control Act (Act). The Act established a comprehensive plan for the statewide regulation of legal gambling.

As a result of its compliance and enforcement investigations, the Bureau files accusations that may impose fines as penalties for violations of the Act. Recently, the Bureau received a settlement check in the amount of $1.75 million from a Northern California cardroom for fines and penalties assessed in a previous year. Per Business and Professions code section 19950, the funds received were deposited into Gambling Control Fines and Penalties Account. The Gambling Control Fines and Penalties Account currently has a balance of $2.8 million.

Resource History (Dollars in thousands)

Program Budget 2010-11 2011-12 2012-13 2013-14 2014-15 Authorized Expenditures $20,447 $20,372 $20,076 $25,939 $26,333 Actual Expenditures $19,199 $18,809 $19,514 $22,221 $24,846 Revenues* $32,153 $33,144 $28,812 $36,555 $47,540** Authorized Positions 155.0 156.0 156.0 185.0 187.0 Filled Positions 143.0 131.0 133.0 147.0 143.0 Vacancies 12.0 25.0 23.0 38.0 44.0

•Includes: Indian Gaming Special Distribution Fund, Gambling Control Fund, Reimbursement, Gambling Control Fines and Penalties Fund.

"Includes: 2015/16 Governor's Budget revenue estimate for Indian Gaming Special Distribution Fund

Over the past year, the Bureau has been criticized for its perceived lack of skill in regulating gaming in the State of California. In an online Blog^ by author Dave Palermo entitled "Let's Revisit Bifurcated Regulatory System", he discusses the lack of manpower and skills within the Bureau and questions the Bureau's capability to regulate Internet poker, if, and when it becomes legal in this State. In the same article, California Gambling Control Commissioner Richard Scheutz is quoted as saying "We have a regulatory apparatus that is understaffed and doesn't have access to training as much as they need." Furthermore, during a June 24, 2015, Assembly Informational Hearing^ regarding Internet poker, Assemblyman Jim Cooper voiced concern over the lack of funding to the Bureau.

The Bureau seeks to increase its authority and use the funds to develop an ongoing, in-depth academy style training program which would include courses in financial audits, investigative writing, fraud investigations, investigative trends, high technology investigations, open source internet investigations, and other courses related to the gaming industry. Courses would be geared towards all programs and levels of employees (sworn and non-sworn), including licensing, enforcement, as well as audit and compact compliance.

Due to the industry the Bureau regulates, quality gambling- related training courses are usually offered in Las Vegas, Nevada, or Atlantic City, New Jersey. Although not all courses can be offered in-house, the Bureau's goal is to bring these types of quality courses to its staff in an effort to minimize the exorbitant travel and per diem costs it would incur

^ Palermo, Dave, "Let's Revisit Bifurcated Regulatory System" Retrieved July 2, 2015, f rom http:/ /www.pechanga.net ^ Ruddock, Steve, "Live Reporting of California Online Poker Hearing June 24", Retrieved July 2, 2015, f rom www.californiaonlinepoker.com

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Analysis of Problem

if the Bureau attended these out-of-state courses. The Bureau seeks the funding necessary to bring subject matter experts to instruct staff on a regular basis in order to provide training ranging from beginner to journeyperson levels. Training curriculum would be developed over time according to the level of experience of the Bureau's employees, as well as gaming and investigative trends.

To demonstrate how the Bureau would utilize these funds, the Bureau has created a sample curriculum for the first four years the funds would be available^. Each fiscal year the Bureau will offer three courses to each target group of employees including Special Agents, Auditors, and Analysts. The curriculum would vary from year to year, based on the skill and knowledge base of the Bureau's workforce. If the bureau recognizes deficiencies in specific areas, the focus of the academy would shift accordingly.

Table 2 provides the sample curriculum" for the first four years including cost and course information. The costs associated with each course were obtained from research conducted via the Internet and information provided directly from the various companies identified in quotes for services. The number of allocated positions reflects the position authority the bureau has received related to each target group.

TABLE 2: Yean

Auditor Academy

Course Title Cost Per

Employee

Number of Allocated Positions

Total Cost per Course Vendor Course Description

Fundamentals of Auditing Financial Statements and Processes $2,150 29 $62,350

CPA Training Center

Three-day seminar intended to provide knowledge of operational and IT auditing skills. Students will learn general concepts and techniques for planning and conducting financial audits and how to apply these skills to audits of business cycles and functions.

