11151721 Level III Training Book.pdf

11151721 Level III Training Book.pdf

NIGA

CERTI Fl ED SEMINAR INSTITUTE COMMISSIONER CERTIFICATION TRAINING LEVEL Ill

Sept. 15 - 17 , 202 1 Temecula, CA

Commissioner Certification Training Level III AGENDA November 15 - 17, 2021 Pechanga, Calif PST time

Monday, November 15

8:00 AM 9:00 AM

Breakfast to be provided Avoiding and Detecting Fraud: Active Investigation & Forensic Audits Josh Peukert, CFE & CIA Gaming MICS Compliance, Blue Bird CPA's Break Title 31/OFAC Josh Peukert, CFE & CIA Gaming MICS Compliance , Blue Bird CPA's Lunch Break

9:00 AM 10:30 AM

10:30 AM 10:45 AM

10:45 AM 12:30 PM

12:30 PM 2:00 PM

Effective Regulation of Gaming Elizabeth Homer, Homer Law CHTD Break Hearing and Appeals Elizabeth Homer, Homer Law CHTD Tuesday, November 16

2:00 PM 3:15 PM

3:15 PM

3:30 PM

3:30 PM 5:00 PM

8:00 AM 9:00 AM

Breakfast to be provide d

Conflict Management Elizabeth Homer, Homer Law CHTD

9:00 AM 10:30 AM

10:30 AM 10:45 AM

Break

Employment Issues for Gaming Regulators Charlene Jackson, Jackson Law

10:45 AM 12:30 PM

12:30 PM 2:00 PM

Lunch Break

Network Risk Assessment Peter Nikiper, BMM Test Labs

2:00 PM 3:15 PM

3:15 PM

3:30 PM

Break

Managing a Tribal Gaming Regulatory Agency Billy David, Be-Co-Pa & Associates Wednesday, November 18

3:30 PM 5:00 PM

8:00 AM 9:00 AM

Breakfast to be provided

Surveillance Frauds, Threats & Vulnerabilities, PT 1 Billy David, Be-Co-Pa & Associates

9:00 AM 10:30 AM

10:30 AM 10:45 AM

Break

Surveillance Frauds, Threats & Vulnerabilities, PT 1 Billy David, Be-Co-Pa & Associates

10:45 AM 12:15 PM

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

9/15/20

Avoiding and Detecting Frauds Sheryl L. Ashley, CIA, CFE, FCPA, CPA Partner BlueBird, CPAs

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Definition of Fraud Black’s Law Dictionary:

“…all multifarious means which human ingenuity can devise, and which are resorted to by one individual to get an advantage over another by false suggestions or suppression of the truth. It includes all surprise, trick, cunning, or dissembling, and any unfair way by which another is cheated.”

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Common Law 4 Elements of Fraud

• A material false statement. • Knowledge that the statement was false when it was uttered. • Reliance of the victim on the false statement. • Damages resulting from the victim’s reliance on the false statement.

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Abbreviated Definition of Fraud Fraud includes any intentional or deliberate act to deprive another of property or money by guile, deception or other unfair means.

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AICPA Definition of Fraud “An intentional act that results in material misstatement in financial statements that are subject to audit…There are two types of fraud: • Misstatements from fraudulent financial reporting & • Misstatements frommisappropriation of assets”

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Principal Categories of White Collar Crime

Misrepresentation of material facts Concealment of material facts

•

•

Bribery

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Conflicts of interest

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Theft of money or property

•

• Theft of trade secrets or intellectual property • Breach of fiduciary duty • Statutory offenses

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Predication • Predication is the totality of circumstances that would lead a reasonable, professionally trained, prudent person to believe that a fraud has occurred, is occurring, or will occur. • All fraud investigations must be based on proper predication; without it, a fraud investigation should not begin.

