07202221 Master Training Book

07202221 Master Training Book

Cheats & Scams July 20-22 , 20 2 1 Las Vegas, NV

SOUTH TOWE R

Escalator to Las Vegas Ballroom

PACIFIC BALLROOM

Lobby

S ECOND F LOOR

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Offices

Lobby

LAS VEGAS BALLROOM

Convention Service Office

TH I RD F LOOR

Master on Cheats & Scams Commissioner Training July 20 - 22, 2021 Indian Gaming Trade Show & Convention Bally's Las Vegas Ballroom, South Tower,Third Floor Las Vegas, Nevada

Tuesday, July 20

8:00 AM 9:00 AM Breakfast

Whos in the Hot Seat Josh Peukert, Junior Partner, Blue Bird CPA's, Sheryl Ashley, Partner BlueBird CPA's

9:00 AM 10:30 AM

10:30 AM 10:45 AM Break

Human Resources vs. Human Resoursefullness Josh Peukert, Junior Partner, Blue Bird CPA's, Sheryl Ashley, Partner BlueBird CPA's

10:45 AM 12:30 PM

12:30 PM 2:00 PM Lunch

Situation Awareness Billy David Bo-Ca-Pa & Associates

2:00 PM 3:15 PM

3:15 PM 3:30 PM Break

Human Trafficking Billy David Bo-Ca-Pa & Associates Wednesday, July 21

3:30 PM 5:00 PM

8:00 AM 9:00 AM Breakfast

Minimizing/Mitigating Surveillance Departments Billy David Bo-Ca-Pa & Associates

9:00 AM 10:30 AM

10:30 AM 10:45 AM

Break

How to Watch a Game You Never Dealt George Joseph, Worldwide Casino Consulting, Inc .

10:45 AM 12:30 PM

12:30 PM 2:00 PM Lunch

Slot Player Club Scams & Schemes George Joseph, Worldwide Casino Consulting, Inc.

2:00 PM 3:15 PM

3:15 PM 3:30 PM Break

Top 10 Gaming Commission Concerns George Joseph, Worldwide Casino Consulting, Inc Thursday, July 22

3:30 PM 5:00 PM

8:00 AM 9:00 AM Breakfast

Indian Country Jurisdictions Elizabeth Homer, Homer Law CHTD

9:00 AM 10:30 AM

10:30 AM 10:45 AM Break

Gaming Crimes Elizabeth Homer, Homer Law CHTD

10:45 AM 12:30 PM

Please plan to stay for the entire class on each day to get your certificate of completion. Please be on time for sessions

7/13/21

Players’ Club Fraud

Josh Peukert, CFE, CIA Junior Partner

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What the heck is going on?! Who’s in the Hot Seat

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Outline

• Fraud example • How it was identified • How to prevent (or detect sooner)

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Fun Fact

If I ever wanted to commit fraud, I want to work in your Player’s Club.

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Regulatory Requirements

NIGC MICS 542.13(j)(1)(iii) The addition of points to members' 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 members' 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.

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Side Note

• Most reasons documented in the player tracking system are not sufficient.

• The previous requirement is silent regarding free play.

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Regulatory Requirement

NIGC MICS 543.24(d) • (ii) At least monthly, for computerized player tracking systems, perform the following procedures: o (A) Review authorization documentation for all manual point additions/deletions for propriety; o (B) Review exception reports, including transfers between accounts; and o (C) Review documentation related to access to inactive and closed accounts.

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Regulatory Requirement

NIGC MICS 543.24(d) • (iii) At least annually, all computerized player tracking systems must be reviewed by agent(s) independent of the individuals that set up or make changes to the system parameters. The review must be performed to determine that the configuration parameters are accurate and have not been altered without appropriate management authorization Document and maintain the test results.

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0 for 2

• Again…silent on free play

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Hot Seat Promotions

How employees can take advantage of the process…

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Table Games – Ratings Shenanigans

• Table Rating Fraud

• Adding a rating for a player who isn’t even at the table or inflating their rating by increasing their avg. bet, buy-in, time played, etc.

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Gotcha!

• The Casino was doing random Title 31 audits. The pit employee rated someone for more than $3,000 and forgot to log on the MTL….whoops.

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How to Correct/Identify

• Random rating audits are easiest

• Easiest if surveillance performs since they have camera access.