Auditing For internal Fraud $750 29 $21,750

Association of Certified Fraud

Examiners This two-day course helps develop and sharpen skills and teach techniques for effective fraud detection.

Money Laundering Schemes $750 29 $21,750

Association of Certified Fraud

Examiners

This two-day course will teach students how to recognize both traditional and emerging methods of Laundering assets, including new payment technologies.

Total Course

Cost $105,850

Analyst Academy

Course Title Cost Per Employee



investigative Writing $400 59 $23,600 Creative Law

Personalized two-day training course based on BGC's tasks and responsibilities. Will provide instruction and guidance on writing a clear and concise investigation

report geared specifically to BGC Investigations.

Financial investigations $1,995 59 $117,705 TrainUp

Solutions

Three-day course focusing on Financial Analysis, including cash flow analysis, identifying patterns of value, and how to interpret and evaluate financial information

Background Investigation $108.00 59 $6,372

Sacramento Regional Public Safety Center

This four-day course is designed for law enforcement or civilian personnel who are responsible for conducting background investigations.

Total Course

Cost $147,677

" The BGC's current training authority will be coupled with the BCP request of $200,000 to fund the balance of the yearly training

needs.

" It should be noted that this is a sample curriculum the training academy. Actual courses may differ slightly f rom those listed based

on workload trends, gaming trends, attr i t ion, and availability.

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Analysis of Problem

Special Agent


Employee



Computer Crime High Technology Investigations $512 42 $21,504

California Criminalistics

Institute

This 36-hour course is designed to provide law enforcement personnel with foundation skills for the investigation of computer related crimes.

Open Source Internet Training $395 42 $16,590

Western States Information

Network

This two-day course is designed for law enforcement officers. They will learn to use open source investigations to search unsecured websites to investigate real world criminal activity.

Table Games Protection Workshop $895 42 $37,590 Mike Joseph

This five-day course teaches ways to identify cheating and protect table games. Topics include blackjack scams, baccarat scams, and review of gaming equipment, unethical practices and more.

Total Course Cost $75,684

Year 2

Auditor Academy

Totai Estimated First Year Academy Cost: $329,211


Employee

Number of Allocated Positions Total Cost per Course Vendor

Forensic Accounting $195 29 $5,655 CPA Training Academy Interviewing Techniques for Auditors $845 29 $24,505 Association of Certified Fraud Examiners

Project and Workload Management $1,895 29 $54,955 Project Management Academy


Analyst Academy


Employee


Completed Staffwork $300 59 $17,700 CPS Consulting

Protecting the Games $500 10 $5,000 Nevada Gaming Control Board

Fundamentals of Auditing Financial Statements and Processes $2,150 59 $126,850 CPA Training Academy


3

Analysis of Problem

Special Agent Academy


Employee



International Banking and Money Laundering Training Program $1,400 42 $58,800 Federal Law Enforcement Training Centers

Ethical Use of Technology in Law Enforcement $266 42 $11,172 POST

Totai Course Cost $90,972

Total Academy

Cost: $325,637

Year 3

Auditor Academy



Total Cost per Course Vendor

Best Practices: Auditing Internal Controls $345 29 $10,005 Compliance Seminars

Fraud Examination Techniques $995 29 $28,855 Association of Certified Fraud

Examiners

Writing Audit Reports That Get Results $1,695 29 $49,155 CPA Training Center

s

Total Course

Cost $88,015

Analyst Academy




Comprehensive Tax Course $397 59 $23,423 Tax Education School

Project and Workload Management $1,895 59 $111,805 Project Management Academy

Investigating Personal Financial Statements $448 59 $26,432 Skillpath

Total Course

Cost $161,660

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Analysis of Problem





Money Laundering and Asset Forfeiture Training Program $880 42 $36,960

Federal Law Enforcement Training Centers

Table Games Protection Workshop Refresher $895 42 $37,590 Mike Joseph

Peak Performance for Law Enforcement $266 42 $11,172 POST

Total Course

Cost $85,722

Totai Academy

Cost: $335,397 Year 4

Auditor Academy


Employee


Totai Cost per Course Vendor

Advanced Fraud Examination Techniques $995 29 $28,855 Association of Certified Fraud Examiners

Fraud Auditing School $2,495 29 $72,355 CPA


Analyst Academy


Employee




Decision Making & Problem Solving Skills with Analytical Thinking $199 59 $11,741 TrainUp Solutions

