Instrument Count Standards
Effective Date: October 1, 2015
(g) Player interface financial instrument count standards.
(1) Access to stored full financial instrument storage components must be restricted to:
(i) Authorized members of the drop and count teams; and
(ii) In an emergency, authorized persons for the resolution of a problem.
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(iii) Access to stored, full drop boxes or bill acceptor canisters will be restricted to the following: (A) Authorized Drop Team Associates;
(B) Authorized Security Associates who perform the Table Games and/or Card Games Drop; (C) Authorized Count Associates; and
(D) Authorized associates, with a Security escort, in an emergency for resolution of a problem.
[The above standards also comply with 542.21 (f) (11); 542.31 (f) (11); 542.41 (f) (11)]
(2) The player interface financial instrument count must be performed in a Count Room or other equivalently secure area with comparable controls.
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(i) The count for Table Games, Card Games or gaming machine funds must be performed in the Count Room.
[The above standards also comply with 542.21 (f) (1); 542.31 (f) (1); 542.41 (f) (1)]
(3) Access to the Count Room during the count must be restricted to members of the drop and count teams, with the exception of authorized observers, supervisors for resolution of problems, and authorized maintenance personnel.
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(i) Access to the Count Room during the count is restricted. Only the following are allowed in the Count Room during the count:
Page 170 of 463 (A) Soft Count Team;
(B) Authorized observers;
(C) Choctaw Nation Gaming Commission;
(D) Supervisory Associates for resolution of problems; and (E) Authorized maintenance or vendors with a Security escort.
(ii) Maintenance should wait until the count is complete whenever possible.
[The above standards also comply with 542.21 (f) (2); 542.31 (f) (2); 542.41 (f) (2)]
(4) If counts from various revenue centers occur simultaneously in the Count Room, procedures must be in effect that prevent the commingling of funds from different revenue centers.
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(i) Counts for each revenue department, such as Card Games, Table Games, gaming machines, Kiosk/ATM, etc. must be counted independently to prevent the commingling of funds. [The above standards also comply with 542.21 (f) (3); 542.31 (f) (3); 542.41 (f) (3)]
(5) The count team must not have access to amount-in or bill-in meter amounts until after the count is completed and the drop proceeds are accepted into the cage/vault accountability.
(i) The count team must not have access to amount-in or bill-in meter amounts until after the count is completed and the drop proceeds are accepted into the cage/vault accountability.
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(ii) Count Associates must not have access to amount-in or bill-in meter amounts, it must be a blind count.
(6) Count equipment and systems must be tested, and the results documented, before the first count begins, to ensure the accuracy of the equipment.
(i) Count equipment and systems must be tested, and the results documented, before the first count begins; to ensure the accuracy of the equipment.
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(ii) Count equipment and systems must be tested, and the results documented, before the first count begins, to ensure the accuracy of the equipment.
(7) If a currency counter interface is used:
(i) It must be adequately restricted to prevent unauthorized access; and
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(A) If currency counters are used in the Count Room, a Soft Count Associate must be able to observe the loading and unloading of all cash at the cash counter, including rejected cash. [The above standards also comply with 542.21 (f) (5); 542.31 (d) (5); 542.41 (d) (5)]
(ii) The currency drop figures must be transferred via direct communications line or computer storage media to the accounting department.
Page 171 of 463 (A) The currency drop figures must be transferred via direct communications line or computer storage
media to the accounting department. SICS
(B) The currency drop figures must be transferred via direct communications line or computer storage media to the accounting department.
(8) The financial instrument storage components must be individually emptied and counted so as to prevent the commingling of funds between storage components until the count of the storage component has been recorded.
(i) The count of each storage component must be recorded in ink or other permanent form of recordation.
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(A) Counts for each revenue department, such as Card Games, Table Games, gaming machines, Kiosk/ATM, etc. must be counted independently to prevent the commingling of funds. (B) Recording of all transactions on paperwork in the Count Room will be made in ink or
electronically, if applicable.
[The above standards also comply with 542.21 (f) (4); 542.31 (f) (4); 542.41 (f) (4)]
(ii) Coupons or other promotional items not included in gross revenue may be recorded on a supplemental document by the count team members or accounting personnel. All single-use coupons must be cancelled daily by an authorized agent to prevent improper recirculation.
(A) Coupons, vouchers, or other promotional items not included in gross revenue may be recorded on a supplemental document by the Soft Count Team. All single-use coupons/vouchers must be cancelled daily to prevent improper recirculation.
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(B) Items not included in gross revenue may be recorded on a supplemental document by the Soft Count Team. All single-use coupons must be cancelled daily to prevent improper recirculation.