• Can match rating sheet to table games drop as a whole

• Can match rating sheet to MTL

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Here’s Some Points For You

• Employee manually adding promo or ratings to friend's accounts

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How to Identify/Correct

• Manual adjustments require forms and secondary signatures at different levels.

• Perform audits as required by both 542 and 543.

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Long Story

• A Casino offers free-play incentives for you to return after an absence from the property

• A “bounce-back” offer o Offer is based on your play prior to your absence o The more money you spent, the higher your offer

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Long Story

• Super Playmate does not show a trip if a patron uses only free play (on the primary screen when searching) o It also will not show coin-in o You have to look several screens in to see the transactions of the patron

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Get to the Point

• A group figured this out and spent roughly $90,000 in free play related to bounce back offers o Would not have gotten if a trip was registered

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How it was Identified

• Title 31!

• The Casino verifies large ticket redemptions cashed at kiosks to determine whether cards were inserted when tickets were printed (a suggestion by their incredible auditor)

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How it was Identified

• Casino found multiple tickets redeemed in a kiosk over their redemption threshold and found that the card had been pulled just before the ticket was printed.

• This was done multiple times

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How to Fix

• If you use Super Playmate and offer bounce back groups, verify that the higher tier players are not coming back to the Casino.

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For those of you without a Player’s Club

• Do you offer match play vouchers for slots?

• Do you record, track, and audit appropriately?

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For those of you without a Player’s Club

• A Casino without a player’s club offered $10 match play.

• The player would come to the cage, the cage cashier would fill out a voucher which was to be given to the security or slot person along with a $10. Slots would watch patron play substantially all of the money given by the Casino.

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For those of you without a Player’s Club

• The cage cashier was “helping” slots/security by filling out their vouchers most of the time since she knew which machines players preferred.

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For those of you without a Player’s Club

• Cashier was short one day, and never called to find out why she was short o She had a history of being worried when she didn’t balance.

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For those of you without a Player’s Club

• Commission determined that she was short as a result of the theft, terminated her, and then told us about it. o They also mentioned to us that this cashier did substantially more match play vouchers than any other cashier.

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What we determined I thought the last story was long…. • The Cashier was filling out fraudulent 2 match play vouchers and moving money to a different part of her drawer, generally $100 at a time. o Money was folded up, dropped on the floor, and placed in the employee’s sock

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What we determined Policy Violations • This was a violation of the Casino policy. Only slots/security were supposed to complete the match play voucher.

• Patron required to sign a log as receiving the match play. o Signatures were forged by cage cashier

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Sharing the Wealth

• Enrolling friends into free play groups o Groups approved prior to use o Promotional logs audited after event o Random auditing of large FSP automatic uploads

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Scenario

• Player’s Club Rep at a Casino was typing in random player’s club numbers and looking for people who were not from the area and close to archiving (expiration) o Reactivated account o Reset the pin o Reprinted a card o Gave to bf who played the free play.

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How it was Identified

• Casino is fairly small, and surveillance was wondering why the player’s club rep was printing cards when no one was standing at their window.

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How to Correct

• Account reactivation, card reprints, new accounts, and PIN resets audited for fraud by a department separate from Player’s Club.

• Segregate permissions in Super Playmate, CMP, Patron Management, etc. to prohibit one employee from being able to do all functions.

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All in the Family

• Multiple patrons using one patron’s account to gain a higher card status

• Scan the floor for same club account used in multiple machines at the same time.

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Not so Common Sense?

• Abandoned (or lost) club cards used to steal free play

• Do not allow players to select certain PINs (Birth Year, 1234, etc.)

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Risky Business

• Patrons asking for PIN reset or reprint for another Patron

• Patrons must be present at the club window for a reprint or PIN reset

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Key Takeaways

• Include free play in your audits o Not just points because that’s what is required

• Base audits on regulatory requirements AND risk o Do what is required but add in additional risks to the Casino based on your internal policies and permissions.

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Detailed Audit Procedures Sheryl L. Ashley, CIA, CFE, CRFAC, RFI, FCPA, CPA Partner BlueBird, CPAs

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Analyzing What Happened After Fraud Is Found… • How did the fraud occur? • What controls failed? • What controls were overridden? • Why wasn’t the fraud detected earlier? • What red flags were missed by management? • What red flags did internal audit miss? • How can future frauds be prevented or more easily detected? • What controls need strengthening? • What internal audit plans and audit steps need to • be enhanced? • What additional training is needed?