Financial Analysis $2,545 59 $150,155 American Management Solutions




Employee



Computer Crime High Technology Investigations Refresher $512 42 $21,504 California Criminalistics Institute Understanding Jurisdiction on Tribal Lands $157 42 $6,594 POST

Robbery Investigations $375 42 $15,750 Third Degree Communications


5

Analysis of Problem

Total Academy

Cost: $311,954

As employees in the Bureau of Gambling Control, their assignments are unique to this bureau. As such, it is crucial to the success of the Bureau that its workforce be experts in subjects related to gaming. The academy will focus on trends within the gaming industry which are constantiy evolving and changing, as well as skill development respective to the classification. Furthermore, the Bureau has recently increased the frequency of which it wiil require employees to enroll in Conflict of Interest and Ethics training and recertification to an annual basis. These courses will be incorporated into the training academy.

To identify possible courses and areas of training, the Bureau contacted agencies in Ontario, Canada; State of Nevada; State of Kansas, and State of Pennsyivania to discern the types of training given to employees performing similar tasks to those of the Bureau.

Ontario Provincial Police Department. Alcohol and Gaming Commission Within the Ontario Provincial Police Department (OPP), Alcohol and Gaming Commission, there are fifty-five Inspectors who are designated as Provisional Offense Officers for the purposes of investigating violations of the Liquor License Act and the Gaming Control Act. Representatives from the Division of Gaming Enforcement provided information regarding the Casino Investigation Course (CIC) that was developed specifically for employees within their Casino Enforcement Unit (CEU). The CIC is a two-week course intended to provide knowledge and skills to new members of the CEU. Topics include, but are not limited to, legislative structure, table games, card marking, cheat behavior, slot cheating, counterfeit chips, and practical exercises. Students participate in play of thirteen table games and the game of Craps. At the conclusion of the course, students are asked to demonstrate a myriad of skills relating to the topics of instruction.

After three years of service in the CEU, the employee is required to take a CIC refresher course, which is a one-week course, intended to assess knowledge and skill and qualify previously trained CEU investigators to continue with their active duties. Course topics mirror the original course. At the conclusion of the refresher course, students must demonstrate skills relating to the topics of instruction.

Licensing and financial investigations are completed by sworn officers with assistance from two Accountants employed within the Commission. The accountants must possess a degree in an accounting field prior to obtaining employment. O'Halloran further relayed that in addition to the CIC courses, staff are sent to college accounting and investigation courses to develop their skills. Additional training needs for CEU employees are identified on an individual basis and submitted through the chain of command for approval.

Nevada Gaming Control Board The purpose of the Nevada Gaming Control Board is to protect the stability of the gaming industry though investigations, licensing, and enforcement. The Board is also tasked with collection of gaming taxes and fees. Within the Board, there are three divisions that correlate to our three target groups: the Enforcement Division, Auditing Division, and Investigations Division.

The Enforcement Division consists of sworn officers conducting criminal and non-criminal investigations. Upon appointment, the officers are required to attend a basic police academy. The officers are provided "Protecting the Games" training. This training is conducted by the Board and is available to all law enforcement agencies. The one-week course is intended to deveiop knowledge of casino games, cheating schemes, sleight of hand techniques, evidence collection and courtroom testimony. Other training courses are identified by individual employees and approved on a case-by-case basis by their supervisor.

The Auditing Division is staffed with ninety-six employees; eighty-nine of which have degrees in accounting, seven of which are clerical support staff. On their website, the Division describes itself as "organized much like a large CPA firm, but with different job titles". The Division is primarily tasked with auditing 148 Group I casinos to ensure proper reporting of gaming revenue, ensure compliance with gaming law, and monitoring internal controls. Upon appointment, the employees are given on-the-job training to complete their duties. Training courses are identified by individual employees and approved on a case-by-case basis by their supervisor. The Bureau contacted the Board Training Officer who advised that the employees in the Auditing Division attend the annual conference hosted by the Nevada Society of Certified Public Accountants.

6

Analysis of Problem

The Investigations Division is tasked with investigating all license and key employee applicants to determine their suitability for licensure. Non-sworn investigators produce detailed reports which are used as the basis for licensing recommendations/decisions. Upon appointment, the Board required that each employee attend a Financial Crimes Investigation Course taught by Board staff. The course was previously given at the University of Nevada, Las Vegas, but for the last year, has only been offered to Board employees.

