CTGC Compliance Section staff work with Tribal Gaming, Surveillance, Tribal Police and the Three Rivers Casino Resort staff, to monitor compliance with the Compact, CTGC Regulations, Minimum Internal Controls Standards (MICS), Tribal Internal Control Standards (TICS) and Casino policies and procedures, thereby ensuring the fairness, integrity, security, and honesty of the Gaming Operation. The Compliance Section is made up of the Audit Unit and the Gaming Inspector Unit and is supervised by the Deputy Director, Dean Durgan, who reports directly to the Brad Kneaper, the Executive Director of the Gaming Commission.
The essential duties of Compliance Section are to:
- Approve the Casino's Policy & Procedures related to the Gaming Operation.
- Approve all Casino rules dealing with promotional giveaways where chance is an element of the giveaway.
- Approve all Casino rules related Gaming play, including tournament rules.
- Enforce Regulations, Minimum Internal Control Standards (MICS), Tribal Internal Control Standards (TICS) and Casino Policy & Procedures.
- Conduct audits as required by the Compact, MICS, and TICS, as well as additional audits required by the Executive Director.
- Conduct investigations of any potential violations of the Compact, applicable regulations, internal controls, policy and procedures.
- Conduct investigations on reported Casino Guest Gaming disputes.
- Assist Law Enforcement as needed in the investigation of gaming related crimes.
- Issue Notice of Violations as required.
- Review the Casino's response and corrective action to Audit Findings and Notice of Violations for adequacy.
- Submit petitions to the Commissioners for licensee assessment of fines as necessary to ensure compliance.
The Manager of Internal Audit, Mark Williams, oversees the functions of this Unit and reports directly to the Deputy Director of the Gaming Commission, Dean Durgan. The Audit Unit includes Daniel Jagels, Compliance Auditor, who assists the Manager of Internal Audit with the audits of the Three Rivers Casino Resort (TRCR).
The essential duties of the Audit Unit are to:
- Learn, comprehend, and maintain a working knowledge of Gaming Commission Regulations, Tribal/State Minimum Internal Control Standards (MICS), Tribal Internal Controls (TICS), NIGC MICS, and Casino Operations policies and procedures.
- Conduct compliance reviews to assess the effectiveness of internal controls and compliance with Compact, CTGC Regulations, MICS, TICS and Casino policies and procedures.
- Develop and update the audit check lists needed for completing all audits as required in the Audit Plan.
- Work with OSP detectives and auditors to coordinate state participation of all Class III audits required by Compact.
- Prepare written reports to document audit findings and recommendations, and report such information to CTGC and TRC management.
- Review TRC management responses to audit findings for sufficiency and plan follow-up audits of any implemented corrective action.
- Assist in the selection and engagement of an External Auditing Firm to perform the annual audit required by the NIGC and coordinate the external audit once a firm has been selected.
- Review all TRCR contracts with Class III vendors & Class II vendors to ensure Compact language and NIGC compliance requirements are met.
- Assist with writing, implementation and updating of CTGC Regulations, TICS, State and NIGC MICS as needed.
- Maintain master records of all CTGC Regulations, TICS, State and NIGC MICS and ensuring that all CTGC staff and TRCR staff have access to most current revisions.
- Monitor other promotional giveaways periodically or as needed and maintain archive records of all promotional giveaways as required in CTGC policy.
- Investigate any cash variance greater than $100 in a specific variance report or that the CTGC determines to be a threat to the integrity of the gaming operation.
- Investigate any potential violation of the Compact, TICS, State and NIGC MICS, and TRCR policies and procedures related to the Cage, Soft Count, Drop and Accounting/Audit areas and Issue CTGC violations as appropriate.
- Monitor each month, as required by the Compact, the VLT, EGM, Table Game Drop & Soft Count, Chip Inventory and Surveillance compliance with procedure.
Gaming Inspector Unit
The functions of this Unit are carried out by our Gaming Inspectors (GI), Rakesh Halka, Cheryl Hoile and Brian Culy. Both the Class III VLT’s and Class II EGM’s are highly regulated by the Confederated Tribes Gaming Commission (CTGC), the State and the National Indian Gaming Commission (NIGC). Under our Compact Minimum Internal Controls (MICS), the Tribes Internal Controls (TICS) and NIGC’s MICS, all gaming equipment and software associated with the VLT’s and EGM’s has to be tested and certified as meeting all State, Tribal and Federal technical standards by an independent laboratory, to insure the fairness and integrity of the equipment and/or gaming software. The laboratory then certifies the equipment as authorized for use in Oregon. This certification process must be completed prior to the purchase and installation of these devices at our Casino. The GIs also monitor the Gaming Operations in Florence & Coos Bay for compliance as appropriate with all Federal, State and Tribal laws and regulations, and investigate any guest disputes involving VLT’s or EGM’s that are not adequately dealt with by the Gaming Operations.
The essential duties of the Gaming Inspector Unit are to:
- Inspect all shipments of VLTs & EGMs onto and off of property.
- Ensure that the machines have the proper transportation approval from the State for Class III and the CTGC for Class II and that the machine has been approved for use in the State of Oregon by the independent lab.
- Maintain records of all VLTs & EGMs that are shipped to or from the Florence or Coos Bay Casino.
- Maintain records and track all Class III and Class II Gaming Software ordered by the Casino.
- Test all gaming software against the independent laboratories certification and ensure that it is the correct software approved for use in Oregon.
- Track and securely stored gaming software from the time it arrives on property until it is installed and sealed in the VLT or EGM, as well as once removed from the VLT or EGM until it is either reinstalled, destroyed or returned to the manufacturer.
- Maintain VLT and EGM gaming software integrity in the logic area of all the machines available for play by guests.
- Monthly monitoring as required by the Compact and TICS, including but not limited to, Sensitive Gaming item inventories, daily review of Security and Surveillance logs review, Gaming Department’s regulatory compliance, VLT & EGM Integrity verification, and security of the movement of cash within, into, and outside the gaming facility.
- Issue CTGC violations as appropriate.
- Monitor and verify receipt of Sensitive Gaming Item shipments.
- Inspect and cancel all used cards and dice.
- Insure required Notifications to the State are made within allotted time limits.
- Investigate unresolved customer disputes as required in the Compact and Regulations, and conduct any other gaming related investigations as required.