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The Fraud Triangle (Cressey)

OPPORTUNITY

FINANCIAL PRESSURE

RATIONALIZATION

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Top Ten Personal Characteristics for Fraud • Living beyond their means • Overwhelming desire for personal gain • High personal debt • Close association with customers/vendors • Wheeler-dealer attitude

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Top Ten Personal Characteristics for Fraud • Undue family/peer pressure • Compulsive gambling habits or other addiction • Feeling not commensurate with responsibility • Challenge to beat the system • No recognition for job performance

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Behavioral Red Flags Displayed by Perpetrators

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Top Ten Organizational Characteristics for Fraud • Placing too much trust in employees • Lack of proper authorization procedures • Inadequate disclosure of personal investments/income • Lack – custody/authorization by same person • Lack of independent checks on performance

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Top Ten Organizational Characteristics for Fraud • Inadequate attention to details

• Lack – custody/recording by same person • Lack – separation of duties in accounting • Lack – clear lines of authority and responsibility • No independent review by internal audit

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Employee (Misconduct or Abuse) • Use equipment for personal use • Use internet for personal use at work • Conduct personal business while at work • Long breaks without approval • Late to work/leave early • Slow or sloppy work • Use sick leave when not sick • WWUI (working while under the influence…)

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Perpetrator’s Education Level

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Perpetrator’s Age

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Perpetrator’s Gender

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Common Schemes

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Duration of Fraud Schemes

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Initial Detection of Occupational Frauds

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Source of Tips

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What To Do When We Get Home • How Do We Identify a Perpetrator Before He/She Strikes? • Tackle all three sides of the Fraud Triangle • Raise the overall fraud awareness • Robust anonymous tip reporting process • Develop/enhance policies and procedures • Real pre-employment personality testing for key positions • Also have exit screening with personnel that terminate employment

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Forensic Audits

Sheryl L. Ashley, CIA, CFE, FCPA, CPA, Partner BlueBird, CPAs

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Definitions – External Audit This is an audit performed by an auditor engaged in public practice, leading to the expression of a professional opinion that lends credibility to the assertion under examination. (Materiality, professional skepticism) Forensic accountants can be engaged in public practice or employed by insurance companies, banks, police forces, government agencies, and other organizations. • Litigation (preparing documents & expert testimony) • Investigative

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Definitions – Forensic Accounting The forensic accountant or accounting comprises two distinctly different fields. • Forensic generally is defined as “belonging to the courts of justice.” • An accountant generally is identified as an “expert in the field of accounting.” • Accounting is described as a methodology for organizing, preserving, and reporting on business transactions.

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Definitions – Forensic Audit While a regular audit focuses on errors, omissions, assertions, and misstatements, a forensic audit focuses on suspicious activity, exceptions, and irregularities.

Typical areas of focus include payables, payroll, profits, and revenues.

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Definition – Forensic Investigation • While a forensic investigation can be found in any discipline, including accounting, medicine, DNA analysis, or engineering, the general definition applies in any case. • The forensic investigation involves using special investigative skills in order to carry out an inquiry so that the outcome may be used in a court of law.

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Definition – Internal Audit This is an audit performed by an employee who examines operational evidence to determine whether prescribed operating procedures have been followed.

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Types of Forensic Accountant Investigations

• Employee fraud and criminal fraud • Business economic losses • Shareholder and partnership disputes • Insurance claims • Personal injury and wrongful termination claims • Matrimonial disputes • Mediation and arbitration 29 Forensic Investigator Should Have Knowledge of: • Constraints of legal system • Rights of suspects • Skills in interview techniques • Attorney-client work product privilege • Criminal rules of evidence and procedure

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Useful Websites:

www.acfe.com

Certified Fraud Examiner

www.acfei.com

Certified Forensic Consultant

www.aicpa.org

Certified in Financial Forensics

www.fcpas.org

Forensic Certified Public Accountant

www.imanet.org

Certified Management Accountant

www.isaca.org

Certified Information Systems Auditor

www.nacva.com

Certified Forensic Financial Analyst

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Active Investigations

Sheryl L. Ashley, CIA, CFE, FCPA, CPA, Partner BlueBird, CPAs

32

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Quiz Question 1

• How early can children lie as successfully as adults?

