Casino Internal Controls

Engagement Period:  3 Months

Background

A global casino sought to enhance internal controls in its table gaming operations due to high volumes of cash transactions, rapid gameplay, and risks of fraud and theft. The casino needed to improve its cash management, game integrity, surveillance, and compliance with regulations set by New York State Gaming Commission (NYSGC) and federal AML requirements.

Approach

NextAML implemented a multi-phase approach to enhance various operational areas, focusing on chip control, game integrity, surveillance, AML compliance, and documentation. Cash and chip control was enhanced through standardized drop and count procedures, including secure drop box collection and multi-person counters under surveillance, while chip security was enhanced with unique replacements and controlled storage. Game control integrity was improved through upgraded player tracking systems, and surveillance procedures were refined to improve reporting of suspicious activity to management and regulators. In addition to ensuring a secure and efficient operational environment through improved documentation practices with pre-numbered forms for key transactions and daily reconciliation of table game results, AML compliance was strengthened by aligning with Title 31 of the Bank Secrecy Act and enhancing KYC protocols for high-limit players.

Outcome

NextAML’s enhancements to internal controls significantly strengthened the casino’s overall operations in security, compliance, and efficiency. Fraud risks were reduced through fewer cash and chip discrepancies and a decline in procedural violations. Full AML compliance was achieved, with successful audits. Operational efficiency became more streamlined through improved documentation and faster reconciliation, contributing to a more secure and enhanced regulated gaming environment.