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Understanding… Players’ Clubs To assist the internal auditor in understanding the Casino's club operations, the auditor should perform a walk-through of the operation with management and the employees who perform each function: • From the time the customer inserts his or her card into the machine to the final award payout. • To assess the risks and controls for the various transactions. • It also may be helpful for the auditor to take the information learned from this walk-through and document it in a flowchart for reference during audit planning.

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Understanding… Players’ Clubs • Are club and GM operations employees prohibited from participating? • How much play is required to earn one point or one comp dollar? • What is the value of one point?

• What are the rewards available to players? • What is the procedure for earning rewards?

• What are the procedures and controls for redeeming rewards? • What is the chain of custody for cash-back forms inventory?

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Understanding… Players’ Clubs • Given the audit objectives, what reports are available for management review and audit purposes? • What is the source of the information on the reports? • What controls are in place over system administration and system- parameter changes? • How are changes to system parameters authorized and reported? • What controls are in place to ensure system-parameter changes are valid and authorized?

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Understanding… Players’ Clubs • Which employees have system access to adjust, add, or delete points to an account? • What is the authorization and review process? • Are there access restrictions or levels for viewing and accessing online account information? • Does the system have the capability to show the exact source of transactions? • How are downloadable promotional credits controlled? • How are third-party technicians or service personnel supervised when accessing the system or GM machines?

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Understanding… Players’ Clubs • Unauthorized access or adjustments to dormant, test, and live customer accounts that result in the transfer of award credits to unauthorized accounts. • Extension of complimentary goods and services in excess of policy guidelines. • Computer systemmanipulations such as unauthorized changes to system parameters. • Unauthorized or inappropriate administrative rights, access rights to run customer-sensitive reports, or access rights to import >Page 1 Page 2 Page 3 Page 4 Page 5 Page 6 Page 7 Page 8 Page 9 Page 10 Page 11 Page 12 Page 13 Page 14 Page 15 Page 16 Page 17 Page 18 Page 19 Page 20 Page 21 Page 22 Page 23 Page 24 Page 25 Page 26 Page 27 Page 28 Page 29 Page 30 Page 31 Page 32 Page 33 Page 34 Page 35 Page 36 Page 37 Page 38 Page 39 Page 40 Page 41 Page 42 Page 43 Page 44 Page 45 Page 46 Page 47 Page 48 Page 49 Page 50 Page 51 Page 52 Page 53 Page 54 Page 55 Page 56 Page 57 Page 58 Page 59 Page 60 Page 61 Page 62 Page 63 Page 64 Page 65 Page 66 Page 67 Page 68 Page 69 Page 70 Page 71 Page 72 Page 73 Page 74 Page 75 Page 76 Page 77 Page 78 Page 79 Page 80 Page 81 Page 82 Page 83 Page 84 Page 85 Page 86 Page 87 Page 88 Page 89 Page 90 Page 91 Page 92 Page 93 Page 94 Page 95 Page 96 Page 97 Page 98 Page 99 Page 100 Page 101 Page 102 Page 103 Page 104 Page 105 Page 106 Page 107 Page 108 Page 109 Page 110 Page 111 Page 112 Page 113 Page 114 Page 115 Page 116 Page 117 Page 118 Page 119 Page 120 Page 121 Page 122 Page 123 Page 124 Page 125 Page 126 Page 127 Page 128 Page 129 Page 130 Page 131 Page 132 Page 133 Page 134 Page 135 Page 136 Page 137 Page 138 Page 139 Page 140 Page 141 Page 142 Page 143 Page 144 Page 145 Page 146 Page 147 Page 148 Page 149 Page 150 Page 151 Page 152 Page 153 Page 154 Page 155 Page 156 Page 157 Page 158 Page 159 Page 160 Page 161 Page 162 Page 163 Page 164 Page 165 Page 166 Page 167 Page 168 Page 169 Page 170 Page 171 Page 172 Page 173 Page 174 Page 175 Page 176 Page 177 Page 178 Page 179 Page 180 Page 181 Page 182 Page 183 Page 184

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