a) 5 b) 8 c)

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Quiz Question 2

• What percentage of adults say it’s okay to lie to avoid hurt feelings?

a) 44% b) 65% c) 77%

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Quiz Question 3

• What percentage of adults lie to make themselves sound cool?

a) 25% b) 33% c) 44%

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Quiz Question 4

• What percentage of teens think downloading illegal music is more justified than stealing from

a store? a) 26% b) 47% c) 78%

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Quiz Question 5

• What percentage of adults 18 to 24 would not admit to having STDs to their partner? a) 7% b) 17% c) 37%

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Quiz Question 6

• What percentage of teens admit to lying to their parents?

a) 97% b) 98% c) 99%

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Quiz Question 7

• What percentage of men approve of cheating if their partner loses interest?

a) 14% b) 26% c) 56%

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Facts About Lies On Average: • A person lies 3 times during 10 minutes of conversation • 42% of adults think its okay to lie • 54% of lies are accurately detected • 98% of teenagers lie to their parents

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Facts About Lies • Generational differences: o 1922-1945 •

Bernie Madoff, Bernie Ebbers, Ken Lay

o 1946-1964 o 1965-1980 o 1980-1994 • On average the older the generation, the higher the loss!

41

Micro-Expressions • A micro-expression is a very brief facial expression shown on the face of humans when one is trying to conceal an emotion. o A micro-expression can not be faked. o It usually is only less than 1/25th of second.

• (Dr. Paul Ekman)

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Micro-Expressions

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7 Universal Facial Expressions of Emotion

Happiness

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Surprise Sadness

•

•

Fear

•

Anger

•

Contempt

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Disgust

•

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Happiness

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Happiness & Fake Smiles

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Surprise

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Surprise

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Sadness

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Sadness

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Fear

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Fear

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Anger

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Anger

54

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Contempt

55

Contempt

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Disgust

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Disgust

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What Does This Look Like to You?

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Other Things to Think About…

The face often contains two messages: • What the liar wants to show and • What the liar wants to conceal. False, but convincing, expressions may occur one moment and concealed expressions the very next moment. The true, felt expressions of emotions occur because facial actions can be produced involuntarily, without thought or intention.

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Other Things to Consider:

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Do I Need an Attorney? • Attorney-client privilege prohibits the disclosure of communications between the attorney and the client for the purpose of rendering legal advice • Work product doctrine protects Attorney’s notes and certain other materials the Attorney prepares in anticipation of litigation. • If your investigation is under the direction of an Attorney it may also be protected by the Attorney-client privilege and the work product doctrine.

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Investigative Techniques – Interviewing

• Before embarking on an interview, the auditor should review the case file to ensure that it does not contain important information that has been overlooked.

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Investigative Techniques – Interviewing • Interview Basics: o Only interview one person at time o In a private place o Get a commitment for assistance from the interviewee before the interview begins

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Investigative Techniques – Interviewing • Types of questions in an interview:

o Introductory Questions o Informational Questions o Closing Questions o Assessment Questions o Admission-Seeking Questions

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Investigative Techniques – Interviewing • Introductory Questions: o Provide the Introduction o Establish Rapport o Establish the Interview Theme o Observe Reactions

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Investigative Techniques – Interviewing • Introductory Questions: o Provide the Introduction •

Avoid using titles, (name and department is fine) • Try to be informal

67

Investigative Techniques – Interviewing • Introductory Questions: o Establish Rapport • Limit small talk to only a few minutes

o Make sure to get a verbal commitment before the interview begins. Encourage the interviewee to say ”yes” even if it takes several ways of asking.

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Investigative Techniques – Interviewing • Introductory Questions: o Establish the Interview Theme •

State a basic purpose of the meeting, “I need help understanding the jackpot process. It would be helpful if I could start by asking you to basically tell me about your job, okay?”