The Training Officer for the Board relayed that courses in Fraud Investigation, Anti-Money Laundering, Accounting, and Cyber Crimes are the most common types of courses requested by the employees. She stated that those types of courses are directly related to the duties performed and are rarely denied by management.

Kansas Racing and Gaming Commission The primary mission of the Kansas Racing and Gaming Commission (KRGC) is to ensure gaming in the state of Kansas is conducted with integrity. The enforcement agents of the KRGC have a dual role as law enforcement officers as well as casino regulators. Their duties include criminal enforcement, regulatory enforcement, and conducting background investigations of casino employees prior to licensing. The agents are required to attend a minimum of forty hours of training annually.

Representatives from the KRGC provided information regarding the training provided to staff upon appointment. They relayed that the KRGC provides training through in-house instructors as well as a Field Training Program. Courses include non-gaming topics such as agency policy, fingerprinting, breath testing, and use offeree; as well as gaming related topics including internal controls, responsible gaming, financial reporting, auditing casinos, gaming law, and table games. Agents are also provided training in background Investigations, report writing, and ethics. Additional training needs are identified on an individual basis and submitted through the supervisor for approval.

Furthermore, they relayed that the KRGC attempted to establish an annual in-service training academy, but due to limited manpower they were unable to maintain required casino coverage and abandoned the attempt.

Pennsvlvania Gaming Control Board The Pennsylvania Gaming Control Board (PGCB) is tasked with protecting the interest of the public by ensuring the integrity of legalized gambling. The PGCB is responsible for enforcing applicable laws and regulations, as well as licensing individuals and entities to conduct gaming related business in the State of Pennsylvania.

The Bureau contacted the PGCB to inquire as to the type of training provided to employees upon appointment. She relayed that the PGCB does not have a formal academy-style training plan; however, they rely on a variety of training options to ensure their staff have the knowledge and skills to perform their jobs.

PGCB frequently hires outside instructors with expertise on subjects such as Title 31, casino cheating techniques, casino regulation, online gaming, and report writing. The instructors are brought to the employees and provide onsite training to applicable staff. Additionally, employees are sent to conferences and presentations relative to their job duties. Employees such as Attorneys, Accountants, and Fraud Examiners have minimum training requirements for continuing education.

They relayed that the PGCB develops in-house training modules such as PowerPoint presentations for new commissioners and other staff to educate them on the industry and the agency. She offered to have her staff provide specialized training to the Bureau in the future.

The type of academy the Bureau would like to develop would encompass the ideals, styles, and similar curriculum of all of these agencies. By establishing a basic curriculum, and reassessing training needs and areas of deficiency within the target groups, the Bureau's workforce would be the most knowledgeable, well-developed gaming enforcement agency world-wide.

C. State Level Considerations The Bureau has the primary responsibility for regulating the State's gambling industry, including investigating violations of the California Penai Code as weii as any other applicable law, rule, or statute; performing audits to ensure tribal casinos remain in compliance with negotiated compacts; and approving changes to existing games or new games as introduced by the industry, in accordance with applicable law.

The work produced by Bureau employees assists in implementing the Legislature's policy that "unregulated gambling is contrary to the public health, safety and welfare, and that no person in this state has a right to operate a gambling enterprise except those that are expressly permitted by the laws of this state..." The public trusts that permissible

7

Analysis of Problem

gambling will not endanger public health, safety, or welfare and requires that comprehensive measures be enacted to ensure that such gambling is free from criminal and corruptive elements and conducted honestly. Public trust can only be maintained by strict and comprehensive regulation of all persons and associations related to the operation of lawful gambling, enforcement of applicable laws, rules, and statutes; strict adherence to negotiated compacts; and a thorough vetting and understanding of the games being played in the State of California.

In addition. Business and Professions code section 19950, states in part, "All fines and penalties collected...may be expended by the Department of Justice to offset costs incurred pursuant to this chapter [The California Gambling Control Act]."

D. Just i f icat ion This proposal seeks to increase the Bureau's available resources without imposing additional burdens on the division, department, or State. The Gambling Control Fines and Penalties Account has a current balance of $2.8 million not including the $1.75 million settlement check the Bureau recently received.

