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Policies and Procedures for the Tribal Gaming
Commission and Casino Management




To protect the integrity of your gaming operation, you need to ensure compliance with federal laws. To do that, you must focus on law enforcement, internal controls and staff education. Tribal leaders must provide an honest and effective law enforcement framework and implement a code of high ethical standards among all employees. Understanding your obligations under the Indian Gaming Regulatory Act (IGRA), Title 31 of the Bank Secrecy Act and the National Indian Gaming Commissionís (NIGC) Minimum Internal Control Standards (MICS) is a crucial first step.

This class will prepare you to fully assess potential risks to tribal interests, including money laundering, fraud, employee theft and other types of criminal activities. It will help you establish a proactive approach that discourages crime and questionable activities in your casino and will provide you with the latest information on suspicious activity reporting. Our experienced instructor will guide discussions on the issues tribal gaming commissioners and casino managers face today.

Donít miss this opportunity to gain valuable knowledge on how to keep your gaming operation beyond reproach.

T O P I C S   I N C L U D E
Tribal Gaming Commission Roles and Responsibilities
  • The structure and functions of the commission
  • Gaming establishments and the commission
  • Roles and policies of the commission
  • Interaction with the National Indian Gaming Commission (NIGC)
  • Ethical and legal obligations
  • California v. Cabazon Band of Mission Indians
The First Line of Defense
  • NIGC
  • Updated 2006 Minimum Internal Control Standards (MICS)
  • U.S. Code pertaining to gambling:
    –– 15 U.S.C. 1171-1178, Title 18 crimes and criminal procedures
Challenges for Gaming Operation Leadership
  • Separation of powers
  • Evaluating management
  • Maintaining independence
  • Responsibility to the community
  • Management contracts
  • Grievances and appeals
    –– When to conduct investigations/hearings
    –– Roles, processes and legal issues
  • MICS in union contract negotiations
Ethics for the Tribal Gaming Commission
  • Developing a code of ethics
  • Conflict of interest — real v. apparent
  • Identifying and handling misconduct
  • Penalties and sanctions
  • Diagnostic checklists
  • Family members as patrons
Background Investigations
  • Investigations of key employees and management officials
  • Vendor background investigations — due diligence
  • Preliminary steps
  • Coverage and report writing
  • Supervisor/co-worker interview
  • Recognizing deceptive responses
  • Descriptions and treatments
  • Fair Credit Reporting Act
Organized Crime
  • History of organized crime in the United States
  • Recent trends
  • Attraction to the gaming industry
  • Infiltration methods
  • Video activity
Criminal Enterprises
  • Money laundering — vulnerability of casino gaming
  • Laundering countermeasures
  • Modern techniques
  • Successful law enforcement strategies
  • Fraud
  • Threats to homeland security
Protecting Against Infiltration
  • Identifying and tracking problem areas and criminal elements
  • Detecting suspicious transactions and activities
  • Suspicious activity reporting requirements
  • Role of tribal law enforcement and regulatory personnel
  • Intelligence liaisons with local, state and federal agencies
  • Surveillance of known criminals
  • Patron financial information
  • Employee theft and collusion
  • Title 31 regulations
Intelligence
  • Suspicious activity reporting
  • Proposed regulations
  • Currency transaction reporting
  • Surveillance
Current Trends in Gaming Compacts
  • State requirements
  • Internal controls best practices
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