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Investigative Techniques – Interviewing • Introductory Questions: o Observe reactions: •

Seek continuous agreement - try to ask questions that will have a “yes” answer • Do not invade body space - make sure you can see the interviewee head to toe • Make sure the door is not locked and do not block the exit

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Investigative Techniques – Interviewing • Informational Questions: o Conducting an interview to gain an understanding of internal control systems o Interviews concerning documents o Gathering information regarding business operations or systems

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Investigative Techniques – Interviewing • Types of Informational Questions: o Open Questions (best) o Closed Questions (avoid at this point) o Leading Questions (confirm facts already known) o Double-Negative Questions (avoid!)

o Complex Questions (avoid!) o Attitude Questions (at times)

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Investigative Techniques – Interviewing • Investigative Question Techniques: o Easy questions first o Develop the facts in a systematic order o Ask only one question at a time - frame questions so only one answer is required

o Be straightforward o Do not rush answers o Do not suggest answers

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Investigative Techniques – Interviewing

• Investigative Question Techniques: o Repeat or rephrase to get desired facts o Make sure you understand the answers provided, ask for clarification at that time instead of later o Let interviewee qualify answers o Let interviewee give comparisons to ascertain accuracy o Get all the facts

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Investigative Techniques – Interviewing • Investigative Question Techniques: o After the interviewee has give a long narrative, ask questions about items discussed o At the conclusion of questioning summarize facts as you understand them and have interviewee verify that your conclusions are correct

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Investigative Techniques – Interviewing • Investigative Question Techniques for Note Taking: o Only pertinent facts o If a quote is particularly relevant try to write it verbatim & use “quotes” o Only jot down key words or phrases & then go back over details at the end of the interview o No opinions or impressions of interviewee

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Investigative Techniques – Interviewing • Assessment Question Techniques: • Verbal cues are also possible such as: o Changes in speech o Repeating your question o Timing of responses (delays) o Can not remember o Making excuses Investigative Techniques – Interviewing • Assessment Question Techniques: • Verbal cues are also possible such as: o Emphasis on certain words o Oaths o Offering character witnesses o Answering with questions o Overuse of respect o Weaker denial of facts or failure to deny

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Investigative Techniques – Interviewing • Closing Question Techniques: o Reconfirm facts o Gather additional facts o Conclude, maintain goodwill, provide a business card or contact number o Attempt to obtain commitment for confidentiality o Of course, shake hands and thank them

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Investigative Techniques – Interviewing

Assessment Question Techniques:

•

• Non-verbal cues are also possible such as: o Moving away from interviewer o Perspiration, breathing, etc. o Excessive hand movements o Hands over the mouth o Crossing of the arms o Fake smiles o Keen interest in the evidence presented

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Investigative Techniques – Interviewing • Assessment Question Techniques (and the person is guilty): o Direct Accusation o Observe Reaction o Repeat Accusation o Interrupt Denials o Delays o Interruptions o Reasoning o Establish Rationalization

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Investigative Techniques – Interviewing • Assessment Question Techniques (and the person is guilty): o Diffuse Alibis o Display Physical Evidence

o Discuss Witnesses o Discuss Deceptions o Present Alternative o Benchmark Admission

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Investigative Techniques – Interviewing • Assessment Question Techniques (and the person is guilty): o Reinforce Rationalization

o Verbal Confession o Motive for Offense o Others Involved o Physical Evidence

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Investigative Techniques – Interviewing • Interviewing Techniques: • At end of interview: o Best if summarized immediately after interview in a memorandum o Keep abbreviated notes taken during interview just in case, but if they are kept someone else may be able to see

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Sheryl L. Ashley, Partner [email protected] Thank you!

