Title 31 Program Outline

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  • 1. Eagle Country Gaming Consultants Title 31 Program Overview
  • 2. Preliminary Title 31 System Review
    • Audit of the Casino’s Title 31 Program:
      • Review the Casino’s Title 31 Internal Controls and Procedures
      • Review new hire and ongoing management/employee training programs and training documentation retention.
      • Review Casino documents used for tracking Title 31 reporting.
      • Review filed CTRC & SARC forms for completeness, filing and retention requirements.
      • Check if Casino has “Required” Title 31 coordinator and Compliance Committee with minutes maintained.
      • Prepare summary of findings including recommendations.
      • Provide training systems and support as requested.
  • 3. Internal Controls & Procedure Development
    • Casino Internal Controls
      • Develop controls consistent with Title 31 (CTRC & SARC) in the following areas:
        • Employee Training and Testing
        • Transaction Tracking
        • Obtaining Required Information
        • Patron refusal to provide information
        • Employee discipline for violations
        • Reporting and Filing requirements
        • Identify Title 31 Coordinator
        • Compliance Committee
        • Additional areas as required by law or regulator
  • 4. Training New Hire and Ongoing
    • Train the Trainer
      • Supply the system and materials and then mentor a trainer appointed by the Casino for future management and employee Title 31 trainings.
    • New Hire Training
      • Develop new hire training and testing system.
      • Perform initial new hire training and testing.
    • Ongoing Training
      • Provide a recommend system for continued training and testing.
  • 5. Title 31 Tracking Documentation
    • Develop the following Title 31 Tracking Documentation:
      • Multiple Transaction Log (MTL).
      • Monetary Instrument Log (MIL).
      • Slot Taxable / W-2g Log.
      • Cage Front Money Log.
      • Other Casino Cash handling documentation.
  • 6. Title 31 CTRC & SARC
    • CTRC & SARC Completing:
      • Identify who is to compile documentation and complete required reports.
      • Setup second review process to lessen errors and missed filings.
    • CTRC & SARC Filing:
      • Setup check system to insure filings are timely.
      • Log filings and use certified mail with return receipt.
    • CTRC & SARC Retention:
      • Setup retention system as required by law or Tribal Ordinance.
  • 7. Compliance Committee
    • Establish a Compliance Committee:
      • Committee Members
        • Title 31 Coordinator as Committee Chair
      • Frequency of Committee Meetings
      • Agenda
      • Committee Meeting Minutes
  • 8. Title 31 Audits
    • Title 31 Audit should include:
      • Set timeframe.
      • Completed by external Auditor
      • Areas to be reviewed:
        • CTRC/SARC reports
        • Tracking Documents review
        • New hire and ongoing training
        • Compliance Coordinator
        • Compliance Committee and minutes
        • Internal Control & Procedure review
  • 9. Eagle Country Gaming Consultants Title 31 Program Overview For more information call 760-801-6029