The Bureau's Licensing Section consists of managers, analysts, and support staff. The primary responsibility of the Licensing Section is to conduct investigations into owners, key employees, vendors, and Third Party Providers of Proposition Players Services who seek to do business in the state of California. Licensing investigations are being conducted by analytical staff primarily at the Associate Governmental Program Analyst level. The roles and responsibilities of these non-peace officer positions are unique in state service as they are performing critical investigations that have a direct result on public safety. Upon accepting an analyst position within the Bureau of Gambling Control, staff members are expected to conduct in-depth investigations into the lives of the applicants seeking licensure. The investigations delve into criminal history, financial history, work experience, business associations and transactions, and many other complex facets of the applicant's personal and professional lives. Currently the Bureau sends their employees to completed staffwork, writing, and other standard analytical courses offered by the Department.

With regard to the Bureau's criminal enforcement operations, investigative trends show that the types of gaming crimes are becoming more complex and sophisticated, often using the Internet, computer equipment, body cameras, and a high level communication system. With the recent influx of Internet cafe investigations. Special Agents have had to learn about these Hi-Tech methods during the course of the investigation in an on-the-job capacity. The areas of criminal activity are far reaching, and investigators have to coordinate with local, state, and federal law enforcement agencies on what has previously been considered a routine investigation. Additionally, Internet gaming is on the forefront of gaming legislation in the state of California. The Bureau has been asked to begin developing ways to combat crime associated with Internet gaming. However, training for these types of investigations is typically held in the states where Internet gaming is legal, such as Nevada, New Jersey, and Delaware. The Bureau's Compliance and Enforcement Section consists of Sworn Agents, Special Agent Supervisors, Special Agents in Charge, non-sworn Field Representatives, and support staff.

The Audit and Compact Compliance Section consists of Auditors, Systems Analysts, Supervisors, Managers, and support staff. Within the Audit and Compact Compliance Section, staff conducts inspections on gaming equipment used by tribal casinos, conducts routine audits of tribal casinos to ensure compact compliance, and conducts audits of California cardrooms to ensure compliance with applicable laws and statutes. Audit staff is expected to recognize financial fraud, trends, anomalies, and inconsistencies when reviewing information relative to their audit. Courses for these types of investigations are often located out of state, or are infrequently offered in California. As such, not all auditors receive consistent or timely training on all aspects of their job in a formal setting.

The Bureau seeks to be the example for gaming regulatory agencies in the world. This proposal seeks an avenue for the Bureau to provide a high level of training, suited to our unique area of responsibility. The Bureau wants to develop an academy-style program specific to ail areas of Bureau responsibility. Vendors are available to review the Bureau's work and develop training courses specific to its tasks. The final component to establishing the Bureau's Training Academy is the funding. Preliminary quotes for courses in investigative writing and financial fraud investigations are $20,000 for up to 50 employees at one time. Assuming these rates, or rates similar to these, would apply across the board, the Bureau could host multiple courses for each unit during the year.

E. Outcomes and Accountabi l i ty The approval of this proposal would allow the Bureau to have an avenue to provide much needed to the employees that serve to keep gaming safe for the citizens of the State of California. The Bureau believes that when the

8

Analysis of Problem

employees receive the training warranted by their task, they will become more efficient, produce more work at a higher quality, and become more invested in their job.

F. Analysis of All Feasible Alternatives Alternative 1. Approve Spending as Proposed. Approve the Bureau's request of additional authority of $200,000 annually from the Gambling Control Fines and Penalties Account. These funds will be used to develop, implement, and maintain an academy-style training course for Bureau employees.

Alternative 2. Approve Limited Term Authority This alternative would allow the Bureau to utilize the Gambling Control Fines and Penalties Account to fund training for a three-year period. The Bureau could establish and maintain the academy for three years. At the end of that term, effect on workforce, skills, knowledge base and overall efficiency would be gauged to seek future funding.

Current staff would receive training; however, future staff would not receive the same opportunity leading to a decrease in efficiency and work quality. This alternative does not provide a long term solution to the issue at hand.

Alternative 3. Carry Out this Objective with Existing Funding and Staffing. This is not a viable alternative as it is not feasible for the Bureau to fund training with existing means.

G. Implementation Plan If this proposal is approved, the implementation plan will begin immediately upon availability of spending to contract with vendors to provide courses and schedule training.

H. Supplemental Information

None.

I. Recommendation Alternative 1. Approve Spending as Proposed. Approve the Bureau's request for additional authority of $200,000 annually from the Gambling Control Fines and Penalties Account. These funds will be used to develop, implement, and maintain an academy-style training course for Bureau employees. By establishing a basic curriculum, and reassessing training needs and areas of deficiency within the target groups, the Bureau's workforce would be greatly enhanced to ensure the public trust in California's gaming industry.

9