5585 Kietzke Lane | Reno, NV 89511 Phone: 775.827.5999 | Fax: 775.827.2104 [email protected] | www.bluebirdcpas.com

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Preparing Your Property for a Title 31/AML IRS Compliance Examination

5/3/2016

Title 31 and OFAC

Josh Peukert, CPA Gaming & MICS Compliance AUP, Junior Partner BlueBird, CPAs

1

About Our Firm • Founded in 1996 • Leadership has over 125 years of experience • 15 States o 60 Casinos

o 24 Title 31 engagements in 2017 • 10% of Tribal gaming revenue

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BlueBird, CPAs

1

Preparing Your Property for a Title 31/AML IRS Compliance Examination

5/3/2016

Outline • Changes in Expectations and Updates in BSA • Know Your Customer and Source of Funds o Including OFAC

• CTR Red Flags • SAR Reporting • Top 10 Common Findings • IRS Audit Prep

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Most Recent Updates • Cole Memo:

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BlueBird, CPAs

2

Preparing Your Property for a Title 31/AML IRS Compliance Examination

5/3/2016

Most Recent Updates

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BlueBird, CPAs

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Preparing Your Property for a Title 31/AML IRS Compliance Examination

5/3/2016

Most Recent Updates • Jeff Sessions o “Rescinded” the Cole Memo •

Cole Memo provided updated guidance to US Attorneys related to prosecuting marijuana crimes. • FinCEN then provided a path for Casino’s to do business with Marijuana Based Businesses (FIN-2014-G001)

o Calls federal law “Supreme law of the land”

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What to Do • Marijuana based businesses (if legal in your state) MUST be identified as a risk in your compliance program. • Based solely on Jeff Sessions’ comments, two choices: o Do nothing and risk a FinCEN fine; or o File a SAR

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BlueBird, CPAs

4

Preparing Your Property for a Title 31/AML IRS Compliance Examination

5/3/2016

What to Do If you are a Tribe currently operating in the marijuana industry: • Prohibit those employees from gambling in the Casino. o We typically do this already with slots, table games, finance, etc. • This is most extreme reaction, but protects the Casino from AML ramifications.

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Recent Updates

Enforcement Actions o

•

Trump Taj Mahal – 3/6/15 • $10 Million

o Trinian Dynasty Hotel & Casino – 6/3/15 • $75,000,000 • George Que, VIP Services Manager – Barred from Gaming Industry in August 2014 o Caesar’s Entertainment – 9/8/15 • $8 Million – FinCEN • $1.5 Million – State of Nevada o Oaks Card Club – 12/17/15 • $650,000 o Sparks Nugget – 4/5/16 • $1 Million • More?

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BlueBird, CPAs

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Preparing Your Property for a Title 31/AML IRS Compliance Examination

5/3/2016

Recent Updates • Banks auditing Casinos AML Programs o Under same scrutiny as Casinos o Must know their customers’ source of funds o Casinos do not have to comply • Bank may terminate relationship

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Source of Funds

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BlueBird, CPAs

6

Preparing Your Property for a Title 31/AML IRS Compliance Examination

5/3/2016

Source of Funds

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Source of Funds • 1021.320(a)(2)(i):

• “A transaction requires reporting under the terms of this section if it is conducted or attempted by, at, or through a casino, and involves or aggregates at least $5,000 in funds or other assets, and the casino knows, suspects, or has reason to suspect that the transaction (or a pattern of transactions of which the transaction is a part): o (i) Involves funds derived from illegal activity or is intended or conducted in order to hide or disguise funds or assets derived from illegal activity (including, without limitation, the ownership, nature, source, location, or control of such funds or assets) as part of a plan to violate or evade any Federal law or regulation or to avoid any transaction reporting requirement under Federal law or regulation.”

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BlueBird, CPAs

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Preparing Your Property for a Title 31/AML IRS Compliance Examination

5/3/2016

Source of Funds • Source of funds o How to implement (most common) • Top XX number of players (10, 15, 25, 30, etc.) • IRS looking at roughly 25 of your top players • CTR/SAR threshold o Conduct risk assessment to determine threshold

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Source of Funds • Obtaining information without invading privacy o No longer gaming at Casino • Per FinCEN guidance, not an excuse • According to IRS “Begging for a penalty” o No guidance from FinCEN • AGA best practices 2014 and 2015 (handout) • Host vs Non-Host Casino’s o More difficult to obtain without hosts • Should use Google, Spokeo, Facebook, etc.