(9) If currency counters are utilized, a count team member must observe the loading and unloading of all currency at the currency counter, including rejected currency.
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(i) If currency counters are used in the Count Room, a Soft Count Associate must be able to observe the loading and unloading of all cash at the cash counter, including rejected cash.
[The above standards also comply with 542.21 (f) (5); 542.31 (d) (5); 542.41 (d) (5)]
(10) Two counts of the currency rejected by the currency counter must be recorded per interface terminal as well as in total. Rejected currency must be posted to the player interface from which it was collected.
(i) Two counts of the currency rejected by the currency counter must be recorded per interface terminal, as well as in total. Posting rejected currency to a nonexistent interface terminal is prohibited.
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(ii) If the rejected contents are continually rejected, two designated Soft Count Associates must make a primary count and a separate second count for verification. The associates must then record the counts per table or other drop box, as well as in total. Posting rejected currency to a nonexistent
Page 172 of 463 table or other revenue source is prohibited. The associates must then manually enter the rejects in the count machine for inclusion in the count total, as appropriate.
(11) Storage components, when empty, must be shown to another member of the count team, to another agent who is observing the count, or to surveillance, provided that the count is monitored in its entirety by an agent independent of the count.
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(i) Bill Acceptor Canisters, when emptied, must be shown to one (1) of the following prior to closing and locking the Bill Acceptor Canister to ensure there are no contents remaining in the Bill Acceptor Canister:
(A) Another Soft Count Associate;
(B) Another associate observing the count; or
(C) Surveillance; provided the count is monitored in its entirety by Surveillance. [The above standards also comply with 542.21 (f) (6); 542.31 (f) (6); 542.41 (f) (6)]
(12) Procedures must be implemented to ensure that any corrections to the count documentation are permanent, identifiable and the original, corrected information remains legible. Corrections must be verified by two count team agents.
(i) All documents, forms and logs must be completed accurately and entirely.
(ii) All corrections to count documentation shall be made by drawing a single line through the error, writing the correct information above the error and then obtaining legible initials and gaming license numbers of at least two (2) count team associates who verified the change.
(iii) Corrections requested by Audit Departments must be completed by the Accounting Department within seventy-two (72) hours of receiving the request. The Audit Department must submit requested corrections to financial documents on an exception report. Once the correction is made the report must be placed with the original casino paperwork.
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(iv) All corrections to count documentation will be made by drawing a single line through the error, writing the correct information above the error and then obtaining legible initials and gaming license numbers of at least two (2) count team associates who verified the change.
(13) The count sheet must be reconciled to the total drop by a count team member who may not function as the sole recorder, and variances must be reconciled and documented. This standard does not apply to vouchers removed from the financial instrument storage components.
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(i) The Count Sheet summary must be reconciled to the total count by a Soft Count Associate who does not serve as the sole recorder.
[The above standards also comply with 542.21 (f) (7); 542.31 (f) (7); 542.41 (f) (7)]
(14) All count team agents must sign the report attesting to their participation in the count.
(i) Count Team Associates are required to provide their signature and legible gaming license number (or electronic equivalent).
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(ii) All Soft Count Associates involved in the count must provide their signature and legible gaming license number on the count sheet and/or count summary to attest to their participation in the count.
[The above standards also comply with 542.21 (f) (8); 542.31 (f) (8); 542.41 (f) (8)]
(15) A final verification of the total drop proceeds, before transfer to cage/vault, must be performed by the at least two agents, one of whom is a supervisory count team member and the other a count team agent.
(i) A final verification of the total drop proceeds, before transfer to cage/vault, must be performed by at least two agents, one of whom is a supervisory count team member, and one a count team agent. SICS
(A) Prior to transferring the drop proceeds to the Vault, a final verification of the total drop proceeds for each revenue center must be performed by at least two (2) associates, one of whom is a supervisor or one of whom is in a designated supervisory “lead” position.
(ii) Final verification must include a comparison of currency counted totals against the currency counter/system report, if a counter/system is used.
(A) Final verification must include a comparison of currency counted totals against the currency counter/system report, if any counter/system is used.
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(B) Final verification must include a comparison of the actual currency count to the currency counter receipt to ensure the totals match.
(iii) Any unresolved variances must be documented and the documentation must remain a part of the final count record forwarded to accounting.
(A) Any unresolved variances must be documented, and the documentation must remain part of the final count record forwarded to accounting.
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(B) Any unresolved variances must be documented as an exception. (C) All variances must be documented and investigated.
(D) Variances must be documented as an exception and reported to Surveillance.
