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Cash flows heavily between casinos and patrons seeking jackpots or illegal monetary rewards. Consequently, federal, state and tribal governments regulate casinos by requiring, among other things, extensive record keeping and detailed protocols for their operations. Compliance officers help casinos navigate these rules formulated to protect the casinos and the public.
Keeping the Games Honest
Compliance officers watch players and dealers and review reports to ensure casinos follow minimum internal control standards -- the procedures and rules of games. For example, guidelines tell poker dealers when and how to shuffle card decks and what constitutes a winning bet at the craps table. Compliance officers test slot machines and other computer-run games before and after installation to guard against tampering. The position also involves monitoring the electronic imaging, video surveillance and other tools that detect potential cheaters.
Keeping Out Dirty Money
Casinos must guard against becoming unwitting participants in criminal or terrorist enterprises. Compliance officers run programs and follow laws to keep such individuals from funneling ill-gotten and tainted funds through casinos. Federal law requires casinos to report transactions, such as bets, payouts, buying or turning in chips and markers, that involve more than $10,000. The reporting thresholds drop to $5,000 if the casino suspects or knows that a player has criminal designs, breaks $5,000 or more into pieces to avoid the reporting triggers, or lacks a legitimate purpose in moving the money.
What Casinos Seek
Qualifications for the job vary by casino. Generally, compliance officer candidates should have education beyond high school; a bachelor's degree in business, criminal justice or related fields are preferred. Casinos will consider applicants with experience in internal auditing or regulatory compliance. Compliance officers on certain Native American reservations should have knowledge of Native American culture and the operation and organization of tribal governments.
Pull No Punches
Effective and diligent compliance officers place loyalties aside and do not sugar-coat their findings. Casinos rely on thorough and honest audits to correct deficiencies in complying with gaming laws and keeping players and employees from helping themselves to the casino's coffers. States such as Colorado require casinos to conduct periodic audits and report the results -- good or bad -- to gaming regulators.
Casinos can prove noisy and smoke-filled places to work, especially at times of peak traffic. The officers' job description involves a combination of extended standing, walking the game floor, lifting and moving machines and sitting at computers, surveillance monitors and desks completing compliance reports. Compliance officers have long, often night-time, shifts and must handle testy, disappointed and frustrated players and casino staff.
- Kickapoo Lucky Eagle Casino: Complaince Officer -- Position Description
- Smith River Ranchiera: Tribal Gaming Agency
- Financial Crimes Enforcement Network: Supicious Reporting Activity Guidelines for Casions
- IRS.gov: Indian Tribal Governments Frequently Asked Question #8 Answer -- What are the Reporting Requirements for Casinos?
- Wisconsin Department of Administration: Gaming -- Minimum Internal Control Standards
Christopher Raines enjoys sharing his knowledge of business, financial matters and the law. He earned his business administration and law degrees from the University of North Carolina at Chapel Hill. As a lawyer since August 1996, Raines has handled cases involving business, consumer and other areas of the law.