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BlueBird, CPAs

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Preparing Your Property for a Title 31/AML IRS Compliance Examination

5/3/2016

Source of Funds • KYC Program should be established o Include: • How information is obtained • How it is verified • How it is retained • How it is secured (who has access) • How often it will be updated • At least annually

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OFAC • Office of Foreign Assets Control:

• Specially Designated Nationals (SDNs)

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BlueBird, CPAs

9

Preparing Your Property for a Title 31/AML IRS Compliance Examination

5/3/2016

SDN List https://www.treasury.gov/resource-center/sanctions/SDN- List/Pages/default.aspx

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Source of Funds • Legitimate play ≠ no suspicious activity

• Level of play does not match information obtained during customer review o Suspicious Activity Report should be prepared

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BlueBird, CPAs

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Preparing Your Property for a Title 31/AML IRS Compliance Examination

5/3/2016

Source of Funds Example SAR Scenario 1

• A credit union manager wagers approximately $192,000 in gaming devices from January 2014 through March 2014.

• What do you think? Suspicious?

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Source of Funds Example SAR Scenario 2

• Male patron carrying a backpack enters Casino with female companion. The male patron enters high limit room and begins to play high limit slots. The female begins performing currency exchanges $20s for $100s, totaling roughly $6,000. The 100s are given to the male to wager in the slot machines. Total, the male has over $18,000 in bills inserted and $17,500 in jackpots.

o What do you think? Suspicious?

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BlueBird, CPAs

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Preparing Your Property for a Title 31/AML IRS Compliance Examination

5/3/2016

Scenario 3 Example SAR Scenario 3

• Casino’s highest roller in table games has had a KYC search done. He is a dentist. Unable to find car registration. o Owns a boat o Owns a plane (has a license with the FAA)

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Scenario 3 • Brother has been in/out of prison for crimes ranging from drug trafficking to money laundering.

• Suspicious? File? Source of funds issue?

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BlueBird, CPAs

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Preparing Your Property for a Title 31/AML IRS Compliance Examination

5/3/2016

Scenario 4 Example SAR Scenario 4

• Casino allows patrons to purchase gift cards in the gift shop on credit, and redeem in the cage for cash. A high limit player regularly engages in this activity and has rated play. Today, he enters the Casino, purchases $9,000 in gift cards, redeems them in the Cage, and has no rated play.

• What do you think? Suspicious?

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CTR Red Flags • Late filing • Use of passport with one home country and address in another • No SSN o Other required information unknown • No filing • Support ≠ CTR o Information, amounts, etc.

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BlueBird, CPAs

13

Preparing Your Property for a Title 31/AML IRS Compliance Examination

5/3/2016

Common Issues • The next several slides discuss common exceptions identified by our audit firm as well as the IRS

• We will discuss ways to correct each of these as we progress

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Common Issues #10 No/inadequate risk assessment performed #9 Compliance program not based on risk o Superficial, FinCEN only regulations #8 No KYC or Source of Funds program #7 MTL entries o Transactions not logged

o Lack of adequate description of unknown patrons (or known)

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BlueBird, CPAs

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Preparing Your Property for a Title 31/AML IRS Compliance Examination

5/3/2016

Common Issues #6 MIL entries

o Missing information o Transactions not logged #5 Inadequate or non-existent training #4 Lack of documentation regarding date of notification for filed SARs

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Common Issues #3

Lack of review of MTLs for suspicious activity #2 Automated >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 Page 185 Page 186 Page 187 Page 188 Page 189 Page 190 Page 191 Page 192 Page 193 Page 194 Page 195 Page 196 Page 197 Page 198 Page 199 Page 200

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