(iv) This verification does not require a complete recount of the drop proceeds but does require a review sufficient to verify the total drop proceeds being transferred.
(A) This verification does not require a complete recount of the drop proceeds, but does require a review sufficient to verify the total drop proceeds being transferred.
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(B) Final verification must include a comparison of the actual currency count to the currency counter receipt to ensure the totals match.
(v) The two agents must sign the report attesting to the accuracy of the total drop proceeds verified.
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(B) Both the Soft Count Supervisor/Manager or designated supervisory “lead” associate and the Soft Count Associate(s) who completed the verification must sign the count sheet to attest the accuracy of the drop proceeds verified.
(vi) All drop proceeds and cash equivalents that were counted must be turned over to the cage or vault cashier (who must be independent of the count team) or to an agent independent of the revenue generation and the count process for verification. Such cashier or agent must certify, by signature, the amount of the drop proceeds delivered and received. Any unresolved variances must be reconciled, documented, and/or investigated by accounting/Revenue Audit.
(A) The Vault Associate (who must be independent of the count team and Slot Department) accepting the counted drop proceeds and cash equivalents must perform an independent count and make a comparison to ensure accuracy and individual accountability. All discrepancies must be noted and investigated. Unverified transfers of cash and/or cash equivalents are prohibited. SICS
(B) Once a matching total is reached, the Vault Associate will provide their signature and gaming license number (or electronic equivalent) for documentation.
[The above standards also comply with 542.21 (f) (9); 542.31 (f) (9); 542.41 (f) (9)]
(16) After certification by the agent receiving the funds, the drop proceeds must be transferred to the cage/vault.
(i) The count documentation and records must not be transferred to the cage/vault with the drop proceeds.
(A) The count documentation and records must not be transferred to the cage/vault with the drop proceeds.
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(B) The Soft Count Supervisor/Manager or designated Soft Count Associate must not provide any amounts or count documentation to the Vault during the transfer.
(ii) The cage/vault agent must not have knowledge or record of the drop proceeds total before it is verified.
(A) The cage/vault agent must not have knowledge or record of the drop proceeds total before it is verified.
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(B) Upon transfer of drop proceeds to the Vault, the count documentation and records must NOT be transferred to the Vault with the drop proceeds.
(C) The Vault Associate must have no knowledge or record of the drop proceeds total and must perform an independent count.
(iii) All count records must be forwarded to accounting secured and accessible only by accounting agents.
(A) A secured bag/container must be utilized to transport soft count documentation. (B) The bag/container must be secured under audio and video surveillance.
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(C) The count sheet(s) and all supporting documents must be placed in a seal-it-once bag and must be delivered by hand from the Soft Count Associate(s) to Accounting or placed in the
designated Accounting drop box.
[The above standards also comply with 542.21 (f) (10); 542.31 (f) (10); 542.41 (f) (10)]
(iv) The cage/vault agent receiving the transferred drop proceeds must sign the count sheet attesting to the verification of the total received, and thereby assuming accountability of the drop proceeds, and ending the count.
(A) The Vault Associate (who must be independent of the count team and Slot Department) accepting the counted drop proceeds and cash equivalents must perform an independent count and make a comparison to ensure accuracy and individual accountability. All discrepancies must be noted and investigated. Unverified transfers of cash and/or cash equivalents are prohibited. SICS
(B) Once a matching total is reached, the Vault Associate will provide their signature and gaming license number (or electronic equivalent) for documentation.
[The above standards also comply with 542.21 (f) (9); 542.31 (f) (9); 542.41 (f) (9)]
(v) Any unresolved variances between total drop proceeds recorded on the Count Room report and the cage/vault final verification during transfer must be documented and investigated.
(A) The Vault Associate (who must be independent of the count team and Slot Department) accepting the counted drop proceeds and cash equivalents must perform an independent count and make a comparison to ensure accuracy and individual accountability. All discrepancies must be noted and investigated. Unverified transfers of cash and/or cash equivalents are prohibited. SICS
(B) Once a matching total is reached, the Vault Associate will provide their signature and gaming license number (or electronic equivalent) for documentation.
[The above standards also comply with 542.21 (f) (9); 542.31 (f) (9); 542.41 (f) (9)]
(17) The count sheet, with all supporting documents, must be delivered to the accounting department by a count team member or agent independent of the cashiers department. Alternatively, it may be adequately secured and accessible only by accounting department.
(i) A secured bag/container must be utilized to transport soft count documentation. (ii) The bag/container must be secured under audio and video surveillance.
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(iii) Once a matching total is reached, the Vault Associate will provide their signature and gaming license number (or electronic equivalent) for documentation.
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