Organization Responsibility
The best way to have an honest and successful gambling operation is to involve an organization’s members.
| Delegate within the organization | Do not let an outside party, including an accountant, a consultant, a lessor, or a distributor, manage the organization’s gambling operation. To do so puts an organization’s gambling operation—and eventually its license—in jeopardy. |
| Involve more than one or two persons | Experience has shown that when an organization delegates too much authority to one person (whether a member or not), or when one person takes over the gambling operation—ordering inventory, auditing games, doing deposits, preparing reports—without oversight, theft often occurs. Most organizations with serious problems had only one or two people involved with the actual day-to-day business of conducting lawful gambling. |
| Keeping everyone honest |
Lawful gambling is a cash business. With huge sums of money passing through a person’s hand, there may be a temptation to “just take a little that no one will miss.” Involving an organization’s membership can prevent a person from being tempted to steal and being criminally charged when caught. |
| Preventing major problems | If an organization’s members do their job—provide oversight, approve expenditures, and participate in the gambling operation—major problems will be prevented |
The organization is accountable and responsible for the actions of its employees and volunteers.
Include administrative and accounting controls as part of the organization’s business plan. The controls should show how the organization is structured and who is responsible for what.
Job descriptions—To help the employees and volunteers comply with statutes and rules, it is a good idea to have a specific job description for each person.
EXAMPLE: A job description for a paper pull-tab seller might contain these duties:
- Verify serial numbers on flare to tickets.
- Fill out all prize receipt forms completely.
- Deface all winning paper pull-tab tickets.
- Do not provide any inside information to customers.
Use the checklists provided in each “conduct chapter” as a guideline.
Organization Duties
An organization may not outsource the management of its gambling operation. The following duties must be performed only by organization members, gambling employees, or gambling volunteers:
- Prepare source documents, including:
___ inventory records for daily tracking of game inventory, site inventory, monthly physical inventory, and merchandise inventory. The person who maintains the perpetual inventory must not be the person who performs the physical inventory;
___ gambling deposit slips;
___ gambling occasion and daily activity records; and
___ authorization for disbursement of gambling funds.
- Provide oversight of lawful gambling, including:
___ conducting lawful gambling;
___ monitoring the organization’s permitted premises to detect illegal gambling;
___ investigating cash variances;
___ determining product to be purchased;
___ ordering product;
___ presenting gambling report to members;
___ monitoring the organization’s lawful purpose rating.
- Hire, discipline, or fire employees.
- Train employees.
- Deposit gambling receipts into gambling bank accounts.
- Verify cash banks.
- Verify the accuracy of records and reports, including but not limited to:
___ check register;
___ monthly bank statement reconciliation;
___ tax returns and forms;
___ final audit of closed games;
___ bank deposit reconciliation to the game and bank records; and
___ reconciliation of physical and perpetual inventory.