I'm afraid to admit that your dark scenarios may be more prevalent in Indian gaming than we would like to admit. You forget to mention that Indians are likely to "keep it quiet" to avoid embarrassment or public scrutiny. This is difficult but not impossible even in the highly regulated Indian gaming environment. In short, it all starts ends at the top -- from Tribal governance and casino management. I would add that a strong non-political TGA, a reputable CPA firm and a good vacation policy are helpful. Strong non-political TGA. The ability to lose your badge to the local gaming authority is a strong deterrent to white collar crime. The loss of a gaming badge usually means the end of a career in gaming. Reputable CPA firm. Through the regular annual audit, most of these seamy schemes would not be detected. However, an experienced auditor will tell you whether your internal controls (esp, checks & balances over cash transactions)are weak or strong. As a CPA with operational experience in Indian gaming, it would take me about 1 day to get a sense of the quality of internal controls. Strong Vacation Policy??! Top management and persons in charge of cash transactions and recording of cash transactions should be encouraged to take at least 1 week straight 7 days vacation each year. Many schemes depend upon an otherwise "hard working" employee who must show up for work every day to conceal their dishonesty. This is just one example of many internal policies that can help prevent and detect fraud. The most alarming element of this piece is that Tribes are allowing casino managers to sign contracts without Tribal attorney review or Council resolution. It takes a lot of time, but we --in our Tribal Enterprise group have an attorney review EVERY contract and obtain a resolution over a certain $ threshold or over a certain term.
Tuesday, May 24, 2011 - 03:24